Putnam Investment Management, LLC

September 16, 2026 Form ADV Part 2A Putnam Investment Management, LLC 100 Federal St. Boston, MA 02110 617-292-1000 www.putnam.com This brochure provides information about the qualifications and business practices of Putnam Investment Management, LLC. The information herein about primarily focuses on the investment advisory services Putnam Investment Management, LLC provides to clients who do not participate in third-party investment adviser, broker-dealer and other financial services firm separately managed accounts, unified managed accounts or other wrap fee programs (collectively, “SMA Programs”). With respect to SMA Programs, effective January 1, 2025, Putnam Investment Management, LLC acts as a sub-adviser to an affiliated registered investment adviser, Franklin Templeton Private Portfolio Group, LLC (“FTPPG”). A combined brochure containing information about our SMA Program sub-advisory services, and FTPPG’s brochure (the “SMA Program Brochure”) is available upon request. If you have any questions about the contents of this brochure, please contact James Clark, Chief Compliance Officer, at james.f.clark@franklintempleton.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about Putnam Investment Management, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. Clients should note that SEC registration does not imply a certain level of skill or training.  Item 2: Material Changes While not considered a material change, edits have been made throughout the Brochure to reflect the name change of Franklin Resources, Inc. to Franklin Templeton, Inc. which occurred on August 17, 2026. 2 Putnam Investment Management, LLC  Item 3: Table of Contents Item 2: Material Changes 2 Item 3: Table of Contents 3 Item 4: Advisory Business 4 Item 5: Fees and Compensation 7 Item 6: Performance-Based Fees and Side-By-Side Management 10 Item 7: Types of Clients 12 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss 12 Item 9: Disciplinary Information 27 Item 10: Other Financial Industry Activities and Affiliations 28 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 30 Item 12: Brokerage Practices 37 Item 13: Review of Accounts 45 Item 14: Client Referrals and Other Compensation 45 Item 15: Custody 46 Item 16: Investment Discretion 46 Item 17: Voting Client Securities 48 Item 18: Financial Information 53 3 Putnam Investment Management, LLC  Item 4: Advisory Business Introduction to Putnam Putnam Investment Management, LLC ("PIM") has been registered with the Securities and Exchange Commission (‘SEC”) as an investment adviser since 1971. 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, PIM, a 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. PIM primarily manages Putnam’s open-end and closed-end registered investment companies, including actively-managed exchange traded funds (the “Putnam Funds”). PIM also sub-advises registered investment companies sponsored by other financial firms and manages assets for institutional clients. Effective January 1, 2025, PIM acts as sub-adviser to its affiliate FTPPG with respect to certain clients and program sponsors (“Sponsors”) in connection with third-party investment adviser, broker-dealer and other financial services firm separately managed accounts (“SMAs”), unified managed accounts (“UMAs”) or other wrap fee programs (collectively, “SMA Programs”). Information about the provision of sub-advisory services to FTPPG with respect to certain SMA Programs in the United States can be found in the combined SMA Program Brochure, which is available upon request. PIM is affiliated, through common ownership by Putnam Investments, with:  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  The Putnam Advisory Company, LLC (“PAC”), a registered investment adviser that manages assets for institutional and international clients. PAC also manages various pooled investment funds, such as limited liability companies, limited partnerships, and non-U.S. funds, and also sub-advises some Putnam Funds. 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. 4 Putnam Investment Management, LLC  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. Putnam 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, PIM had approximately $110.56 billion in discretionary net assets under management1 and approximately $6.68billion in non-discretionary assets under management. Non-discretionary assets under management include accounts such as model portfolios offered in SMA Programs or on a standalone basis. PIM manages the Putnam Funds in accordance with their written investment objectives, strategies and guidelines, as disclosed in their SEC registration statements. The investment program of a Putnam Fund cannot be tailored to the individual needs of any particular investor. Investment in a Putnam Fund does not create an advisory client relationship between the investor and Putnam. Therefore, investors should consult their financial representatives and consider whether a Putnam Fund meets their investment objectives and risk tolerance prior to investing. PIM manages other discretionary advisory clients’ 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 PIM 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, PIM must consult with the client prior to implementing any investment decisions. In addition to the Putnam Funds, PIM may also manage or sub-advise other 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, and non-U.S. investment 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 5 Putnam Investment Management,  investment objectives and risk tolerance prior to investing. Investors in pooled funds receive an offering memorandum, prospectus, or similar document that describes the fund, including its risks, fees, and the qualifications needed to invest. Some investment funds may be offered on a private placement or other limited basis and may not be available to, or appropriate for, all prospective investors. Index Products From time-to-time PIM engages in other business activities related to its core investment business, including licensing of intellectual property with respect to, for example, the development of methodologies for compiling and calculating a benchmark index. We license or sell our intellectual property rights in these methodologies to third parties who use these methodologies to create and issue investment products that are based on such indices and/or correlated to the underlying components of such indices. In connection with such indices, we may retain third parties as calculation agents and/or license the third parties’ underlying intellectual property, to the extent used in constructing our indices. 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, PIM provides a specific service. PIM does not provide tax, legal, or accounting advice, and clients should note that, unless otherwise specifically agreed or disclosed in writing, PIM 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 pooled investment 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. 6 Putnam Investment Management,  Item 5: Fees and Compensation 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 in effect when the management agreement is signed. Management fees are negotiated with some clients, so fees vary from the standard schedules. Other investment advisers may charge higher or lower fees for comparable services than Putnam charges. Generally, PIM’s fund clients pay management fees to PIM out of fund assets. For separate account clients, 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). Except with respect to the Putnam Funds, 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. Putnam Fund Fees PIM's fees under its investment management agreements with respect to the Putnam Funds (and, where required by SEC rules, other registered investment company clients) are shown in the funds’ registration statements, on file with the SEC. 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 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 funds or portfolio’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. SMA Programs With respect to Accounts for which PIM serves as a sub-adviser through an SMA Program, the timing of fee payments will be negotiated with each client or the SMA Program sponsor. See the SMA Program Brochure, which is available upon request, for more information regarding fees and compensation with respect to SMA Programs. 7 Putnam Investment Management,  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. Non-Discretionary Advice In addition to discretionary asset management, Putnam may sometimes agree to provide non-discretionary advice for a specific client portfolio in a particular asset class. Putnam does not act as general investment counsel for these accounts, but instead makes specific, security-level recommendations for the client to implement in its discretion. The fees for these services, or for any additional services such as unusual reporting needs or other client-specific requirements, are determined on a case-by-case basis. Account Termination The terms and conditions of PIM’s services are specified in the investment management agreement between PIM and the client. The management agreement generally allows either the client or PIM to terminate it at any time on written notice (typically, of not less than 60 days). 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. 8 Putnam Investment Management,  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”). Valuation of Portfolio Assets in Calculating Fees Putnam’s management fees are based on the value and performance of the assets held in the client account. Putnam generally does not act as an official record keeper or pricing agent for its client accounts. However, if the investment management agreement provides that fees will be based on Putnam’s calculation of the portfolio’s net assets or performance, or in the case of an investment fund managed by Putnam, Putnam’s valuation of securities determines the fees that a client or fund investor pays. Although most investment types are valued based on publicly available prices (such as equity closing prices), third party pricing sources, or broker dealer prices, Putnam does have a role in determining asset values in some asset classes and circumstances. For example, Putnam may be required to price a portfolio holding when a market price is not readily available or when Putnam has reason to believe that the market price is inaccurate. To the extent Putnam’s fees are based on the value or performance of client accounts, Putnam will benefit by receiving a fee 9 Putnam Investment Management,  based on the impact, if any, of the increased value of assets in an account. As a result, valuation of assets by Putnam could involve a potential conflict of interest. Putnam has adopted detailed pricing procedures and related oversight controls to assist in proper valuation of client investments. The Putnam Funds have adopted their own pricing procedures; however, the Board of Trustees of the Putnam Funds has also designated PIM as the “valuation designee” (as that term is defined in Rule 2a-5 under the Investment Company Act of 1940, as amended) to perform fair valuation determinations for each Putnam Fund managed by PIM with respect to assets for which a market quotation is not readily available. Item 6: Performance-Based Fees and Side-By-Side 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. 10 Putnam Investment Management,  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 performance-based 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. 11 Putnam Investment Management,   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. Item 7: Types of Clients PIM primarily manages the Putnam Funds. PIM also sub-advises other financial firms’ registered investment companies and offers its advisory services to a wide variety of other institutional clients. Effective January 1, 2025, PIM also provides investment advisory services to individuals through its affiliate FTPPG, as described in FAV’s SMA Program Brochure, which is available upon request. PIM generally requires an institutional 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. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Putnam is an active, long-term investment manager offering a variety of equity investment strategies. 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. 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 12 Putnam Investment Management,  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 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. 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 13 Putnam Investment Management,  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. 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. 14 Putnam Investment Management,  INVESTMENT RISKS Particular investment strategies or investments in different types of securities or other investments involve specific risks, including risk of loss, that clients should be prepared to bear. The risks involved, and their degree of significance, for different accounts will vary based on each client’s investment strategy and the type of securities or other investments held in the account. The following is a list of certain of the material risks, listed alphabetically, related to the significant investment strategies used by the Putnam Advisers. Not all possible risks are described below. For purposes of this section, the terms “Fund” and “Account” shall be interchangeable. Artificial Intelligence - We may use Artificial Intelligence (“AI”) in various areas of our business, including informing economic views, assisting with security analysis, and enhancing portfolio analytics, and we expect to expand its use over time. While AI can improve efficiency, it also presents risks, including inaccurate or biased outputs, data security, privacy, intellectual property, regulatory compliance, and potential reputational harm. These tools require ongoing oversight and controls. Limitations or failures in AI systems could affect our analyses and recommendations and result in compliance or operational risks to our firm. Asset Allocation – The Advisers’ ability to achieve their investment goal may depend upon their skill in determining a portfolio’s asset allocation mix and/or selecting sub-advisers. There is the possibility that the Advisers’ evaluations and assumptions regarding asset classes and the selected sub-advisers will not be successful in view of actual market trends. Asset-Backed Securities – Issuers of asset-backed securities may have limited ability to enforce the security interest in the underlying assets, and credit enhancements provided to support the securities, if any, may be inadequate to protect investors in the event of default. Asset-backed securities are subject to prepayment and extension risks. Blend Style Investing – A “blend” strategy results in investments in both growth and value stocks, or in stocks with characteristics of both. Growth stock prices reflect projections of future earnings or revenues and can fall dramatically if the company fails to meet those projections. With respect to value stocks, if other investors fail to recognize the company’s value, or favor investing in faster-growing companies, value stocks may not increase in value as anticipated by the Adviser or may decline even further. Concentration – To the extent the Fund concentrates in a specific industry, a group of industries, sector or type of investment, the Fund will carry much greater risks of adverse developments and price movements in such industries, sectors or investments than a fund that invests in a wider variety of industries, sectors or investments. There is also the risk that the Fund will perform poorly during a slump in demand for securities of companies in such industries or sectors. Convertible Securities – A convertible security is generally a debt obligation, preferred stock or other security that pays interest or dividends and may be converted by the holder within a specified period of time into common stock. The value of convertible securities may rise and fall with the market value of the underlying stock or, like a debt security, vary with changes in interest rates and the credit quality of the issuer. A convertible security tends to perform more like a stock when the underlying stock price is high relative to the conversion price (because more of the security's value resides in the option to convert) and more like a debt security when the underlying stock price is low relative to the conversion price (because the option to convert is less valuable). Because its value can be influenced by many different factors, a convertible security is not as sensitive to interest rate changes as a similar non-convertible debt security and generally has less potential for gain or loss than the underlying stock. Credit Facilities – Certain Private Funds may utilize credit facilities for short-term money management purposes in connection with the receipt of subscription proceeds, redemption requests, or portfolio reallocations. Such credit facilities may be provided at prevailing market rates by a Private Fund’s custodian or its affiliates, or from unaffiliated third parties. Should such credit facilities be utilized, a Private Fund may be subject to greater risk of loss than if it did not utilize such credit facilities and would incur additional interest 15 Putnam Investment Management,  and other expenses with respect to such facilities. A credit facility provider would be entitled to all or part of the collateral posted by the applicable Private Fund should the Private Fund default on its obligations under the agreement with such credit facility provider. Currency Management Strategies –Currency management strategies may substantially change the Fund's exposure to currency exchange rates and could result in losses to the