Document/Exhibit Description Pages Size
1: 485BPOS Registration Statement 136 522K
2: EX-1 Designation of Class R Shares 2± 12K
3: EX-6 Dealer Sales Agreement 14± 62K
4: EX-8 Custody Agreement 51 156K
6: EX-9 Administration Agreement 14 50K
5: EX-9 Service Agreement 17 52K
7: EX-11 Auditor Consent 1 7K
8: EX-20 Code of Ethics 17 66K
9: EX-21 Powers of Attorney 2 11K
[March 2004]
[logo] PIONEER
Investments(R)
CODE OF ETHICS FOR PERSONAL INVESTING
Code of Ethics for
Personal Investing
March 1, 2004
TABLE OF CONTENTS
INTRODUCTION.................................................................1
STATEMENT OF POLICY..................................................1
APPLICABILITY........................................................2
RESTRICTED ACTIVITIES........................................................2
RESTRICTIONS APPLICABLE TO ALL ACCESS PERSONS........................2
ADDITIONAL RESTRICTIONS APPLICABLE TO ALL ADVISORY PERSONS...........3
GIFTS................................................................4
EXEMPTIONS...................................................................5
COMPLETE EXEMPTIONS..................................................5
PARTIAL EXEMPTIONS...................................................5
PROCEDURAL REQUIREMENTS......................................................6
LIST OF HOLDINGS.....................................................6
QUARTERLY TRANSACTIONS REPORTS.......................................7
CERTIFICATION OF COMPLIANCE..........................................7
PRE-CLEARANCE........................................................8
ENFORCEMENT..................................................................9
REVIEW...............................................................9
VIOLATIONS...........................................................9
SANCTIONS............................................................9
APPEALS PROCEDURES...................................................10
REPORTING............................................................10
POLICIES APPLICABLE TO INDEPENDENT TRUSTEES..................................11
REPORT OBLIGATIONS...................................................11
VIOLATIONS...........................................................11
PRE-CLEARANCE........................................................11
MISCELLANEOUS................................................................11
POLICIES AND PROCEDURES TO PREVENT INSIDER TRADING VIOLATIONS........12
CONFIDENTIALITY......................................................12
INTERPRETATION.......................................................12
QUESTIONS AND EDUCATIONAL MATERIALS..................................12
RECORDKEEPING........................................................12
GLOSSARY OF TERMS............................................................13
FREQUENTLY ASKED QUESTIONS...................................................15
INTRODUCTION
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This Code of Ethics for Personal Investing (the "Code") governs personal
investment activities by associates, officers, directors or trustees of
Pioneer Investment Management USA Inc. and its subsidiaries and each U.S.
registered mutual fund for which Pioneer Investment Management, Inc. serves
as investment adviser. It has been adopted pursuant to the provisions of
Rule 17j-1 under the Investment Company Act of 1940 and of Rules
204-2(a)(12) and 204-2(a)(13) under the Investment Advisers Act of 1940.
The Compliance Department of Pioneer Investment Management, Inc.
administers the Code.
The procedures and restrictions outlined in the Code apply differently
based on your position within Pioneer. It is your responsibility to
familiarize yourself with this document initially and again if you change
positions in the future.
Certain terms appearing in this Code have special meanings. Please see the
"Glossary of Terms" later in this Code for definitions of these terms.
Unless indicated otherwise, the term "you" refers to all access persons
except independent trustees and the terms "we" and "our" refer to Pioneer.
This document includes sections that are in shaded boxes. These are
operating procedures that Pioneer has adopted to better implement and help
you use the Code. These procedures do not form part of the Code itself.
STATEMENT OF POLICY
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Pioneer is committed to maintaining the highest ethical standards in
connection with the management of our client's assets. An important element
of our commitment is our philosophy of always putting our clients'
interests ahead of our own. This Code is designed to provide us with a high
level of confidence that your personal investment activities are consistent
with our clients' interests and do not interfere with our mission.
You must conduct all of your personal securities transactions in a manner
that is consistent with this Code and in such a manner as to avoid any
actual or potential conflict of interest or abuse of your position of trust
and responsibility. You must also avoid taking inappropriate advantage of
your position with Pioneer. You should avoid any situation that may create
the perception of abuse or call into question the exercise of your judgment
including, but not limited to, the receipt of exceptional trading
opportunities and gifts of more than an insignificant value from any
persons or institutions doing or attempting to do business with Pioneer.
