THE PIONEER COMPLEX OF FUNDS
--------------------------------------------------------------------------------
CODE OF ETHICS
--------------------------------------------------------------------------------
INTRODUCTION
This Code of Ethics (the "Code") has been adopted by each registered investment
company (individually an "Investment Company" and collectively the "Investment
Companies") for which Pioneer Investment Management, Inc. ("Pioneer
Investments") serves as an investment adviser or for which Pioneer Funds
Distributor, Inc. ("PFD") serves as principal underwriter, Pioneer Investments
and PFD. The Code is applicable to Access Persons, including Independent
Trustees, of the Investment Companies, as well as Access Persons of Pioneer
Investments and PFD. Pioneer Investments, PFD and the Investment Companies are
sometimes together referred to herein as "Pioneer."
Pioneer and its affiliated entities are committed to maintaining the highest
ethical standards in connection with the management of investment companies and
institutional accounts. Dishonesty, self-dealing, conflicts of interest and
trading on material non-public information will not be tolerated.
The Code reflects Pioneer's views on dishonesty, self-dealing and conflicts of
interest. Every person who has been designated by Pioneer as an "Access Person"
is required to read the Code annually and to certify that he/she has complied
with its provisions and with the reporting requirements. In addition, every
employee of Pioneer is subject to Pioneer's Policies and Procedures to Prevent
Insider Trading.
Any person who has any question regarding the applicability of the Code or
Pioneer's Policies and Procedures to Prevent Insider Trading or the related
prohibitions, restrictions and procedures or the propriety of any action, is
urged to contact the Office of the General Counsel.
SECTION 1
STATEMENT OF POLICY
Section 17(j) of the Investment Company Act of 1940 (the "1940 Act") provides,
among other things, that it is unlawful for any Access Person of Pioneer to
engage in any act, practice or course of business in connection with the
purchase or sale, directly or indirectly, by such Access Person of any Covered
Security held or to be acquired by an Investment Company in contravention of
such rules and regulations as the Securities and Exchange Commission (the
"Commission") may adopt to define and prescribe means reasonably necessary to
prevent such acts, practices or courses of business as are fraudulent, deceptive
or manipulative.
It is the policy of Pioneer that no Access Person shall engage in any act,
practice or course of conduct that would violate the provisions of Section 17(j)
and the rules thereunder. The fundamental position of Pioneer is, and has been,
that each Access Person shall place at all times the interests of the Investment
Companies and their shareholders and the Institutional Accounts ahead of his/her
private Covered Securities transactions. Accordingly, private Covered Securities
transactions by Access Persons must be conducted in a manner consistent with
this Code so as to avoid any actual or potential conflict of interest or any
abuse of an Access Person's position of trust and responsibility. Further,
Access Persons should not take inappropriate advantage of their positions with
or relationships to any Investment Company, any Institutional Account or
Pioneer.
<PAGE>
Without limiting in any manner the fiduciary duty owed by Access Persons or the
provisions of this Code, it should be noted that Pioneer considers it proper
that purchases and sales be made by its Access Persons in the marketplace of
Covered Securities owned by the Investment Companies or Institutional Accounts;
PROVIDED, HOWEVER, that such personal Covered Securities transactions comply
with the spirit of, and the specific restrictions and limitations set forth in,
this Code. Such personal Covered Securities transactions also should be made in
amounts consistent with the normal investment practice of the Access Person
involved and with an investment, rather than a trading, outlook. Not only does
this policy encourage investment freedom and result in establishing investment
experience, but it also fosters a continuing personal interest in such
investments by those responsible for the continuous supervision of the
portfolios of the Investment Companies and Institutional Accounts. In making
personal investment decisions with respect to any Covered Security, extreme care
must be exercised by Access Persons to ensure that the prohibitions of this Code
are not violated. Further, personal investing by Access Persons should be
conducted in such a manner so as to eliminate the possibility that the Access
Person's time and attention is being devoted to his/her personal investments at
the expense of time and attention that should be devoted to management of an
Investment Company's or Institutional Account's portfolio. It should be
emphasized that technical compliance with the procedures, prohibitions and
limitations of this Code will not automatically insulate from scrutiny personal
Covered Securities transactions by an Access Person which show a pattern of
abuse of his/her fiduciary duty to any Investment Company or Institutional
Account.
