<PAGE>
EX-99.B(p)(9)
WELLS CAPITAL MANAGEMENT
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CODE OF ETHICS
POLICY ON PERSONAL SECURITIES TRANSACTIONS
AND
INSIDER TRADING
Version 7.00
Date of last revision: September 2000
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Wells Capital Management Code of Ethics 7.00 2
TABLE OF CONTENTS
<TABLE>
<S> <C>
I. INTRODUCTION............................................................................................ 3
I.1 CODE OF ETHICS....................................................................................... 3
I.2 "ADVISORY REPRESENTATIVE"............................................................................ 3
I.3 "BENEFICIAL OWNERSHIP"............................................................................... 3
II. PENALTIES............................................................................................... 5
II.1 VIOLATIONS OF THE CODE................................................................................ 5
II.2 PENALTIES............................................................................................. 5
11.3 DISMISSAL AND/OR REFERRAL TO AUTHORITIES.............................................................. 5
III. EMPLOYEE TRADE PROCEDURES................................................................................ 7
III.1 PRE-CLEARANCE......................................................................................... 7
III.2 TRADE REPORTS......................................................................................... 8
III.3 POST-REVIEW........................................................................................... 9
III.4 PRE-CLEARANCE AND REPORTING REQUIREMENTS.............................................................. 9
III.5 CONFIDENTIALITY....................................................................................... 9
III.6 ACKNOWLEDGMENT OF BROKERAGE ACCOUNTS.................................................................. 10
III.7 INITIAL AND ANNUAL HOLDINGS REPORT.................................................................... 10
IV. RESTRICTIONS............................................................................................. 11
IV.1 RESTRICTED SECURITIES................................................................................. 11
IV.2 SHORT-TERM TRADING PROFITS (60-DAY TRADING RULE)...................................................... 12
IV-3 BLACKOUT PERIODS...................................................................................... 12
IV.4 NSIDER TRADING........................................................................................ 13
IV.5 GIFTS AND HOSPITALITY................................................................................. 13
IV.6 DIRECTORSHIPS AND OTHER OUTSIDE EMPLOYMENT............................................................ 13
V. REGULATORY REQUIREMENTS.................................................................................. 14
V.1 INVESTMENT ADVISERS ACT OF 1940 AND INVESTMENT COMPANY ACT OF 1940.................................... 14
V.2 REGULATORY CENSURES................................................................................... 14
VI. ACKNOWLEDGMENT AND CERTIFICATION......................................................................... 15
VII. FREQUENTLY ASKED QUESTIONS (FAQS)........................................................................ 16
</TABLE>
Date of last revision: September 2000
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Wells Capital Management Code of Ethics 7.00 3
I. INTRODUCTION
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I.1 Code Of Ethics Wells Capital Management (Wells Capital), as a
registered investment adviser, has an obligation
to maintain a policy governing personal securities
transactions and insider trading by its officers
and employees. This Code of Ethics and Policy on
Personal Securities Transactions and Insider
Trading ("Code") is adopted under Rule 17j-1 of
the Investment Company Act and Section 204A of the
Investment Advisers Act. This Code outlines the
policies and procedures for such activities based
on the recognition that a fiduciary relationship
exists between Wells Capital and its clients. All
references in this Code to employees, officers,
directors, accounts, departments and clients refer
to those of Wells Capital.
In addition to this Code, please refer to the
policies outlined in the Handbook for Wells Fargo
Team Members and the Wells Fargo Code of Conduct
and Business Ethics.
Acknowledgment of, and compliance with, this Code
is a condition of employment. A copy of the Code
and applicable forms are available on Wells
Capital's common drive:
As an employee, you must -
. Be ethical
. Act professionally
. Improve competency
. Exercise independent judgment
I.2 "Advisory For the purposes of this Code, Wells Capital
Representative" defines "advisory Representative" representative"
as any director, officer or employee, 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 for an advisory
client, or
. whose functions are related to the
making of any recommendations with
regard to such purchases or sales.
Because all personnel may at some time access or
obtain investment information, Wells Capital
designates all employees (including independent
-------------
contractors, if deemed appropriate) as "advisory
representatives," and thereby subject to the
policies and procedures of the Code. The list of
advisory personnel will be updated each quarter.