Fund if currencies do not perform as the investment manager expects. In addition, currency management strategies, to the extent that they reduce the Fund's exposure to currency risks, also reduce the Fund's ability to benefit from favorable changes in currency exchange rates. There is no assurance that the investment manager's use of currency management strategies will benefit the Fund or that they will be, or can be, used at appropriate times. Furthermore, there may not be a perfect correlation between the amount of exposure to a particular currency and the amount of securities in the Fund's portfolio denominated in that currency. Investing in foreign currencies for the purpose of gaining from projected changes in exchange rates, as opposed to hedging currency risks applicable to the Fund's holdings, further increases the Fund's exposure to foreign investment losses. Cybersecurity Risks – Cybersecurity incidents, both intentional and unintentional, may allow an unauthorized party to gain access to a client’s assets, Account or customer data (including private shareholder information), or proprietary information, cause an Account, the Adviser and any sub-adviser and/or their service providers (including, but not limited to, an Account’s accountants, custodians, sub-custodians, transfer agents and financial intermediaries) to suffer data breaches, data corruption or loss of operational functionality or prevent an Account’s clients from purchasing, redeeming or exchanging shares or receiving distributions. An Adviser and any sub-adviser have limited ability to prevent or mitigate cybersecurity incidents affecting third-party service providers, and such third-party service providers may have limited indemnification obligations to a client, an Adviser or a sub-adviser. Cybersecurity incidents may result in financial losses to an Account and its clients, and substantial costs may be incurred in an effort to prevent or mitigate future cybersecurity incidents. Issuers of securities in which an Account invests are also subject to cybersecurity risks, and the value of these securities could decline if the issuers experience cybersecurity incidents. Because technology is frequently changing, new ways to carry out cyber-attacks are always developing. Therefore, there is a chance that some risks have not been identified or prepared for, or that an attack may not be detected, which puts limitations on an Adviser’s ability to plan for or respond to a cyber-attack against an Account. Like other investment accounts and business enterprises, an Account, its Adviser and any sub- adviser and their service providers are subject to the risk of cyber incidents occurring from time to time. Derivative Instruments –The performance of derivative instruments depends largely on the performance of an underlying instrument, such as a currency, security, interest rate, or index, and such instruments often have risks similar to the underlying instrument, in addition to other risks. Derivative instruments involve costs and can create economic leverage in the Fund’s portfolio, which may result in significant volatility and cause the Fund to participate in losses (as well as gains) in an amount that significantly exceeds the Fund’s initial investment. Other risks include illiquidity, mispricing or improper valuation of the derivative instrument, and imperfect correlation between the value of the derivative and the underlying instrument so that the Fund may not realize the intended benefits. Their successful use will usually depend on the investment manager’s ability to accurately forecast movements in the market relating to the underlying instrument. Should a market or markets, or prices of particular classes of investments move in an unexpected manner, especially in unusual or extreme market conditions, the Fund may not realize the anticipated benefits of the transaction, and it may realize losses, which could be significant. If the investment manager is not successful in using such derivative instruments, the Fund’s performance may be worse than if the investment manager did not use such derivative instruments at all. When a derivative is used for hedging, the change in value of the derivative instrument also may not correlate specifically with the currency, security, interest rate, index or other risk being hedged. There is also the risk, especially under extreme market conditions, that an instrument which usually would operate as a hedge provides no hedging benefits at all. Use of these instruments could also result in a loss if the counterparty to the transaction does not perform as promised, including because of such counterparty’s bankruptcy or insolvency. This risk is heightened with respect to over-the-counter (OTC) instruments, such as certain swap agreements, and may be greater during 16 Putnam Investment Management,  volatile market conditions. Other risks include the inability to close out a position because the trading market becomes illiquid (particularly in the OTC markets) or the availability of counterparties becomes limited for a period of time. In addition, the presence of speculators in a particular market could lead to price distortions. To the extent that the Fund is unable to close out a position because of market illiquidity, the Fund may not be able to prevent further losses of value in its derivatives holdings and the Fund’s liquidity may be impaired. Some derivatives can be particularly sensitive to changes in interest rates or other market prices. Investors should bear in mind that, while the Fund intends to use derivative strategies on a regular basis, it is not obligated to actively engage in these transactions, generally or in any particular kind of derivative, if the investment manager elects not to do so due to availability, cost or other factors. Many swaps currently are, and others eventually are expected to be, required to be cleared through a central counterparty. Central clearing is designed to reduce counterparty credit risk and increase liquidity compared to OTC swaps, but it does not eliminate those risks completely. With cleared swaps, there is also a risk of loss by the Fund of its initial and variation margin deposits in the event of bankruptcy of the futures commission merchant (FCM) with which the Fund has an open position, or the central counterparty in a swap contract. With cleared swaps, the Fund may not be able to obtain as favorable terms as it would be able to negotiate for a bilateral, uncleared swap. In addition, an FCM may unilaterally amend the terms of its agreement with the Fund, which may include the imposition of position limits or additional margin requirements with respect to the Fund’s investment in certain types of swaps. The regulation of cleared and uncleared swaps, as well as other derivatives, is a rapidly changing area of law and is subject to modification by government and judicial action. In addition, the SEC, Commodity Futures Trading Commission (CFTC) and the exchanges are authorized to take extraordinary actions in the event of a market emergency. It is not possible to predict fully the effects of current or future regulation. Certain types of derivatives require the Fund to post margin or collateral in a manner that satisfies contractual undertakings and regulatory requirements. In order to satisfy margin or other requirements, the Fund may need to sell securities from its portfolio or exit positions at a time when it may be disadvantageous to do so. The use of derivative strategies may also have a tax impact on the Fund. The timing and character of income, gains or losses from these strategies could impair the ability of the investment manager to use derivatives when it wishes to do so. Developing Market Countries- The Fund's investments in securities of issuers in developing market countries are subject to all of the risks of foreign investing generally and have additional heightened risks due to a lack of established legal, political, business and social frameworks to support securities markets. Some of the additional significant risks include: less social, political and economic stability; • • • a higher possibility of the devaluation of a country’s currency, a downgrade in the credit ratings of issuers in such country, or a decline in the value and liquidity of securities of issuers in that country if the United States, other nations or other governmental entities (including supranational entities) impose sanctions on issuers that limit or restrict foreign investment, the movement of assets or other economic activity in the country due to political, military or regional conflicts or due to terrorism or war; smaller securities markets with low or non-existent trading volume and greater illiquidity and price volatility; • more restrictive national policies on foreign investment, including restrictions on investment in issuers or industries deemed sensitive to national interests; • less transparent and established taxation policies; • less developed regulatory or legal structures governing private and foreign investment or allowing for judicial redress for injury to private property, such as bankruptcy; • less familiarity with a capital market structure or market-oriented economy and more widespread corruption and fraud; • less financial sophistication, creditworthiness and/or resources possessed by, and less government regulation of, the financial institutions and issuers with which the Fund transacts; • less government supervision and regulation of business and industry practices, stock exchanges, brokers and listed companies than in the U.S.; 17 Putnam Investment Management,  • greater concentration in a few industries resulting in greater vulnerability to regional and global trade conditions; • higher rates of inflation and more rapid and extreme fluctuations in inflation rates; • greater sensitivity to interest rate changes (for example, a higher interest rate environment can make it more difficult for developing market governments to service their existing debt); • increased volatility in currency exchange rates and potential for currency devaluations and/or currency controls; • greater debt burdens relative to the size of the economy; • more delays in settling portfolio transactions and heightened risk of loss from share registration and custody practices; and • less assurance that when favorable economic developments occur, they will not be slowed or reversed by unanticipated economic, political or social events in such countries. Because of the above factors, the Fund's investments in developing market countries may be subject to greater price volatility and illiquidity than investments in developed markets. The definition of emerging market countries or companies as used in this prospectus may differ from the definition of the same terms as used in other Franklin Templeton fund prospectuses. Emerging Market Countries- The Fund's investments in securities of issuers in emerging market countries are subject to all of the risks of foreign investing generally and have additional heightened risks due to a lack of established legal, political, business and social frameworks to support securities markets. Some of the additional significant risks include: less social, political and economic stability; • • • a higher possibility of the devaluation of a country’s currency, a downgrade in the credit ratings of issuers in such country, or a decline in the value and liquidity of securities of issuers in that country if the United States, other nations or other governmental entities (including supranational entities) impose sanctions on issuers that limit or restrict foreign investment, the movement of assets or other economic activity in the country due to political, military or regional conflicts or due to terrorism or war; smaller securities markets with low or non-existent trading volume and greater illiquidity and price volatility; • more restrictive national policies on foreign investment, including restrictions on investment in issuers or industries deemed sensitive to national interests; • less transparent and established taxation policies; • less developed regulatory or legal structures governing private and foreign investment or allowing for judicial redress for injury to private property, such as bankruptcy; • less familiarity with a capital market structure or market-oriented economy and more widespread corruption and fraud; • less financial sophistication, creditworthiness and/or resources possessed by, and less government regulation of, the financial institutions and issuers with which the Fund transacts; • less government supervision and regulation of business and industry practices, stock exchanges, brokers and listed companies than in the U.S.; • greater concentration in a few industries resulting in greater vulnerability to regional and global trade conditions; higher rates of inflation and more rapid and extreme fluctuations in inflation rates; • • greater sensitivity to interest rate changes (for example, a higher interest rate environment can make it more difficult for emerging market governments to service their existing debt); • increased volatility in currency exchange rates and potential for currency devaluations and/or currency controls; greater debt burdens relative to the size of the economy; • • more delays in settling portfolio transactions and heightened risk of loss from share registration and custody practices; and • less assurance that when favorable economic developments occur, they will not be slowed or reversed by unanticipated economic, political or social events in such countries. Because of the above factors, the Fund's investments in emerging market countries may be subject to greater price volatility and illiquidity than investments in developed markets. 18 Putnam Investment Management,  The definition of emerging market countries or companies as used in this prospectus may differ from the definition of the same terms as used in other Franklin Templeton fund prospectuses. Dividend-Oriented Companies – Companies that have historically paid regular dividends to shareholders may decrease or eliminate dividend payments in the future. A decrease in dividend payments by an issuer may result in a decrease in the value of the issuer’s stock and less available income for the portfolio. Equity Securities – Equity securities represent a proportionate share of the ownership of a company. Their value is based on the success of the company’s business and the value of its assets, as well as general market conditions, including changes in economic conditions, growth rates, profits, interest rates, and the market’s perception of the company’s securities. The purchaser of an equity security typically receives an ownership interest in the company as well as certain voting rights. The owner of an equity security may participate in a company’s success through the receipt of dividends, which are distributions of earnings by the company to its owners. Equity security owners may also participate in a company’s success or lack of success through increases or decreases in the value of the company’s shares. Equity-Linked Notes (ELNs) – Investments in ELNs often have risks similar to their underlying securities or index, which could include management risk, market risk and as applicable, foreign securities and currency risks. In addition, since ELNs are in note form, ELNs are also subject to certain debt securities risks, such as interest rate and credit risks. Should the prices of the underlying securities or index move in an unexpected manner, the Fund may not achieve the anticipated benefits of an investment in an ELN, and may realize losses, which could be significant and could include the Fund’s entire principal investment. An investment in an ELN is also subject to counterparty risk, which is the risk that the issuer of the ELN will default or become bankrupt, and the Fund will have difficulty being repaid, or fail to be repaid, the principal amount of, or income from, its investment. Investments in ELNs are also subject to liquidity risk, which may make ELNs difficult to sell and value. In addition, ELNs may exhibit price behaviour that does not correlate with their underlying securities, index or a fixed-income investment. ESG Considerations – ESG considerations are one of a number of factors that the investment manager examines when considering investments for the Fund’s portfolio. In light of this, the issuers in which the Fund invests may not be considered ESG-focused issuers and may have lower or adverse ESG assessments. Consideration of ESG factors may affect the Fund’s exposure to certain issuers or industries and may not work as intended. In addition, ESG considerations assessed as part of the Fund’s investment process may vary across types of eligible investments and issuers. In certain circumstances, there may be times when not every investment is assessed for ESG factors and, when they are, not every ESG factor may be identified or evaluated. The investment manager’s assessment of an issuer’s ESG factors is subjective and will likely differ from that of investors, third party service providers (e.g., ratings providers) and other funds. As a result, securities selected by the investment manager may not reflect the beliefs and values of any particular investor. The investment manager also may be dependent on the availability of timely, complete and accurate ESG data reported by issuers and/or third-party research providers, the timeliness, completeness and accuracy of which is out of the investment manager’s control. ESG factors are often not uniformly measured or defined, which could impact the investment manager’s ability to assess an issuer. While the investment manager views ESG considerations as having the potential to contribute to the Fund’s long-term performance, there is no guarantee that such results will be