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Document Preview Code of Business Conduct and Ethics |
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Title: |
Code of Business Conduct and Ethics |
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Date: |
2008 |
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$38 |
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ID: |
#3269948 |
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BLACKROCK, INC.
Code of Business Conduct and Ethics
Introduction
BlackRock, Inc. and its subsidiaries (collectively, ?BlackRock? or the ?Company?) have maintained a reputation for conducting their business activities in the highest ethical and professional manner. Indeed, BlackRock?s reputation for integrity is one of its most important assets and has been instrumental in its business success. Each BlackRock employee ? whatever his or her position ? is responsible for continuing to uphold these high ethical and professional standards.
This Code of Business Conduct and Ethics covers a wide range of business activities, practices and procedures. It does not cover every issue that may arise in the course of BlackRock?s many business activities, but it sets out basic principles designed to guide employees, officers and directors of BlackRock. All of our employees, officers and directors must conduct themselves in accordance with this Code, and seek to avoid even the appearance of improper behavior.
Any employee who violates the requirements of this Code will be subject to disciplinary action. If you are in a situation which you believe may violate or lead to a violation of this Code, you should follow the guidelines described in Section 14 of this Code.
BlackRock?s business activities are subject to extensive governmental regulation and oversight. In particular, as an investment adviser and sponsor of investment companies and other investment products, BlackRock is subject to regulation under numerous U.S. federal and state laws (such as the Investment Advisers Act of 1940, the Investment Company Act of 1940, various state securities laws, ERISA, and the Commodity Exchange Act), as well as the laws and regulations of the other jurisdictions in which we operate. In addition, BlackRock is subject to regulation and oversight, as a public company, by the Securities and Exchange Commission (the ?SEC?) and the New York Stock Exchange and, as an affiliated company of The PNC Financial Services Group, Inc. (?PNC?), the Federal Reserve Board.
It is, of course, essential that BlackRock comply with the laws and regulations applicable to its business activities. Although you are not expected to know the details of these laws and regulations, it is important to know enough about them to determine when to seek advice from supervisors and BlackRock?s Legal and Compliance Department.
To assist in this effort, BlackRock has provided to all employees its Compliance Manual and various policies and procedures which provide guidance for complying with these laws and regulations. In addition, the Company holds information and training sessions, including annual compliance meetings conducted by BlackRock?s Legal and Compliance Department, to assist employees in achieving compliance with the laws and regulations applicable to BlackRock and its activities.
In addition, as a public company, BlackRock is required to file periodic reports with the SEC. It is BlackRock?s policy to make full, fair, accurate, timely and understandable disclosure in compliance with applicable rules and regulations in all periodic reports required to be filed by the Company.
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