This Code does not attempt to identify all possible conflicts of interest
and literal compliance with each of its specific provisions will not shield
you from accountability for personal trading or other conduct that violates
a fiduciary duty to our clients. You should not only technically comply
with this Code, but also should abide by its spirit.
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Code of Ethics for Personel Investing 1
APPLICABILITY
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PERSONS TO WHOM THIS CODE APPLIES. This Code applies to all access persons.
Upon the determination that you are an access person, the compliance
officer will provide you with a copy of this Code. If you know that you are
an access person under this Code, you will be required to comply with it
even though the compliance officer has not yet advised you that you are an
access person. The prohibitions described below will apply only to a
transaction in a reportable security in which you had, or by reason of the
transaction acquire, any direct or indirect beneficial ownership. Except as
provided in the Statement of Policy, Independent trustees are not generally
subject to this Code and only must comply with those provisions that are
expressly stated as applying to independent trustees. Please refer to the
"Glossary of Terms" for a definition of "access person."
ACCOUNTS TO WHICH THIS CODE APPLIES. The Code applies to transactions in
reportable securities beneficially owned by you and to transactions by
portfolio managers in shares of reportable funds. The term "beneficial
ownership" is more encompassing than one might expect. For example, an
individual may be deemed to have beneficial ownership of securities held in
the name of a spouse, minor children, or relatives sharing his or her home,
or under other circumstances indicating investment control or a sharing of
financial interest. See the "Glossary of Terms" for a more comprehensive
explanation of "beneficial ownership." Regardless of your position with
Pioneer all of your transactions in Pioneer Funds must be consistent the
prospectus requirements of the Pioneer Funds at all times.
REPORTABLE SECURITIES. The requirements of the Code relate to reportable
securities and, in some cases, reportable funds. In general, reportable
securities are all securities except U.S. Treasury securities, shares in
U.S. registered open-end mutual funds and money market instruments. See the
"Glossary of Terms" for a more comprehensive explanation of the term
"reportable security."
RESTRICTED ACTIVITIES
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Your personal securities trading, outside affiliations and receipt of gifts
are subject to restrictions, and, in some cases, prohibitions. Certain of
these activities, such as competing with client trades or holdings and
making personal use of or benefiting from client trades or holdings, are
unethical. Others, such as purchases of initial public offerings and
private placements, are restricted because they present the potential for
actual or perceived conflicts of interest. The prohibitions and
restrictions contained in this Code are based on the rules and interpretive
positions of the Securities and Exchange Commission, industry "best
practices" recommendations and Pioneer's policies.
RESTRICTIONS APPLICABLE TO ALL ACCESS PERSONS
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Access persons may not:
TRANSACT IN REPORTABLE SECURITIES WITHOUT PRE-CLEARANCE.
ENGAGE IN ACTIVITIES FOR PERSONAL BENEFIT. You may not induce or cause a
client to take action, or to fail to take action, when you intend for such
action to benefit you personally rather than primarily the client. For
example, you would violate this Code by causing a client to purchase or
refrain from selling a security you owned for the purpose of supporting or
increasing the price of that security.
PROFIT FROM KNOWLEDGE OF CLIENT TRANSACTIONS. You may not use your
knowledge of client transactions to profit by the market effect of such
transactions. This means that you may not purchase or sell a security when
you knew, or should have known, that the security was being considered for
any client.
Code of Ethics for Personel Investing 2
USE DERIVATIVES TO EVADE THE CODE. You may not use derivatives to evade the
restrictions of this Code. This includes using futures, options, and other
arrangements with similar effects to take positions the Code would prohibit
if taken directly.
COMPETE WITH CLIENT TRADES. You may not buy or sell a security on a day
during which a client has a pending "buy" or "sell" order in that same
security, until that order is executed or withdrawn. You will not be deemed
to have violated this restriction if your order was pre-cleared, placed and
executed before the client trade, you did not know and had no reason to
believe that a trade for a client in such security was being considered.
PLACE GOOD UNTIL CANCELED ORDERS. You may not place any "good until
canceled" or "limit" order with any broker other than a limit order that is
good for that day only.