I.3 "Beneficial Personal securities transaction reports should
Ownership" include all accounts for which you have direct or
indirect control. These include accounts over
which you have any control, influence, authority,
either with or without beneficial interest,
whether directly or indirectly, including -
Date of last revision: September 2000
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Wells Capital Management Code of Ethics 7.00 4
. accounts of immediate family members in
the same household; and
. any other account including but not
limited to those of relatives and
friends, over which you direct
activities.
Direct and indirect control may be further
construed to include accounts for which an
Advisory Representative is sole owner, joint
owner, trustee, co-trustee, or attorney-in-fact.
Date of last revision: September 2000
<PAGE>
II. Wells Capital Management Code of Ethics 7.00 5
II. PENALTIES
================================================================================
II.1 Violations of the Code The firm's Chief Compliance Officer will report
violations of the Code on a quarterly basis to
the President. Each Advisory Representative
should immediately report to the Chief
Compliance Officer any known or reasonably
suspected violations of this Code of which he or
she becomes aware.
II.2 Penalties Penalties may be imposed on an Advisory
Representative as follows:
. Minor Offenses -
. First minor offense - Verbal warning;
. Second minor offense - Written notice;
. Third minor offense - $1,000.00 fine to be
donated to the advisory representative's
charity of choice*;
. Substantive Offenses -
. First substantive offense - Written
notice;
. Second substantive offense - $1,000 or
disgorgement of profits (whichever is
greater) to be donated to the advisory
representative's charity of choice*;
. Third substantive offense - Termination of
employment and/or referral to authorities.
Minor offenses include the following:
failure or late submissions of quarterly
trade reports and signed acknowledgments of
Code of Ethics forms and certifications,
failure to request trade pre-clearance, and
conflicting pre-clear request dates versus
actual trade dates.
Substantive offenses include the following:
unauthorized purchase/sale of restricted
securities outlined in the Code, violations
of seven-day blackouts, short-term trading
for profit (60-day rule), trading in
conflict with clients' transactions (such as
the appearance of potential front-running or
scalping), and insider trading.
Date of last revision: September 2000
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Wells Capital Management Code of Ethics 7.00
Wells Capital reserves the right to escalate the terms of
this Penalties section at any time and to use corrective
action that it determines is appropriate (including
referral to authorities) - and, if necessary, to terminate
employment immediately.
* The fines will be made payable to the Advisory
Representative's charity of choice and turned over to
Wells Capital, which in turn will mail the donation check
on behalf of the advisory representative.
II.3 Dismissal Repeated violations of the Code may result in dismissal.
and/or In addition, a single flagrant violation, such as fraud or
Referral to insider trading, will result in dismissal and referral to
Authorities authorities.
The firm's Chief Compliance Officer will forward potential
Code violations involving affiliated mutual funds to Wells
Fargo Bank Mutual Fund Compliance.
Date of last revision: September 2000
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Wells Capital Management Code of Ethics 7.00 7
III. EMPLOYEE TRADE PROCEDURES
================================================================================
III.1 Pre-clearance . All Advisory Representatives in the firm must pre-
----------------------------
clear personal securities transactions as specified
in Section III.4.
. All pre-clearance requests must be submitted via
electronic mail to WCM Risk Manage in the Global
Address List. This will allow anyone in the
Compliance group to pre-clear requests at all times.
Responses will be sent back via electronic mail.
Exceptions will be made only for telephone requests
----
from Advisory Representatives who are out of the
office on business or on vacation. It is the
responsibility of the Advisory Representative to
ensure that Compliance receives pre-clearance
requests. If it appears that E-mail is down, please
contact anyone from the Compliance group directly.
. At a minimum, indicate the following information on
------------
your pre-clearance request -
(a) Transaction Type: BUY or SELL
(b) Security Description / Ticker or CUSIP
(c) Security Type: Common Stock, Options, or Bonds
. Telephone requests from beneficial account holders
outside the firm will be accepted. Responses to
requests will be forwarded to the Advisory
Representative via electronic mail.
. Requests may be submitted from 7:00 am (Pacific)
until an hour before the market closes for the day.
Barring any problems with systems access (i.e., SEI,
Advent/Moxy), responses will be made no more than an
hour from the receipt of request.
. Pre-cleared trades are valid for same day trades
only. No exceptions.