SECTION 2
DEFINITIONS
2.1 ACCESS PERSON. The term "Access Person" shall mean the following:
o The term "Access Person" with respect to an Investment Company
shall mean any Trustee, officer or Advisory Person of such
Investment Company.
o The term "Access Person" with respect to Pioneer Investments shall
mean any general partner, director, officer or Advisory Person of
Pioneer Investments.
o The term "Access Person" with respect to PFD shall mean any
director or officer of PFD who in the ordinary course of business
makes, participates in or obtains information regarding the
purchase or sale of Covered Securities for an Investment Company
for which PFD acts, or whose functions or duties, in the ordinary
course of business, relate to the making of any recommendation to
an Investment Company or Institutional Account regarding the
purchase or sale of Covered Securities.
2.2 ADVISORY PERSON. The term "Advisory Person" shall mean (i) every
employee of an Investment Company, Pioneer Investments, PFD or The
Pioneer Group, Inc. ("PGI") (or any other company in a Control
relationship with Pioneer Investments) who, in connection with his or
her regular functions or duties, makes, participates in, or obtains
information regarding, the purchase or sale of a Covered Security by an
Investment Company or Institutional Account, or whose functions relate
to the making of any recommendations with respect to such purchases or
sales, (ii) every natural person in a Control relationship to an
Investment Company, Pioneer Investments, PFD or
2
<PAGE>
PGI who obtains
information concerning recommendations made to an Investment Company or
Institutional Account with regard to the purchase or sale of a Covered
Security and (iii) any other employee or independent contractor of any
Investment Company, Pioneer Investments, PFD or PGI designated as an
Advisory Person by the Review Officer. Advisory Person shall not
include directors of PGI who are not also officers or employees of
Pioneer Investments, PFD, PGI or an Investment Company.
2.3 BENEFICIAL OWNERSHIP "Beneficial Ownership" of a security shall mean
having or sharing an opportunity, either directly or indirectly,
through any contract, arrangement, understanding, relationship or
otherwise, to profit or share in any profit derived from a transaction
in a security. Indirect opportunities to profit or share in any profit
would be deemed to exist as a result of, but not limited to, the
following:
o securities held by members of an Access Person's immediate family
sharing the same household (I.E., any child, stepchild,
grandchild, parent, stepparent, grandparent, spouse, sibling,
mother-in-law, father-in-law, son-in-law, daughter-in-law,
brother-in-law, sister-in-law, including adoptive relationships)
or any other individual(s) sharing the same household;
o a general partner's proportionate interest in securities held by
a general or limited partnership;
o a performance-related fee, other than an asset-based fee, received
by any broker, dealer, bank, insurance company, investment
company, investment adviser, investment manager, trustee or person
or entity performing a similar function;
o the right to dividends which is separate or separable from the
underlying security;
o an Access Person's interest in securities held by a trust; or
o an Access Person's right to acquire securities through the
exercise or conversion of any derivative security.
2.4 CONSIDERED FOR PURCHASE OR SALE. A Covered Security is being
"Considered for Purchase or Sale" by an Investment Company or
Institutional Account during any period in which Pioneer Investments
is: (i) actively trading or attempting to trade in the Covered Security
for an Investment Company or Institutional Account; (ii) passively
interested in trading in the Covered Security for an Investment Company
or Institutional Account, I.E., would buy or sell the Security within a
price range communicated to Pioneer Investments' trading department; or
(iii) considering, within an Investment Committee of Pioneer
Investments, the implementation of a trading program for the Covered
Security (including any period during which the Investment Committee is
in receipt of a recommendation with respect to which it has not yet
made a decision). With respect to a Pioneer Investments analyst, the
foregoing period shall commence on the day that he/she decides to
recommend the purchase or sale of the Covered Security to the
Investment Committee of Pioneer Investments and shall continue for a
period of three months after such date.