TRADE EXCESSIVELY. We strongly discourage unusually high levels of personal
trading activity and may monitor such activity. If we determine that you
have engaged in a pattern of excessive trading, we may place restrictions
on your personal trading.
INTENTIONALLY EVADE THE PROSPECTUS REQUIREMENTS OF REPORTABLE FUNDS. All
transactions in shares of a reportable fund must be consistent with the
prospectus requirements applicable to the fund.
ADDITIONAL RESTRICTIONS APPLICABLE TO ALL ADVISORY PERSONS
--------------------------------------------------------------------------------
In addition to the restrictions applicable to all access persons, advisory
persons may not:
COMPETE WITH CLIENT TRADES. You may not:
o Buy or sell a security within seven (7) days before or after a
client trades in that security. You will not be deemed to have
violated this restriction if your trade occurs within the
seven-day period prior to the client trade, you did not know and
had no reason to believe that a trade for a client in such
security was being considered and your transaction was
pre-cleared.
o Establish long positions in your personal accounts in a security
if a client maintains a position that would directly benefit from
a decrease in the value of such security. For example, an advisory
person would be prohibited from establishing a long position if
(1) a client holds a put option on such security (aside from a put
purchased for hedging purposes where the client holds the
underlying security), (2) a client has written a call option on
such security, or (3) a client has sold such security short, other
than "against-the-box."
o Purchase put options or write call options where a client holds a
long position in the underlying security.
SELL SHORT. You may not sell short any security where a client holds a long
position in the same security or where such client otherwise maintains a
position in which the client would directly benefit from an increase in the
value of the security.
PURCHASE SECURITIES IN INITIAL PUBLIC OFFERINGS OR PRIVATE PLACEMENTS
WITHOUT PRIOR APPROVAL. You may not purchase any security in an initial
public offering or in a private placement without first obtaining written
approval from the Head of Investment Management. Any approval will take
into account whether the investment opportunity should be reserved for a
client and whether the opportunity is being offered to you by virtue of
your position with or relationship to a client. If you have been authorized
to acquire securities in an initial public offering or a private placement,
you must disclose such investment to the Head of Investment Management when
you play a part in any subsequent consideration of an investment by a
client in the issuer. In such circumstances, a client's decision to
purchase securities of the issuer will be subject to an independent review
by appropriate personnel with no personal interest in the issuer.
Code of Ethics for Personel Investing 3
SERVE AS A DIRECTOR OR TRUSTEE OF ANY PUBLICLY TRADED COMPANY. You may not
serve on the board of directors of any publicly traded company without
first obtaining written approval from the compliance officer. Likewise, you
may not accept any other service, employment, engagement, connection,
association or affiliation in or with any enterprise, business or other
financial venture without first obtaining written approval from the
compliance officer. In determining whether to approve such requests, the
compliance officer may consider whether such service will involve an actual
or perceived conflict of interest with client trading, place impediments on
our ability to trade on behalf of clients or otherwise materially interfere
with the effective discharge of our duties to clients.
FAIL TO DISCLOSE PERSONAL INTERESTS IN RECOMMENDED SECURITIES. You may not
recommend any securities transaction for a client without disclosing in
advance any interest that you or any member of your immediate family has in
such security or the issuer thereof to the Head of Investment Management or
the person expected to act on such recommendation. You may not participate
in the decision to purchase and sell securities of such issuer for a
client. Factors that should be disclosed include, but are not limited to:
o Your beneficial ownership of any securities of such issuer;
o Any contemplated transaction by you in such securities;
o Any position with such issuer or its affiliates held by you or
any member of your immediate family; and
o Any present or proposed business relationship (including
employment) between such issuer or its affiliates and you or any
member of your immediate family or any party in which you or any
member of your immediate family have a significant interest.
PARTICIPATE IN INVESTMENT CLUBS.
SHORT-TERM TRADING PROFITS. You may not profit in the purchase and sale, or
sale and purchase, of the same (or equivalent) securities within 60
calendar days.
MANAGE DISCRETIONARY ACCOUNTS OF OTHER PEOPLE. You may not exercise
investment discretion over accounts in which you have no beneficial
interest. If you wish to apply for a waiver, you must contact the
compliance officer.
