THE PUTNAM ADVISORY COMPANY, LLC

Introduction to Putnam The Putnam Advisory Company, LLC ("PAC") has been registered with the Securities and Exchange Commission (“SEC”) as an investment adviser since 1968. On January 1, 2024, a subsidiary of Franklin Templeton, Inc. (“Franklin Templeton”) acquired Putnam U.S. Holdings I, LLC, which does business as Putnam Investments (“Putnam” or “Putnam Investments”) in a stock and cash transaction (the “Transaction”). As a result of the Transaction, PAC, an indirect wholly-owned subsidiary of Putnam, became an indirect wholly-owned subsidiary of Franklin Templeton. Putnam, a Boston-based firm whose history reaches back to 1937, is an active asset manager providing investment advice to individuals and institutions worldwide through separately managed accounts and pooled investment funds. Franklin Templeton is a holding company with subsidiaries that operate under the Franklin Templeton® and/or subsidiary brand names. Franklin Templeton is a global investment management organization, and the various distinct brand names it offers investment services and products under include, but are not limited to, Alcentra®, Benefit Street Partners®, Brandywine Global Investment Management®, Canvas®, Clarion Partners®, ClearBridge Investments®, Fiduciary Trust International™, Franklin®, Franklin Mutual Series®, K2®, Legg Mason®, Lexington Partners®, Martin Currie®, O’Shaughnessy® Asset Management, Royce® Investment Partners, Templeton®, and Western Asset Management Company®. Franklin Templeton, through current and predecessor subsidiaries, has been engaged in the investment management and related services business for over 75 years. Franklin Templeton’s common stock is traded on the New York Stock Exchange under the ticker symbol “BEN” and is included in the Standard & Poor’s 500 Index. PAC manages assets for institutional and international clients through its head office in Boston, Massachusetts and a branch office in Singapore. In addition, PAC manages various pooled investment funds, such as limited liability companies, limited partnerships, and non-U.S. funds, and also sub-advises some of the Putnam Funds, which are discussed below. PAC is affiliated, through common ownership by Putnam Investments, with:  Putnam Investment Management, LLC (“PIM”), a registered investment adviser that manages Putnam’s registered investment companies, including open-end mutual funds, exchange-traded funds (“ETFs”), and closed-end funds (the “Putnam Funds”). PIM acts as sub-adviser to its affiliate Franklin Templeton Private Portfolio Group, LLC with respect to certain clients and program sponsors in connection with third-party investment adviser, broker-dealer and other financial services firm separately managed accounts, managed accounts or other wrap fee programs (collectively, “SMA Programs”). PIM also subadvises registered investment companies sponsored by other financial firms and manages assets for institutional clients.  Putnam Fiduciary Trust Company, LLC (“PFTC”), a New Hampshire non-depository trust company that manages assets through collective investment trusts and separate accounts, and also provides trustee and custodial services pursuant to its banking and fiduciary powers, and These three Putnam management companies generally market their services together (depending on the type of client involved) under the Putnam brand. They are sometimes called “Putnam,” the “Putnam Advisers,” the “Adviser” or simply “We” in this brochure.

Services of Other Affiliates Franklin Templeton operates its investment management business through the Putnam Advisers, as well as through multiple affiliates of the Putnam Advisers, some of which are investment advisers registered with the SEC, some of which are registered with non-U.S. regulatory authorities, and some of which are registered with multiple regulatory authorities. A Putnam Adviser uses the services of appropriate personnel of one or more of its affiliates for investment advice, portfolio execution and trading, administrative services (such as middle office or back-office services), and/or client servicing in their local or regional markets or in their areas of special expertise, except to the extent restricted by the client under its investment management agreement, or if inconsistent with applicable law. Arrangements among affiliates take a variety of forms, including delegation arrangements, formal sub-advisory arrangements, and servicing agreements. Certain employees and officers of Franklin Templeton and its subsidiaries who engage in investment advisory services may also be appointed to serve as officers and/or authorized persons of a Putnam Adviser and, in that capacity, may provide investment research, investment recommendations and other services to a Putnam Adviser from time to time. In each of these circumstances, the Putnam Adviser remains fully responsible for the account from a legal and contractual perspective. No additional fees are charged for the affiliates’ services except as disclosed in the investment management agreement. Please see Item 10 (“Other Financial Industry Activities and Affiliations”) for more details.

Investment Management Services Putnam offers professional, active investment management to investors worldwide, with a focus on a diversified set of equity strategies. Prior to July 15, 2024, Putnam also offered additional strategies across a broad range of asset classes, including fixed income and multi-asset class strategies, and Putnam continues to provide investment management in these strategies to existing clients. New accounts in fixed income and multi-asset class strategies formerly offered by Putnam are generally offered by the Franklin Templeton Fixed Income and Franklin Templeton Investment Solutions teams through the SEC-registered investment adviser Franklin Advisers, Inc. and its affiliated firms. In addition, Franklin Advisers, Inc., Franklin Templeton Investment Management Limited and other Franklin Templeton affiliates currently manage certain products formerly managed by the Putnam Advisers, including products that continue to bear the Putnam brand. Putnam manages client assets based on the individual needs of the client, which are stated in the written objectives and guidelines of the client’s account. In a typical discretionary separate account relationship (that is, an investment portfolio pursuing a particular investment strategy, established in the client’s name at its custodian), the client authorizes PAC to supervise, manage and direct the investment of the assets of the portfolio without prior consultation with the client. For non-discretionary accounts, which are less common, PAC must consult with the client prior to implementing any investment decisions. PAC is primarily a discretionary asset manager and does not routinely provide general investment advice or planning services to its clients. As of September 30, 2025, PAC had approximately $33.19 billion in discretionary net assets under management1 (which includes services with respect to certain bank collective investment trusts). In addition to separate accounts, PAC also manages or sub-advises pooled investment funds. These funds include privately-offered funds exempt from registration under the Investment Company Act of 1940 pursuant to its Sections 3(c)(1) or 3(c)(7), bank trusts for pension and profit-sharing plans, non-U.S. investment funds and certain Putnam Funds (collectively, “Funds”). Some non-U.S. funds may be offered in the United States to “qualified purchasers,” but others are available only in specific non-U.S. countries. Like separate accounts, investment funds are managed in accordance with written investment objectives, strategies and guidelines. However, a Fund is a pooled vehicle, and its investment program cannot be tailored to the individual needs of any particular investor. Investment in a fund (including receipt of this brochure as an investor) does not create an advisory client relationship between the investor and Putnam. Therefore, investors should consult their consultant or financial representative and consider whether a fund meets their investment objectives and risk tolerance prior to investing. Investors in Funds receive an offering memorandum, prospectus, or similar document that describes the fund, including its risks, fees, and the qualifications needed to invest. Some Funds may be offered on a private placement or other limited basis and may not be available to, or appropriate for, all prospective investors.

PAC also provides non-discretionary investment management services through fee programs such as Unified Managed Account programs or other programs, where PAC generally provides ongoing investment recommendations through one or more “model” portfolios, and the program sponsor, rather than PAC, makes investment decisions and executes trades on behalf of its underlying clients. The sponsor decides in its discretion whether to make any changes to the model that PAC recommends, and is also solely responsible for determining the suitability of the strategy and investments for each client that participates. All management and support of underlying client accounts, such as investment allocation, restrictions, or tax harvesting, is also the responsibility of the sponsor or any overlay manager selected by the sponsor.

Sales and Marketing Activities In order to promote our products and services, Putnam and its affiliates engage in sales and marketing activities, including responding to client requests for proposals (RFPs) and presenting or making available information on our investment capabilities and pooled fund products, as well as sharing education materials, market commentary, white papers, investment and portfolio analysis tools and models, and other resources. Clients and prospective clients should be aware that neither Putnam nor any of its affiliates will be considered an investment advice fiduciary in connection with selling and distributing our products and services, including under the Employee Retirement Income Security Act of 1974 or any similar law. When we or our affiliates discuss a possible investment with Putnam with a prospective or current client, we and they do not undertake to provide impartial investment advice, or to give advice in a fiduciary capacity in connection with any related investment decision or transaction. This is because providing such advice could involve an inherent conflict of interest, since Putnam earns fees, such as the management fees discussed in Item 5 of this brochure, when clients invest with us. We earn our fees in connection with selecting portfolio investments for our clients within a specific investment discipline or fund strategy; in contrast, we do not provide advice, and do not earn fees for providing advice, on the selection of investment advisers (such as Putnam and its competitors) or investment funds (such as our managed funds and those offered by other asset managers). We offer and sell only our own products and services, and do so on an arm’s length basis. Clients and prospects who want professional guidance on whether or not to hire Putnam, or whether or not to invest in a particular Putnam offering, should seek independent advice.

Limitations on Services As an asset manager, PAC provides a specific service. PAC does not provide tax, legal, or accounting advice, and clients should note that, unless otherwise specifically agreed or disclosed in writing, PAC will not take tax considerations into account in managing a client’s portfolio. In addition, for clients other than our managed funds, we do not advise on or take any action in any legal proceedings on their behalf, including bankruptcies or class actions involving securities or other investments held or formerly held in a client’s account or the issuers of those securities, except where specifically agreed with the client in writing. For Putnam-sponsored Funds, Putnam manages portfolio cash as part of its overall investment services or arranges for cash to be managed through its affiliate Franklin Advisers, Inc. (See “Services of Other Affiliates” above). Cash arrangements for other clients, such as separate accounts or sub-advised clients, vary depending on the client’s preferences and the account documents. Where the short-term investment fund (STIF) or similar vehicle offered by a client’s custodian is used for residual cash investment (for example, where a client directs that all cash be swept daily to the STIF), clients should note that the STIF involve additional credit, market and other risks beyond the securities managed directly by Putnam. Clients interested in greater detail about their custodian’s STIF should contact their custodian for more information.