2.5 CONTROL. The term "Control" shall mean the power to exercise a
controlling influence over the management or policies of Pioneer
Investments, PFD or PGI, unless such power is solely the result of an
official position with Pioneer Investments, PFD or PGI, all as
determined in accordance with Section 2(a)(9) of the 1940 Act.
2.6 COVERED SECURITY. The term "Covered Security" shall have the meaning
set forth in Section 2(a)(36) of the 1940 Act and also shall include
other derivative financial instruments
3
<PAGE>
(including, but not limited to, options, futures contracts and options
on futures contracts) except that it shall not include:
o Direct obligations of the government of the United States;
o Bankers' acceptances;
o Bank certificates of deposit;
o Commercial paper;
o High quality short-term debt instruments, including repurchase
agreements (I.E., any instrument that has a maturity at issuance of
fewer than 366 days and that is rated in one of the two highest rating
categories by a Nationally Recognized Statistical Rating Organization);
or
o Shares of registered open-end investment companies, including the
Investment Companies.
(For reporting purposes, transactions in shares of Pioneer Interest
Shares must be reported.)
2.7 FIDUCIARY ACCOUNT. "Fiduciary Account" is an account with respect to
which an Access Person is an investment adviser, trustee or other
fiduciary and in which the Access Person does not otherwise have any
Beneficial Ownership interest.
2.8 INDEPENDENT TRUSTEE. "Independent Trustee" shall mean any Trustee of
an Investment Company who is not an "interested person" (within the
meaning of Section 2(a)(19) of the 1940 Act) of the Investment
Company, Pioneer Investments or PFD.
2.9 INITIAL PUBLIC OFFERING. "Initial Public Offering" shall mean 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.
2.10 INSTITUTIONAL ACCOUNT. "Institutional Account" refers to any account,
other than an Investment Company, to which Pioneer Investments provides
investment advice.
2.11 INVESTMENT COMPANY. "Investment Company" refers to any U.S. registered
investment company for which Pioneer Investments serves as an
investment adviser or subadviser or for which PFD serves as principal
underwriter. "Investment Companies" refers to all such companies.
2.12 LIMITED OFFERING. "Limited Offering" shall mean an offering of
securities that is exempt from registration under the Securities Act of
1933 pursuant to Section 4(2) or Section 4(6) or pursuant to Rules 504,
505 or 506 under the Securities Act of 1933.
2.13 MATERIAL NON-PUBLIC INFORMATION. "Material Non-Public Information" with
respect to an issuer is information, not yet released to the public,
that would have a substantial likelihood of affecting a reasonable
investor's decision to buy or sell any Covered Securities of such
issuer.
4
<PAGE>
2.14 PORTFOLIO MANAGER. "Portfolio Manager" shall mean every person who is
responsible for the day-to-day management of an Investment Company or
an Institutional Account, or every person who shares such
responsibility with another Portfolio Manager.
2.15. PRECLEARANCE OFFICER. "Preclearance Officer" shall mean the officer of
Pioneer Investments designated from time to time by the Chairman of
Pioneer Investments to provide written prior approval of purchases and
sales by Access Persons. The term "Alternative Preclearance Officer"
shall mean the officer designated from time to time by the Chairman of
Pioneer Investments to provide written prior approval of purchases and
sales by the Preclearance Officer, as well as Access Persons when the
Preclearance Officer is not available, and who shall act in all
respects in the manner prescribed herein for the Preclearance Officer.
2.16 REVIEW OFFICER. "Review Officer" shall mean the officer of Pioneer
Investments designated from time to time by the Chairman of Pioneer
Investments to receive and review reports of purchases and sales by
Access Persons. The term "Alternative Review Officer" shall mean the
officer designated from time to time by the Chairman of Pioneer
Investments to receive and review the reports of purchases and sales by
the Review Officer, as well as Access Persons when the Review Officer
is not available, and who shall act in all respects in the manner
prescribed herein for the Review Officer.