RESTRICTIONS APPLICABLE TO ALL PORTFOLIO MANAGERS
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Portfolio managers may not transact in shares of reportable funds for which
they serve as portfolio manager without pre-clearance.
GIFTS
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You may not accept gifts or personal benefits of more than insignificant
value from any person or entity that does business with or on behalf of
Pioneer or from an entity that is a potential investment for a client. Any
solicitation of gifts or gratuities is unprofessional and is strictly
prohibited.
Code of Ethics for Personel Investing 4
EXEMPTIONS
The compliance officer may prospectively grant exemptions from the trading
restrictions, pre-clearance requirements or other provisions of this Code
if the compliance officer believes that such an exemption is appropriate in
light of all of the surrounding circumstances. The factors the compliance
officer may review, include, but are not limited to, whether the granting
of the exemption would violate the spirit of this Code and whether the
granting of the exemption would cause any injury to any client. The
compliance officer may grant exemptions under the Code only after reviewing
all material information. Exemptions to the Code will rarely, if ever, be
granted.
All exemption requests must be submitted to the compliance officer in
writing. If appropriate, the compliance officer will consult with the
Management Committee of Pioneer, in considering such requests. The
compliance officer will inform you in writing whether or not the exemption
has been granted. If you are granted an exemption to any provision of this
code, you will be expected to comply with all other provisions of this
Code.
As described below, Pioneer has established certain categories of
transactions and conduct that are completely or partially exempt from
various provisions of this Code.
COMPLETE EXEMPTIONS
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The prohibitions, restrictions, pre-clearance requirements and reporting
requirements of this Code do not apply to:
ANY TRANSACTION IN A SECURITY THAT IS NOT INCLUDED IN THE DEFINITION OF A
REPORTABLE SECURITY. Please refer to the "Glossary of Terms" for a
definition of "reportable security."
TRANSACTIONS IN NON-DISCRETIONARY ACCOUNTS (i.e., purchases or sales of
securities for an account over which neither you nor any member of your
immediate family sharing the same household as you had any direct or
indirect influence or control). This exemption would include any account of
yours that is managed on a discretionary basis by someone other than you
(or any member of your immediate family sharing the same household) and
with respect to which you (or any member of your immediate family sharing
the same household) do not in fact have influence or control.
PARTIAL EXEMPTIONS
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The prohibitions, restrictions, and pre-clearance requirements (except as
otherwise indicated) of this Code do not apply (but the reporting
requirements shall continue to apply) to:
PURCHASES OR SALES OF SECURITIES THAT ARE NON-VOLITIONAL (e.g., an
in-the-money option that is automatically exercised by a broker; a security
that is called away as a result of an exercise of an option; or a security
that is sold by a broker, without your consultation, to meet a margin call
not met by you).
PURCHASES OR SALES OF SECURITIES, INCLUDING TRANSACTIONS IN SHARES OF
REPORTABLE FUNDS BY PORTFOLIO MANAGERS, PURSUANT TO AN AUTOMATIC DIVIDEND
REINVESTMENT, PURCHASE OR WITHDRAWAL PLANS.
RIGHTS OFFERINGS (i.e., purchases of securities effected upon the exercise
of rights issued by an issuer proportionately to all holders of a class of
its securities, to the extent such rights were acquired by you from the
issuer, and sales of such rights so acquired).
Code of Ethics for Personel Investing 5
TENDER OFFERS (i.e., tenders of securities pursuant to tender offers that
are expressly conditioned on the tender offeror's acquisition of all of the
securities of the same class). This exemption does not apply to tenders of
securities pursuant to any other tender offer.
TRANSACTIONS IN SECURITIES OR INVESTMENT VEHICLES TIED TO THE PERFORMANCE
OF A BROAD-BASED INDEX. The compliance officer maintains a list of
securities and investment vehicles that qualify for this partial exemption.
SMALL TRANSACTIONS. You may enter into transactions of an insignificant
value, as determined by Pioneer from time to time.
