Appendix A

• Code of Ethics
  Required for each investment adviser registered with the Commission.

• Code of Ethics
  Required for each investment adviser of a registered investment company.

• Standards of Conduct
  Required element of code of ethics.

• Standards of Conduct
  Not required.

• Compliance with Laws
  Required element of code of ethics.

• Compliance with Laws
  Not required in code of ethics.

• Limited Access to Material Nonpublic Information
  Required element of code of ethics.

• Limited Access to Material Nonpublic Information
  Not required.

• Internal Reporting of Code Violations
  Required element of code of ethics.

• Internal Reporting of Code Violations
  Not required in code of ethics.

• Employee Acknowledgment
  Employee must receive copy of code of ethics and acknowledge in writing.

• Employee Acknowledgment
  Not required.

• Personal Securities Trading Reports
  Required element of code of ethics.
   
• Reporting Personnel
  "Access Persons" — partners, officers, directors, employees, and certain controlled persons of adviser, who have access to nonpublic information about client securities transactions or recommendations, or holdings of affiliated mutual funds.
   
  
  For advisers primarily in the business of providing advice, all of an adviser's directors, officers and partners are presumed to be Access Persons.

• Reportable Securities exclude:
  
  • Direct obligations of the U.S. government;
  • Money market instruments;
    
  • Shares issued by unaffiliated open-end funds and money market funds.

• Personal Securities Reports
  
  • Initial and Annual Holdings Reports
  • Quarterly Transaction Reports

• Personal Securities Trading Reports
  Required by rule.

• Reporting Personnel
  "Access Persons" — any directors, officers, general partners of the adviser.
   
  "Advisory persons" — employees and certain control persons (and their employees) who obtain information regarding fund securities transactions or recommendations.
   
  
  For advisers not primarily in the business of advising funds or advisory clients, access persons only include directors, officers, general partners, or advisory persons, who make or who obtain information concerning, recommendations made to fund.

• Reportable Securities exclude:
• Direct obligations of the U.S. government;
• Money market instruments;
• Shares issued by open-end funds.

• Personal Securities Reports
• Initial and Annual Holdings Reports
• Quarterly Transaction and New Account Reports

• Pre-Approval of Trades
  Required for IPO and Limited Offering.

• Pre-Approval of Trades
  Required for IPO and Limited Offering.

• Recordkeeping
• Copies of codes of ethics;
• Employee acknowledgments;
• Records of violations of code and responses to violations;
• List of access persons;
• Holdings and transaction reports (electronically);
• Record of adviser's approval of investments in IPOs and limited offerings.

• Recordkeeping
• Copies of codes of ethics;
• Records of violations of code and responses to violations;
• Record of all persons required to make or review reports;
• Holdings and transaction reports;
• Record of adviser's approval of investments in IPOs and limited offerings.

Modified: 01/21/2004