This Conflicts of Interest Policy for the TCW Funds (the "Funds") has been adopted regarding the Fund Directors and Conducting Officers to promote:

  • honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships,
  • full, fair, accurate, timely, and understandable disclosure in reports and documents that a registrant files with, or submits to, the CSSF and in other public communications made by the Funds,
  • compliance with applicable laws and governmental rules and regulations,
  • prompt internal reporting of violations of this Policy to an appropriate person or persons identified in this Policy, and
  • accountability for adherence to this Policy.

Each Director and Officer should adhere to a high standard of business ethics and should be sensitive to situations that may give rise to actual or apparent conflicts of interest.

A "conflict of interest" occurs when a Director's or Officer's private interest interferes with the interests of, or service to, a Fund. For example, a conflict of interest would arise if a Director or Officer, or a member of his or her family, receives improper personal benefits as a result of his or her position in a Fund.

In reading the following examples of conflicts of interest under this Policy, Directors and Officers should keep in mind that such a list will never be exhaustive or cover every possible scenario. The overarching principle is that the personal interest of a Director of Officer should not be placed improperly before the interest of a Fund.

Each Director or Covered Officer must, as applicable:

  • not use his or her personal influence or personal relationships improperly to influence investment decisions or financial reporting by a Fund, including where the Director or Officer would benefit personally to the detriment of the Fund.
  • not cause a Fund to take action, or fail to take action, for the individual personal benefit of the Director or Officer rather than the benefit of the Fund.
  • not use material non-public knowledge of portfolio transactions made or contemplated for a Fund to trade personally or cause others to trade personally in contemplation of the market effect of such transactions.
  • report at least annually any directorships or other affiliations with other public companies.should refrain from accepting gifts of more than a de minimis value from providers of goods and services to a Fund.

Additionally each Director or Conducting Officer:

  • should be familiar with the disclosure requirements generally applicable to each Fund.
  • should not knowingly misrepresent, or cause others to misrepresent, facts about a Fund to others, whether within or outside the Fund, including to an auditors, or to governmental regulators and self-regulatory organizations.
  • to the extent appropriate within his or her area of responsibility, consult with other Directors and Officers of the Fund with the goal of promoting full, fair, accurate, timely, and understandable disclosure in the reports and documents that the Fund files with, or submits to, the CSSF and in other public communications made by the Fund.
  • is responsible for promoting compliance with the standards and restrictions imposed by applicable laws, rules, and regulations