PROCEDURAL REQUIREMENTS
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LIST OF HOLDINGS
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You must provide a list of all reportable securities in which you have a
beneficial interest and a list of all brokerage accounts established by you
or for your benefit to the compliance officer within 10 days of the
commencement of your employment with Pioneer or, if you were not an access
person upon the commencement of your employment, within 10 days of becoming
an access person. Annually, you must provide to the compliance officer a
list of all reportable securities in which you have a beneficial interest
and a list of all brokerage accounts established by you or for your
benefit. The information contained in the initial and annual holdings
reports must be current as of a date no more than 30 days before the report
is required to be submitted. Each report also must be dated. Portfolio
managers must also report shares held of reportable funds for which they
serve as portfolio manager.
Code of Ethics for Personel Investing 6
QUARTERLY TRANSACTIONS REPORTS
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Within 10 days after the end of a calendar quarter, you must report to the
compliance officer transactions in any reportable security in which you
acquire or dispose of beneficial ownership during such quarter and any
account established by or for your benefit during such quarter in which
reportable securities are held for your benefit. Portfolio managers must
also report shares held of reportable funds for which they serve as
portfolio manager. You are deemed to have complied with the transaction
reporting requirements of this section if the compliance officer receives
duplicate statements and confirmations directly from your brokers.
CERTIFICATION OF COMPLIANCE
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You must certify within 10 days of hire and annually thereafter that you
have:
Code of Ethics for Personel Investing 7
o Read and understood this Code and recognized that you are\
subject to it;
o Complied with all requirements of this Code, except as otherwise
notified by the compliance officer that you have not complied
with certain of such requirements; and
o Reported all transactions required to be reported under the
Code.
PRE-CLEARANCE
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One of the most important objectives of this Code is to prevent you from
making personal trades on the basis of information about securities
transactions made for our clients. Trading on such information for personal
benefit constitutes a violation of this Code. To reduce the possibility of
a conflict with a client transaction, except as otherwise permitted by this
Code, you must pre-clear all personal transactions in reportable
securities. In addition, portfolio managers must pre-clear all transactions
in shares of reportable funds for which they serve as portfolio manager.
Code of Ethics for Personel Investing 8
ENFORCEMENT
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Federal law requires that a code of ethics must not only be adopted but
must also be enforced with reasonable diligence. The compliance officer
will keep records of any violation of the Code and of the actions taken as
a result of such violations.
The policies and procedures described in the Code do not create any
obligations to any person or entity other than Pioneer and the Pioneer
Funds. The Code is not a promise or contract, and it may be modified at any
time. Pioneer and the Pioneer Funds retain the discretion to decide whether
the Code applies to a specific situation, and how it should be interpreted.
REVIEW
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The compliance officer will review on a regular basis the reports filed
pursuant to the Code. In this regard, the compliance officer will give
special attention to evidence, if any, of potential violations of the
antifraud provisions of the federal securities laws or the procedural
requirements or ethical standards set forth in the Code and the Policy on
Insider Trading.
VIOLATIONS
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When potential violations of the Code or Pioneer's Policies and Procedures
to Prevent Insider Trading Violations come to the attention of the
compliance officer, the compliance officer will investigate the matter.
Upon completion of the investigation, if necessary, the matter will be
reviewed with the Management Committee, and a determination will be made as
to whether any sanction should be imposed as detailed below. The employee
will be informed of any sanction determined to be appropriate.
SANCTIONS
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Violations of this Code may result in the imposition of such sanctions as
the Management Committee deems appropriate under the circumstances. These
sanctions may include, but are not limited to: terminating or suspending
your employment; suspending your personal trading privileges; issuing a
letter of censure or warning; requiring you to pay a fine; requiring you to
compensate the affected client for an amount equal to the advantage you
gained by reason of such violation; and requiring you to reverse the
trade(s) at issue and forfeit any profit or absorb any loss from the trade.
The Management Committee may take into account any factors that it
determines to be appropriate in imposing sanctions. Such factors may
include, but are not limited to, your history of compliance, the nature of
the violation, whether the violation was intentional or inadvertent and any
harm suffered by a client. Violations of this Code also may result in
criminal prosecution or civil action. The Board of Trustees of the Pioneer
Funds shall have the power to modify or increase any sanction, as it deems
appropriate.
Code of Ethics for Personel Investing 9
APPEALS PROCEDURES
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If you believe you have been mistreated by any action rendered with respect
to a violation of the Code or a waiver request, you may appeal the
determination by providing the compliance officer with a written
explanation within 30 days of being informed of such determination. If
appropriate, the compliance officer will arrange for a review by senior
management and will advise you whether the action will be imposed, modified
or withdrawn.