achieved. Extension –The market value of some fixed rate debt securities (such as certain asset-backed and mortgage- backed securities) will be adversely affected when bond calls or prepayments on underlying mortgages or other assets are less or slower than anticipated, particularly when interest rates rise. When that occurs, the effective maturity date of the Fund’s investment may be extended, resulting in an increase in interest rate sensitivity to that of a longer-term instrument. Such extension may also effectively lock-in a below market interest rate and reduce the value of the debt security. Forward Trading – Certain Accounts may directly or indirectly engage in forward trading. Forward contracts and options thereon, unlike futures contracts, are not traded on exchanges and are not standardized; rather, banks and dealers act as principals in these markets, negotiating each transaction on an individual basis. Forward 19 Putnam Investment Management,  and “cash” trading is substantially unregulated, there is no limitation on daily price movements and position limits are not applicable. The principals who deal in the forward markets are not required to continue to make markets in the currencies or commodities they trade, and these markets can experience periods of illiquidity, sometimes of significant duration. There have been periods during which certain participants in these markets have been unable to quote prices for certain currencies or commodities or have quoted prices with an unusually widespread between the price at which they were prepared to buy and that at which they were prepared to sell. Futures – Futures markets are highly volatile. Investing in the futures markets requires the ability to correctly analyze such markets, which are influenced by, among other things: changing supply and demand relationships; weather; governmental, agricultural, commercial, and trade programs and policies designed to influence commodity prices; world political and economic events; and changes in interest rates. Moreover, investments in futures involve additional risks including, without limitation, credit risk with respect to the contract counterparty and from the use of leverage. The low initial margin deposits normally required in futures contract trading permit an extremely high degree of leverage, which may lead to immediate and substantial losses to an Account from a relatively small price movement. An Account’s futures positions may be illiquid because certain commodity exchanges limit fluctuations in certain futures contract prices during a single day by regulations referred to as “daily price fluctuation limits” or “daily limits.” Under such daily limits, during a single trading day no trades may be executed at prices beyond the daily limits. Once the price of a contract for a particular future has increased or decreased by an amount equal to the daily limit, positions in the future can neither be taken nor liquidated unless traders are willing to effect trades at or within the limit. This could prevent the Account from promptly liquidating unfavorable positions and subject it to substantial losses. Growth Style Investing – Growth stock prices reflect projections of future earnings or revenues, and can, therefore, fall dramatically if the company fails to meet those projections. Growth stocks may be more expensive relative to their current earnings or assets compared to value or other stocks, and if earnings growth expectations moderate, their valuations may return to more typical norms, causing their stock prices to fall. Prices of these companies’ securities may be more volatile than other securities, particularly over the short term. In addition, investment styles can go in and out of favor, which could cause additional volatility in the prices of the Fund’s portfolio holdings. Highly Volatile Markets – The prices of securities and derivative instruments, including futures and options prices, may be highly volatile. Price movements of securities, forward contracts, futures contracts, and other derivative contracts in which Accounts may directly or indirectly invest are influenced by, among other things: interest rates; changing supply and demand relationships; trade, fiscal, monetary, regulatory and exchange control programs and policies of governments; and U.S. and international political and economic events and policies. In addition, governments from time to time intervene, directly and/or by regulation, in certain markets, particularly those in currencies and interest rate related futures and options. Such intervention often is intended directly to influence prices and may, together with other factors, cause all of such markets to move rapidly in the same direction because of, among other things, interest rate fluctuations. Accounts also are subject to the risk of the failure of any of the exchanges on which their positions trade or of their clearinghouses. Inflation – The market price of debt securities generally falls as inflation increases because the purchasing power of the future income and repaid principal is expected to be worth less when received. Debt securities that pay a fixed rather than variable interest rate are especially vulnerable to inflation risk because variable-rate debt securities may be able to participate, over the long term, in rising interest rates which have historically corresponded with long-term inflationary trends. Interest Rate – Interest rate changes can be sudden and unpredictable, and are influenced by a number of factors, including government policy, monetary policy, inflation expectations, perceptions of risk, and supply of and demand for bonds. Changes in government or central bank policy, including changes in tax policy or changes in a central bank’s implementation of specific policy goals, may have a substantial impact on interest rates. There can be no guarantee that any particular government or central bank policy will be continued, discontinued or changed, nor that any such policy will have the desired effect on interest rates. Debt securities 20 Putnam Investment Management,  generally tend to lose market value when interest rates rise and increase in value when interest rates fall. A rise in interest rates also has the potential to cause investors to rapidly sell fixed income securities. A substantial increase in interest rates may also have an adverse impact on the liquidity of a debt security, especially those with longer maturities or durations. Securities with longer maturities or durations or lower coupons or that make little (or no) interest payments before maturity tend to be more sensitive to interest rate changes. Investing in Funds – Certain accounts may invest in shares of funds as part of their core investment strategy or to gain exposure to certain asset classes. Funds are actively or passively managed portfolios that invest in a particular strategy, index, asset class or other objective defined by each fund for a management fee. Investing in funds generally carry the same risks as investing directly in the underlying assets but carry additional expenses in the form of management fees, distribution fees, brokerage expenses, shareholder service fees and/or other fees and expenses imposed or incurred by the funds, with a proportionate share borne by investors. Performance will be reduced by these costs and other expenses, which clients typically pay in addition to an Adviser’s advisory fees. Additionally, investments in ETFs may trade at a premium or discount to the ETF’s net asset value or an ETF may not replicate exactly the performance of the benchmark index it seeks to track. Leverage – Certain Putnam Advisers will, from time to time, cause certain Accounts that they advise to leverage their capital if the Putnam Advisers believe it may enable the Accounts to achieve a higher rate of return. This is particularly true with respect to Accounts that are not U.S.-registered Funds, as they are not generally subject to the regulatory restrictions that apply to borrowing by U.S.-registered Funds. However, the use of leverage means that a decline in value of an Account’s investment could result in a substantial loss that would be greater than if the Account were not leveraged. In addition, leveraging by means of borrowing may exaggerate the effect of any increase or decrease in the value of portfolio securities on an Account’s net asset value, and money borrowed will be subject to interest and other costs (which may include commitment fees and/or the cost of maintaining minimum average balances), which may or may not exceed the income or gains received from the securities purchased with borrowed assets. Liquidity – Liquidity risk exists when the markets for particular securities or types of securities are or become relatively illiquid so that it is or becomes more difficult to sell the security, partially or in full, at the price at which the security was valued. Illiquidity may result from political, economic or issuer-specific events; changes in a specific market’s size or structure, including the number of participants; or overall market disruptions. Securities with reduced liquidity or that become illiquid involve greater risk than securities with more liquid markets. Market quotations for illiquid securities may be volatile and/or subject to large spreads between bid and ask prices. Reduced liquidity may have an adverse impact on market price and the ability to sell particular securities when necessary to meet liquidity needs, which may arise or increase in response to a specific economic event or because of a desire to purchase particular investments or a belief that a higher level of liquidity would be advantageous. An investment may become illiquid if the Adviser and its affiliates receive material non-public information about the issuer or the investment. To the extent that a significant portion of an issuer’s outstanding securities is held, greater liquidity risk will exist than if the issuer’s securities were more widely held. Management – The Fund is actively managed and could experience losses (realized and unrealized) if the investment manager’s judgment about markets, interest rates or the attractiveness, relative values, liquidity, or potential appreciation of particular investments made for the Fund's portfolio prove to be incorrect. The Fund could also experience losses if there are imperfections, errors or limitations in the models, tools, and data used by the investment manager or if the investment manager’s techniques or investment decisions do not produce the desired results. Additionally, legislative, regulatory, or tax developments may affect the investment techniques available to the investment manager in connection with managing the Fund and may also adversely affect the ability of the Fund to achieve its investment goal. Market – The market values of securities or other investments owned by the Fund will go up or down, sometimes rapidly or unpredictably. The Fund’s investments may decline in value due to factors affecting individual issuers (such as the results of supply and demand), or sectors within the securities markets. The value of a security or other investment also may go up or down due to general market conditions that are 21 Putnam Investment Management,  not specifically related to a particular issuer, such as real or perceived adverse economic conditions, changes in interest rates, inflation or exchange rates, or adverse investor sentiment generally. Furthermore, events involving limited liquidity, defaults, non-performance or other adverse developments that affect one industry, such as the financial services industry, or concerns or rumors about any events of these kinds, have in the past and may in the future lead to market-wide liquidity problems, may spread to other industries, and could negatively affect the value and liquidity of the Fund’s investments. In addition, unexpected events and their aftermaths, such as the spread of diseases; natural, environmental or man-made disasters; financial, political or social disruptions; terrorism and war; and other tragedies or catastrophes, can cause investor fear and panic, which can adversely affect the economic prospects of many companies, sectors, nations, regions and the market in general, in ways that cannot necessarily be foreseen. During a general downturn in the securities markets, multiple asset classes may decline in value. When markets perform well, there can be no assurance that securities or other investments held by the Fund will participate in or otherwise benefit from the advance. The long-term impact of the COVID-19 pandemic and its subsequent variants on economies, markets, industries and individual issuers is not known. The U.S. government and the Federal Reserve, as well as certain foreign governments and central banks, took extraordinary actions to support local and global economies and the financial markets in response to the COVID-19 pandemic. This and other government intervention into the economy and financial markets have resulted in a large expansion of government deficits and debt, the long-term consequences of which are not known. The United States and various countries are currently involved in disputes over trade and other matters, which may result in tariffs, investment restrictions and other adverse impacts on affected companies and securities. Trade disputes may adversely affect the economies of the United States and its trading partners, as well as companies directly or indirectly affected by tariffs or restrictions and financial markets generally. For example, the United States has imposed tariffs and other trade barriers on Chinese exports, has restricted sales of certain categories of goods to China, and has established barriers to investments in China. The United States government has prohibited U.S. persons from investing in Chinese companies designated as related to the Chinese military. These and possible future restrictions could limit the Fund’s opportunities for investment and require the sale of securities at a loss or make them illiquid. Moreover, the Chinese government is involved in a longstanding dispute with Taiwan that has included threats of invasion. If the political climate between the United States and China does not improve or continues to deteriorate, if China were to attempt unification of Taiwan by force, or if other geopolitical conflicts develop or get worse, economies, markets and individual securities may be severely affected both regionally and globally, and the value of the Fund’s assets may go down. Stock prices tend to go up and down more dramatically than those of debt securities. A slower-growth or recessionary economic environment could have an adverse effect on the prices of the various stocks held by the Fund. Merger Arbitrage Securities and Distressed Companies- Certain underlying funds may invest in merger arbitrage securities and distressed companies. A merger or other restructuring, or a tender or exchange offer, proposed or pending at the time an underlying fund invests in merger arbitrage securities may not be completed on the terms or within the time frame contemplated, which may result in losses to the underlying fund. Debt obligations of distressed companies typically are unrated, lower-rated, in default or close to default and are generally more likely to become worthless than the securities of more financially stable companies. Multi-Manager Risk – Certain Putnam Advisers employ a multi-manager strategy where the Putnam Adviser monitors each underlying manager in the arrangement as well as the overall management of the Account. In such arrangements, the Adviser and each underlying manager make investment decisions for Accounts independently from one another. It is possible that the investment styles used by an underlying manager will not always be complementary to those used by other underlying managers, which could adversely affect the performance of the Account. There can be no assurance that the use of a multi-manager approach will not result in losses by certain underlying managers offsetting any profits achieved by others. In addition, underlying managers may, from time to time, compete with the others for the same positions. Conversely, one underlying 22 Putnam Investment Management,  manager may buy the same securities that another underlying manager sells. Therefore, the client would bear the cost of these trades without accomplishing any investment purpose. Non-Diversification – A "non-diversified" fund generally invests a greater portion of its assets in the securities of one or more issuers and invests overall in a smaller number of issuers than a diversified fund. The Fund may be more sensitive to a single economic, business, political, regulatory or other occurrence than a more diversified fund might be, which may negatively impact the Fund's performance and result in greater fluctuation in the value of the Fund's shares and a greater risk of loss. Non-U.S. Securities –Directly or indirectly investing in non-U.S. securities typically involves different risks than investing in U.S. securities, and includes risks associated with: (i) internal and external political and economic developments – e.g., the political, economic and social policies and structures of some foreign countries may be less stable and more volatile than those in the U.S. or some foreign countries may be subject to trading restrictions or economic sanctions; diplomatic and political developments could affect the economies, industries, and securities and currency markets of the countries in which the Fund is invested, which can include rapid and adverse political changes; social instability; regional conflicts; sanctions imposed by the United States, other nations or other governmental entities, including supranational entities; terrorism; and war; (ii) trading practices – e.g., government supervision and regulation of non-U.S. security and currency markets, trading systems and brokers may be less than in the United States, (iii) availability of information – non-U.S. issuers may not be subject to the same disclosure, accounting and financial reporting standards and practices as U.S. issuers and information may be less timely and/or reliable than information provided by U.S. issuers, (iv) limited markets – the securities of certain non-U.S. issuers may be less liquid (harder to sell) and more volatile, and (v) currency exchange rate fluctuations and policies. In addition, there is risk of unfavorable tax policies, including but not limited to, substantial, punitive or confiscatory tax increases; withholding and other non-U.S. taxes on income (including capital gains or other amounts); taxation on a retroactive basis; sudden or unanticipated changes in non-U.S. tax laws; financial transaction taxes; denial or delay of the realization of tax treaty benefits; and the payment of non-U.S. taxes not available for credit or deduction when passed through to shareholders. Although not typically subject to currency exchange rate risk, depositary receipts may be subject to the same risks as non-U.S. securities generally. The risks of investments outside the United States may be greater in developing countries or emerging market countries. Certain of the foregoing risks also may apply to securities of U.S. companies with significant non-U.S. operations. Options – Certain Accounts directly or indirectly invest in options. Purchasing put and call options, as well as writing such options, are highly specialized activities and entail greater than ordinary investment risks. Although an option buyer’s risk is limited to the amount of the original investment for the purchase of the option, an investment in an option may be subject to greater fluctuation than is an investment in the underlying securities. In theory, an uncovered call writer’s loss is potentially unlimited, but in practice the loss is limited by the term of existence of the call. The risk for a writer of a put option is that the price of the underlying securities may fall below the exercise price. The ability to trade in or exercise options may be restricted if trading in the underlying securities interest becomes restricted. Unlike exchange-traded options, which are standardized with respect to the underlying instrument, expiration date, contract size, and strike price, the terms of over- the-counter options (options not traded on exchanges) are generally established through negotiation with the other party to the option contract. While this type of arrangement allows greater flexibility to tailor an option to its needs, over-the-counter options generally involve greater credit risk than exchange-traded options, which are guaranteed by the clearing organization of the exchanges where they are traded. OTC Transactions – Certain Accounts may directly or indirectly trade in derivative instruments that are not traded on organized exchanges and, as such, are not standardized. These transactions are known as over-the- counter (“OTC”) transactions. In general, there is less governmental regulation and supervision in the OTC markets than there is with respect to transactions entered into on an organized exchange. In addition, many of the protections afforded to participants on some organized exchanges, such as the performance guarantee of an exchange clearinghouse, are not available in connection with OTC transactions. Moreover, while some OTC markets are often highly liquid, transactions in OTC derivatives may involve greater risk than investing in exchange traded instruments because there is no exchange market on which to close out an open position. It may be impossible to liquidate an existing position, to assess the value of the position arising from an off- 23 Putnam Investment Management,  exchange transaction or to assess the exposure to risk. Bid and offer prices need not be quoted and, even where they are, they will be established by dealers in these instruments and consequently it may be difficult to establish what is a fair price. Outbreaks, Pandemics and Other Public Health Issues – In general, unexpected local, regional or global events, such as the spread of infectious illnesses or other public health issues and their aftermaths, could have a significant adverse impact on the Advisers’ operations (including the ability of the Advisers to find and execute suitable investments) and therefore the Accounts' potential returns. In addition, such infectious illness outbreaks, as well as any restrictive measures implemented to control such outbreaks, could adversely affect the economies of many nations or the entire global economy, the financial condition of individual issuers or companies (including those that are held by, or are counterparties or service providers to, the Accounts) and capital markets in ways that cannot necessarily be foreseen, and such impact could be significant and long term. Moreover, the impact of infectious illnesses in emerging market countries may be greater due to generally less established healthcare systems. If such events occur, an Account’s exposure to a number of other risks described elsewhere in this brochure can increase. For example, an outbreak of an infectious respiratory illness caused by a novel coronavirus known as COVID- 19 was first detected in China in December 2019 and later detected globally, causing the World Health Organization to declare it a pandemic. This coronavirus has caused global distress and market volatility and uncertainty, and it resulted in travel restrictions, closed international borders, enhanced health screenings at ports of entry and elsewhere, disruption of and delays in healthcare service preparation and delivery, prolonged quarantines, cancellations of services, supply chain disruptions, volatility in consumer demand for certain products, and disruptions or suspensions of business activities across a wide range of industries (including causing the Advisers and other service providers to certain Accounts to implement business contingency plans). As of the date of this brochure, the long-term economic fallout of COVID-19 is difficult to predict, and the outbreak could adversely affect the Accounts’ investments and/or the Advisers’ operations. Portfolio Turnover – The portfolio turnover rate in certain Accounts may exceed 100% per year because of the anticipated use of certain investment strategies. Other Accounts may experience greater turnover rates due to rebalancing services provided by an Adviser’s digital advisory program. Such frequent trading may affect the Account’s investment performance, particularly through increased brokerage and other transaction costs and taxes. Private Investments in Public Equities (“PIPEs”) – Accounts investing in PIPE transactions invest money in public corporations in exchange for shares of the company, usually unregistered under the Securities Act. Often, warrants will be utilized to provide greater upside potential. Quantitative Model Risk – When executing an investment strategy using various proprietary quantitative or investment models, securities or other financial instruments selected can perform differently than expected, or from the market as a whole, as a result of a model’s component factors, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction, implementation and maintenance of the models (e.g., data problems, software issues, etc.). A model’s assumptions or its data inputs may be inaccurate from the outset or may become inaccurate as a result of many factors, such as changes in market structure, increased government intervention in markets or growth in assets managed in accordance with similar investment strategies. Moreover, the use of computers in collating information or developing and operating a quantitative or investment model does not assure the success of the model because a computer is merely an aid in compiling and organizing trade information. Accordingly, there can be no assurance that a model will achieve its objective. Real Estate Securities – Real estate values rise and fall in response to a variety of factors, including local, regional and national economic conditions, interest rates, tax and insurance considerations, changes in zoning laws, environmental regulations or hazards, or overbuilding, increases in property taxes and operating expenses or value decline in a neighbourhood. When economic growth is slow, demand for property decreases and prices may decline. 24 Putnam Investment Management,  REITs – A REIT’s performance depends on the types, values and locations of the properties and companies it owns and how well those properties and companies are managed. A decline in rental income may occur because of extended vacancies, increased competition from other properties, tenants’ failure to pay rent or poor management. Because a REIT may be invested in a limited number of projects or in a particular market segment, it may be more susceptible to adverse developments affecting a single project or market segment than more broadly diversified investments. Loss of status as a qualified REIT under the U.S. federal tax laws could adversely affect the value of a particular REIT or the market for REITs as a whole. These risks may also apply to securities of REIT-like entities domiciled outside the U.S. Risk of Loss – All investments involve the risk of the loss of capital. No guarantee or representation is made that any Account will achieve its investment objective or avoid losses. The value of a security can go up or down more than the market as a whole and can perform differently from the value of the market as a whole, often due to disappointing earnings reports by an issuer, unsuccessful products or services, loss of major customers, major litigation against the issuer, changes in government regulations affecting the issuer or the competitive environment, or investor sentiment. While each Account has its own investment objectives and strategies, there are risks associated with investing in general. Risks Related to Russia’s Invasion of Ukraine – Russia’s military invasion of Ukraine in February 2022, the resulting responses by the United States and other countries, and the continued conflict has increased volatility and uncertainty in the financial markets and adversely affected regional and global economies. The United States and other countries and certain international organizations have imposed broad-ranging economic sanctions on Russia and certain Russian individuals, banking entities and corporations as a response to Russia’s invasion of Ukraine. The United States and other countries have also imposed economic sanctions on individuals and corporations in other countries in connection with the conflict and may continue to do so. These sanctions, as well as any other economic consequences related to the invasion, such as additional sanctions, boycotts or changes in consumer or purchaser preferences or cyber-attacks on governments, companies or individuals, may further decrease the value and liquidity of certain Russian securities and securities of issuers in other countries that are subject to economic sanctions related to the invasion. To the extent that the Fund has exposure to Russian investments or investments in countries affected by the invasion, the Fund’s ability to price, buy, sell, receive or deliver such investments on behalf of an Account may be impaired. The Fund could determine that affected securities of an Account have zero value. In addition, any exposure that the Fund may have to counterparties in Russia or in countries affected by the invasion could negatively impact the Fund’s portfolio. The extent and duration of Russia’s military actions and the repercussions of such actions (including any retaliatory actions or countermeasures that may be taken by those subjects to sanctions) are impossible to predict, but could result in significant market disruptions, including in the oil and natural gas markets, and may negatively affect global supply chains, inflation and global growth. These and any related events could significantly impact the Fund’s performance and the value of an investment in the Fund, even beyond any direct exposure the Fund may have to Russian issuers or issuers in other countries affected by the invasion. Securities Lending –To generate additional income, the Putnam Adviser may lend certain of an Account’s portfolio securities to qualified borrowers, including banks and broker-dealers, in exchange for cash collateral at least equal to the value of the security loaned that may then be invested while the loan is outstanding. If the borrower defaults on its obligation to return the securities loaned because of insolvency or other reasons, there could be delays and costs in recovering the securities loaned or in gaining access to the collateral. These delays and costs could be greater for non-U.S. securities. If the Adviser is not able to recover the securities loaned, it may sell the collateral and purchase a replacement investment in the market. Additional transaction costs would result, and the value of the collateral could decrease below the value of the replacement investment by the time the replacement investment is purchased. Until the replacement can be purchased, the Account will not have the desired level of exposure to the security which the borrower failed to return. Cash received as collateral through loan transactions may be invested in other eligible securities, including shares of a money market fund. Investing this cash creates additional market risk, including losses on the collateral and, should the Adviser need to look to the collateral in the event of the borrower's default, losses on the loan secured by that collateral. 25 Putnam Investment Management,  Short Selling Risk – A short sale is where an Account borrows securities from a lender and sells them in the open market. The Account must repurchase the securities at a later date in order to return them to the lender. In the interim, the proceeds from the short sale are deposited with the lender and the Account pays interest to the lender on the borrowed securities. If the value of the securities declines between the time of the initial short sale and the time it repurchases and returns the securities, the Account makes a profit for the difference (less any interest paid to the lender). If the price of the borrowed securities rises, however, a loss results. There are risks associated with short selling, namely, that the borrowed securities will rise in value or not decline enough to cover the borrowing costs. Any loss on short positions may or may not be offset by investing short sale proceeds in other investments. In addition, the Account may experience difficulties in repurchasing the borrowed securities if a liquid market for the securities does not exist. The lender from whom the securities have been borrowed may also become bankrupt, causing the borrowing Account to lose the collateral it deposited with the lender. Small and Mid-Capitalization Companies – While small and mid-capitalization companies may offer substantial opportunities for capital growth, they also may involve more risks than larger companies. Historically, securities issued by small and mid-capitalization companies have been more volatile in price than securities that are issued by larger companies, especially over the short term. Among the reasons for the greater price volatility are the less certain growth prospects of small and mid-capitalization companies, the lower degree of liquidity in the markets for such securities, and the greater sensitivity of small and mid- capitalization companies to changing economic conditions. In addition, small and mid-capitalization companies may lack depth of management, be unable to generate funds necessary for growth or development, have limited product lines or be developing or marketing new products or services for which markets are not yet established and may never become established. Small and mid-capitalization companies may be particularly affected by interest rate increases, as they may find it more difficult to borrow money to continue or expand operations, or may have difficulty in repaying loans, particularly those with floating interest rates. State and U.S. Territories – Certain Accounts may directly or indirectly invest predominantly in state- specific municipal securities, in which case, events in that specific state are likely to affect the Account’s investments and its performance by increasing price volatility, market yield and taxes owed on income earned. These events may include economic or political policy changes, tax base erosion, state constitutional limits on tax increases, budget deficits and other financial difficulties, and changes in the credit ratings assigned to municipal issuers of that state. Swaps – Certain Advisers enter into swap contracts for certain Accounts, including but not limited to, total return, interest rate, basis, currency, credit default, and inflation. These Advisers may enter into swaps for speculative or hedging purposes and therefore may increase or decrease exposure to the underlying instrument, and these Advisers utilize swaps for certain Accounts where it believes such investments will further the Account’s objectives. Notional amounts of swap transactions are not subject to any limitations, and swap contracts may expose an Account to unlimited risk of loss. Swaps may be used as an alternative to futures contracts. To the extent an Account directly or indirectly invests in repos, swaps, forwards, futures, options and other “synthetic” or derivative instruments, the Account would be subject to counterparty risk. In addition, certain Advisers may enter into swaps on securities, baskets of securities or securities