. Pre-clearance does not preclude the possibility of a
potential conflict appearing after the execution of
an employee trade. Trades will be screened for
blackout violations and other conflicts, but
quarter-end review of each personal trade will
reveal conflicts occurring after the trade is
executed (for example, 60-day rule violation).
. The use of the electronic mail system ensures that
each report is date-stamped, and it is the
responsibility of each Advisory Representative to
ensure that the report has been received by Wells
Capital Compliance.
Personal securities transactions should be reported,
whether pre-cleared or not.
Date of last revision: September 2000
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Wells Capital Management Code of Ethics 7.00 8
III.2 Trade Reports . Quarterly Trade Reports which list personal
securities transactions for the quarter must be
submitted by all employees no later than the 10th
----------------------
day after the end of each calendar quarter. This 10-
------------------------------------------
day deadline is a federal requirement and includes
weekends and holidays. If the 10th day falls on a
weekend or a holiday, the report is due the business
day immediately preceding this deadline.
. Quarterly Trade Reports must be submitted using the
Quarterly Trade Report form to Wells Capital
Compliance, either via email (to WCM Risk Manage) or
via MAC (A0103-101). If there are no activities for
the quarter, a report indicating such is still
required to be submitted.
. Wells Capital requires duplicate copies of trades
confirms and monthly or quarterly brokerage account
statements to be forwarded to Compliance. If your
broker is unable to directly send duplicate copies,
please inform Compliance in writing to document
this. Use the Request for Dupe Confirms form to
submit your request to your brokers (with a cc to
Wells Capital Compliance).
. When opening or closing brokerage accounts, please
notify Compliance in writing (quarterly) by using
the Acknowledgment of Brokerage Accounts form.
Forms relating to the Code of Ethics are available in
the common drive under the Wells Cap-News/Risk
Management/Code of Ethics folder.
Date of last revision: September 2000
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Wells Capital Management Code of Ethics 7.00 9
III.3 Post-review Wells Capital Compliance will match any broker
confirms/statements received to pre-clearance requests.
Discrepancies will be documented and may be subject to
censures, as outlined in the PENALTIES section of this
Code.
Employee transactions will also be screened for the
following:
. Same day trades: Transaction occurring on the same
----------------
day as the purchase or sale of the same security in
a managed account.
. 7-day Blackout period: Transaction up to and
----------------------
including seven calendar days before and after the
purchase and/or sale of the same security in a
managed account as described in Sec. I.V.3 of the
Code (For non-S&P500 securities). Note: All interim
activity is considered, not just the initial
purchase or sale of a security.
. Short-term trading profits: Purchase/Sale, or vice
---------------------------
versa, occurring within 60 days in the same security
resulting in net profit. Advisory Representatives
are responsible for ensuring that the 60-day rule is
observed when sale requests are made for securities
previously purchased, or vice versa.
. Other Potential conflicts: Certain transactions may
--------------------------
also be deemed in conflict with the Code and will
warrant additional review, depending on the facts
and circumstances of the transaction.
III.4 Pre-Clearance The table below indicates pre-clearance and reporting
and Reporting requirements. Requirements for all other security type
Requirements transactions must be checked with Compliance.
Security Type Pre-Clearance Qtrly
------------- ------------- Reporting
---------
Equity transactions* Yes Yes
Fixed Inc transactions Yes Yes
Wells Fargo stock No Yes
Open-ended MF No No
Proprietary MF No No
US Tsy/Agencies No No
Short term/cash equiv. No No
SPP/DRIPs- auto purch** No No
*Including options, exchange-traded closed-end mutual
funds.
**Sale of stocks from SPP or DRIPS: Please notify Wells
----
Capital Compliance in writing of the sale and include
transactions in your quarterly reports.
Date of last revision: September 2000
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Wells Capital Management Code of Ethics 7.00 10
III.5 Confidentiality All reports of personal securities transactions,
holdings and any other information filed pursuant
to this Code will be kept CONFIDENTIAL, provided,
however that such information will also be
subject to review by appropriate Wells Capital
Personnel (Compliance and/or Senior Management)
and legal counsel. Such information will also be
provided to the Securities and Exchange
Commission ("SEC") or other government authority
when properly requested or under court order.