REPORTING
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Each year, the compliance officer will submit a report to the Board of
Trustees of the Pioneer Funds and to the Management Committee. The report
must include, among other things:
o The number and nature of all material violations of the Code and
the sanctions imposed;
o Any recommended changes to the Code based upon Pioneer's
experience with the Code, evolving industry practices and
developments in applicable laws or regulations; and
o A certification that Pioneer and the Pioneer Funds have adopted
procedures reasonably necessary to prevent access persons from
violating the Code.
Code of Ethics for Personel Investing 10
POLICIES APPLICABLE TO INDEPENDENT TRUSTEES
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Independent trustees are subject to the following reporting obligations,
sanctions and pre-clearance requirements In lieu of the reporting
obligations, sanctions for violations and pre-clearance requirements
contained elsewhere in this Code.
REPORT OBLIGATIONS
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Independent trustees do not need to make initial holdings reports or annual
holdings reports under this Code. In addition, an independent trustee does
not need to make a quarterly transaction report under this Code unless, at
the time of the transaction, the trustee knew, or, in the ordinary course
of fulfilling the official duties of a trustee of a Pioneer Fund, should
have known, that during the 15-day period immediately before or after the
date of the transaction the security was purchased or sold by a Pioneer
Fund or was being considered for purchase or sale by any Pioneer Fund for
which he/she is a trustee. In reporting such transactions, an independent
trustee must provide transactions in any reportable security in which the
independent trustee acquired beneficial ownership during such quarter and
any account established by or for the independent trustee's benefit during
such quarter in which reportable securities are held for the independent
trustee's benefit.
VIOLATIONS
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Any violation of this Code by an independent trustee shall result in the
imposition of such sanctions as the other members of the Board of Trustees
of the Pioneer Funds may deem appropriate under the circumstances, which
may include, but are not limited to, removal from office.
PRE-CLEARANCE
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Independent trustees are neither encouraged nor required to pre-clear
personal transactions in reportable securities, unless there is reason to
believe that the proposed transaction may conflict with the then current
trading activities of a Pioneer Fund.
MISCELLANEOUS
--------------------------------------------------------------------------------
You may have other obligations related to your purchase and sale of
securities that are not covered by the Code. Please follow any guidelines
you receive from Pioneer in this regard.
Code of Ethics for Personel Investing 11
POLICIES AND PROCEDURES TO PREVENT INSIDER TRADING VIOLATIONS
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In addition to the requirements of this Code, all associates of Pioneer are
subject to Pioneer's Policies and Procedures to Prevent Insider Trading
Violations (EXHIBIT E). Pioneer's Policies and Procedures to Prevent
Insider Trading Violations prohibits associates from buying or selling any
security while in possession of material nonpublic information about the
issuer of the security. The policy also prohibits associates from
communicating to third parties any material nonpublic information about any
security or issuer of securities. Any violation of Pioneer's Policies and
Procedures to Prevent Insider Trading Violations that adversely affects a
client shall be deemed to be a violation of this Code.
CONFIDENTIALITY
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Normally, we will keep all information obtained under this Code in strict
confidence; however, violations will be reported to senior management and
we may report information to third parties under certain circumstances. For
example, we may make reports of securities transactions and violations of
this Code available to clients or former clients, the Securities and
Exchange Commission or any other regulatory or self-regulatory organization
to the extent required by law or regulation, or to other civil or criminal
authorities if we consider it to be necessary or advisable.
INTERPRETATION
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The Board of Trustees of the Pioneer Funds and Pioneer may from time to
time adopt such interpretations of this Code as they deem appropriate.
QUESTIONS AND EDUCATIONAL MATERIALS
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You are encouraged to bring to the compliance officer any questions you may
have about interpreting or complying with this Code, about securities
accounts or personal trading activities of you or your family or household
members, about your legal or ethical responsibilities or about similar
matters that may involve this Code.
The compliance officer may from time to time circulate educational
materials or bulletins designed to assist you in understanding and carrying
out your duties under this Code.