indices and they may use such swaps to gain investment exposure to the underlying security or securities where direct ownership is either not legally possible or is economically unattractive. Certain Advisers may enter into swaps to modify an Account’s exposure to particular currencies using currency swaps. Tracking Error and ETF Management Risk – ETFs trade like stocks, fluctuate in market value and may trade at prices above or below the ETF’s net asset value. ETF shares may be bought or sold throughout the day at their market price on the exchange on which they are listed. However, there can be no guarantee that an active trading market for ETF shares will develop or be maintained, or that their listing will continue or remain unchanged. While the shares of ETFs are tradable on secondary markets, they may not readily trade in all market conditions and may trade at significant discounts due to market forces. Certain ETFs are designed to track a specified market index; however, in some cases an ETF’s return may deviate from the specified 26 Putnam Investment Management,  index. Other ETFs are actively managed and are therefore subject to management risk. Furthermore, unlike traditional open-end funds, investors generally cannot purchase ETF shares from, or redeem ETF shares with, the ETF sponsor. Rather, only specified large blocks of ETF shares called “creation units” can be purchased from, or redeemed with, the ETF sponsor. For more information on any ETF, investors should carefully consider the ETF’s investment goals, risks, sales charges and expenses before investing. An ETF’s prospectus contains this and other information. Unlisted Securities – Unlisted securities (i.e., securities not listed on a stock exchange or other markets and for which no liquid secondary trading market exists) may involve a high degree of business and financial risk and may result in substantial losses. The companies underlying such securities may have relatively limited operating and profit histories. Many of these companies may also need substantial additional capital to support expansion or to achieve or maintain a competitive position and there is no assurance that capital will be available to finance such needs. In the absence of a liquid trading market for unlisted securities, they will be difficult to value. It is also possible that such investments will be difficult to liquidate when desired, which may limit the ability to realize their full value. Although it is generally desirable that unlisted securities become listed in due course, there can be no assurance that this will be the case, or that sufficient liquidity for substantial shareholdings will be available following listing. Additionally, companies whose securities are not publicly traded generally are not subject to the same disclosure and investor protection requirements that apply to publicly traded companies. As a consequence, the information available to security holders of such companies about their business models, quality of management, earnings growth potential, and other criteria that are normally considered when evaluating the investment prospects of such companies may be less complete and less reliable than would be the case with a publicly traded company. Valuation Risk – An Account may directly or indirectly invest in securities for which reliable market quotations are not available. The process of valuing such securities is based on inherent uncertainties, and the resulting values may differ from values that would have been determined had readily available market quotations been available. As a result, the values placed on such securities by the Advisers may differ from values placed on such securities by other investors or a client’s custodian and from prices at which such securities may ultimately be sold. Where appropriate, third-party pricing information, which may be indicative of, or used as an input in determining, fair value may be used, but such information may at times not be available regarding certain assets or, if available, may not be considered reliable. Even if considered reliable, such third-party information might not ultimately reflect the price obtained for that security in a market transaction, which could be higher or lower than the third-party pricing information. In addition, an Account may rely on various third-party sources to calculate its market value. As a result, the Account is subject to certain operational risks associated with reliance on service providers and service providers’ data sources. Value Style Investing – Value stock prices are considered "cheap" relative to the company's perceived value and are often out of favor with other investors. The investment manager may invest in such stocks if it believes the market may have overreacted to adverse developments or failed to appreciate positive changes. However, if other investors fail to recognize the company's value (and do not become buyers, or if they become sellers or favor investing in faster growing companies), value stocks may not increase in value as anticipated by the investment manager and may even decline in value. Item 9: Disciplinary Information PIM entered into a Settlement Agreement with the SEC on September 27, 2018. The Settlement Agreement states: (i) a trader formerly employed by Putnam engaged in prearranged trades in certain mortgage-backed securities, (ii) as a result of these undisclosed prearranged trades PIM did not seek best execution, (iii) PIM did not ensure compliance with applicable policies regarding cross-trades and failed to supervise the former employee. The SEC found violations of Sections 203(e) (6), 206 (2) (4), and 207 of the Investment Advisers Act, and Section 17(a) of the Investment Company Act. The SEC entered a cease and desist order, and Putnam paid a $1,000,000 fine and agreed to reimburse the clients that participated in the relevant trades in an aggregate amount of $1,095,006.10. 27 Putnam Investment Management,  Item 10: Other Financial Industry Activities and 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. PIM has certain business arrangements with related persons/companies that are material to its advisory business or to PIM 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 28 Putnam Investment Management,  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 Side-By- 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. Related Service Providers for Certain Separate Accounts and Model Programs As described above in Item 4 (“Investment Advisory Services”), effective January 1, 2025, PIM acts as a subadviser to its affiliate FTPPG in connection with SMA Programs. Under this engagement, FTPPG provides operational support on behalf of PIM (the “Support Services”). FTPPG has retained Market Street Advisors, Inc., dba “Archer,” a company not affiliated with PIM or FTPPG, to provide some or all of the Support Services as its delegate with respect to separate accounts. PIM has engaged FTPPG to provide PIM with Support Services with respect to PIM’s non-discretionary advisory arrangements for Model Portfolio programs. In exchange for the Support Services for SMA Programs, PIM pays FTPPG a blended fee depending on the account’s assets under management and account type. Such fees would be paid by PIM out of its own resources. 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 29 Putnam Investment Management,  affiliates could cause clients to forego attractive investment opportunities in some strategies. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Summary PIM, 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 PIM (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 non- public; 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 30 Putnam Investment 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 31 Putnam Investment Management,  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. 32 Putnam Investment Management,  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 for whom the Advisers execute cross trades bear the risk that one or more other accounts in the cross trade will be treated more favorably, particularly in cases where such other accounts pay a higher management or performance-based fee or incentive allocation. The Advisers have established certain policies and procedures as they relate to cross trades, under which certain cross trades are permitted when it is in the best interest of each account. Cross trades also pose a risk that the price of a security or other instrument bought or sold through a cross trade will not be as favorable as it might have been had the trade been executed in the open market or that an account receives a security that is difficult to dispose of in a market transaction. The Advisers seek to ensure that the price paid, or amount received by a client in a cross trade is fair and appropriate, which is sometimes based on independent dealer quotes or information obtained from recognized pricing services. Moreover, absent certain circumstances, if the Advisers are unable to obtain sufficient price quotes or otherwise determine the security is illiquid, then the cross trade would not typically be executed. In addition, the Advisers will not receive compensation (other than their normal advisory fee for managing the Account), directly or indirectly, for effecting a cross trade between advisory clients, and accordingly will not be deemed to have acted as a broker with respect to such transactions. Any cross trades effected with respect to U.S.-registered Funds are subject to Rule 17a-7 under the 1940 Act. Please also see Item 6 (“Performance-Based Fees and Side-by-Side Management”) for additional information. Personal Trading Management of personal accounts by a portfolio manager or other investment professionals will, from time to time, give rise to potential conflicts of interest. The Putnam Advisers have adopted the Personal Investments Policy, which they believe contains provisions reasonably designed to prevent a wide range of prohibited activities by portfolio managers and others with respect to their personal trading activities, as well as certain additional compliance procedures that are designed to address these and other types of conflicts. However, there is no guarantee that the Personal Investment Policy or such additional compliance procedures will detect and/or address all situations where an actual or potential conflict arises. Conflicts Related to Investments in Securities of Companies in Which an Adviser, an Affiliate or Another Account Holds Interests The Putnam Advisers will, from time to time, recommend to clients, or buy or sell for accounts, securities in which the Advisers or their affiliates have a material financial interest. Such financial interests include, among other things, seed capital contributed by an Adviser or an affiliate to a Fund that such Adviser manages, or an actual investment by an Adviser or an affiliate in the Fund or in third-party vehicles in which the Adviser or a related person has a financial interest. The Advisers or their related persons may also purchase or sell for themselves securities or other investments that one or more advisory clients own, previously owned, or may own in the future, subject to the Personal Investments Policy, other policies and procedures of the Advisers, and applicable law. Under certain circumstances and to the extent permitted by applicable law, certain Accounts will invest directly or indirectly in the securities of companies in which a related person of the Adviser, for itself or its clients, has an equity, debt, or other interest. For example, an Adviser’s affiliate may have contributed seed capital to a Private Fund or other Account that the Adviser concludes should co-invest in the same company with another Private Fund or other Account managed by the Adviser. In addition, an affiliate or a related person of an Adviser may make a strategic investment in a company (such as a company in the financial technology industry) that an Adviser separately determines is a prudent investment for an Account to make. Accordingly, an Adviser’s management of its client’s assets will, in certain circumstances, benefit the interests of members of the Adviser and/or its affiliates. With respect to a particular account, the Putnam Advisers are not obligated to recommend, buy or sell, or to refrain from recommending, buying or selling any security that the Advisers and “access persons,” as defined by applicable federal securities laws, may buy or sell for their own account or for the accounts of any other fund. Additionally, the Advisers are permitted to invest in securities held by any Accounts they manage, subject 33 Putnam Investment Management,  to applicable policies and procedures adopted by the Advisers and applicable law. Conflicts Related to Investing Alongside Other Accounts Under certain circumstances, an account will make an investment in which one or more other accounts are expected to participate, or already have made, or will seek to make, an investment in the same security. Such Accounts may have conflicting interests and objectives in connection with such investments, including with respect to views on the operations or activities of the issuer involved, the targeted returns from the investment and the timeframe for, and method of, exiting the investment. When making such investments, an Adviser may do so in a way that favors one account over another account, even if both accounts are investing in the same security at the same time. For example, if two accounts have different time horizons, and the account with a shorter time horizon sells its interest first, this sale could affect the value of the investment in the company held by the account with the longer time horizon. There will also be cases where accounts invest on a “parallel” basis (i.e., proportionately in all transactions at substantially the same time and on substantially the same terms and conditions). The Putnam Advisers have no obligation to provide the same investment advice or to purchase or sell the same securities for each account. Differing facts and circumstances among accounts will, from time to time, result in an Adviser and one or more of its related persons giving advice and taking action with respect to one account they manage, or for their own account, that differs from action taken on behalf of other accounts they manage. However, such differing actions are subject to applicable policies and procedures adopted by the Advisers and are guided by the Advisers’ fiduciary duties to act in each account’s best interests. For example, in certain circumstances, clients will seek to take an opposite investment position (e.g., a long position versus a short position) in the same security held by other clients (or proprietary accounts), but policies and procedures of the Advisers’ prohibit such opposite positions in certain circumstances. The Putnam Advisers serve as sub-advisers to various sub-advised Accounts, some of which have an investment goal and strategy similar to that of other types of client Accounts for which such Advisers serve as investment adviser. Even when there is similarity in investment goal and strategy, investment performance and portfolio holdings may vary between these accounts, potentially significantly, as a result of, among other things, differences in: (i) inception dates, (ii) cash flows, (iii) asset allocation, (iv) security selection, (v) liquidity, (vi) income distribution or income retention, (vii) fees, (viii) fair value pricing procedures, (ix) diversification methodology, (x) use of different foreign exchange rates, (xi) use of different pricing vendors, (xii) ability to access certain markets due to country registration requirements, (xiii) legal restrictions or custodial issues, (xiv) legacy holdings in the account, (xv) availability of applicable trading agreements such as ISDAs, futures agreements or other trading documentation, (xvi) restrictions placed on the account (including country, industry or environmental and social governance restrictions) and (xvii) other operational issues that impact the ability of an Account to trade in certain instruments or markets. Please see Item 6 (“Performance-Based Fees and Side-By-Side Management”) for additional information regarding conflicts related to side-by-side management of different Accounts. Conflicts Related to Investing in Different Levels of the Capital Structure Potential conflicts exist in certain uses of multiple strategies by a Putnam Adviser. For example, conflicts will arise in cases where different accounts invest in different parts of an issuer’s capital structure, including circumstances in which one or more accounts own private securities or obligations of an issuer and one or more other accounts own or seek to acquire securities of the same issuer. For instance, an account may acquire a loan, loan participation or a loan assignment of a particular borrower in which one or more other accounts have an equity investment or may invest in senior debt obligations of an issuer for one account and junior debt obligations or equity of the same issuer for another account. In such and other similar situations, an Adviser may take actions with respect to the assets held by one account that are adverse to the other accounts, for example, by foreclosing on loans, disposing of equity, or by exercising rights to purchase or sell to an issuer, causing an issuer to take actions adverse to certain classes of securities. In these situations, decisions over items such as whether to make the investment, exercise certain rights, or take or determine 34 Putnam Investment Management,  not to take an action, proxy voting, corporate reorganization, how to exit an investment, bankruptcy or similar matters (including, for example, whether to trigger an event of default or the terms of any workout) will result in