FPA Legal Info

The information contained on this Web site is intended for the use of United States institutional investors only, and is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject Franklin Portfolio Associates, LLC (“FPA”) or its affiliates to any registration requirement within such jurisdiction or country. Nothing contained in this site shall constitute the provision of investment advice or an offer to sell, or a solicitation of an offer to buy, or a recommendation to buy or sell, any security.

Copyright/Trademark

The entire contents of this Web site, including images, text and the “look and feel” attributes, are copyright © 2005 by The Bank of New York Mellon Corporation. All rights reserved. If the viewer downloads or prints a hard copy of individual pages and/or sections of this Web site, the viewer agrees not to remove any copyright or other proprietary notices. Any downloading or otherwise copying from this Web site will not transfer title to any software or material to anyone. The viewer may not reproduce (in whole or in part), transmit (by electronic means or otherwise), modify, link into or use for any public or commercial purpose this Web site without the prior written permission of FPA or BNY Mellon.

FPA is a wholly owned indirect subsidiary of The Bank of New York Mellon Corporation and has no affiliation to the Franklin Templeton Group of Funds or Franklin Resources, Inc.

Licenses

“Standard & Poor’s™”, “S&P™”, “S&P 500™”, “Standard & Poor’s 500™”, “Standard & Poor's 400 Mid Cap™”, and “S&P 400 Mid Cap™” are trademarks of McGraw-Hill, Inc. and have been licensed for use by The Bank of New York Mellon Corporation (together with its affiliates and subsidiaries). Russell Investments is the owner of the trademarks and copyrights relating to the Russell 1000™, Russell 1000 Value™, Russell 1000 Growth™, Russell 2000™, Russell 2500™ and Russell 3000™ indices. “Wilshire Large Cap Value™” is a service mark of Wilshire Associates, Inc. The foregoing index licensers do not sponsor, endorse, sell or promote the investment strategies or products mentioned in this Web site. They make no representation regarding the advisability of investing in the products or strategies described herein.

Product Information

Portfolio composition and statistical information regarding the various investment products displayed on this Web site is based on a composite of FPA’s accounts for the product or on a representative account included in the composite. When the information is based on a composite, the composite may include, along with FPA’s own accounts, a bank collective trust fund managed by The Bank of New York Mellon, an affiliate of FPA, as trustee, using the same portfolio management personnel and the same investment style and strategies as are employed by FPA in managing the product for the accounts managed by FPA. In managing these bank collective trust funds, such portfolio managers are acting in their capacities as officers of The Bank of New York Mellon. Individual portfolios may differ in both composition and holdings from the information displayed. Assets in such bank collective trust funds are counted as part of FPA’s overall assets under management. At Franklin Portfolio Associates (“FPA”), we take the issue of privacy very seriously. We want to assure visitors to our Web site of the security, privacy and confidentially that they expect from a premier financial services institution.

Information Collected

General

FPA does not collect any personal information from anyone who is merely visiting or browsing our Web site. Personal information may be collected if the visitor chooses to send FPA an e-mail message.

E-Mail and Product Inquiry

Visitors of our Web site are encouraged to send e-mail messages to us so that we may respond to inquiries regarding FPA and our products or services. FPA retains copies of these e-mail messages. The information provided by a visitor will only be used to respond to the visitor's inquiry and to provide better customer service.

Use of Information Collected

FPA uses the information collected from visitors to our Web site to address the specific needs of those visitors and to provide better customer service, including the provision of the latest information regarding financial products and services offered. The information collected also is used to provide a record of communications between FPA and our Web site visitors and to comply with any applicable legal and/or regulatory requirements.

Access to Information Collected

By FPA:

Employees: Certain FPA employees will be provided with a visitor's information in order to respond to that visitor's needs and provide the visitor with information regarding specific products or services in which the visitor may have an interest. FPA employees are instructed to use care in handling the personal, confidential information of FPA customers, and the guidelines regarding the handling of such information are discussed within our Code of Conduct. FPA employees who do not conform to FPA's confidentiality rules are subject to disciplinary sanctions that include dismissal.

FPA Affiliates: FPA is a wholly-owned subsidiary of The Bank of New York Mellon, (“BNY Mellon”) and a member of the BNY Mellon Asset Management (“BNY MAM”) group. BNY Mellon and its subsidiaries, such as the other members of the BNY MAM group, along with nonrelated service providers that assist FPA in meeting the needs of its customers, may receive personal information collected from a Web site visitor. Such information will be disclosed only in an effort to respond to the visitor's needs and provide information to the visitor about other financial products and services offered. The personal information is treated with the same standards of confidentiality that FPA itself uses, as the employees of FPA’s affiliates are subject to BNY Mellon’s Code of Conduct, and FPA’s non related service providers are legally bound to employ strict standards of confidentiality.

Third Parties

FPA does not transmit any personal information collected through its Web site to any third-parties. Personal information may be transmitted, however, if there is a specific need to complete a transaction requested by the visitor. FPA offers the opportunity to its Web site visitors to link to the Web pages of third parties who provide products and services not offered by FPA. Once the visitor leaves the FPA site, FPA does not receive any information from the visitor.