Putnam’s management fees are set forth in the client’s investment management agreement. Putnam generally charges management fees to its discretionary account clients in accordance with its standard fee schedules when the management agreement is signed. Management fees are negotiated with some clients, so fees vary from the standard schedules. Putnam is required to deliver this brochure only to “qualified purchasers” as defined in section 2(a)(51)(A) of the Investment Company Act of 1940. As a result, SEC rules do not require us to include our standard fee schedules in this brochure. Other investment advisers may charge higher or lower fees for comparable services than Putnam charges. Generally, management fees are billed to the client and are payable quarterly in arrears. Putnam does not require prepayment of management fees. Putnam must comply with SEC rules about “custody” of client assets (which can include automatic billing arrangements). Clients other than registered investment companies who prefer that Putnam deduct fees directly from their account will be required to make specific arrangements with a qualified custodian and to provide Putnam with additional information (including confirmation that the custodian provides the client with required account statements). Fees, minimum account sizes, and fee breakpoints may be negotiated or modified in Putnam’s discretion based on factors such as asset class, pre-existing fee schedules, account size and overall size of the client relationship, the client’s status as a “founder” or early investor in a given strategy or pooled vehicle, portfolio complexity and customization requests (such as specific investment restrictions requested by the client that cause the account to differ from similar accounts managed at Putnam), service requirements (such as non-standard reporting and information requests), the country or market in which a client is located, affiliate status, or other factors. Putnam sometimes also chooses to waive all or a portion of negotiated fees for a period. While we act as a fiduciary in managing client assets, not all our business decisions are fiduciary decisions. Subject to applicable law and any contractual commitments, we may choose to charge different fees or otherwise offer different levels of service to different clients for the same fee, depending on our own business needs and market demands.

UMA and other Wrap Program and Model Portfolio Fees PAC receives fees quarterly in arrears based on a percentage of the aggregate or average asset value of all UMA program assets managed by the sponsor in accordance with PAC’s model portfolios. This fee is negotiated with and paid by the sponsor. Advisory fees paid by the client to the sponsor in order to participate in these programs are established by the sponsor; PAC does not negotiate advisory fees with a UMA client. Each client should evaluate whether a particular UMA program is suitable for his or her needs, including the fees charged and services provided. Please see the sponsor’s wrap fee program brochure or similar disclosure document for additional fee information and disclosures.

Performance Fees Some Putnam clients, including some investment funds, pay performance-based fees. For more information on these fees, please read Item 6 of this brochure.

Separate account Termination The terms and conditions of PAC’s services are specified in the investment management agreement between PAC and the separate account client. The management agreement generally allows either the client or PAC to terminate it at any time upon written notice (typically, of less than 60 days).

Investment Funds In addition to separate accounts, PAC manages or subadvises pooled investment funds of various kinds. Each fund’s offering and subscription documents describe the fees that apply. Normally, the Putnam management fees that a fund investor pays are similar to the fees for a similar Putnam separate account. However, investors should note that the fees for fund investments differ from the fees for separate accounts in several ways. First, a separate account client arranges for custody, recordkeeping and other service providers for its portfolio on its own (and pays for these services separately). In contrast, Putnam-managed funds hire their own service providers, and pay the related operating costs. Depending on the fund and account documentation, in some cases, Putnam bears some or all of these expenses. For details, please refer to the specific fund’s offering documents. In addition, the management fees on a fund may also differ from the fees for similar separate accounts depending, for example, on the specific services provided and Putnam’s related costs. Interested qualified investors can request a fund’s offering documents from Putnam. From time to time, where permitted by law, Putnam may agree to rebate a portion of advisory fees or other fund expenses to certain investors in our pooled funds. These rebates may be made by purchasing additional shares of the fund, or as a refund payment to the investor. PAC also sub-advises some of the Putnam Funds, which are registered investment companies. More information about this relationship, including fees, is disclosed in the prospectus and statement of additional information for each Putnam Fund; however, these sub-advisory fees are paid by PIM or another relevant affiliate, not by the Putnam Funds.

Other Third-Party Fees and Expenses In addition to the fees described above, clients of the Putnam Advisers typically bear other costs associated with their accounts or portfolio investments. Depending on the type of investment account, vehicle or product that a client is invested in these costs and expenses may include, but are not limited to: (i) custodial charges, brokerage fees/costs, commissions, other transaction costs and related costs, certain consulting fees, auditing fees, and transfer agency fees, (ii) interest expenses, (iii) taxes, duties and other governmental charges (including regulatory, licensing and filing expenses and fees, costs and expenses for preparation therefor), (iv) transfer and registration fees or similar expenses, (v) costs associated with foreign exchange transactions, (vi) other portfolio expenses (including, without limitation, research, risk modelling and software expenses), (vii) costs, expenses and fees (including investment advisory and other fees charged by the investment advisers of funds in which the client invests) associated with products or services that may be related to such investments and (viii) extraordinary expenses or costs that a client incurs from time to time. With respect to services used in connection with making, holding and divesting investments (which, depending on the circumstances, include, but are not limited to, custodial, securities lending, brokerage, futures, banking, consulting or third-party advisory services), each client will be required to establish business and contractual relationships with relevant service providers or other counterparties based on the client’s own credit standing. The Putnam Advisers will not have any obligation to allow their credit to be used in connection with the establishment of such relationships, nor is it expected that such service providers or counterparties will consider or rely on the Putnam Advisers’ credit in evaluating the client’s creditworthiness. When the Putnam Advisers believe it is beneficial for an account, an affiliate of the Putnam Advisers may be engaged to oversee the activities of an unaffiliated service provider, such as in provision of administrative services. In these circumstances, the Putnam Advisers’ affiliate generally collects the fees for such services from the client, retains a portion as compensation for providing oversight activities, and remits the remainder of the fee to the unaffiliated service provider. Clients will also generally incur brokerage costs. See Item 12 (“Brokerage Practices”) for discussion on brokerage, including fees/costs associated therewith. In addition to the expenses listed above, Funds generally bear their own operating and other expenses, including, but not limited to: (i) sales expenses, (ii) legal, regulatory, reporting and compliance expenses, (iii) internal and external accounting, audit, valuation and tax preparation expenses, (iv) insurance, (v) directors’ fees and other costs associated with professionals retained by the Putnam Adviser or an affiliate to perform services on behalf of the Fund, (vi) fees, interest and other costs related to the use of derivative instruments or other similar transactions, (vii) expenses related to credit facilities, (viii) organizational and offering expenses, (ix) expenses related to the Putnam Adviser’s research, due diligence, and monitoring of Fund investments,(x) fees

and expenses related to any investments in other funds or vehicles and (xi) all other expenses that the Putnam Adviser or its affiliates have not expressly agreed to pay. Further details of these and certain other expenses (some of which are unique to a particular type of Fund given its strategy) are described in the relevant Fund’s PPM and/or other offering documents. The Advisers that manage private Funds will use a master/feeder structure for certain private Funds, which allows the Putnam Advisers to manage a single portfolio of investments at the master fund level and have one or more feeder funds that invest substantially all of their respective assets into the master fund. Individual and institutional investors typically invest in the feeder funds, or, under certain circumstances, in the master fund. When applicable, a management fee and performance fee or carried interest is charged either at the master fund level or the feeder fund level depending on the specific circumstances of the master/feeder fund. Administrative and custodian fees (when all portfolio investments are held in the master fund) are often waived at the feeder fund level and charged only at the master fund level. However, the feeder funds will indirectly bear their pro rata share of all fees and expenses of the master fund in which they invest. Such fees and expenses include, but are not limited to, the master fund’s administrative and custodian fees; expenses incurred in connection with the master fund’s operations and trading activities, including brokerage and clearing expenses, margin interest expenses, custodial expenses and routine legal, accounting, auditing, and tax preparation fees and expenses; and extraordinary expenses. In addition, fees and expenses specific to a feeder fund are usually charged only to that feeder fund. Under certain circumstances, a Putnam Adviser will, on behalf of certain clients, invest in or recommend pooled investment vehicles, including U.S.-registered Funds. Subject to applicable law and regulation and the terms of their agreements, clients will generally bear the costs and expenses charged by these investment vehicles to their investors, such as management and administrative fees, in addition to the Adviser’s management fees (subject to any adjustment as described below). A Putnam Adviser may determine it is appropriate to invest a portion of a client’s assets into other funds for which the Putnam Adviser or an affiliate of the Putnam Adviser serves as investment adviser or sub-adviser (“Affiliated Funds”) This might be appropriate where, for example, the Affiliated Fund provides a more efficient and cost-effective way to help further diversify an account. Such an arrangement creates a conflict of interest for the Putnam Adviser to the extent that the Putnam Adviser has an incentive to recommend investments in one of the Affiliated Funds rather than in unaffiliated funds or other securities. The Putnam Adviser or its affiliates will, under certain circumstances, receive investment advisory and other fees from the Affiliated Funds but not from unaffiliated funds or other securities (although any investments in such securities would generally be subject to the advisory fees applicable to the securities). The Putnam Advisers seek to mitigate the potential conflict by excluding any assets invested in Affiliated Funds from the management fee charged by a Putnam Adviser to the account or rebating the portion of such fee attributable to investments in Affiliated Funds, unless otherwise agreed with a client (for example, where a client receives separate asset allocation or other advisory services at the account level) or disclosed to a client and subject to applicable law. Those assets that are invested in Affiliated Funds are instead subject to the Affiliated Fund’s fees and charges applicable to all investors in such fund, as disclosed in the Affiliated Fund’s current prospectus or other relevant offering documents. As a result, the Putnam Advisers or their affiliates will indirectly receive advisory and other fees paid by those clients as investors of an Affiliated Fund. While the management fees charged to the account with respect to such assets are excluded or rebated (unless otherwise agreed or disclosed), the client would generally still bear any operating expenses of the Affiliated Fund investment. This and other conflicts as well as similar arrangements with respect to investments in Affiliated Funds and conflicts associated therewith are further discussed in Item 11 (“Code of Ethics, Participation or Interest in Client Transactions and Personal Trading – Conflicts Related to Investment in Affiliated Funds and Affiliated Accounts”).