III.6 Acknowledgment of All Advisory Representatives are required to
Brokerage Accounts submit a list of all brokerage accounts as
required by the Code at the time of hire. In
addition, employees are responsible for ensuring
that new or closed accounts are communicated to
Compliance quarterly. For reporting purposes, use
the Acknowledgment of Brokerage Accounts form.
III.7 Initial and Annual All Advisory Representatives are required to
Holdings Report report brokerage accounts and holdings (subject
to Code requirements) within 10 days of
employment. An Advisory Representative's broker
statement will suffice in lieu of a separate
initial or annual holdings report. It is the
Advisory Representative's responsibility to
ensure that Compliance receives duplicate copies
of statements and/or confirms if those are sent
directly by the brokers.
Date of last revision: September 2000
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Wells Capital Management Code of Ethics 7.00 11
IV RESTRICTIONS
================================================================================
The following are Wells Capital's restrictions on personal trading:
IV.1 Restricted Securities
<TABLE>
<CAPTION>
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SECURITY TYPE PURCHASE SALE
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<S> <C> <C>
A. S&P500 stocks
PERMITTED PERMITTED
Subject to one-day blackout during Subject to one-day blackout during
execution of client trades (except execution of client trades (except
index program trades). Must index program trades). Must pre-clear
---- --------------
pre-clear.
--------
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B. Any security not included in PERMITTED
the S&P500 above and not defined PERMITTED Subject to pre-clearance requirements.
as "small cap" below. Subject to pre-clearance requirements.
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C. Any restricted list security PERMITTED, subject to the following:
(and its associated option) PROHIBITED . If security held prior to Wells
defined as "small cap" Capital employment and/or version
(capitalization as defined by the 9.99 of the Code, sale permitted
holdings in WCM-actively managed subject to pre-clearance
Small Cap funds including mutual requirements.
funds, DIFs and Collectives.
Small cap holdings in WCM-managed
small cap index funds are excluded
from this list.
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D. Any security issued by a Wells PERMITTED, subject to the following:
Capital client PROHIBITED . If security held prior to Wells
Capital employment and/or version
9.99 of the Code, sales subject to
pre-clearance requirements.
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E. Automatic investment programs
or direct stock purchase plans PERMITTED PERMITTED
. Subject to Code of Ethics . Subject to Code of Ethics reporting
reporting requirements requirements
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F. Initial Public Offerings (IPO's) PERMITTED, only
PROHIBITED . If security held prior to Wells
(An IPO is a corporation's first Capital employment and/or version
offering of a security 9.99 of the Code, sales subject to
representing shares of the company pre-clearance requirements.
to the public)
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G. Private Placements PERMITTED, only
PROHIBITED . If security held prior to Wells
(A private placement is an offer or Capital employment and/or version
sale of any security by a 9.99 of the Code, sales subject to
brokerage firm not involving a pre-clearance requirements.
public offering, for example, a
venture capital deal).
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</TABLE>
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Wells Capital Management Code of Ethics 7.00 12
IV.2 Short-Term Trading Profits The purchase and sale, or the sale and
(60-Day Trading Rule) purchase, of the same security
(or equivalent) within 60 calendar days
and at a profit is PROHIBITED.
. This restriction applies
without regard to tax lot
considerations and short-
sales;
. Exercised options are not
restricted, however, purchases
and sales of options occurring
within 60 days resulting in
profits are PROHIBITED;
. Exceptions require advance
written approval from the
firm's Chief Compliance
Officer (or designee).
Profits from any sale before the 60-day
period expires may require disgorgement.
Please refer to "Penalties", section II
of this Code, for additional details.
IV. 3 Blackout Periods For securities in the S&P 500 stocks, a
one-day firm-wide blackout will apply if
the issue is being traded on behalf of a
client, at the time the pre-clear
request is made. The blackout will not
apply to trades of WCM-managed Index
funds.
All other issues are subject to a seven-
day firm-wide blackout period if traded
on behalf of WCM-managed funds (Mutual
funds, DIFs, Collectives).
Blackout periods apply to both buy and
sell transactions.
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Wells Capital Management Code of Ethics 7.00 13
IV.4 Insider Trading Wells Capital considers information
material if there is a substantial
likelihood that a reasonable shareholder
would consider it important in deciding
how to act. Information is considered
non-public when it has not been
disseminated in a manner making it
available to investors generally.