conflicts of interest. Conflicts Related to Use of Information The Putnam Advisers receive and generate various kinds of portfolio company data and other information, including those related to financial, industry, market, business operations, trends, budgets, customers, suppliers, competitors and other metrics. This information may, in certain instances, include MNPI received or generated in connection with efforts on behalf of an account’s investment (or prospective investment) to better enable the Adviser to anticipate macroeconomic and other trends, and otherwise develop investment strategies. Information barriers and/or confidentiality or similar arrangements entered into by an Adviser with companies or other sources of information will limit such Adviser’s ability to internally share and use such information. The Advisers rely on these barriers in some instances to mitigate potential conflicts of interest, to preserve confidential information and to prevent the inappropriate flow of MNPI and confidential information. When not limited from using this information, the Advisers are likely in certain instances to use such information in a manner that could provide a material benefit to certain other accounts (or the Advisers and/or their affiliates) without equally benefiting the account(s) from which such information was obtained. In addition, the Advisers have an incentive to pursue investments in companies based on the data and information expected to be received or generated by such companies. Subject to applicable law and confidentiality obligations, the Advisers have in the past and are likely in the future to utilize such information to benefit certain accounts (or the Advisers and/or their affiliates) in a manner that may otherwise present a conflict of interest. Conflicts Related to Investment in Affiliated Funds and Affiliated Accounts An Adviser, where appropriate (including in compliance with any applicable investment guidelines or restrictions) and in accordance with applicable laws and regulations, will at times purchase on behalf of the Adviser’s clients, or recommend to the Adviser’s clients that they purchase, shares of Affiliated Funds, or invest their assets in other portfolios managed by the Advisers or their affiliates (“Affiliated Accounts”). In addition, a Putnam Adviser may construct Model Portfolios without considering the universe of potential funds sponsored by Third-Party Funds, even though there may (or may not) be Third-Party Funds that are more appropriate for inclusion in such portfolios, including available Third-Party Funds in the applicable asset classes that have lower fees and expenses, greater performance or other favorable terms relative to an Affiliated Fund. Conflicts of interest arise when investing a client's assets into Affiliated Funds or Affiliated Accounts. For example, as a shareholder in a pooled investment vehicle, a client will generally pay a proportionate share of the vehicle’s fees and expenses. Investment by a client in an Affiliated Fund or Affiliated Account could therefore result in the client, depending on the circumstances and subject to applicable law, directly or indirectly paying advisory (or other) fees to the Affiliated Fund or Affiliated Account in addition to any fees it pays to the Adviser for managing the client’s account. Moreover, in certain circumstances, the Adviser will receive some or all of such advisory (or other) fees from an affiliate, including on occasion via a fee sharing or referral arrangement. The client investment will also, from time to time, be subject to other fees and expenses charged to the Affiliated Fund or Affiliated Account by other parties. Similarly, an Adviser’s client who invests into an Affiliated Account that is a separate account managed by another Adviser would be subject to any advisory fees charged by that Adviser to the separate account. If a client does not want its account assets to be invested in Affiliated Funds and/or Affiliated Accounts, then the client should notify its Adviser to discuss modifying its investment guidelines. The Advisers’ Separate Account clients are also permitted to invest directly in certain Affiliated Funds (including U.S. Registered Funds) or Affiliated Accounts independent of their Separate Account without paying additional separate account management fees to the Advisers. In order to avoid duplication of fees, the Putnam Advisers typically exclude any assets invested in Affiliated Funds or Affiliated Accounts from the management fee charged by the Advisers to the Account, unless otherwise agreed with a client (for example, where a client requests additional allocation services at the 35 Putnam Investment Management,  Account level) or disclosed to a client, and subject to applicable law. In some instances, certain private Funds will not pay management fees to the Affiliated Fund or Affiliated Account with respect to such investment, unless the client (or investors therein) has been provided disclosure regarding such compensation arrangements. Similarly, the separate account management fees paid by certain retirement accounts (including those subjects to the Employee Retirement Income Security Act of 1974 (“ERISA”) or Section 4975 of the Internal Revenue Code of 1986, as amended) that invest in Affiliated Funds or Affiliated Accounts will exclude account assets invested in such Affiliated Funds or Affiliated Accounts to the extent required by law when calculating the Advisers’ Separate Account management fees. Accordingly, the assets of such Accounts invested in Affiliated Funds or Affiliated Accounts will pay their pro rata share of such applicable fees of the Affiliated Fund or Affiliated Account, to the extent permitted by applicable law. Alternatively, the Advisers may elect to provide a credit representing the respective account’s pro rata share of fees paid with respect to any assets of a client invested in shares of any such Affiliated Funds or Affiliated Accounts. Conflicts Related to Trading for Multiple Accounts Franklin Templeton generally endeavors to aggregate same-day client trades in the same security for accounts under the management of an Adviser’s portfolio management team. However, from time to time, a Putnam Adviser will manage or implement a portfolio decision on behalf of a client ahead of, or contemporaneously with, portfolio decisions of another client. In these circumstances, market impact, liquidity constraints, or other factors could result in one of the clients receiving less favorable pricing or trading results, paying higher transaction costs, or being otherwise disadvantaged. Similarly, from time to time, an Adviser or an affiliate will buy or sell securities for clients before or at about the same time that such Adviser or affiliate buys or sells the same securities for its own account(s); however, to mitigate the conflicts associated with such trades, Franklin Templeton has adopted policies and procedures applicable to the Advisers requiring such buy or sell orders to generally be aggregated. Please see Item 12 (“Brokerage Practices – Aggregation and Allocation of Trades”) for more information regarding aggregation of transactions. Conflicts Related to Service Providers A Putnam Adviser will, in its discretion, contract with a related person of the Adviser, including related broker- dealers, administrators and/or transfer agents, to perform services for the Adviser in connection with its provision of advisory services to its clients. In these circumstances, the related person may perform such services itself, or it may engage an unaffiliated service provider that it oversees to provide the services. Similarly, an Adviser, in its discretion, at times recommends to its clients that they contract services with a related person of the Adviser or an entity with which the Adviser or its affiliates or a member of their personnel has a relationship or from which the Adviser or its affiliates or their personnel otherwise derives financial or other benefit. An Adviser will engage a related person to provide such services when it believes such engagement is beneficial to the account, such as providing efficiencies in information sharing and higher quality of service. However, the Adviser also has an incentive, even if it does not act on such incentive, to recommend the related person even if another person may be more qualified to provide the applicable services and/or can provide such services at a lesser cost. Similarly, in hindsight, circumstances could be construed that the Adviser was not as incentivized to pursue remedies and enforce rights against affiliated service providers as compared to unaffiliated service providers, and the Adviser may be incentivized to agree to more favorable compensation terms with an affiliated service provider than with an unaffiliated service provider. An Adviser and its affiliates may, to the extent permitted by applicable laws, make payments, or assign the right to receive performance fees, to financial intermediaries relating to the placement of interests/shares in private Funds. These payments may be in addition to or in lieu of any placement fees payable by investors in those private Funds. These payments to the financial intermediary and/or its representative create an incentive for the financial intermediary to recommend the private Fund over other products. In certain circumstances, conflicts of interest will also arise with respect to investments by a Putnam Adviser, its affiliates, or an Account in a service provider. For example, the Advisers will, under certain circumstances, have an incentive to pursue investments in companies where an Adviser or its affiliates are, or could become, a customer of the companies’ services, or vice versa. 36 Putnam Investment Management,  Where appropriate and permitted under an account’s governing documents or investment management agreement, a Putnam Adviser will, from time to time, recommend that such Account file claims or threaten action against other parties. To the extent such party is a service provider, vendor, distributor or placement agent for the Adviser or its affiliates, the Adviser will at times have an incentive not to recommend such action. The Advisers address such conflicts of interest by acting on behalf of their clients in accordance with their fiduciary obligations to each client. Accordingly, the Advisers’ general practice is not to take into account the fact that an issuer is a client, service provider, vendor, distributor, or placement agent when making investment decisions or deciding to file claims or pursue legal actions. Trade and Guideline Errors; Compliance Review Investment management is complex. On occasion, a Putnam Adviser may make an error in executing securities transactions or in complying with a client's guidelines – for example, by buying a position where we intended to sell it, or by purchasing an ineligible security for an account. Where a client suffers a loss and the Putnam Adviser believes the error is one for which we should make the client whole, we generally correct the error by placing the client account, to the extent practical, in the same position (net of any associated gains) as it would have been if there had been no error. Depending on the circumstances, and subject to applicable law and client agreements, Putnam may take various steps, including canceling the trade, correcting an allocation, or buying or selling a position, to achieve this result. We do not maintain an “error account” on our own books, so any relevant corrective trading is done in the client’s account. We generally notify separate account clients (or the relevant governance body in the case of Putnam-sponsored or Putnam-branded investment funds) of any material error correction that involves a guideline breach and/or reimbursement to the client, but the form and timing of this notification may differ based on the particular account and the facts and circumstances. While most errors are straightforward, and we routinely reimburse client accounts for most trade and guideline errors (to the extent they result in a loss) when they do arise, not all mistakes require compensation by the Putnam Advisers. In some cases, a third party such as the broker on the trade may take responsibility for a particular error. In addition, in some cases, an element of subjective judgment is required to determine whether an error has taken place, whether it requires compensation, and how to calculate the loss involved. With the assistance of the Compliance Department and other relevant professionals, the Putnam Advisers carefully review errors to determine whether we have breached our standard of care and, if so, what compensation may be due. In cases where a correction of an error results in a net gain, the client retains that gain. Clients should also be aware that the need to review a guideline or relevant portfolio restriction (including an applicable law) carefully may in some cases create a potential opportunity cost. The Putnam Advisers and their affiliates sometimes choose, as a prudential matter, to limit certain accounts from trading in a particular instrument while reviewing and interpreting relevant law or contractual limitations or, where necessary, notifying the client and, in certain cases, obtaining client consent, and this delay could cause some accounts to miss investment opportunities. In certain situations where a Putnam Adviser is unable to confirm with confidence that a particular account is permitted to invest in a particular opportunity, or where client notification or consent is needed, but cannot practically be arranged in a timely manner, the Putnam Adviser may be unable to proceed with the investment for that account, even if other clients do participate. Because any such delay or missed investment opportunity arises from the need to ensure guideline compliance, the Putnam Advisers do not regard these situations as errors. Item 12: Brokerage Practices BEST EXECUTION 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 broker-dealers can provide best execution, (iii) evaluation of the execution capabilities of, and the 37 Putnam Investment Management,  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 broker-dealers, 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. PIM’s traders 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 38 Putnam Investment Management,  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 39 Putnam Investment Management,  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. Directed Brokerage: Client Counterparty Limits Clients may request that Putnam execute transactions through a specified broker-dealer in order to recapture commissions or obtain other products or services for their accounts. This kind of direction (“directed brokerage”) is subject to best execution. As a condition to accepting direction from a client, Putnam generally requires assurances that the client is receiving services of value and a description of such services. Consistent with SEC guidelines, Putnam may disaggregate directed brokerage trades from the trades for our other client accounts when Putnam believes disaggregation is necessary or advisable to avoid disadvantaging other clients. Disaggregated trades may be transacted after other client trades in a specific security and executed at prices and for commission rates that may be less advantageous than those of aggregated trades. Some clients may limit the counterparties with which Putnam can place account trades by imposing additional restrictions (such as a client specific approved broker list) beyond the requirements of Putnam’s own counterparty policies. Clients should be aware that limitations of this kind have the potential to affect trade execution and impact performance. 