RECORDKEEPING
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Pioneer shall maintain and preserve in an easily accessible place:
o A copy of the Code (and any prior code of ethics that was in
effect at any time during the past five years) for a period of
not fewer than five years;
o A record of any violation of the Code and of any action taken as
a result of such violation for a period of not fewer than five
years following the end of the fiscal year in which the
violation occurs;
Code of Ethics for Personel Investing 12
o A copy of each report submitted under the Code, including
periodic account statements and duplicate trade confirmations,
by an access person for a period of not fewer than five years
following the end of the fiscal year in which the pre-clearance
request or report is made, the first two years in an easily
accessible place;
o A record of all persons who are, or within the past five years
were, required to make reports pursuant to the Code and who are
or were responsible for reviewing such reports;
o A copy of each report submitted to the Board of Trustees of the
Pioneer Funds under the Code for a period of not fewer than five
years following the end of the fiscal year in which such report
is made, the first two years in an easily accessible place; and
o A record of any decision, and the reasons supporting such
decision, to approve the acquisition by an investment person of
initial public offerings or private placements for at least five
years after the end of the fiscal year in which such approvals
are granted.
GLOSSARY OF TERMS
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Access person means any director, trustee, or officer of Pioneer or the
Pioneer Funds. It also means:
o Every associate or independent contractor of Pioneer (or of any
company that controls Pioneer), who, in connection with his or
her regular functions or duties, makes, participates in, or
obtains information regarding the purchase or sale of a security
by Pioneer on behalf of clients, or whose functions relate to
the making of any recommendations with respect to such purchases
or sales;
o Every natural person who controls Pioneer and who obtains
information concerning recommendations made to a client with
regard to the purchase or sale of a security; and
o Any other associate designated by the compliance officer as an
advisory person under this Code.
Advisory person of a Fund or of a Fund's investment adviser means:
o Any associate of Pioneer (or of any company that controls
Pioneer) who, in connection with his or her regular functions or
duties, makes or participates in making recommendations
regarding the purchase or sale of securities by a client.
o Any natural person who controls Pioneer and who obtains
information concerning recommendations made to a client
regarding the purchase or sale of securities by such client.
Examples of an advisory person include portfolio managers, research and
credit analysts, and traders.
Beneficial ownership means a direct or indirect "pecuniary interest" that
is held or shared by you directly or indirectly (through any contract,
arrangement, understanding, relationship or otherwise) in a security. The
term "pecuniary interest" in turn generally means your opportunity directly
or indirectly to receive or share in any profit derived from a transaction
in a security whether or not the security or the relevant account is in
your name or is held in an ordinary brokerage or retirement plan account.
Although this concept is subject to a variety of Securities and Exchange
Commission rules and interpretations, you should know that you are presumed
under the Code to have an indirect pecuniary interest as a result of:
o Ownership of a security by your spouse or minor children;
Code of Ethics for Personel Investing 13
o Ownership of a security by your other family members sharing
your household (including an adult child, a stepchild, a
grandchild, a parent, stepparent, grandparent, sibling, mother-
or father-in-law, sister- or brother-in-law, and son- or
daughter-in-law);
o Your share ownership, partnership interest or similar interest
in the portfolio securities held by a corporation, general or
limited partnership or similar entity you control;
o Your right to receive dividends or interest from a security even
if that right is separate or separable from the underlying
securities;
o Your interest in a security held for the benefit of you alone or
for you and others in a trust or similar arrangement (including
any present or future right to income or principal); and
o Your right to acquire a security through the exercise or
conversion of a "derivative security."
In the case of unmarried persons who share a household and combine their
financial resources in a manner similar to that of married persons, each
person will be presumed to have beneficial ownership in the securities and
transactions of the other.
Client means any account to which Pioneer provides investment advice,
including the Pioneer Funds.
Compliance officer means the Director of Compliance of Pioneer Investment
Management, Inc. (including his/her designees). Alternative compliance
officer means the person designated from time to time by the Director of
Compliance or the Chief Executive Officer or General Counsel of Pioneer
Investment Management, Inc. as having responsibility for compliance with
the requirements of this Code when the compliance officer is not available.
Control means the power to exercise a controlling influence over the
management or policies of a company, unless such power is solely the result
of an official position with such company
Independent trustee means any Trustee of a Pioneer Fund who is not an
"interested person" (within the meaning of Section 2(a)(19) of the 1940
Act) of the fund.