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and Risk of Loss For new client accounts, Putnam offers a variety of equity investment strategies. As noted above, prior to July 15, 2024, Putnam also offered additional strategies across a broad range of asset classes, including fixed income and multi-asset class strategies, and Putnam continues to provide investment management in these strategies to existing clients. New accounts in fixed income and multi-asset class strategies formerly offered by Putnam are generally offered by the Franklin Templeton Fixed Income and Franklin Templeton Investment Solutions teams through the SEC-registered investment adviser Franklin Advisers, Inc. and its affiliated firms.

Methods of Analysis Putnam is an active, long-term investment manager. Our analysis of the financial markets is generally based on fundamental analysis and research, but also includes quantitative elements. Fundamental analysis attempts to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) in order to determine if the company is underpriced or overpriced. Quantitative analysis applies concepts of fundamental valuation and security selection via computer models. These computer-based models are designed to analyze a variety of financial data from various sources and generate investment selections. We may consider, among other factors, a company’s valuation, financial strength, growth potential, competitive position in its industry, projected future earnings, cash flows and dividends when deciding whether to buy or sell equity investments. We may consider, among other factors, credit, interest rate, prepayment, and liquidity risks, as well as general market conditions, when deciding whether to buy or sell fixed-income investments. As part of our investment analysis, depending on the strategy or portfolio in question, we may integrate environmental, social, or governance (“ESG”) issues or considerations into our research and/or investment decision-making. In our view, analysis of ESG issues is part of good investing, as these issues, like other, more traditional areas of investment analysis, such as market position, growth prospects, and business strategy, have the potential to impact risk and returns. For example, in the governance area, evaluation of the strength of a company’s management has always been a critical consideration in our investment process. The relevance and materiality of other ESG issues in our process will differ from strategy to strategy, from sector to sector, and from portfolio manager to portfolio manager, and for some strategies, including those where we lack relevant ESG data, depending on the strategy, ESG considerations may not be a material part of our process. It is also important to note that consideration of ESG issues does not mean that a particular account pursues a specific “ESG” or “sustainable” investment strategy, and, depending on the strategy, we sometimes make investment decisions notwithstanding the associated ESG considerations. In all cases, our task is to pursue the agreed-on investment objective for a given account. In our view, pursuing that goal often requires appropriate consideration of ESG matters, just as it does other investment factors. Generally, Putnam research is focused on developing both a top-down view of broader market performance and a bottom-up outlook for individual securities. Putnam relies significantly on research generated in-house which is tailored to the precise needs of our investment professionals. External research is also used – for example, to evaluate consensus views and to augment the research process. For more information, see Item 12 of this brochure.

Investment Strategies Putnam offers a wide variety of investment strategies to its clients. In managing assets, Putnam has the flexibility to invest in securities and other financial instruments of almost any type (including both cash securities, such as stocks and bonds, and derivative instruments, such as swaps, futures, forwards, and options). This flexibility is subject to the investment objectives and guidelines of each account, as agreed with the client.

Equity Mandates Putnam’s equity mandates typically seek competitive results over time, backed by original, fundamental research on a global scale. Putnam seeks to generate alpha though a bottom-up approach to investing, seeking to identify the most attractive investment opportunities based on valuation and perceived quality while considering overall portfolio construction. Portfolios are designed in an attempt to maximize alpha from stock selection, and while individual portfolios vary, holdings tend to be broad based, which can help dampen volatility over time, although there can be no guarantee of investment results. We employ global sector coverage, with each team having extensive experience in researching their sectors.

Putnam’s primary equity strategies are listed below. Putnam may also manage or offer other products or strategies not listed here, including private funds. U.S. Large Cap Value U.S. Large Cap Value Concentrated Non-U.S. Value U.S. Core U.S. Core Concentrated U.S. Research Non-U.S. Core Focused U.S. Focused Non-U.S. George Putnam Balanced* Convertible Securities* U.S. Large Cap Growth U.S. Large Cap Growth Concentrated Non-U.S. Durable U.S. Sustainable Future U.S. Sustainable Leaders Global Sustainable Global Technology Global Health Care Business Development Companies BioRevolution Emerging Markets Emerging Markets Small Cap Emerging Markets ex China U.S. Small Cap Growth U.S. Small Cap Value Non-U.S. Small Cap.

*These strategies also draw on personnel and resources at Franklin Advisers, Inc. Equity investing involves many risks. See the “Risk of Loss” section below for more information.

Fixed Income Mandates The fixed income portfolios managed by the Fixed Income team of Franklin Advisers, Inc., operating through Putnam with respect to certain accounts active on July 15, 2024, offer actively managed fixed income strategies ranging from a broad global multi-sector perspective to regionally focused, as well as sector-specific styles of investing. Such strategies emphasize rotation among different types of debt on a relative value basis, specific security selection, quantitative analysis of each security and the portfolio as a whole, as well as intensive credit analysis and review. Portfolios seeking income generally focus on one or more of the following securities: (i) taxable and tax-exempt money market instruments, (ii) tax-exempt and taxable municipal securities, (iii) global fixed-income securities, and (iv) taxable fixed-income debt securities of corporations, of the U.S. government and its sponsored agencies and instrumentalities, of non-U.S. governments, and nongovernment structured securities, such as residential mortgage backed securities or unsecured consumer loans. In addition, certain products will focus on investments in particular countries and regions. Fixed-income investing involves many risks. See the “Risk of Loss” section below for more information.

Investment Solutions Mandates Franklin Templeton’s Investment Solutions group (“FTIS”), operating through Putnam for certain accounts active on July 15, 2024, offers various multi-asset strategies utilizing a combination of strategic asset allocation, dynamic allocation and manager research capabilities, as well as income generation techniques. Our multi-asset strategies cross a broad spectrum of investment goals including income strategies, target date and target risk strategies, global allocation strategies, real return strategies, factor-based strategies and others. FTIS, which includes members of Franklin Advisers, Inc., seeks to provide risk-adjusted returns within the asset allocation framework of individual mandates. The FTIS investment approach combines long-term strategic allocation decisions designed to provide investment solutions to client needs with shorter-term dynamic allocation adjustments to take advantage of the current market environment. Asset class views are built on proprietary evaluations of the relative attractiveness of equity, fixed income, cash and alternative investments from both within FTIS and the broader Franklin Templeton organization. In addition to asset class views, FTIS will, from time to time, also take regional or country views within asset classes depending on strategy flexibility. The Mandate Research team within FTIS provides recommendations on individual funds to be used within our multi-asset and multi-strategy portfolios based on a qualitative and quantitative review of performance, risk, management and investment process. Investing in a diversified portfolio of equity and fixed-income instruments involves many risks. See the “Risk of Loss” section below for more information.

Risk of Loss While Putnam seeks to achieve a client’s stated investment objective, there is no guarantee that we will succeed. Investing in securities and other financial instruments involves risk of loss that clients should be prepared to bear. Our accounts may not perform as well as accounts managed by others or as well as their benchmarks. This section gives more information on the material risks that may apply to a client portfolio depending on the asset class or classes in which it invests. These descriptions cover our most significant strategies, and they focus on risks that are shared by most portfolios in a given asset class (such as equities or fixed-income). Some specialized portfolios may be subject to additional risks. For example, our regional or sector strategies, such as Emerging Markets Equity or Global Technology, will be subject to risks associated with focusing in one geographic region or sector. Of course, this section does not cover every possible risk, and Putnam sometimes buys investments that we do not describe below. In addition, each specific account’s guidelines and strategy will determine the risks that apply.

For example, if you invest in a portfolio of mostly large-cap equities, the risks of small-cap investing may not be significant. If you invest in a high yield bond portfolio, credit risk may be significant, but prepayment risk may not be. If your account does not permit the use of derivatives, derivatives risks will not apply. For more detailed information about your portfolio’s risks, please contact Putnam. Fund investors should also refer to their fund’s offering materials for a more detailed discussion about risks.

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PAC provides investment advice to a wide variety of clients, such as U.S. and non-U.S. pension and profit-sharing plans; charities, endowments and foundations; U.S. and non-U.S. investment funds; state, local and non-U.S. governments, their agencies and instrumentalities; and corporations. PAC also sub-advises some Putnam Funds and other portfolios managed by other Putnam companies and provides investment advice as a non-discretionary portfolio manager in UMA or other "wrap fee" programs. PAC generally requires a separate account, at or shortly after commencement, to have, depending on the product, minimum assets ranging from $25 million to $100 million. Exceptions to account minimums may be made in some cases.

Use and Provision of Client Information and Confidentiality Clauses in Investment Management Agreements A Putnam Adviser will at times include a separate account client’s name in a representative or sample client list prepared by the Putnam Adviser with the client’s consent. The Putnam Advisers are not generally required to provide notice to, or obtain the consent of, any client for use or disclosure of account information to third parties, provided such use does not disclose the client’s name or other personal information. This may include information relating to the Putnam Advisers’ investment experience with respect to an account or an account’s performance, composite and representative account performance presentations, marketing materials, attribution and research analyses, statistical and data compilations, or similar materials. In various circumstances, a Putnam Adviser will disclose information to third parties that include a client’s name, account number or other account information (including non-public information), including, but not limited to: (i) in connection with the performance of the adviser’s services under the respective investment management agreement (including, but not limited to, providing trading and other account information to brokers, third-party administrators, consultants, auditors and other counterparties, and the preparation and printing of client account statements and reports by third parties), (ii) if required by law or regulatory authority, including, but not limited to, any subpoena, administrative, regulatory or judicial demand or court order, or (iii) in connection with the bylaws or equivalent governing documents of any issuer in which the account is invested. While the Putnam Advisers are not generally required to provide notice or obtain consent in these situations, certain clients may have provisions in their investment management agreements that require the Advisers to provide notice of certain types of disclosures or disclosure requests. However, any such notice will be limited to the extent permitted by applicable law, court order or regulation.