40 Putnam Investment Management,  Equity Allocation Policies In general, Putnam allocates market equity trades pro rata among clients based on the relative size of orders for a security placed by portfolio managers for each account. The Trading Department manages the flow of orders to the securities markets with the objective of minimizing market impact. Subject to specific client instructions or portfolio needs, the Trading Department may choose to take several days to implement an order. All clients trading a security in any day will (within a block order) normally receive the average price received or paid by all Putnam clients for the day. Putnam maintains separate "program" and "block trading" desks for equities. Block trading represents normal trading within the equity marketplace. Program trades are typically highly structured trades of a large number of transactions at one time. These desks normally operate independently. In some circumstances, the same security may be traded on the Program and block trading desks on the same day at a different price. Generally, if the Trading Department believes that the securities in a program trade are material to the block trade, securities in the program trade will be withdrawn from the program trade and included in the block trade. Smaller trades for a client account, which the Trading Department believes will not have a significant market impact or otherwise materially affect execution, are not subject to these procedures. These smaller trades may be executed independently of the Trading Department’s primary trading desk, or, if executed through the primary trading desk, may receive varying allocations intended to reduce the administrative burden on Putnam and its clients’ custodian banks. As a non-discretionary adviser to wrap fee “model provider” programs, PIM will release its model portfolio holdings information to the sponsor consistent with sponsor procedures. In some cases, PIM provides information on its model portfolio holdings on a daily basis. PIM communicates changes to the model portfolios to the sponsor or overlay managers and the sponsor or overlay manager is solely responsible for adjusting existing model provider program accounts to conform to model portfolio changes. All trades within the model provider program are executed by the sponsor or overlay manager, as the case may be, with the broker dealer of their choice, based on their judgment. As such, the sponsor or overlay manager has sole responsibility for pursuing best execution for wrap fee accounts. For Retail SMA accounts, PIM communicates changes to the Retail SMA portfolios to the relevant SMA Service Provider, and the SMA Service Provider is responsible for executing the necessary trades with the Program Sponsor (or the Program Sponsor’s designated broker). In the case of trades that require multiple trading days for Putnam’s own trading desk to complete on behalf of other Putnam clients, Putnam may treat each day’s activity as representing a partial model revision. As a result, Putnam may transmit the model portfolio revision to the SMA Service Provider over consecutive trading days in proportion to Putnam’s completion of the order for other Putnam clients. At times, some sponsors or overlay managers may place transactions pursuant to PIM’s model portfolio recommendations and the SMA Service Provider may place transactions pursuant to PIM’s instructions for Retail SMA accounts after or at the same time that PIM places the same or a similar transaction as a discretionary investment manager, for the benefit of its other Putnam client accounts. This process could result in varying levels of execution for wrap fee accounts and Retail SMA accounts versus other clients and could lead to competing orders for the same security in the market, potentially harming execution quality. This may also have an adverse effect on the prices paid or received in the market for such transactions and, as a result, some accounts may experience a short-term benefit or detriment. The actual percentage weighting of each holding in a model may vary from the percentage weighting held by accounts managed in accordance with that model. For wrap fee “model provider” programs and Retail SMA programs, in order to treat all clients fairly and equitably, PIM provides updated models to the sponsor or overlay manager, or, in the case of Retail SMAs, to Vestmark, concurrently with the receipt of orders on the trading desk for the model portfolio and other funds and accounts in the same strategy or in line with the sponsor or overlay manager’s or Retail SMA Program Sponsor’s delivery requirements (e.g. accepting instructions or recommendations only once daily or only during particular times of 41 Putnam Investment Management,  the day). In addition, Putnam has implemented policies and procedures designed to promote equitable treatment of trading by model SMA accounts, Retail SMA accounts and other client accounts by, among other things, monitoring the cross-over of issuer names and/or holdings between model provider accounts, Retail SMA accounts and any managed accounts managed using a substantially similar strategy. To the extent an investment strategy is used in an SMA program and in one or more Putnam client accounts that are structured as pooled investment vehicles (each, a “Comparable Putnam Pooled Vehicle” and collectively, the “Comparable Putnam Pooled Vehicles”), the manner in which such investment strategy is implemented for use in such SMA program may, for a variety of reasons, differ from how that same investment strategy is implemented by Putnam for use in connection with the relevant Comparable Putnam Pooled Vehicle. For example, the model portfolio supplied by Putnam for an SMA program might not include non-U.S. traded securities that are held by the applicable Comparable Putnam Pooled Vehicle(s). Likewise, the model portfolio supplied by Putnam for such an SMA program may not include every security held by the relevant Comparable Putnam Pooled Vehicle in the event the SMA program is significantly smaller than such Comparable Putnam Pooled Vehicle in terms of net assets. In addition, Putnam undertakes “active risk” assessments comparing the Putnam U.S. Small Cap Growth Equity and Putnam U.S. Small Cap Value Equity SMA programs to Putnam Small Cap Growth Fund and Putnam Small Cap Value Fund, respectively, with the goal of seeking to achieve performance for the relevant SMA program that is comparable to that of such Comparable Putnam Pooled Vehicle while avoiding excessive model change trades for the Putnam U.S. Small Cap Growth Equity and Putnam U.S. Small Cap Value Equity SMA programs. Therefore, Putnam will only transmit updated investment instructions or recommendations for those programs when Putnam deems there to have been a “model change” to such an account. Putnam monitors for model changes daily by comparing the “active risk” between the Putnam U.S. Small Cap Value Equity SMA program and Putnam Small Cap Value Fund and by comparing the “active risk” between the Putnam U.S. Small Cap Growth Equity SMA program and Putnam Small Cap Growth Fund. When the “active risk” for the Putnam U.S. Small Cap Value Equity SMA program relative to Putnam Small Cap Value Fund or the “active risk” for the Putnam U.S. Small Cap Growth Equity SMA program relative to Putnam Small Cap Growth Fund exceeds a threshold deemed by Putnam to be sufficient to justify a “model change,” the model for Putnam U.S. Small Cap Growth Equity or Putnam U.S. Small Cap Value Equity, as applicable, will be adjusted to reduce “active risk.” In situations in which Putnam has decided to implement a model change based upon the “active risk” threshold described above, Putnam will have transmitted trade orders on behalf of Putnam Small Cap Growth Fund or Putnam Small Cap Value Fund and other substantially similar Putnam-advised accounts, as applicable, prior to submitting transmitting model changes for the Putnam U.S. Small Cap Growth Equity or Putnam U.S. Small Cap Value Equity SMA programs, respectively. Given that values of investments change with market conditions, this could cause an SMA program’s return to be lower than if such trade orders for Putnam Small Cap Growth Fund or Putnam Small Cap Value Fund and other substantially similar Putnam-advised accounts, as applicable, had been affected simultaneously with such model changes for the applicable SMA program. When a portfolio security is added to Putnam Small Cap Growth Fund or Putnam Small Cap Value Fund, as applicable, or completely eliminated from Putnam Small Cap Growth Fund or Putnam Small Cap Value Fund, as applicable, Putnam’s goal is to transmit the initial trade adding a new position to such Fund, or the last trade entirely deleting a position from such Fund, at the same time it transmits: (i) model changes for Putnam U.S. Small Cap Growth Equity or Putnam U.S. Small Cap Value Equity, as applicable, and (ii) trade orders, investment instructions, or investment recommendations for any other substantially similar Putnam-advised accounts. Putnam actively monitors the performance of Putnam U.S. Small Cap Growth Equity or Putnam U.S. Small Cap Value Equity versus that of the corresponding fund to confirm that the above-stated goal of the “active risk” assessments is being achieved. For the foregoing reasons, the performance of a particular model SMA program that is managed in accordance with a particular Putnam investment strategy will likely differ from the performance of the Comparable Putnam Pooled Vehicles and other model SMA programs that employ substantially similar Putnam investment strategies. In addition, Putnam cannot control the market impact of any transactions effected on behalf of a model SMA program because it does not have trading authority or discretion with respect to such model SMA programs. Putnam has adopted procedures to manage trading in derivatives whose underlying security is also currently being traded. When derivatives trading is both regarded as significant by the Trading Department and is in the same direction as the securities trading, (for example, both are going “long” or trading to gain exposure to an 42 Putnam Investment Management,  issuer), trading activity is allocated between securities and derivatives trading based on the ratio of the size of the securities trade pending to the notional value of the derivatives trade adjusted by the latter’s “delta” (the relationship of the value of the option or other derivative to movements in the underlying security’s price). The Trading Department will normally alternate between the securities and derivatives desks (with the larger order trading first), completing a portion of one desk’s trades and then permitting the completion of an equal percentage of the second desk’s trades. Syndicate Allocation Policy As a general policy, if the orders of all Putnam clients seeking to participate in an underwritten offering of equity securities cannot be satisfied by the total allocation made available to Putnam clients by the underwriters, shares will be allocated among the Putnam clients based on their total assets (the "General Policy"), subject to the following exceptions: The General Policy may be modified in the case of regional or specialty funds in offerings of securities which fall within the special focus of those funds. In those cases, the regional or specialty funds may be weighted at 150% of assets for purposes of the allocation, provided that the allocations to those funds may not be increased above 50% of the amount allocated to Putnam by the incremental weighting. A specialty or regional account is one that focuses on a relatively narrow area of the overall securities markets. For example, a European equity fund is a specialty account as to equities of European corporations and a utilities fund is a specialty account for offerings of utilities companies. The Putnam Trading Department, with the approval of the Compliance Department, approves categories of specialty accounts. In some circumstances, exceptions may be made to these policies to permit Putnam clients with relatively smaller total assets to participate more meaningfully in underwritten offerings of equity securities. Before an exception is made, Putnam will ensure that the exception will produce an allocation that is fair and equitable to the Putnam client accounts seeking to participate in the offering, taking into consideration the portfolio composition of such accounts, allocation of previous offerings, and other relevant factors. If an exception is made, some accounts participating in the offering may receive a smaller allocation of securities than they would have otherwise. Underwritten offerings of convertible fixed income instruments (convertible bonds and preferred shares) are subject to the same procedures as equities unless the only accounts participating in the offering are convertible and high yield fixed income accounts. In that case, allocation of convertible instruments is subject to the fixed income allocation procedures described below. In secondary offerings of equity securities, Putnam may allocate securities among participating client accounts of a portfolio manager so that each account holds as close to the same relative amount of the security as a percentage of net assets as possible. Putnam will first calculate the number of shares to which the participating client accounts of the portfolio manager would be entitled based upon the offering allocation policies described above (the "allotted shares"). Putnam will then allocate the allotted shares among participating client accounts of the portfolio manager so that, to the extent possible, each of the participating client accounts would hold the same relative amount of the security as a percentage of net assets. Foreign Currency Transactions Accounts that invest outside their base currency typically require the execution of foreign currency exchange (FX) transactions. In some cases, where two Putnam client accounts have matching currency needs (for example, one client must purchase $10 million in Euro and another must sell $15 million in Euro) and the other details of the required trades match, we will execute a net transaction by submitting only one order (to sell $5 million in Euro) to the relevant broker- dealer. Net transactions of this type do not constitute a cross-trade as described in Item 11. Putnam executes most material FX transactions, including trades required to complete security purchases and sales as well as standalone FX trades, with third party brokers through its currency desk. These trades are 43 Putnam Investment Management,  subject to Putnam’s best execution policies, which are described in this Item 12. In some circumstances described below, Putnam does not perform FX trading due to practical and legal impediments. First, local currency controls or other regulations in some countries, primarily in emerging markets, permit only a locally licensed firm such as a local sub-custodial bank to execute FX transactions, or otherwise make it impracticable for Putnam to execute FX transactions. In these countries, Putnam does not provide FX trading of any kind. Instead, the client’s or fund’s custodial bank (through a sub-custodial affiliate or third- party sub-custodian) generally executes the necessary FX transactions. Second, for operational and administrative reasons, Putnam will direct a client’s custodian bank to repatriate all non-U.S. dollar portfolio income (such as dividends or bond interest payments), regardless of the country or market of origin, to the operating currency of the account. Income transactions are typically not material to a client account, and these transactions may as a general matter benefit from aggregation with other small transactions by a custodial bank. In each of these cases, because the counterparty executing FX trades is the client’s custodian, the client generally negotiates fees/commission rates on transactions executed by such custodian. Unless otherwise discussed and agreed with the client, Putnam does not evaluate the FX execution services provided by the custodian to its client. Clients interested in more information on FX execution should speak with their Putnam client service manager. Currency Allocation Policies To ensure that all accounts with an active currency management strategy are treated fairly, all trades that share a common currency and direction are traded as a block regardless of account strategy or base currency of the account. Typically, allocations are based on the initial client order. A general exception to block trading occurs in the instance of particular accounts that have restrictions in place limiting trading activity to specific counterparties. In general, the largest trading block, which is comprised of accounts with no counterparty restrictions, is traded first. Smaller blocks, which are comprised of accounts that cannot trade with the large block counterparty but are allowed to trade with multiple counterparties, are traded second. The final accounts to be traded are those restricted to a single counterparty. These single counterparty accounts are rotated in order of execution on a reasonable efforts basis. Futures and Swaps Allocation Policies Under CFTC rules, Putnam maintains procedures and policies on allocation of bunched orders for futures and swaps subject to the CFTC’s jurisdiction (which include certain swaps, options and foreign exchange forwards). When Putnam wishes to place parallel orders for futures or swaps transactions for multiple clients, Putnam normally submits combined or “bunched” orders instead of separate orders on behalf of each client. Doing so generally increases the efficiency and timeliness of order placement, thereby facilitating best execution. Putnam’s procedures are designed to ensure that no eligible client account is favored over any other client. Putnam allocates any purchases or sales in a bunched order on a pro-rata basis based on order size to the client accounts in proportion to the size of the order placed for each account. If more than one execution is required, it may be possible to average the price of the fills. If the fills are average priced, each account participating in the order will receive the same price for the day. If it is not possible to average price, Putnam allocates the fills pro-rata to ensure equitable distribution of prices. Except in limited cases, trades are allocated at Putnam at the time of execution. Putnam submits the specific allocation to the futures commission merchant clearing trades (or the counterparty, or swap execution facility, as applicable) by the end of the day or as otherwise required by CFTC rules. In accordance with applicable CFTC regulations permitting post execution notification to the futures commission merchant or trade counterparty of allocation of bunched orders, clients whose accounts use futures or swaps are entitled to review the general nature of the allocation methodology, whether any 44 Putnam Investment Management,  interested accounts are included in such orders, and summary or composite data to compare a client’s results on bunched order transactions with those of other clients participating in such transactions. This information is available to clients upon request. Item 13: Review of Accounts The Putnam Advisers’ portfolio managers generally review client portfolios daily with the assistance of portfolio associates/trading assistants who review and coordinate portfolio trading. These investment professionals use computer analyses which are prepared daily to monitor portfolio composition. Any material issues identified during the portfolio review are addressed by the portfolio manager and escalated to their group head or Chief Investment Officer, as appropriate. The number of accounts that each portfolio manager is responsible for varies from portfolio manager to portfolio manager. For most accounts, analysis of portfolio risk and attribution is also run