<PAGE> 1
Exhibit p(6)(b)
<TABLE>
<CAPTION>
----------------------------------------------------------------------- ---------------- --------------------------
TITLE: SECTION: EXHIBITS
GGP PERSONAL SECURITIES TRADING GUIDELINES - CHARLOTTE
AND NEW YORK
----------------------------------------------------------------------- ---------------- --------------------------
<S> <C> <C> <C>
----------------------------------------------------------------------- ---------------- --------------------------
ADOPTED/REVISED: 3/00 REF. NO. EXHIBIT D11-C
----------------------------------------------------------------------- ---------------- --------------------------
</TABLE>
GARTMORE GLOBAL PARTNERS INVESTMENT MANAGEMENT
(CHARLOTTE AND NEW YORK EMPLOYEES)
PERSONAL SECURITIES TRADING GUIDELINES
Each associate of Gartmore Global Partners (GGP) located in Charlotte and New
York is subject to both the GGP and Bank of America Codes of Ethics. These codes
specifically state that "Associates must never make changes in their personal
investments on the basis of confidential information relating to GGP or Bank of
America". The Bank of America Code of Ethics also incorporates the Bank's
General Policy on Insider Trading.
No associate will trade for their personal account based on knowledge of trades
by a style team or fund manager. GGP associates are expected to maintain the
highest standards of personal integrity in regard to any personal securities
activity. The mere appearance of impropriety is to be avoided due to the
position of public trust in which GGP and Bank of America operate.
I. GENERAL GUIDELINES
------------------
A. PURPOSE. These guidelines are designed to provide rules governing
the purchase and sale of individual securities by associates who
have access to sensitive investment information. They apply to all
purchases and sales of securities and their derivatives unless
specifically exempted below.
B. INDIVIDUAL TRADING. Associates are encouraged by management to use
mutual funds for personal investment purposes. However, associates
are permitted to trade in individual securities as long as they
observe these guidelines.
C. APPLICATION. All associates must report all securities
transactions in which they have a direct or indirect beneficial
interest.
D. EXEMPT SECURITIES. These guidelines do not apply to individual
purchases or sales in the following securities:
1. Open-end mutual funds whether proprietary or non
proprietary.
2. Money market instruments.
Exhibit D11-C Page 1 of 4
<PAGE> 2
3. U.S. Government securities.
4. Short term U.S. Government agency securities and short term
securities guaranteed by the U.S. Government or its
agencies.
5. Derivative securities of any of the above instruments.
E. BANK OF AMERICA STOCK. Associates are encouraged to own Bank of
America Stock. However, purchases, sales, or holdings of Bank of
America stock must be reported as detailed below in Section L.
F. ORGANIZATION APPLICATION.
1. Sections G, H and I of these guidelines shall apply only to
any investment associates located in Charlotte or New York,
including any members of investment style teams and any
senior portfolio managers as designated by the Chief
Investment Officer, as well as any investment personnel who
would be considered "access "(1) persons under the
Investment Company Act of l940, or "advisory
representatives"(2) under the Investment Advisers Act of
l940, as well as other associates who might come into
possession of sensitive investment information.
G. STOCK PURCHASES. The first time a stock is added to any common
trust fund or to a mutual fund (other than an index fund), managed
by GGP, no personal purchases of the security will be permitted
for 15 calendar days.
1. The first time a stock is added to a common trust fund or to
a mutual fund, the clock starts to run anew. For example, if
ABC was added to the International Equity Fund on March 3,
the 15-day clock would begin. If on March 10, ABC was added
to the Emerging Markets Fund, the 15-day clock
--------------------
(1)Rule 17j-1(c)(1)(iii) of the Investment Company Act defines an "access"
person as any director, officer, general partner, or advisory person of the
investment adviser who, with respect to any registered investment company, makes
any recommendation, participates in the determination of which recommendation
shall be made, or whose principal function or duties relate to the determination
of which recommendation shall be made to any registered investment company; or
who, in connection with his duties, obtains any information concerning
securities recommendations being made by such investment adviser to any
registered investment company; or who, in connection with his duties, obtains
any information concerning securities recommendations being made by such
investment adviser of any registered investment company.
(2)Advisory Representatives as defined under the Investment Advisers Act of 1940
means any person who, for compensation, engages in the business of advising,
either directly or through publications, as to the value of securities or as to
the advisability of investing in, purchasing or selling securities or who, for
compensation and as a part of regular business issues or promulgates analyses or
reports concerning securities.
Exhibit D11-C Page 2 of 4
<PAGE> 3
would begin again. No one could buy ABC from March 3 until
15 days after March 10.
H. STOCK SALES. When a final sales order is placed for elimination of
a holding from any common trust fund or a mutual fund by GGP,
(other than an index fund), no personal sale of the security can
be made for 15 calendar days.
1. When a final sales order is placed for elimination of a
holding from a fund, the clock starts to run anew. For
example, if ABC was deleted from the International Equity
Fund on March 3, the 15-day clock would begin. If on March
8, ABC was deleted from the Emerging Markets Fund, the
15-day clock would begin again. No one could sell ABC from
March 3 until 15 days after March 8 or March 24.
I. BLACK OUT PERIODS. In addition to the purchase and sale
restrictions noted above, no Fund manager may purchase or sell a
security for their own account within seven (7) calendar days
BEFORE AND AFTER the fund he/she manages trades in that security.
J. SHORT TERM TRADING. Associates may not profit from the purchase
and sale, or sale and purchase, of the same securities within a
period of 60 calendar days. This prohibition includes any
derivative or market equivalent of the security. Profits
recognized on short term trades ( i.e., trades made within a 60
day period) will be required to be disgorged. This prohibition
applies to any trade of the associate and is not contingent on the
security being held by a fund.
K. OTHER PROHIBITED TRANSACTIONS
1. Associates subject to these guidelines are prohibited from
acquiring securities through private placements or initial
public offerings.
* EXCEPTION. Associates may acquire municipal bonds
underwritten by Bank of America during the initial public
offering period, inasmuch as these bonds are ineligible for
purchase by any fund.
2. Associates may not purchase foreign securities, ADR's or
GDR's traded on US exchanges, without the prior written
approval of the Charlotte Compliance Officer.
3. Associates are also prohibited from trading in any closed
end fund for which Bank of America or any of its affiliates
is acting as investment adviser.
Exhibit D11-C Page 3 of 4
<PAGE> 4
Holdings acquired prior to the date of this policy should
be reported and sales of units pre approved by the
Compliance Office.
4. The provisions of section I, J, and K include transactions
in corporate and municipal bonds.
L. BROKERAGE STATEMENTS. Associates subject to these guidelines are
required to provide the Bank of America Corporate Compliance
Office with copies of their brokerage statements and trading
confirmations.
M. ANNUAL LISTING OF ASSETS. In January of each year, all associates
subject to these Guidelines will provide to the Compliance Office
a statement of assets. Such a statement will also be obtained when
an individual commences employment in these areas.
II. MONITORING AND DISCLOSURE
-------------------------
The Compliance Officer will monitor the observance of these guidelines and is
authorized to modify these requirements upon proper disclosure and under
appropriate circumstances.
Exhibit D11-C Page 4 of 4