Management The Putnam Advisers manage different types of accounts with a variety of fee arrangements and charge performance-based fees or allocations with respect to certain clients in addition to management fees. These are described in more detail in Item 5 (“Fees and Compensation”) above. U.S.-registered Funds, for example, generally pay management fees based on a fixed percentage of assets under management, whereas separate accounts and Private Funds typically have more varied fee structures, including potentially a combination of asset- and performance-based compensation. Side-by-side management by a Putnam Adviser of Funds, separate accounts and sub-advised accounts creates potential conflicts of interest, including those associated with any differences in fee structures, as well as other economic interests the Putnam Adviser or its supervised persons will, in certain circumstances, have in an account managed by the Putnam Adviser. When a Putnam Adviser receives performance-based fees or allocations, the reward for strong investment returns can incentivize the Putnam Adviser to make investments that are riskier or more speculative than it would otherwise make. The prospect of achieving higher compensation from a private Fund or separate account that pays performance-based fees or allocations than from an account that does not pay such fees (e.g., U.S.-registered Funds) provides a Putnam Adviser with an incentive to favor the private Fund or separate account when, for example, placing securities transactions that the Putnam Adviser believes could more likely result in favorable performance. Similarly, a significant proprietary investment held by a Putnam Adviser or an affiliate in an account creates an incentive for the Putnam Adviser to favor such account relative to other accounts. In addition, the application of tax laws affecting performance-based fees or allocations can create incentives and affect the behavior of a Putnam Adviser and its personnel with respect to holding or disposing of account investments. Please see Item 11 (“Code of Ethics, Participation or Interest in Client Transactions and Personal Trading – Potential Conflicts Relating to Advisory and Other Activities – Allocation of Investment Opportunities”) for more information regarding conflicts of interest related to allocation of investment opportunities. The Putnam Advisers seek to conduct their business by treating all clients equally and by appropriately managing conflicts of interest that arise when conducting transactions involving multiple clients. The Putnam Advisers do this by disclosing potential conflicts to their clients and by implementing policies and procedures reasonably designed to address those conflicts. The Putnam Advisers have implemented a number of policies and procedures designed to address side-by-side management and the potential conflicts of interest that arise when a portfolio manager or different portfolio managers within a single investment adviser or investment group manage multiple funds and investment accounts for advisory clients. Putnam Advisers with U.S.-registered Funds as clients are subject to applicable law and/or policies and procedures with respect to such clients that limit or prescribe practices related to side-by-side management. For example, the U.S.-registered Funds are subject to restrictions relating to engaging in transactions with their affiliates, including restrictions relating to engaging in transactions jointly with their affiliates. These restrictions will, under certain circumstances, prohibit a U.S. Registered Fund from engaging in certain transactions alongside its affiliates. Additional examples of situations that create the potential for conflicts of interest are discussed below. A potential conflict of interest can arise if a Putnam Adviser sells short a security in one account while simultaneously advising another account to hold the same security long. The Putnam Advisers may have a legitimate reason for engaging in such inconsistent transactions. For example, the investment objectives of the two accounts may differ. Nonetheless, the Putnam Advisers could be viewed as harming the performance of the Account with the long position for the benefit of the account with the short position if the short sale caused the market value of the security to drop. To alleviate this potential conflict of interest, the Putnam Advisers have implemented policies

and procedures to deny a short sale request in certain circumstances. Moreover, Putnam Advisers with U.S.registered Funds as clients are subject to applicable law with respect to such clients that limit or prescribe practices related to short sales. Please see Item 11 (“Code of Ethics, Participation or Interest in Client Transactions and Personal Trading”) for additional information regarding conflicts arising from clients investing alongside other clients. Cross trades are another area that can present potential conflicts of interest in that they may be viewed as favoring one client over another. For example, a Putnam Adviser making a cross trade that is expected to increase in value from an account (e.g., U.S.-registered Funds) with an asset-based fee to an account with a performance fee could be perceived as doing so merely to increase the performance-based compensation it receives from the account with a performance fee. The reverse is true with respect to securities expected to decrease in value. The Putnam Advisers have implemented inter-account transaction procedures to address these potential conflicts of interest by, among other things, requiring pre-clearance of all cross trades from the Compliance Department. Putnam Advisers with U.S.-registered Funds as clients are also subject to applicable law with respect to such clients that limit or prescribes practices related to cross trades. Please see Item 11 (“Code of Ethics, Participation or Interest in Client Transactions and Personal Trading”) for additional information regarding conflicts of interest related to cross trades. Aggregation and allocation of transactions and investment opportunities are other areas where potential conflicts of interest will arise. The Putnam Advisers, from time to time, aggregate orders of their clients to effect a larger transaction with the aim of reducing transaction costs. The Putnam Advisers must then allocate the securities among the participating accounts. Although aggregation of transactions is permissible, potential conflicts of interest exist in the aggregation and allocation of client transactions. For example, a Putnam Adviser could be viewed as allocating securities that it anticipates will increase in value to certain favored clients, especially those that pay a performancebased fee to that Putnam Adviser. Similarly, if a portfolio manager identifies a limited investment opportunity that is suitable for several Funds or accounts, a single Fund or account may not be able to take full advantage of that opportunity due to an allocation of that opportunity across all eligible Funds and other accounts. In other limited investment opportunities, including some privately offered investments, where the investment opportunity is suitable for multiple and different types of clients, allocation will, from time to time, be based on alternative methodologies designed to comply with applicable law and ensure fair and consistent treatment of such clients. The Putnam Advisers have implemented trade aggregation and allocation procedures designed to address these potential conflicts of interest. These procedures require that an average price be used for multiple executions of a particular security through the same broker on the same terms on the same day and describe the allocation methodologies to be applied as well as permissible exceptions from standard allocation methods that must be pre-approved by a designated trading desk compliance officer. Please see Item 11 (“Code of Ethics, Participation or Interest in Client Transactions and Personal Trading – Potential Conflicts Relating to Advisory and Other Activities – Allocation of Investment Opportunities”) for further discussions on conflicts of interest related to allocation of investment opportunities and Item 12 (“Brokerage Practices – Aggregation and Allocation of Trades”) for further discussions on aggregation and allocation of trades. In addition, under our policies:  Performance fee accounts must be included in all standard trading and allocation procedures with all other legacy Putnam accounts.  All accounts must be assigned to a specific category of account and trade together with allocations of accounts in their categories.

 All trading must be effected through normal queues and procedures must be followed (that is, no special treatment is permitted for performance fee accounts or higher-fee accounts based on account fee structure).

 Front running is prohibited.  Without approval of the Chief Compliance Officer, no portfolio manager or team may be guaranteed or specifically allocated any portion of a performance fee. Interested clients whose accounts bear performance fees should refer to the documentation for their particular fund or account for more information.

As part of these policies, we have also implemented trade oversight and review procedures in order to monitor whether particular accounts (including higher-fee accounts, performance fee accounts and affiliated accounts) are being favored over time.

Although we believe our policies and procedures are reasonably designed, it is not possible to eliminate all the potential risks of these conflicts. For more information about other potential conflicts of interest in trading and managing client accounts, see Item 11.

Affiliations The Putnam Advisers are indirect wholly-owned subsidiaries of Franklin Templeton, a holding company with its various subsidiaries that operate under the Franklin Templeton and/or subsidiary brand names. PAC has certain business arrangements with related persons/companies that are material to its advisory business or to PAC clients, including those described in this Item 10 (“Other Financial Industry Activities and Affiliations”). In some cases, these business arrangements will, from time to time, create a potential conflict of interest, or the appearance of a conflict of interest, between the Putnam Advisers and a client. Please see Item 4 (“Advisory Business”) for additional information on services of affiliates. Recognized conflicts of interest are discussed in Item 6 (“Performance-Based Fees and Side-By-Side Management”) above and Item 11 (“Code of Ethics, Participation or Interest in Client Transactions and Personal Trading”) and Item 12 (“Brokerage Practices”) below. The Putnam Advisers have arrangements with one or more of the following types of related persons that may be considered material to their advisory business or to their clients.

Related Broker-Dealer The Putnam Advisers are under common control with Franklin Distributors, LLC (“FD, LLC”), which is an SEC registered broker-dealer and member of the Financial Industry Regulatory Authority (“FINRA”). FD, LLC is also registered with the Commodity Futures Trading Commission (“CFTC”) as an introducing broker and is a member of the National Futures Association (“NFA”). FD, LLC is a limited purpose broker-dealer that serves as an underwriter and distributor for Franklin’s U.S. registered funds and 529 college savings plan. Furthermore, FD, LLC serves as a placement agent for affiliated private funds. FD, LLC also serves as broker-dealer of record on certain accounts of Putnam Fund shareholders that are held directly with the Fund’s transfer agent. FD, LLC registered staff principally engage in wholesaling and marketing activities. FD, LLC does not make recommendations to purchase or sell fund shares to retail investors. Underwriting and distribution fees are earned primarily by distributing Putnam Funds pursuant to distribution agreements between FD, LLC and the Funds. In addition, certain of the Putnam Advisers’ employees are registered representatives of FD, LLC. Please see Item 11 (“Code of Ethics, Participation or Interest in Client Transactions and Personal Trading”) for a discussion of the associated conflicts. In addition to the above, certain non-U.S. affiliates of the Putnam Advisers promote the services and managed funds of the Putnam Advisers outside the United States. Clients and potential clients should be aware, in choosing to begin a client relationship with a Putnam Adviser or invest in an investment fund offered by Putnam, that our affiliated sales personnel and various affiliated companies are compensated for their distribution activities. This compensation may include commissions based on the successful sale of particular Putnam funds or strategies/services. Accordingly, our personnel and our affiliates’ personnel have an incentive to sell Putnam products and services.