Information becomes public once it is
publicly disseminated, limited
disclosure does not make the information
public (e.g., disclosure by an insider
to a select group of persons).
Wells Capital generally defines insider
trading as the buying or selling of a
security, in breach of fiduciary duty or
other relationship of trust and
confidence, while in possession of
material non-public information. Insider
-------
trading is a violation of federal
---------------------------------
securities laws, punishable by a maximum
---------------
prison term of 10 years and fines of up
to $1 million for the individual and
$2.5 million for the firm.
Tipping of material, non-public
information is PROHIBITED. An Advisory
Representative cannot trade, either
personally or on behalf of others, while
in possession of such information.
Front-running/scalping involves trading
on the basis of non-public information
regarding impending market transactions.
. Trading ahead of, or "front-
running," a client or proprietary
mutual fund order in the same
security; or
. Taking a position in stock index
futures or options contracts prior
to buying or selling a block or
securities for a client or
proprietary mutual fund account
(i.e., self-front running).
Scalping occurs when an Advisory
Representative purchases shares of a
security for his/her own account shortly
before recommending or buying that
security for long-term investment to a
client and then immediately selling the
shares at profit upon the rise in the
market price following the
recommendation.
IV.5 Gifts and Hospitality Wells Capital, as a policy, follows
Wells Fargo Bank's policy regarding
gifts and hospitality. Please refer to
WFB Employee Handbook for requirements.
IV.6 Directorships and Other Wells Capital, as a policy, follows
Outside Employment Wells Fargo Bank's policy regarding
directorships and other outside
employment. Please refer to WFB Employee
Handbook for requirements.
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Wells Capital Management Code of Ethics 7.00 14
V REGULATORY REQUIREMENTS
================================================================================
V.1 Investment Advisers Act The SEC considers it a violation of general
of 1940 and Investment antifraud provisions of federal securities
Company Act of 1940 laws whenever an adviser, such
as Wells Capital, engages in fraudulent,
deceptive or manipulative conduct. As a
fiduciary to client assets, Wells Capital
cannot engage in activities which would
result in conflicts of interests (for
example, "front-running," scalping, or
favoring proprietary accounts over those of
the clients').
V.2 Regulatory Censures The SEC can censure, place limitations on the
activities, functions, or operations of,
suspend for a period not exceeding twelve
months, or revoke the registration of any
investment adviser based on a:
> Failure reasonably to supervise, with a
view to preventing violations of the
provisions of the federal securities
laws, an employee or a supervised person
who commits such a violation.
> However, no supervisor or manager shall
be deemed to have failed reasonably to
supervise any person, if
(a) there have been established
procedures, and a system for
applying such procedures,
which would reasonably be
expected to prevent and
detect, insofar as
practicable, any such
violation by such other person
and
(b) such supervisor or manager has
reasonably discharged the
duties and obligations
incumbent upon him/her by
reason of such procedures and
systems without reasonable
cause to believe that such
procedures and system were not
being complied with.
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Wells Capital Management Code of Ethics 7.00 15
VI ACKNOWLEDGEMENTS AND CERTIFICATION
================================================================================
I certify that I have received, read, understood and recognize that I am subject
to Wells Capital Management's Code of Ethics and Policy on Personal Securities
Transactions and Insider Trading. This Code is in addition to Wells Fargo's
policy on Business Conduct and Ethics, as outlined in the Employee Handbook.
In addition to certifying that I will provide complete and accurate reporting as
required by the Code and have complied with all requirements of the Wells
Capital Management Code, I certify that I will not:
. Execute any prohibited purchases and/or sales, directly or indirectly, that
are outside those permissible by the Code;
. Employ any device, scheme or artifice to defraud Wells Fargo, Wells Capital
Management or any company;
. Engage in any act, practice or course of business which operates or would
operate as a fraud or deceit upon Wells Fargo, Wells Capital Management or
any company;
. Make any untrue statement of a material fact or omit to state a material fact
necessary in order to make the statements, in light of the circumstances
under which they are made, not misleading;
. Engage in any manipulative practice with respect to Wells Fargo, Wells
Capital Management or any company;
. Trade on inside information;
. Trade ahead of or front-run any transactions for Wells Capital managed
accounts;
. Trade without obtaining the necessary pre-clearance.