SECTION 3
PROHIBITED ACTIVITIES
While the scope of actions which may violate the Statement of Policy set forth
above cannot be exactly defined, such actions would always include at least the
following prohibited activities:
3.1 Except on behalf of Fiduciary Accounts with respect to such Access
Person, no ACCESS PERSON who is not an Independent Trustee shall enter
an order for the purchase or sale of a Covered Security which an
Investment Company or Institutional Account is purchasing or selling or
considering for purchase or sale until the later of (i) the day after
the Investment Company's or Institutional Account's transaction in that
Covered Security is completed or (ii) after the Investment Company or
Institutional Account is no longer considering the Covered Security for
purchase or sale, unless the Review Officer determines, after
disclosure and review of all material information, that it is clear
that, in view of the nature of the Covered Security and the market for
such Covered Security, the order of the Access Person will not
adversely affect the price paid or received by the Investment Company
or Institutional Account and that the order of the Access Person will
not be advantaged by the transaction by the Investment Company or
Institutional Account. Any Covered Securities transactions by an Access
Person in violation of this Subsection 3.1 shall, at the discretion of
the Chairman of Pioneer Investments, be reversed, any profits disgorged
to the affected Investment Company or Institutional Account or to
charity or other appropriate sanctions imposed.
Except on behalf of Fiduciary Accounts as to which the Independent
Trustee is a fiduciary, no Independent Trustee shall enter an order for
the purchase or sale of a Covered Security if he/ she knew or, in the
ordinary course of fulfilling his/ her official duties as an
Independent Trustee, should have known, that during the 15-day period
immediately before or after the entry of such order, such Covered
Security was purchased or sold by an Investment Company, or such
Covered Security was considered by Pioneer Investments for purchase or
sale by an Investment Company.
5
<PAGE>
3.2 No ACCESS PERSON shall, directly or indirectly, purchase or sell any
Covered Security in which he/she has, or by reason of such purchase
acquires, any Beneficial Ownership interest within a period of seven
calendar days before and after any Investment Company or Institutional
Account advised by Pioneer Investments has purchased or sold such
Covered Security or within seven calendar days of the Covered Security
being recommended for purchase or sale by Pioneer Investments. Any
Covered Security transaction by an Access Person in violation of this
Subsection 3.2 shall, at the discretion of the Chairman of Pioneer
Investments, be reversed, any profits disgorged to the affected
Investment Company or Institutional Account or to charity or other
appropriate sanctions imposed. The provisions of this Subsection 3.2
are subject to a DE MINIMUS exception for Access Persons other than
Advisory Persons at the discretion of the Preclearance Officer.
3.3 No ACCESS PERSON shall purchase or sell, or cause to be purchased or
sold, any Covered Security for a Fiduciary Account as to which he/she
is a fiduciary if any such purchase or sale may, to the reasonable
knowledge of such Access Person, adversely affect the interest of an
Investment Company or Institutional Account in purchasing or selling
such Covered Security or use the transaction by an Investment Company
or Institutional Account to advantage such Fiduciary Account. Covered
Securities transactions for a Fiduciary Account which may adversely
affect an Investment Company or Institutional Account include (i)
purchases that put upward pressure on the price of a Covered Security
being purchased or considered for purchase or (ii) sales that put
downward pressure on the price of a Covered Security being sold or
considered for sale by an Investment Company or Institutional Account.
No Access Person shall be in violation of this Subsection 3.3 with
respect to:
o a transaction in a Covered Security for Fiduciary Accounts if the
aggregate number of shares included in all such transactions on
any trading day does not exceed the lesser of (x) 1% of the
outstanding shares of the Covered Security or (y) the average
weekly trading volume of shares of such Covered Security during
the four previous calendar weeks; or
o the sale of a Covered Security on behalf of a Fiduciary Account by
an Access Person acting in good faith in fulfillment of his/her
fiduciary duty to sell the Covered Security.