Related Advisers The Putnam Advisers will, under certain circumstances, enter into a sub-advisory arrangement with, or refer a client to, an investment adviser affiliate, including from time to time another Putnam Adviser, capable of meeting the client’s specific investment needs. One or more of these affiliated investment advisers may be serving as a commodity trading advisor (“CTA”) and/or a commodity pool operator (“CPO”) that is either registered or exempt from registration with the CFTC. The Putnam Advisers as well as other investment adviser affiliates are affiliated with each other through the common control of Franklin Templeton, and certain of these advisory entities share certain supervised persons, portfolio management personnel and investment research with each other. A Putnam Adviser uses the services of appropriate personnel of one or more of its affiliates for investment advice, portfolio execution and trading, administrative services (such as middle office or back-office services), and/or client servicing in their local or regional markets or in their areas of special expertise, except to the extent restricted by the client under its investment management agreement, or if inconsistent with applicable law. Arrangements among affiliates take a variety of forms, including delegation arrangements, formal sub-advisory arrangements, and servicing agreements. Certain employees and officers of Franklin Templeton and its subsidiaries who engage in investment advisory services may also be appointed to serve as officers and/or authorized persons of a Putnam Adviser and, in that capacity, may provide investment research, investment recommendations and other services to a Putnam Adviser from time to time. In each of these circumstances, the Putnam Adviser remains fully responsible for the account from a legal and contractual perspective. No additional fees are charged for the affiliates’ services except as disclosed in the investment management agreement. These relationships will, from time to time, present potential conflicts of interest relating to the Advisers’ activities. Please see Item 6 (“Performance-Based Fees and SideBy- Side Management”) and Item 11 (“Code of Ethics, Participation or Interest in Client Transactions and Personal Trading”) for additional information.

Affiliated Funds Putnam also manages various affiliated funds, as described in Item 4. Putnam does not invest the assets of its discretionary client accounts or Putnam funds in other funds managed by Putnam without consent of the client or fund (which may, in some cases, be obtained through disclosure in the investment management agreement or a fund’s offering documents), and generally structures these investments to avoid any duplication of Putnam advisory fees (such as through waivers of Putnam fees at either the investing fund or underlying fund level, depending on the specific facts). Subject to these requirements and any other applicable law, Putnam may use affiliated funds to manage portfolio cash (including cash collateral) efficiently, as underlying “building block” portfolios, or for other purposes.

Conflicts of Interest Being part of a large corporate group could involve conflicts of interest if, for example, an asset manager were to use affiliated products and services when those products and services may not be in its clients’ best interests. Many U.S. and non-U.S. laws aim to limit these conflicts of interests – for example, by preventing a money manager from entering into trades between its clients and its affiliates where the client might be disadvantaged. At Putnam we have policies and procedures designed to comply with these laws. In addition, we believe that our business relationships with our affiliates are carried out on market terms. In some key areas where potential conflicts may arise, we do not currently deal with our affiliates. For example, Putnam currently does not execute portfolio transactions for client accounts with any “affiliated” broker-dealers (as defined under relevant securities laws), and we do not generally invest in the stocks of our corporate affiliates that are public companies. We may, however, deal with or invest in companies whose relationship with Putnam is immaterial (for example, where our parent company has a very small indirect interest that would not make the company an “affiliate” under applicable law). While we do not expect our policies to have any material impact on our management of client accounts, it is possible that refraining from investing in our affiliates could cause clients to forego attractive investment opportunities in some strategies.

Client Transactions and Personal Trading Code of Ethics Summary PAC, an indirect, wholly owned subsidiary of Franklin Templeton, has adopted the Franklin Templeton Code of Ethics and Business Conduct (the “Code of Ethics”), which is applicable to all officers, directors, and employees of Franklin Templeton and its U.S. and non-U.S. subsidiaries and affiliates, including PAC (each, an “Adviser” and collectively, the “Advisers”). The Advisers are also subject to the Franklin Templeton Personal Investments and Insider Trading Policy (the “Personal Investments Policy”), which serves as a code of ethics adopted by Franklin Templeton pursuant to Rule 204A-1 under the Advisers Act and Rule 17j-1 of the 1940 Act. A brief description of the main provisions of the Personal Investments Policy follows. The Personal Investments Policy states that the interests of the Advisers’ clients are paramount and come before any employee. All Covered Employees (as defined below) are required to conduct themselves in a lawful, honest and ethical manner in their business practices and to maintain an environment that fosters fairness, respect and integrity. “Covered Employees” include the Advisers’ partners, officers, directors (or other persons occupying a similar status or performing similar functions), and employees, as well as any other person who provides advice on behalf of the Advisers and are subject to the supervision and control of the Advisers. The personal investment activities of Covered Employees must be conducted in a manner that avoids actual or potential conflicts of interest with the clients of the Advisers. Covered Employees are required to use their positions with the Advisers and any investment opportunities they learn of because of their positions with the Advisers in a manner consistent with their fiduciary duties to use such opportunities and information for the benefit of the Advisers’ clients and with applicable laws, rules and regulations. In addition, the Personal Investments Policy states that information concerning the security holdings and financial circumstances of the Advisers’ clients is confidential and Covered Employees are required to safeguard this information. Additionally, Access Persons, a subset of Covered Employees, are required to provide certain periodic reports on their personal securities transactions and holdings. “Access Persons” are those persons who have access to non-public information regarding the securities transactions of the Advisers’ funds or clients; are involved in making securities recommendations to clients; have access to securities recommendations that are nonpublic; or have access to non-public information regarding the portfolio holdings of funds for which an Adviser serves as an investment adviser or a sub-adviser or any fund whose investment adviser or principal underwriter controls an Adviser, is controlled by an Adviser or is under common control with an Adviser. The Advisers’ Access Persons must obtain pre-clearance from the Compliance Department before buying or selling any security (other than those not requiring pre-clearance under the Personal Investments Policy). The Personal Investments Policy also requires pre-clearance before investing in a private investment or purchasing securities in a limited offering. The Personal Investments Policy generally prohibits Access Persons from investing in initial public offerings (“IPOs”); however, such investments may be permissible in certain circumstances or jurisdictions with prior approval from the Compliance Department. To avoid actual or potential conflicts of interest with the Advisers’ clients, certain transactions and practices are prohibited by the Personal Investments Policy. These include: front-running, trading parallel to a client, trading against a client, using proprietary information for personal transactions, market timing, and short selling Franklin Templeton stock and the securities of Franklin Templeton closed-end funds. The Personal Investments Policy requires prompt internal reporting of suspected and actual violations of the Personal Investments Policy. In addition, violations of the Personal Investments Policy are referred to the Director of Global Compliance and/or the Chief Compliance Officer as well as the relevant management personnel.

The Advisers maintain a “restricted list” of securities in which the Advisers’ personnel generally may not trade. The restricted list is updated as necessary and is intended to prevent the misuse of material, non- public information by their employees. In addition to continuous monitoring, the Compliance Department will conduct forensic testing or auditing of reported personal securities transactions to ensure compliance with the Personal Investments Policy. No Covered Employee or Access Person may trade while in possession of material, non-public information (“MNPI”) or communicate MNPI to others. Information is considered material if there is a substantial likelihood that a reasonable investor would consider the information to be important in making his or her investment decision, or if it is reasonably certain to have a substantial effect on the price of the company’s securities. Information is non-public until it has been effectively communicated to the marketplace. If the information has been obtained from someone who is betraying an obligation not to share the information (e.g., a company insider), that information is very likely to be non-public. The Advisers have implemented a substantial set of personal investing procedures designed to avoid violation of the Personal Investments Policy. Copies of the Personal Investments Policy are available to any client or prospective client upon request by emailing GCSS at GlobalClientServiceSupportAmericas@franklintempleton.com.

Affiliated Accounts The Advisers and their affiliates sometimes create “seed” or “incubator” funds and accounts in order to develop a performance track record in new investment products and strategies before offering them to clients. Franklin Templeton or a subsidiary funds these portfolios. Franklin Templeton employees also invest in some seed portfolios. Franklin Templeton and its related companies and employees also invest in registered investment companies and other investment funds that are offered to clients immediately from inception. Franklin Templeton and any investing employees will benefit from the investment performance of seed portfolios and other Franklin Templeton portfolios in which they invest. These two kinds of portfolios are called “affiliated accounts” below. In some cases, Franklin Templeton and its affiliates and employees may own all or a substantial portion of a particular fund or account for an extended period. Affiliated accounts often invest in the same securities, at or around the same time, as client accounts. The policy of the Putnam Advisers is to allocate trades to affiliated accounts in the same way as client accounts – neither favoring nor disfavoring them except where legally required. Affiliated accounts are normally included in a Putnam Adviser’s daily block trades to the same extent as client accounts, except that seed accounts do not participate in initial public offerings. For more information, please read “Potential Conflicts of Interest in Trading and Management” below. Franklin Templeton employees may also invest in the Putnam Funds in accordance with the terms of the prospectus. Franklin Templeton or an affiliate may discuss with its clients potential investment in investment funds for which a Putnam Adviser acts as an investment adviser and/or managing member/general partner or trustee.

Potential Conflicts Relating to Advisory and Other Activities The Putnam Advisers and their affiliates engage in a broad range of activities, including investment activities for their own account and for the accounts of others and providing transaction-related, investment advisory, management and other services. In addition, while the Putnam Advisers are typically not themselves a general partner of any

limited partnership, one or more of their affiliates often serve as a manager, general partner or trustee or in a similar capacity of a partnership, trust or other collective investment vehicle in which the Advisers’ clients are solicited to invest. In the ordinary course of an Adviser conducting its activities for a client, the interests of a client will, from time to time, conflict with the interests of the Adviser, other clients and/or their respective affiliates. Potential or actual conflicts of interest arise, from time to time, in (i) principal transactions, (ii) cross trades, (iii) investments by the Putnam Advisers or their employees for their personal accounts, (iv) client investment in entities affiliated with an Adviser or in which an Adviser or an affiliate has an interest, (v) allocation of investment opportunities and expenses, (vi) diverse membership among investors in a client account, and (vii) diversity of client base, among others. In addition, while the Advisers are part of the Franklin Templeton organization, the Advisers have their own clients. Although an Adviser may focus primarily on an investment strategy different from other Advisers, clients of the Adviser and such other Advisers will, from time to time, invest in the same company or issuer, including in the same security or in different securities of such company or issuer. In such circumstances, interests of the Adviser’s clients will, at times, therefore conflict with the interests of the clients of the other Advisers. In addition, the interests of and between the Advisers themselves will at times be in conflict. These and other conflicts of interest are more fully described below. The Putnam Advisers manage assets of clients in accordance with the investment mandate selected by the clients and applicable law and will seek to give advice to, and make investment decisions for, such clients that the Advisers reasonably believe to be in the best interests of such clients. The Advisers have implemented policies and procedures that are reasonably designed to appropriately identify, disclose, limit and/or mitigate conflicts of interest. Additional limits and mitigants of conflicts are identified below. Any review of a conflict of interest will take into consideration the interests of the relevant accounts, the circumstances giving rise to the conflict, applicable policies and procedures of the Advisers, and applicable laws. The following discussion is not a complete list of conflicts to which the Putnam Advisers or clients are subject. In addition, other conflicts are discussed elsewhere in this brochure.

