Item 2. Code of
Ethics
As of the end of the
period covered by this report, the registrant has adopted a code of ethics that
applies to the registrant’s principal executive officer, principal financial
officer, principal accounting officer or controller, or persons performing
similar functions. There were no amendments made to or waivers granted under the
code of ethics during the period covered by this report. The registrant’s code
of ethics is filed herewith pursuant to Item 19(a)(1) of this Form N-CSR.
Item 3. Audit Committee
Financial Expert
Registrant’s board of
trustees has determined that Robert J. Chersi, an independent trustee, is the
Audit Committee Financial Expert.
Item 4. Principal
Accountant Fees and Services
(a)
Audit
Fees
The aggregate fees billed by registrant’s independent public accountants,
PricewaterhouseCoopers LLP (“PwC”), for each of the last two fiscal years for
professional services rendered in connection with the audit of registrant’s
annual financial statements or services that are normally provided by the
accountant in connection with statutory and regulatory filings or engagements
were $162,950 for the year ended October 31, 2024 and $139,160 for the year
ended October 31, 2025.
(b)
Audit-Related
Fees
The aggregate fees PwC billed to registrant for each of the last two fiscal
years for assurance and other services that are reasonably related to the
performance of registrant’s audit and are not reported under Item 4(a) were $0
for the year ended October 31, 2024 and $0 for the year ended October 31,
2025. The aggregate fees PwC billed to registrant’s investment adviser and
any entity controlling, controlled by, or under common control with registrant’s
investment adviser for assurance and other services directly related to the
operations and financial reporting of registrant were $0 for the year ended
October 31, 2024 and $0 for the year ended October 31, 2025.
(c)
Tax
Fees
The aggregate tax fees PwC billed to registrant for each of the last two fiscal
years for tax compliance, tax advice and tax planning services were $53,295 for
the year ended October 31, 2024 and $53,035 for the year ended October 31,
2025. These fees include payments for tax return compliance services,
excise distribution review services and other tax related matters. The
aggregate tax fees PwC billed to registrant’s investment adviser and any entity
controlling, controlled by, or under common control with registrant’s investment
adviser for services directly related to the operations and financial reporting
of registrant were $0 for the year ended October 31, 2024 and $0 for the year
ended October 31, 2025.
(d)
All Other
Fees
The aggregate fees PwC billed to registrant for each of the last two fiscal
years for products and services provided, other than the services reported in
paragraphs (a) through (c) of this item, were $0 for the years ended October 31,
2024 and October 31, 2025. The aggregate fees PwC billed to registrant’s
investment adviser and any entity controlling, controlled by, or under common
control with registrant’s investment adviser for products and services provided,
other than the services reported in paragraphs (a) through (c) of this item,
were $0 for the year ended October 31, 2024 and $0 for the year ended October
31, 2025. These figures are also reported in response to item 4(g)
below.
(e)
Registrant’s
audit committee charter provides that the audit committee (comprised of the
independent Trustees of registrant) is responsible for pre-approval of all
auditing services performed for the registrant. The audit committee also is
responsible for pre-approval (subject to the de minimis exceptions for
non-audit services described in Section 10A(i)(1)(B) of the Securities Exchange
Act of 1934) of all non-auditing services performed for the registrant or an
affiliate of registrant. In addition, registrant’s audit committee charter
permits a designated member of the audit committee to pre-approve, between
meetings, one or more audit or non-audit service projects, subject to an expense
limit and notification to the audit committee at the next committee meeting.
Registrant’s audit committee pre-approved all fees described above that PwC
billed to registrant.
(f)
Less than 50% of
the hours billed by PwC for auditing services to registrant for the fiscal year
ended October 31, 2025 were for work performed by persons other than full-time
permanent employees of PwC.
(g)
The aggregate
non-audit fees billed by PwC to registrant and to registrant’s investment
adviser and any entity controlling, controlled by, or under common control with
registrant’s investment adviser for the fiscal years ending October 31, 2024 and
October 31, 2025 were $0 for each respective year. These figures are also
reported in response to item 4(d) above.
(h)
Registrant’s
audit committee has considered the non-audit services provided to the registrant
and registrant’s investment adviser and any entity controlling, controlled by,
or under common control with registrant’s investment adviser as described above
and determined that these services do not compromise PwC’s
independence.
(i)
Not applicable.
(j)
Not applicable.
Item 5. Audit Committee
of Listed Registrants
(a)
Not applicable.
(b)
Not applicable.
Item 6.
Investments
(a)
Registrant’s
Schedules of Investments are included in the financial statements filed under
Item 7 of this Form N-CSR.
(b)
Not
applicable.
Item 7. Financial
Statements and Financial Highlights for Open-End Management Investment
Companies
The registrant’s
audited financial statements and financial highlights as of the end of the
period covered by this report are included in this Form N-CSR.
