<PAGE> 1
NYLIFE DISTRIBUTORS, INC.
CODE OF ETHICS
This Code of Ethics (the "Code") has been issued by NYLIFE Distributors,
Inc.(the "Corporation" or the "Company") in order to set forth applicable
guidelines and procedures that promote ethical practices and conduct by all of
its employees.1 All recipients of the Code are to read it carefully, retain it
for future reference and abide by its requirements. Also, please refer to the
Corporation policy entitled, "Personal Investment Policy," which has been
incorporated into the Code and is an integral part of its requirements. The
Personal Investment Policy will provide each employee with specific guidance
concerning personal security investments and the responsibilities associated
with that activity.
The Corporation requires that all employees observe the applicable standards' of
duty and care. An employee may not evade the provisions of the Code by having
another person, including a friend, relative or other, act or fail to act in a
manner in which the employee is prohibited.
I. GENERAL POLICY
It shall be a violation of this Code and its procedures, for any employee of the
firm, in connection with the purchase or sale, directly or indirectly, of any
security held or to be acquired by any client including a registered investment
company or other entity (collectively a "Client"):
1. to employ any device, scheme or artifice to defraud any Client
for which the firm serves as an investment adviser or
sub-adviser;
2. to make to the Client any untrue statement of a material fact
necessary or to omit to state to the Client a material fact
necessary in order to make the statements made, in light of
the circumstances under which they are made not misleading;
3. to engage in any act, practice or course of business that
operates or would operate as a fraud or deceit upon the
Client; or
4. to engage in any manipulative practice with respect to the
Client.
------------------
(1) "Employee" shall mean all Monitor employees and Directors.