Principal Transactions From time to time the Putnam Advisers may recommend, to the extent permitted by law, that clients buy an asset from, or sell an asset to, the Advisers or their affiliates. These transactions involving the purchase and sale of assets are commonly referred to as “principal transactions.” A principal transaction may also be deemed to occur if an Adviser and/or an affiliate owns a substantial portion of a Fund, and that Fund participates in a transaction with another client. Principal transactions present an inherent conflict of interest because an Adviser and/or one or more of its affiliates are on both sides of such transactions. To the extent that an Adviser engages in a principal transaction covered by Section 206(3) of the Advisers Act, the Adviser will comply with the requirements of Section 206(3) of the Advisers Act, including that the Adviser will notify the applicable client (or an independent representative thereof) in writing of the transaction and obtain the client’s consent (or the consent of an independent representative thereof). The Advisers seek to alleviate the conflict of interest posed by principal transactions with procedures requiring pre-clearance of any principal transaction by the Compliance Department and ensuring requisite client consent has been received. On occasion and subject to applicable law and a private Fund’s governing documents, an Adviser that advises a private Fund or a related person (including the Adviser’s affiliates, officers, directors or employees) may purchase investments on behalf of and in anticipation of opening a Private Fund that will hold such investment. Such investments are typically then transferred to the Private Fund.

Cross Trades In certain circumstances, the Putnam Advisers will conclude that it is appropriate to sell securities held in one account to another account. Consistent with its fiduciary duty to each client (including the duty to seek best execution), an Adviser will, from time to time, (but is not required to) effect purchases and sales between clients or clients of affiliates (“cross trades”) if the Adviser believes such transactions are appropriate based on each client’s investment objectives, subject to applicable law and regulation. In a cross trade, a Putnam Adviser has a conflict of interest because the Adviser and/or one or more of its affiliates represent the interests of both the selling party and the buying party in the same transaction. As a result, accounts

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The Putnam Advisers have adopted policies and procedures that address best execution with respect to equity and fixed income investments and provide guidance on brokerage allocation. The policies and procedures are reasonably designed to ensure (i) that execution services meet the quality standards established by the Advisers’ trading teams and are consistent with established policies, (ii) the broadest flexibility in selecting which brokerdealers can provide best execution, (iii) evaluation of the execution capabilities of, and the quality of execution services received from, broker-dealers effecting portfolio transactions for the Advisers’ clients, and (iv) the identification and resolution of potential conflicts of interest. The policies and procedures for equity transactions outline the criteria that the trading team at each global location uses to determine which broker-dealer(s) have provided the highest quality execution services over a particular time period. These include a periodic review of brokerage allocations, the rationale for selecting certain brokerdealers, and a review of historical broker- dealer transactions to test application of the Putnam Advisers’ best execution procedures.

While the Putnam Advisers generally seek competitive commission rates for equity transactions, they do not necessarily pay the lowest commission or commission equivalent; nor will they select broker- dealers solely on the basis of purported or posted commission rates or seek competitive bidding for the most favorable commission rate in advance. In an effort to maximize value for their clients, the Putnam Advisers will seek to obtain the best combination of low commission rates relative to the quality of execution and other brokerage services received. Transactions involving specialized services or expertise on the part of the broker-dealer may result in higher commissions or their equivalents. The policies and procedures for fixed income transactions reflect the same general fiduciary principles that are covered in the equity transaction policies and procedures, but also address the special considerations for executing transactions in fixed income securities. Since trading fixed income securities is fundamentally different from trading in equity securities in that PAC will generally deal directly with market makers, PAC considers different factors when assessing best execution. In these transactions, PAC typically effects trades on a net basis, and does not pay the market maker any commission, commission equivalent or markup/markdown other than the spread. The Advisers’ traders for both fixed income and equity investments are responsible for determining which qualified broker-dealers will provide best execution, taking into account the best combination of price and intermediary value given the client’s strategies and objectives. The Putnam Advisers may also engage in derivative transactions that are entered into under a negotiated agreement with a counterparty or futures commission merchant, including, but not limited to, swaps, futures, forwards and options. The agreements to trade these instruments must be in place prior to effecting a transaction. If the Advisers are unable to negotiate acceptable terms with a counterparty or are restricted from engaging certain counterparties for an Account, for example, based on an Adviser’s assessment of a counterparty’s creditworthiness and financial stability at any given time, the universe of counterparties that the Advisers can choose from will be limited and the standard for best execution may vary with the type of security or instrument involved in a particular transaction. The policies and procedures for equity and fixed income transactions also address the aggregation and allocation principles established by the Advisers for derivatives trading. Where practicable, Putnam places orders to purchase and sell securities on an aggregated basis for all clients of the Putnam Advisers. Client account trades may also be aggregated with trades for Putnam affiliated accounts on terms no less advantageous than those of the affiliated accounts or other Putnam clients. However, Franklin Templeton Investment Management Limited (“FTIML”), which is the UK-based entity in which UK-based personnel within the Putnam Equity investment group, will only place trades at an execution-only rate, whereas other Putnam accounts may pay a “bundled” or “full service” rate. Putnam may aggregate trades in FTIML accounts with other Putnam accounts that pay a bundled rate so long as all participating accounts pay the same execution rate. To the extent that the bundled rate for non-FTIML accounts includes an additional amount for research products and services, the FTIML and other Putnam accounts would not be paying the same total commission rate.

Soft Dollars In the case of a broker-dealer that provides to Putnam any “brokerage and research services,” as defined in Section 28(e) of the Securities Exchange Act of 1934, as amended (the “1934 Act”) and discussed below, Putnam may cause the client to pay a broker-dealer an amount of disclosed commission for effecting agency transactions (on stock exchanges or otherwise) even though the commission is in excess of the commission another broker-dealer would have charged for effecting the transaction. For those funds sub-advised by FTIML and where FTIML places trades on behalf of those funds, the rules of the United Kingdom’s Financial Conduct Authority (the FCA Rules) apply with respect to the receipt of investment research. Under the FCA Rules, FTIML may not obtain research using brokerage commissions paid by the funds sub-advised by FTIML . except with respect to minor non-monetary benefits as defined by the FCA Rules. FTIML will use only “hard dollars” (i.e., from its own resources), to acquire external research used by London-based personnel, including fixed income personnel, except with respect to minor non-monetary benefits as defined by the FCA Rules. To the extent that Putnam may so cause the client to pay any such greater commissions, it will do so only when the safe harbor of Section 28(e) of the 1934 Act applies. It is the position of the staff of the SEC that Section 28(e) of the

1934 Act does not apply to the payment of such greater commissions in "principal" transactions. Subject to the overriding requirements to seek best execution under the circumstances, Putnam receives brokerage and research products and services from broker dealers, including both the broker dealers with which Putnam places its clients’ portfolio transactions and other third parties, which may include other broker-dealers. These products and services are sometimes called “soft dollar” purchases. Research products and services received from executing broker-dealers are sometimes called “proprietary research.” Except with respect to FTIML, Putnam may also allocate equity trades to generate “soft dollar credits” used to pay for brokerage services and trading systems and investment research reports and other research products and services from third-party providers when, in Putnam’s judgment, trading through the firm generating the research would not be feasible (for instance, where the firm is not a broker-dealer) or in the account’s best interest (for instance, where the firm has not satisfied Putnam’s internal eligibility criteria for trading counterparties). Such products and services are referred to as “third-party research” or “third-party brokerage.” In addition to generating soft-dollar credits to pay for third-party services, Putnam may instruct executing brokers to “step out” a portion of the trades placed with them to other broker-dealers providing brokerage and research services. The proprietary and third-party products and services that Putnam may receive in connection with client portfolio transactions include, among others:  trading systems and other brokerage services  economic and political analysis  market data and statistical information, including benchmark data and trade data  fundamental and macro investment research  industry and company reviews  evaluations of investments, strategies, markets and trading venues  recommendations as to the purchase and sale of investments  performance measurement services  meetings with management of current or prospective portfolio companies or with industry experts Some of these products and services obtained through soft dollar credits are “mixed-use;” i.e., they may be used both for investment / brokerage and non-investment / brokerage -related purposes. In these cases, Putnam will use its own resources to pay for that portion of the mixed-use product or service that in its good-faith judgment does not relate to investment or brokerage purposes. Use of soft dollars, while common in the asset management industry, may involve potential conflicts of interest. Research products and services provided by broker-dealers are supplemental to Putnam’s own research efforts and relieve Putnam of the possible expense of generating the research internally. Management fees paid by clients are not reduced because Putnam receives brokerage and research products and services, even though Putnam might otherwise be required to purchase some of these products and services for cash. Putnam may have an incentive to select or recommend a broker-dealer based on its interest in receiving the research or other products or services, rather than on its clients’ interest in paying the lowest commission. Because of the nature of Putnam’s trading process, it is not possible to trace trades in any account to specific products and services. An aggregated trade with a broker-dealer providing proprietary research or a trade that generates soft dollar credits by its nature represents commissions of multiple clients. Brokerage and research products and services acquired will be paid out of the aggregate of soft dollar credits generated by various trades over time. Clients do not receive a direct monetary benefit from brokerage and research products and services; however, these products and services may be useful to Putnam in providing investment advice to all its clients. Likewise, research products and services made available to Putnam from brokerage firms effecting securities transactions for a client may be utilized by Putnam in managing the accounts of other clients. Some of these brokerage and research products and services are of value to Putnam and its affiliates in advising multiple clients, although not all of these services are necessarily useful and of value in managing any particular account. There may be no correlation between the amount of brokerage commissions generated by a particular client and the indirect benefits received by that client.