Initial public offering means an offering of securities registered under
the Securities Act of 1933, the issuer of which, immediately before
registration, was not subject to the reporting requirements of Section 13
or 15(d) of the Securities Exchange Act of 1934 and other similar non-U.S.
securities.
Participating affiliate means a non-U.S. advisory affiliate of Pioneer
Investment Management, Inc. that has entered into an agreement with
Pioneer Investment Management, Inc. to provide investment advisory
services to clients.
Pioneer means Pioneer Investment Management USA Inc., its subsidiaries
and any participating affiliates of Pioneer Investment Management, Inc.
Pioneer Fund refers to any U.S registered investment company for which
Pioneer serves as investment adviser or sub adviser and principal
underwriter. Pioneer Funds refers to all such companies.
Pioneer Retirement Plan means Pioneer's Savings and Investment Plan,
Retirement Benefit Plan, Mandatory Bonus Deferral Plan or Voluntary Bonus
Deferral Plan.
Portfolio Manager means the person (or one of the persons) primarily
responsible for the day-to-day management of a Pioneer Fund's portfolio.
The term portfolio manager includes individuals that provide back-up
services where the primary portfolio manager is unavailable.
Code of Ethics for Personel Investing 14
Private placement means an offering of securities that is exempt from
registration pursuant to Section 4(2) or Section 4(6) or pursuant to Rules
504, 505 or 506 under the Securities Act of 1933 and other similar non-U.S.
securities. Private placements include, but are not limited to, private
equity partnerships, hedge funds, limited partnerships and venture capital
funds.
Reportable fund refers to any U.S registered investment company for which
Pioneer serves as investment adviser or sub adviser. Reportable funds refer
to all such companies.
Reportable security means any type of equity or debt security (such as
common and preferred stocks, and corporate and government bonds or notes)
and any instrument representing, or any rights relating to, a security
(such as certificates of participation, depository receipts, put and call
options, warrants, convertible securities and securities indices). For
purposes of this Code, the term "reportable security" does not include:
o Direct obligations of the government of the United States.
Please note that securities issued by agencies or
instrumentalities of the U.S. government (e.g., GNMA
obligations), municipal obligations and obligations of other
governments are reportable securities.
o Bankers' acceptances.
o Bank certificates of deposit.
o Commercial paper.
o High quality short-term debt instruments, including
repurchase agreements.
o Shares of open-end investment companies registered under the
Investment Company Act of 1940, as amended, including the
Pioneer Funds. Please note that shares of closed-end funds and
investment funds organized under the laws of any other
jurisdiction are securities.
FREQUENTLY ASKED QUESTIONS
--------------------------------------------------------------------------------
Below is list of frequently asked questions regarding the Code. As
always, if you have any questions regarding the Code, please call Rebecca
Cinci at ext. 4975 or Martin Wolin at ext. 4962.
Q1. MUST YOU REPORT BROKERAGE ACCOUNTS THAT DO NOT HOLD "REPORTABLE
SECURITIES"?
Yes. You must include in your initial and annual holdings reports the name
of ANY broker-dealer or bank with which you have an account in which ANY
securities are held for your direct or indirect benefit. You must also
report ANY account established in which ANY securities were held during the
quarter. Thus, you are not limited to reporting accounts that only hold
covered securities for your benefit.
Q2. MUST YOU FILE A TRANSACTION REPORT FOR SECURITIES ACQUIRED THROUGH A GIFT
OR INHERITANCE?
Yes. You must report any transaction (including a purchase or other
acquisition) in a covered security in which you have any direct or
indirect beneficial ownership.
Q3. MUST YOU REPORT THE HOLDINGS AND TRANSACTIONS OF A SPOUSE?
Yes, if you have direct or indirect beneficial ownership interest in
covered securities held by the spouse.
Code of Ethics for Personel Investing 15
Dates Referenced Herein
| Referenced-On Page |
|---|
| This ‘485BPOS’ Filing | | Date | | First | | Last | | | Other Filings |
|---|
| |  |
| Corrected on: | | 4/21/04 | | | | | | | None on these Dates |
| Filed on / Effective on: | | 3/1/04 | | 1 |
| List all Filings |
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