daily. In addition, the Franklin Templeton Compliance Department tests each portfolio daily for compliance with various investment guidelines and restrictions through its automated system or, in cases where rules cannot be automated, through frequent manual processes. In addition to internal reviews, Putnam also reviews portfolios with its clients. Formal client meetings generally are held on a face-to-face basis, video conference or by telephone annually, or more frequently at client request; in addition, informal meetings and video/telephone discussions take place throughout the year. The portfolio manager, the account manager and/or other senior investment or management personnel, as appropriate, attend client review meetings. From time to time, investment personnel may share their general views of economic conditions, markets, asset allocation matters, industries, or issuers as part of client reviews or other client or prospect meetings; however, these views are informal, and should not be relied on as the basis for any investment decision. Upon specific request, investment personnel may also present risk and stress test scenarios on a financial advisor's or other party’s investment portfolio. This analysis is for informational purposes only, is not investment advice and is not customized or individualized based on a client’s particular needs. A Putnam Adviser is not acting as a fiduciary under applicable law in providing this type of analysis. In addition, client service managers are assigned to meet the individual reporting and administration requirements of each client. Client service managers work with account managers and relevant internal experts to provide additional attention and responsiveness to day-to-day client requests. With respect to the Putnam Funds, the Putnam Advisers and affiliates supply the Trustees of the Putnam Funds with periodic reports covering such subjects as portfolio structure and performance data, and such other information as the Trustees may reasonably require. Representatives of the Putnam Advisers also meet frequently with the Trustees of the Putnam Funds, or committees of the Trustees, to review portfolio performance, compliance and regulatory matters, and other matters of interest to the Trustees. Item 14: Client Referrals and Other Compensation 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 an 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 45 Putnam Investment Management,  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 broker-dealer or its representatives, on behalf of such broker-dealer or its representatives, or to which such broker-dealer or its affiliates provides professional services. With respect to SMA Program clients, PIM receives fees, directly or indirectly, from the sponsor of the SMA Program for all services rendered by PIM to the SMA Program clients including, on occasion, out of the sponsor’s own resources. As such, PIM may be considered to receive cash compensation from a non-client in connection with giving advice to SMA Program clients. Similarly, in certain cases where a Putnam Adviser serves as a sub-adviser, the Putnam Adviser will, from time to time, receive advisory fees from the primary investment manager rather than directly from the investment advisory client. In certain arrangements, including in model delivery programs offered by Sponsors of SMA Programs, the applicable Adviser or its affiliate pays the Sponsor or its affiliate various fees in connection with the model delivery program, such as model set up, onboarding and maintenance fees, tax-related analysis fees and data analytics fees allowing for the delivery of the model portfolio on the Sponsor’s platform. 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. Item 15: Custody 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. 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. Item 16: Investment Discretion 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 46 Putnam Investment Management,  • 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. In addition to the situations above, 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. PIM’s management of the Putnam Funds is subject to the ongoing oversight of the Putnam Funds’ Trustees, including policies that they may from time to time establish. PIM consults with the Trustees on a variety of significant matters relating to the Putnam Funds, including some strategic investment matters. 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. 47 Putnam Investment Management,  Item 17: Voting Client Securities 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 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. 48 Putnam Investment Management,  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 Putnam vote proxies under proxy guidelines which vary from the Guidelines or may wish to direct Putnam’s vote on a particular matter. There may be legal limits on a client’s ability to direct Putnam as to proxy voting and on Putnam’s ability to follow such instructions. Putnam 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 Funds and other legacy Putnam accounts managed by Franklin Templeton Investment Solutions, Putnam may vote any referred items on securities held solely in such accounts (and not held by any other investment product team at Putnam) 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) the opportunity to review the referred items and vote on them if they so choose. If the portfolio manager(s) 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 in the Putnam Equity group. 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. 49 Putnam Investment Management,  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. The board of directors has the important role of overseeing management and its performance on behalf of shareholders. When evaluating a company’s board, Putnam may consider the diversity of professional backgrounds and personal characteristics. Putnam believes that companies generally benefit from diversity 50 Putnam Investment Management,  on the board, including diversity with respect to gender, ethnicity, race, skills, perspectives and experience. Putnam will vote on a case-by-case basis and may consider voting against the Nominating Committee Chair if there is a lack of evidence of board diversity. Board independence depends not only on its members’ individual relationships, but also the board’s overall attitude toward management. Putnam believes that independent boards generally are committed to good corporate governance practices and, by providing objective independent judgment, enhance shareholder value. Putnam may withhold votes on a case-by-case basis from some or all directors that, through their lack of independence, have failed to observe good corporate governance practices or, through specific corporate action, have demonstrated a disregard for the interest of shareholders. Putnam will normally vote on a case-by-case basis in contested elections of directors. Executive Compensation Putnam will normally vote on a case-by-case basis on proposals relating to executive compensation. However, where the board of directors meets appropriate independence standards, Putnam will vote for stock option and restricted stock plans that will result in an average annual dilution of 1.67% or less (based on the disclosed term of the plan and including all equity-based plans). Putnam will vote against stock option and restricted stock plans that will result in an average annual dilution of greater than 1.67% (based on the disclosed term of the plan and including all equity plans). Putnam will vote against any stock option or restricted stock plan where the company's actual grants of stock options and restricted stock under all equity-based compensation plans during the prior three (3) fiscal years have resulted in an average annual dilution of greater than 1.67%. Putnam may review plans on a case-by-case basis where average annual dilution cannot be calculated. Whatever the composition of the board, Putnam will review proposals to reprice options on a case-by-case basis if specific criteria are met. Putnam will vote against stock option plans that permit replacing or repricing of underwater options and will vote against stock option plans that permit issuance of options with an exercise price below the stock’s current market price. Putnam will also vote against stock option plans/ restricted stock plans with evergreen features providing for automatic share replenishment. Putnam may vote against executive compensation proposals on a case-by-case basis where compensation is excessive by reasonable corporate standards, where a company fails to provide transparent disclosure of executive compensation, or where Putnam would otherwise be withholding votes for the entire board of directors. In voting on proposals relating to executive compensation, Putnam will consider whether the proposal has been approved by an independent compensation committee of the board. Additionally, Putnam will generally vote in favor of the annual presentation of advisory votes on executive compensation (“say on pay”). Putnam will generally vote for advisory votes on executive compensation but will generally vote against an advisory vote if the company fails to effectively link executive compensation to company performance according to benchmarking performed by the independent proxy voting service provider. Putnam will vote against proposals regarding severance agreements between a company and executives where the company has adopted a policy to seek advisory shareholder approval of agreements, plans or policies that would provide for severance compensation in excess of 299% of an executive officer’s base salary and annual target bonus. Acquisitions, Mergers and Similar Transactions Putnam will normally evaluate business transactions such as acquisitions, mergers, reorganizations involving business combinations, liquidations and sale of all or substantially all of a company’s assets, on a case-by-case basis. Putnam will vote on a case-by-case basis on proposals seeking to change a company’s state of incorporation. However, Putnam will vote for mergers and reorganizations involving business combinations designed solely to reincorporate a company to Delaware. Anti-Takeover Provisions Putnam will normally vote against proposals to adopt anti-takeover measures such as supermajority voting provisions, issuance of blank check preferred stock (except for REITs where measures will be voted on a case- 51 Putnam Investment Management,  by-case basis) and the creation of a separate class of stock with disparate voting rights. However, Putnam will vote on a case-by-case basis on proposals to issue blank check preferred stock if appropriate “de-clawed” language is present (appropriate de-clawed language will include cases where the company states that it will not use preferred stock for anti-takeover purposes, or in order to implement a shareholder rights plan, or discloses a commitment to submit any future issuances of preferred stock to be used in a shareholder rights plan/anti-takeover purpose to a shareholder vote prior to its adoption.). Additionally, Putnam will vote on a case-by-case basis on proposals to ratify or approve shareholder rights plans (commonly referred to as “poison pills”) and on proposals to adopt fair price provisions. Putnam will normally oppose classified boards except in special circumstances where having such a board would be in shareholders’ best interests. Shareholder Proposals, including on Environmental & Social Issues Shareholder proposals are non-binding votes that are often opposed by management. Some proposals relate to matters that are financially immaterial to the company’s business, while others may be impracticable or costly for a company to implement. At the same time, well-crafted shareholder proposals may serve the purpose of raising issues that are material to a company’s business for management’s consideration and response. Putnam seeks to weigh the costs of different types of proposals against their expected financial benefits. More specifically, Putnam will normally vote in accordance with the recommendation of the company’s board of directors on shareholder proposals unless the proposal reflects specific policies enumerated in the Guidelines. For example, Putnam will normally vote in favor of shareholder proposals to declassify a company’s board, require shareholder approval of shareholder rights plans. Additionally, Putnam will normally support proposals requiring the Chairman’s position be filled by an independent director, unless the board has an independent lead-director and Putnam is supporting the nominees for director, in which case Putnam will vote on a case-by-case basis. Putnam believes that sustainable environmental practices and sustainable social policies are important components of long-term value creation. Companies should evaluate the potential risks to their business operations that are directly related to environmental and social factors (among others). In evaluating shareholder proposals relating to environmental and social initiatives, Putnam takes into account (1) the relevance and materiality of the proposal to the company’s business, (2) whether the proposal is well crafted (e.g., whether it references science-based targets, or standard global protocols), and (3) the practicality or reasonableness of implementing the proposal. Putnam may support well-crafted and well-targeted proposals that request additional reporting or disclosure on a company’s plans to mitigate risk to the company related to the following issues and/or their strategies related to these issues: Environmental issues, including but not limited to, climate change, greenhouse gas emissions, renewable energy, and broader sustainability issues; and social issues, including but not limited to, fair pay, employee diversity and development, safety, labor rights, supply chain management, privacy and data security. Putnam will consider factors such as (i) the industry in which the company operates, (ii) the company's current level of disclosure, (iii) the company's level of oversight, (iv) the company’s management of risk arising out of these matters, (v) whether the company has suffered a material financial impact. Other factors may also be considered. Putnam will consider the recommendation of its third-party proxy service provider and may consider other factors such as third-party evaluations of ESG performance. Putnam will vote on a case-by-case basis on proposals relating to a company’s use or potential use of artificial intelligence tools or applications. Additionally, Putnam may vote on a case-by-case basis on proposals which ask a company to take action beyond reporting where a third-party proxy service provider has identified one or more reasons to warrant a vote FOR. 52 Putnam Investment Management,  Non-U.S. Companies Putnam recognizes that the laws governing non-U.S. issuers will vary significantly from U.S. law and from jurisdiction to jurisdiction. It may not be possible or even advisable to apply the Guidelines mechanically to non-U.S. issuers. However, Putnam believes that shareholders of all companies are protected by the existence of a sound corporate governance and disclosure framework. Accordingly, Putnam will seek to vote proxies of non-U.S. issuers in accordance with the Guidelines where applicable. Many non-U.S. jurisdictions impose significant burdens on voting proxies. For example, some jurisdictions require that shares must be frozen for specified periods of time to vote via proxy (“share blocking”) or that shares must be reregistered out of the name of the local custodian or nominee into the name of the client for the meeting and then reregistered back. In addition, other practical administrative challenges, such as late receipt of ballots and other information, often impact Putnam’s normal voting process. Putnam’s policy is to weigh the benefits to clients from voting in these jurisdictions against the detriments of doing so. For example, in a share blocking jurisdiction, it will normally not be in a client’s interest to freeze shares simply to participate in a non-contested routine meeting. More specifically, Putnam will normally not vote shares in non-U.S. jurisdictions imposing burdensome proxy voting requirements, except in significant votes (such as contested elections and major corporate transactions) where directed by portfolio managers. Putnam maintains additional policies for specific non-U.S. markets. In rare cases, Putnam’s voting rights may also be directly limited by non-U.S. law. For example, some countries limit aggregate foreign ownership of companies in particular industries (such as aviation or energy) due to economic or security concerns. Where this limit is exceeded, shares held by foreign investors, including Putnam, may not carry voting rights. More Information Putnam will make its reasonable best efforts to vote all proxies except when impeded by circumstances that are reasonably beyond its control and responsibility. This may happen when the custodian makes an error or the client has not established robust custodial proxy voting services. Putnam also does not recall shares on loan to vote proxies. Putnam may also determine to waive its voting rights or to enter into a voting agreement in connection with some specific equity investments, including privately placed securities. In these situations, the voting policy described above will not apply. For more information, please see Item 8. Clients who want more information about Putnam’s proxy voting policies, including a copy of the Guidelines and related policies or a statement of how proxies were voted for the client’s account, should contact their account executive or client service manager. Item 18: Financial Information Not applicable. 53 Putnam Investment Management,