Due in part to the FCA Rules, Putnam is prohibited from using brokerage commissions from transactions placed on behalf of FTIML clients to generate soft dollar credits. In addition, Putnam may negotiate prohibitions or limitations on the use of soft dollars at the request of other clients. In certain but not all cases, for administrative reasons, the entirety of an account (including an affiliated account) may be as treated as FTIML - managed for this purpose, even though FTIML may normally manage only a portion of the account. Research and brokerage products and services may be used to benefit all clients, including, subject to the requirements of the FCA , FTIML clients and other clients that prohibit Putnam from using, or limit Putnam’s use of, brokerage commissions generated from such clients’ trades to purchase brokerage and research products and services. Senior investment personnel of Putnam determine Putnam's commission allocation policies, the brokerage and research products and services to be obtained, and the amount of commissions appropriate to allocate to the acquisition of these products and services. For brokerage and research products and services (other than market data, certain corporate access services and services provided by firms who do not agree to be subject to a research vote process), these determinations are generally based on a voting process in which investment personnel identify products and services for purchase with soft dollars. FTIML equity investment personnel participate in the voting process noted above. FTIML pays in “hard dollars” (i.e., from its own resources) for external research used by London-based personnel, including fixed income personnel, except for minor non-monetary benefits as defined by the FCA Rules. FTIML also pays for market data and corporate access services for FTIML employees in hard dollars.

Other Products and Services Putnam may receive products and services from broker-dealers other than brokerage and research services at reduced prices or for free. Putnam will not receive such products or services using commissions from client portfolio transactions or otherwise in connection with particular client trades or a commitment to direct client trades to the broker-dealer. These products and services may include analytical software for portfolio modeling; quotations and other pricing information for securities held in Putnam client portfolios; capital introduction services for Putnam’s private funds, and risk and security analyses and databases. Putnam may also use its own resources to acquire any of these products and services, as well as research and brokerage products and services eligible for purchase with soft dollars.

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The Putnam Advisers or a related person, from time to time, enter into referral fee arrangements to compensate affiliated and non-affiliated persons for referring or otherwise recommending its investment advisory services to potential clients. To the extent required, such arrangements would be governed by the policy on the use of solicitors and client referrals adopted by the Putnam Advisers and entered into in accordance with Rule 206(4)-1 under the Advisers Act and other applicable law. The compensation paid may consist of a cash payment computed as a flat fee; a percentage of a Putnam Adviser’s (or an affiliate’s) advisory fee, performance fee or carried interest; or some other method of computation agreed upon between the parties. For some accounts, primarily certain Private Funds, a third-party distributor will be compensated by way of a retrocession that is specified in the applicable selling or referral agreement. Retrocession is a term used to describe an on-going fee payable by the Putnam Adviser to the third-party distributor so long as such assets placed by the third-party distributor remain invested in the account. To the extent allowed under applicable law, the Putnam Advisers’ Code of Ethics and the policies and procedures (including the Anti-Corruption Policy) of the Putnam Advisers, their affiliates, and/or a particular broker-dealer, the Advisers or a related person will, from time to time, (i) pay broker-dealer sponsors for training seminars, conferences and other educational events, (ii) pay travel and lodging expenses relating to financial advisers’ attendance at a Putnam Adviser’s due diligence meetings, (iii) give certain business-related gifts or gratuities and/or pay reasonable expenses relating to meals and/or entertainment for financial advisers, and (iv) make a contribution in connection with a charitable event or to a charitable organization sponsored, organized or supported by a brokerdealer or its representatives, on behalf of such broker-dealer or its representatives, or to which such broker-dealer or its affiliates provides professional services. For details regarding economic benefits provided to the Putnam Advisers by non-clients, including a description of related material conflicts of interest and how they are addressed, please see Item 11 (“Code of Ethics, Participation or Interest in Client Transactions and Personal Trading”) above.

Not applicable.

The Putnam Advisers manage investment portfolios for each of their clients. Generally, the portfolios under a Putnam Adviser’s management are reviewed by one or more portfolio managers who are responsible to their respective Chief Investment Officer (or other, similar senior investment professional), either directly or indirectly. Such review may be made with respect to a Putnam Adviser’s clients’ investment objectives and policies, limitations on the types of instruments in which each of its clients may invest and concentration of investments in particular industries or types of issues. There is no general rule regarding the number of accounts assigned to a portfolio manager. The frequency, depth, and nature of account reviews are often determined by negotiation with individual clients pursuant to the terms of each client’s investment management agreement or by the mandate selected by the client and the particular needs of each client. Written reports of portfolio breakdown, transactions and performance are typically provided to clients no less frequently than quarterly. Additional trade reports may be available upon request.

The overwhelming majority of the Putnam Advisers’ clients maintain custody arrangements with independent qualified custodians to safeguard their funds and securities. However, a Putnam Adviser may sometimes have “custody” (as defined in Rule 206(4)-2 under the Investment Advisers Act of 1940) of client funds and securities, even though it does not actually hold or maintain them. For example, PAC or an affiliate acts as the general partner, managing member or trustee for some Putnam investment funds that PAC advises, and PAC has “custody” of those funds, as Rule 206(4)-2 uses that term, as a result. PAC may also have custody when it bills an account’s custodian and management fees are automatically withdrawn from the client account without the need for client approval.

To help ensure the safekeeping of clients' assets for these accounts, Putnam or the client retains independent, qualified custodians or sub-custodians to hold client funds and securities. Where a Putnam Adviser has “custody” of a separate account (based, for example, on automatic billing practices) it will seek to confirm that the client receives required account statements at least quarterly directly from its qualified custodian. As described in Item 13, the Putnam Adviser itself also sends clients a portfolio appraisal. Clients should carefully review and compare the account statement from the custodian and the Putnam Adviser’s portfolio appraisal.

Generally, the Putnam Advisers have discretionary authority to supervise and direct the investment of the assets under their management, without obtaining prior specific client consent for each transaction. This investment discretion is granted by written authority of the client in the investment management agreement between the client and a Putnam Adviser and is subject to such limitations as a client may impose by notice in writing and as agreed to by the Adviser. To the extent a Putnam Adviser has discretionary authority over assets of a sub-advised account, such authority is granted in an advisory agreement between the Putnam Adviser and the sub-advised account and/or the manager of such sub-advised account. Under their discretionary authority, the Putnam Advisers will generally make the following determinations in accordance with the investment management agreement, the client’s investment restrictions, the Putnam Advisers’ internal policies, commercial practice, and applicable law, without prior consultation or consent before a transaction is effected:

Which securities or other instruments to buy or sell; The total amount of securities or other instruments to buy or sell; The broker-dealer or counterparty used to buy or sell securities or other instruments; and/or The prices and commission rates at which transactions are effected.

When a Putnam Adviser believes engagement will be beneficial, it may, in the Putnam Adviser’s sole discretion unless otherwise agreed, submit a shareholder proposal to, or otherwise actively engage with, the issuer of securities held in one or more accounts. A Putnam Adviser may also delegate its discretionary authority to a sub-adviser where the Putnam Adviser believes, in its sole discretion, that such delegation would be beneficial unless it is prohibited under the investment management agreement or under applicable law. The Putnam Advisers will consider a variety of factors including, but not limited to, costs when considering whether to engage in such activities. The Putnam Advisers may, in an Adviser’s sole discretion, accept the initial funding of an account with one or more securities in-kind. Subject to the terms of the investment management agreement and applicable law, the Putnam Advisers will use good faith efforts to liquidate any such securities that the Advisers do not elect to keep as part of such Account and shall not be liable for any investment losses or market risk associated with such liquidation. Putnam may occasionally request that clients execute a limited power of attorney or trading authorization when additional evidence of Putnam’s authority to act on behalf of the client is required (for example, in dealing with the bankruptcy of the issuer of a portfolio security or a counterparty, or when trading in derivative instruments under the client’s investment documentation). For more information, please contact Putnam. Since 2011 Putnam, through Putnam Holdings and Putnam’s previous parent company, Putnam Investments, LLC, has been a signatory to the United Nations backed Principles for Responsible Investment (“PRI”). Devised by the world’s largest institutional investors, the PRI reflects the view that an economically efficient, sustainable global financial system is necessary for long-term value creation. As a PRI signatory, Putnam is committed to understanding how ESG factors may influence performance, generate alpha, and/or mitigate risk in client portfolios. We believe that incorporating ESG considerations into the investment process has the potential to enhance what asset management can accomplish, and that ESG analysis can be an important component of the research process.

The six Principles for Responsible Investment, created by the PRI, are a voluntary and aspirational set of investment principles that offer a menu of possible actions for incorporating ESG issues into investment practice. Becoming a PRI signatory is not a legally binding commitment, and does not require the application of specific ESG restrictions in the investment process. As a fiduciary on behalf of our asset management clients, Putnam generally looks at the entire investment universe to identify attractive securities, subject to applicable sanctions regimes and other laws that may prohibit some investments. As a general matter, we do not require that portfolios limit their universe or their investments in any company, industry, or country based on ESG criteria (except as stated in a fund’s prospectus or as mutually agreed upon with a client). Rather, we expect sustainability-related insights to be a component of the research processes that are used to arrive at investment decisions. ESG investing is an evolving process, both for Putnam and the industry as a whole. Our research and investing work will vary across asset classes and sectors, as well as by individual portfolio manager and analyst team. In the context of a specific portfolio, strategy, or investment decision, multiple factors impact our views, and we may make decisions that are inconsistent with the PRI, or appear to be so, when we consider it consistent with our overarching fiduciary duty to clients.