I understand that it is a violation of the Investment Advisers Act of 1940 to
fail to submit a record of my personal securities transactions within 10
calendar days of quarter-end.
I understand that, as an employee of Wells Capital Management, it is my
responsibility to submit a list of all brokerage accounts in which I have
beneficial ownership or interest and control (as defined in the Code).
Additionally, I will notify Wells Capital Management Compliance upon opening or
closing brokerage accounts.
Any exceptions, where applicable, are noted as follows:
________________________________________________________________________________
________________________________________________________________________________
________________________________________________________________________________
_____________________________ _____________________
Signature Date
_____________________________
NAME (Print)
The Acknowledgment and Certification form is due 10 days from date of receipt.
----------------------------
Signed copies must be submitted to Wells Capital Compliance, MAC A0103-101.
Date of last revision: September 2000
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Wells Capital Management Code of Ethics 7.00 16
VII FREQUENTLY ASKED Questions (FAQs)
================================================================================
. Who should I submit pre-clearance requests to, what is the minimum
information required, and what are the hours for submission of requests?
Pre-clearance requests should be submitted, via email, to WCM Risk Manage,
in the Global Address list. This ensures that someone in the Compliance
Group can process the request at all times. For specific questions or
concerns regarding the Code, you may direct your inquiries to Monica Poon,
our Chief Compliance Officer ([email protected] or 4I5/396-7016)
--------------------
At a minimum, indicate whether the request is for a BUY or SELL and include
the name and/or ticker symbol of the security/securities.
Requests can be submitted beginning 7:00 am (Pacific) and no later than an
hour before the close of the equity markets. Pre-cleared requests are only
good for the day.
. What is the submission deadline for Quarterly Trade Report?
Quarterly Trade Reports are due 10 calendar days after the end of each
quarter. If the 10th day falls on a weekend or a holiday, the report is due
the business day preceding the weekend or the holiday. The 10-day deadline
is a regulatory requirement.
. Why is a Quarterly Trade Report required if duplicate confirms or statements
are already received from brokers?
WCM as an investment adviser is required to review employee transactions to
ensure that there are no conflicts of interests between trades executed on
personal accounts and those that are executed on behalf of our managed
accounts. The Quarterly Trade Report allows WCM to reconcile the
transactions that are reported by employees and the activities posted on
the statements. The report also provides information when additional
shares, stock dividends or receipts (such as gifts of stocks) are added to
the accounts.
. Why are duplicate copies of confirms and statements required to be submitted
to Compliance? Would the (Quarterly Report and pre-clear requests suffice?
This is a regulatory requirement from a report issued by the SECs Division
of Investment Management (IM). The IM Report, among other things, enlisted
the NASD to adopt a rule requiring its members to notify a fund or an
investment adviser whenever an employee opens an account with an NASD-
member broker. Upon request of the fund or adviser, the member broker is
required to transmit duplicate copies of the employee's trade confirms and
account statements.
. Why are small cap issues restricted from employee purchases?
Because of the volume and size of orders that the small cap funds generate,
this policy ensures that any appearance of conflict (such as front running
and scalping) is avoided. For the purposes of WCM's Code of ethics,
restricted "small cap" issues are those that are held by WCM-managed small
cap funds, including the WF mutual funds, the DIFs and the Collectives.
Restricted small cap issues cannot be
Date of last revision: September 2000
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Wells Capital Management Code of Ethics 7.00 17
purchased by WCM employees until such time that the funds are out of the
same positions. This restriction covers new purchases only. If you held a
restricted stock before your WCM employment or before the Code was revised
in Sept 1999, you can sell your positions (subject to pre-clear
requirements) but you cannot re-purchase or add shares.
All other small capitalization issues that are not owned by these managed
small cap funds can be purchased by employees subject to pre-clearance and
reporting requirements.
. What is the 60-day rule and is it a regulatory requirement?
The 60-day rule prohibits employees from profiting from the purchase and
sale, or vice versa, of the same securities within 60-days.
This is not an SEC requirement but a taskforce guideline instituted by the
Investment Company Institute (ICI), the self-regulating organization for
the mutual fund industry. Similarly, IMR also has recommended restrictions
along the same lines. Because the mutual fund board approves our code of
Ethics and expects us to follow the taskforce guidelines from the ICI/AIMR,
we are closely bound by those restrictions.
