Corporate Behavior

Eaton Vance has a longstanding commitment to ethical business practices and responsible investing. The Company seeks to contribute positively to the communities in which it does business and to society as a whole.

Responsible Investing

The commitments to responsible investing made by the Company’s investment affiliates position us to address the needs of the growing number of investors who seek more from their investments than financial returns. We include consideration of environmental, social and governance (ESG) factors in our evaluation of investment opportunities and in the construction of the investment portfolios we manage. In our discretionary decision-making processes, we focus on ESG criteria that we consider financially material, which we define as ESG risks or opportunities deemed likely to affect the financial condition or performance of the issuer over the long term. Additionally, our range of responsible investing capabilities also include offering proprietary portfolio construction techniques to create customized portfolios that reflect client concerns and priorities.

Each investment affiliate within Eaton Vance follows its own approach to responsible investing. At the corporate level, we add value by enabling collaboration to create better investment outcomes and to expand the range of responsible investment offerings we make available to clients. Eaton Vance strives to be a leader in responsible investing. To us, that means recognizing – and respecting – that responsible investing means different things to different people. Eaton Vance offers clients a diversity of approaches to responsible investing that leverage and combine the distinctive strengths of our investment affiliates. Detailed information on responsible investing at Eaton Vance can be found here.

Responsible Business Practices

Human Capital Management

Hiring, developing and retaining highly talented individuals across functional areas is critical to the Company’s long-term success. Our human capital management strategy focuses on optimizing organizational talent to deliver value to our clients and business partners. We are committed to providing a challenging, productive and healthy environment for our employees, and are proud to be among the small group of employers to be recognized by The Boston Globe as one of the Top Places to Work in Massachusetts for 11 of the past 12 years.

Corruption and Instability

Anti-Corruption Policy

Eaton Vance has established anAnti-Corruption Policy that applies to all directors, officers, other employees and agents acting on the Company’s behalf. This policy was developed to ensure that Eaton Vance employees and other Company representatives adhere to ethical practices and that Eaton Vance strictly complies with the U.S. Foreign Corrupt Practices Act, the U.K. Anti-Bribery Act and all other applicable laws against bribery and other improper payments to government officials or other persons anywhere in the world. This policy is overseen by the Company’s chief legal officer, who reports to the Board on any material violation of this policy of which he is aware.

Business Continuity Program

Eaton Vance takes seriously its fiduciary responsibilities to clients and shareholders, not only for investment performance, but also in terms of business continuity should events arise causing interruption of normal operations. Eaton Vance has developed a Business Continuity Program to help reduce the likelihood of a business interruption and to mitigate the impact in the event a business interruption does occur.

Eaton Vance Business Continuity Plans are designed to enable the Company to respond effectively to business-interrupting events of varying scope – from minor incidents to the complete loss of a facility and/or data center. Business Continuity Plans document data requirements and backup methods, mission critical applications, financial and operational assessments, alternate communications to clients, business partners and employees, alternate work locations for employees, critical service provider impacts and actions, and, where applicable, regulatory reporting.

Eaton Vance’s Business Continuity Plans and associated capabilities are designed to ensure that access to funds and account information are not affected under most circumstances. To access your accounts, either call 1-800-262-1122 or login here. Please note that extreme circumstances beyond our control may affect our ability to service clients.

Risk Management

Our Board has principal responsibility for oversight of the Company’s risk management processes. Most of our directors have professional experience in risk management and compliance oversight. The Board reviews and discusses with senior management the most significant risks facing the Company and receives updates from Board committees related to specific risks and risk processes, as further described below. Regular operational, financial and legal updates provided by the Company’s CEO, chief financial officer, chief accounting officer and chief legal officer facilitate coordination of the Board’s risk oversight function.

The Board’s Audit Committee has primary responsibility for the oversight and evaluation of the integrity of the Company’s financial reporting processes, including the effectiveness of internal controls, the Company’s compliance with legal and regulatory requirements, the qualifications, independence and performance of the Company’s independent registered public accounting firm and the performance of the Company’s internal audit department. The Audit Committee accomplishes these tasks by receiving regular reports from our chief financial officer, chief legal officer, chief information officer, chief accounting officer and the director of internal audit, as well as updates from the Company’s independent registered public accounting firm. Throughout the year, our Audit Committee also meets in executive session with the Company’s independent registered public accounting firm.

A commitment to integrity and ethical business practices is critical for the long-term health of any business. Eaton Vance holds these principles as paramount, and has developed and is implementing policies and procedures that seek to ensure an ethical approach to business is followed consistently by all Eaton Vance employees. Eaton Vance further promotes ethical practices throughout the Company by offering ongoing ethics training, creating an atmosphere where employees are comfortable speaking up about ethical issues and promoting a culture of strict compliance with industry standards of business conduct and applicable law.

Code of Business Conduct and Ethics for Directors, Officers and Employees

The Code of Business Conduct and Ethics for Directors, Officers and Employees addresses a wide range of business conduct and ethical issues. The Code was designed to focus the Eaton Vance Board and the Company’s management on areas of ethical risk, provide guidance to employees to help them recognize and deal with ethical issues, and foster a culture of honesty and accountability. All managers are responsible for communicating and implementing these policies within their areas of supervisory responsibility.

This Code guides ethical behavior at Eaton Vance in the following areas:

  • Conflicts of interest
  • Corporate opportunities
  • Confidentiality/inside information
  • Protection and proper use of corporate assets
  • Fair dealing
  • Compliance with laws and regulations
  • Illegal or unethical payments
  • Accounting and financial reporting standards
  • Outside directorships and employment
  • Political activities
  • Anti-retaliation

Code of Ethics for Principal Executive and Senior Financial Officers

The Code of Ethics for Principal Executive and Senior Financial Officers applies to the CEO, chief financial officer, chief accounting officer and treasurer of Eaton Vance. The purposes of this Code are to deter wrongdoing and to promote:

  • Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;
  • Full, fair, accurate, timely and understandable disclosure in reports and documents that the Company files with, or submits to, the Securities and Exchange Commission and in other public communications made by the Company;
  • Compliance with applicable laws and governmental rules and regulations;
  • The prompt internal reporting of violations of this Code to an appropriate person or persons; and
  • Accountability for adherence to this Code.

Code of Ethics

The Eaton Vance Code of Ethics is designed to help the Company’s employees avoid potential and actual conflicts that may arise from their actions, including personal securities transactions.

Employee Code of Conduct

The Eaton Vance Employee Code of Conduct sets forth the Company's standards of employee conduct, including a list of infractions that would result in disciplinary action, up to and including dismissal. The Employee Code of Conduct can be accessed here.

Anti-Harassment

Eaton Vance seeks to provide a safe, comfortable and inclusive workplace for all employees. Harassment of any kind is not tolerated. The Company has taken steps to define harassment and has developed an Anti-Harassment Policy aimed at identifying, preventing and addressing any incidents of harassment or a hostile or uncomfortable workplace.

All employees are responsible for complying with the Anti-Harassment Policy by reporting any instances of alleged harassment and cooperating in any investigation of alleged harassment. Complaints may be made in writing or orally and directed to an employee’s supervisor, any other supervisor or anyone in human resources, including Eaton Vance’s director of human resources. Any retaliation against an employee who has complained about harassment, or any retaliation against an employee for cooperating with an investigation of a harassment complaint, is unlawful and not tolerated by the Company.