Summary of Proxy Voting Guidelines and Procedures Many of the Putnam Advisers’ investment management clients, including the Putnam Funds, have delegated to the Putnam Advisers the authority to vote proxies for shares held in the client accounts that the Putnam Advisers manage. The Putnam Advisers believe that the voting of proxies can be an important tool for institutional investors to promote best practices in corporate governance and votes all proxies in the best interests of its clients as investors. In Putnam’s view, strong corporate governance policies, most notably oversight of management by an independent board of qualified directors, best serve investors’ interests. Putnam will vote proxies and maintain records of voting of shares for which Putnam has proxy voting authority in accordance with its fiduciary obligations and applicable law. The Putnam Advisers’ voting policies are rooted in our views that (1) strong, independent corporate governance is important to long-term company financial performance, and (2) long-term investors’ active engagement with company management, including through the proxy voting process, strengthens issuer accountability and overall market discipline, potentially reducing risk and improving returns over time. Our voting program is offered as a part of our investment management services, at no incremental fee to Putnam, and, while there can be no guarantees, it is intended to offer potential investment benefits over a long-term horizon. Our voting policies are designed with investment considerations in mind, not as a means to pursue particular political, social, or other goals. As a result, we may not support certain proposals whose costs to the issuer (including implementation costs, practicability, and other factors), in the Putnam Adviser’s view, outweigh their investment merits. In order to implement these objectives, the Putnam Advisers have adopted a set of procedures and guidelines which are summarized below. The guidelines and procedures cover all accounts for which the Putnam Advisers have Putnam has proxy voting authority. Certain other clients may from time to time elect to vote their own proxies by retaining the right to vote all proxies in the investment management agreement rather than giving the Putnam Advisers authority to do so.

Procedures The Putnam Advisers have appointed a Proxy Committee composed of senior investment professionals from the Putnam Equity group and from the Compliance Department. The Proxy Committee is responsible for setting general policy as to proxy voting. The Committee reviews procedures and the guidelines at least annually, approves any amendments considered to be advisable and considers special proxy issues as they may from time to time arise. With respect to the Putnam Funds, the Board of Trustees separately approves the guidelines. The proxy guidelines and procedures are administered through a proxy voting team in the Sustainable Strategy group within the Putnam Equity group. The Proxy Voting Team:

coordinates the Proxy Committee’s review of any new or unusual proxy issues, manages the process of referring issues to portfolio managers for voting instructions, oversees the work of any third-party vendor hired to process proxy votes, coordinates responses to investment professionals’ questions on proxy issues and proxy policies, maintains required records of proxy votes on behalf of the appropriate Putnam client accounts, and prepares and distributes reports required by Putnam Adviser clients.

Putnam has engaged a third-party service, Institutional Shareholder Services (“ISS”), to process proxy votes for its client accounts. Although ISS may supply proxy related research to Putnam and may share with Putnam its recommendations for voting, ISS does not make any decisions on how to vote client proxies.

Proxy Voting Guidelines The Putnam Advisers maintain written voting guidelines (“Guidelines”) setting forth voting positions determined by the Proxy Committee on those issues believed most likely to arise day to day. (For purposes of this Item, the term “Putnam” refers to the Putnam Advisers collectively.) The Guidelines may call for votes normally to be cast in favor of or opposed to a matter or may deem the matter an item to be referred to investment professionals on a case- by-case basis. The Guidelines are summarized below. In light of our views on the importance of issuer governance and investor engagement, which we believe are applicable across our various strategies and clients, regardless of a specific portfolio’s investment objective, Putnam will normally vote all proxies in accordance with the Guidelines except in limited circumstances, such as when client securities are on loan under a securities lending arrangement. However, if the portfolio managers of client accounts holding the relevant stock believe that following the Guidelines in a specific case would not be in clients’ best interests, they may request that the Proxy Voting Team not follow the Guidelines in that case. The request must be in writing and include an explanation of the rationale for doing so. The Proxy Voting Team will review the request with the Proxy Committee or its Chair prior to implementing it. Some clients wish to have a Putnam Adviser vote proxies under proxy guidelines which vary from the Guidelines or may wish to direct the vote on a particular matter. There may be legal limits on a client’s ability to direct the Putnam Adviser as to proxy voting and on the Putnam Adviser’s ability to follow such instructions. A Putnam Adviser may accept instructions to vote proxies under client specific guidelines subject to review and acceptance by the portfolio management team involved and the Legal and Compliance Division. With respect to the Putnam Catholic Values U.S. Large Cap Growth Fund LP, in light of the fund’s investment strategy focusing on investments that Putnam believes are consistent with the components, details and definitions of the socially responsible investment guidelines as adopted from time to time by the U.S. Conference of Catholic Bishops (the “CRI Guidelines”), Putnam has engaged ISS to process proxy votes in accordance with the ISS Catholic Faith-Based Proxy Voting Guidelines, which the fund adopted as its proxy voting policy in lieu of the Guidelines. Putnam may also vote any “referred” items (i.e. items referred to it by ISS for further resolution) on securities held in this Fund in accordance with the recommendation of ISS. Although Putnam intends to rely on ISS’s voting recommendations and proxy-related research, which it believes to be reliable, it does not guarantee the accuracy or reliability of such recommendations and research. ISS’s voting recommendations and proxy-related research may be incomplete, inaccurate or unavailable, which may adversely impact the voting process and outcome. Voting recommendations and research often require qualitative determinations and are often subjective by nature, and there can be no assurance that the process utilized by ISS will align at all times with the principles contained in the CRI Guidelines. Putnam may vote any referred items on securities held solely in PAC accounts managed by the FTIS team (and not held by any other Putnam investment team) in accordance with the recommendation of Putnam’s third-party proxy voting service provider. The Proxy Manager will first give the relevant portfolio manager(s) on the FTIS team the opportunity to review the referred items and vote on them if they so choose. If the portfolio manager(s) on the FTIS team do not decide to make any active voting decision on any of the referred items, the items will be voted in accordance with the service provider’s recommendation. If the security is also held by other investment teams at Putnam, the items will be referred to the largest holder who is not a member of the FTIS team.

Conflicts of Interest A potential conflict of interest may arise when voting proxies of an issuer which has a significant business relationship with Putnam. Putnam’s policy is to vote proxies based solely on the investment merits of the proposal and in the best interests of our clients. In order to guard against conflicts Putnam has adopted a number of procedures designed to ensure that the proxy voting process is insulated from these conflicts. For example, investment professionals do not report to Franklin Templeton’s sales or marketing businesses. In addition, there are limits on the ability of Franklin Templeton employees who are not Putnam Adviser investment professionals to contact portfolio managers voting proxies. Putnam Adviser investment professionals responding to referral requests must disclose any contacts with third parties other than normal contact with proxy solicitation firms and affirm that any potential personal conflicts of interest have been disclosed to the Compliance Department. In addition, the Proxy Voting Team reviews business relationships with companies that have voting items referred to any portfolio management team to consider any potential conflicts and, where appropriate, ensures that potential conflicts are documented and appropriately escalated. The Guidelines may only be overridden with the written recommendation of the relevant investment professionals and approval of the Proxy Committee or its Chair.

Summary of Proxy Voting Guidelines The Guidelines summarize Putnam’s positions on various issues of concern to investors and indicate how client portfolio securities will be voted on proposals dealing with a particular issue. The summary below does not address all topics covered by the Guidelines and is qualified by reference to the actual procedures and Guidelines, which are available to clients from Putnam on request. The Guidelines focus on board governance issues. Normally, if a board meets current best practices such as the maintenance of a majority of independent directors and the independence of key committees such as audit, compensation and nomination, Putnam will support the board’s proposals. Boards which do not meet these standards will have their proposals subjected to higher scrutiny. There are a number of exceptions to this approach. With respect to some major business transactions such as mergers, proposals will be reviewed on a case-by-case basis. In a number of areas, such as the introduction of anti-takeover devices, the Guidelines will normally provide for voting against the introduction of anti-takeover devices whether or not supported by an independent board. The central provisions of the Guidelines are set forth below:

Board of Directors Proxies will normally be voted for the election of the company’s nominees for directors and for board-approved proposals on other matters relating to the board of directors (provided that such nominees and other matters have been approved by an independent nominating committee), except that Putnam will withhold votes for the entire board of directors if:

The board does not have a majority of independent directors;

The board does not have nominating, audit and compensation committees composed solely of independent directors; or The board has more than fifteen members or fewer than five members, absent special circumstances.

Putnam will withhold votes from incumbent nominees to the board if:

The board has not acted to implement a policy requested in a shareholder proposal that received the support of a majority of the shares of the votes actually cast on the matter at its previous two annual meetings, or The board adopted, renewed or made a material adverse modification to a shareholder rights plan (commonly referred to as a “poison pill”) without shareholder approval during the current or prior calendar year.

If the board does not meet these standards Putnam may refer items that would normally be supported for case-by-case review. Putnam may withhold votes for directors under other circumstances such as when a director who is considered an independent director by the company receives compensation from the company other than for service as a director (such as investment banking, consulting, legal or financial advisory fees) or when a director attends less than 75% of board and committee meetings (Putnam may refrain from voting against/withholding on a case-by-case basis if a valid reason for the absences exists such as (illness, personal emergency, potential conflict of interest etc.). In addition, Putnam will withhold votes:

for any nominee for director of a public company (Company A) who is employed as a senior executive of another public company (Company B) if a director of Company B serves as a senior executive of Company A (these arrangements are commonly referred to as “interlocking directorates”); and Putnam will vote on a case-by-case basis for any non-executive nominee who serves on more than four (4) public company boards (boards of affiliated registered investment companies and other similar entities such as UCITS are counted as one board), except where Putnam would otherwise be withholding votes for the entire board of directors. Putnam will withhold votes from any nominee for director who serves as an executive officer of any public company (“home company”) while serving on more than two (2) public company boards other than the home company board. For the purpose of this guideline, boards of affiliated registered investment companies and other similar entities such as UCITS will count as one board.

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Not applicable.