3.4 No ACCESS PERSON shall, directly or indirectly, without first obtaining
approval of the President of Pioneer Investments, communicate to any
person any Material Non-Public Information relating to any issuer of
any Covered Security owned by an Investment Company or Institutional
Account. No Access Person shall, directly or indirectly, without first
obtaining approval of the President of Pioneer Investments, communicate
to any person who is not an Access Person any Material Non-Public
Information relating to an Investment Company or Institutional Account,
including, without limitation, the purchase or sale or the considered
purchase or sale of a Covered Security on behalf of such Investment
Company or Institutional Account, except to the extent necessary to
effect Covered Securities transactions on behalf of such Investment
Company or Institutional Account. No Access Person shall trade on or
otherwise use any Material Non-Public Information for his /her personal
benefit or for the benefit of any other person or entity or otherwise
act in a manner detrimental to the Covered Securities transactions of
an Investment Company or Institutional Account.
3.5 No ACCESS PERSON shall engage in, or permit anyone within his /her
Control to engage in, any act, practice or course of conduct which
would operate as a fraud or deceit upon, or constitute a manipulative
practice with respect to, an Investment Company or Institutional
Account or any
6
<PAGE>
issuer of any Covered Security owned by an Investment Company or
Institutional Account or which would violate Pioneer's Policies and
Procedures to Prevent Insider Trading Violations.
3.6 No ADVISORY PERSON shall, directly or indirectly, purchase any security
pursuant to an Initial Public Offering. Access Persons (other than
Advisory Persons) shall not directly or indirectly purchase any
security pursuant to an Initial Public Offering without obtaining prior
written approval from the Preclearance Officer, after disclosure to and
review by the Preclearance Officer of all material information. Any
approval will take into account whether the investment opportunity
should be reserved for an Investment Company or Institutional Account
and whether the opportunity is being offered to Access Person by virtue
of his /her position with or relationship to an Investment Company or
Institutional Account.
3.7 No ADVISORY PERSON shall, directly or indirectly, purchase any security
sold in a Limited Offering without obtaining prior written approval
from the Preclearance Officer, after disclosure to and review by the
Preclearance Officer of all material information. Any approval will
take into account whether the investment opportunity should be reserved
for an Investment Company or Institutional Account and whether the
opportunity is being offered to such Advisory Person by virtue of his
/her position with or relationship to an Investment Company or
Institutional Account.
3.8 No ADVISORY PERSON shall accept any gift or personal benefit valued in
excess of a DE MINIMUS value (as established from time to time by the
Preclearance Officer). Any solicitation of gifts or gratuities is
unprofessional and is strictly prohibited.
3.9 No ADVISORY PERSON shall serve on the board of directors of any
publicly traded company, absent prior written authorization by the
President of Pioneer Investments and determination by the President of
Pioneer Investments that the board service would be consistent with the
interests of the Investment Companies and the Institutional Accounts.
An Advisory Person who serves on the board of directors of a publicly
traded company may not participate in the decision to purchase or sell
any Covered Securities of such company by or on behalf of any
Investment Company or Institutional Account.
3.10 No ADVISORY PERSON shall recommend any Covered Securities transaction
for any Investment Company or Institutional Account without having
previously disclosed any interest in such Covered Securities or the
issuer thereof to the President of Pioneer Investments, including
without limitation:
o his/her Beneficial Ownership of any Covered Securities of such
issuer;
o any contemplated transaction by such person in such Covered
Securities;
o any position with such issuer or its affiliates; and
o any present or proposed business relationship between such issuer
or its affiliates and such person or any party in which such
person has a significant interest.
Such interested Advisory Person may not participate in the decision by
Pioneer Investments on behalf of any Investment Company or
Institutional Account to purchase and sell Covered Securities of such
issuer.
7
<PAGE>
SECTION 4
EXEMPT TRANSACTIONS AND CONDUCT
The prohibitions of Section 3 of this Code (other than Subsections 3.4 and 3.5)
shall not be deemed to be violated by any of the following transactions:
4.1 Purchases or sales of Covered Securities for an account over which the
Access Person has no direct or indirect influence or Control;
4.2 Purchases or sales of Covered Securities which are non-volitional on
the part of the Access Person;
4.3 Purchases or sales of Covered Securities pursuant to an automatic
dividend reinvestment, cash purchase or withdrawal plan provided that
no adjustment is made by the Access Person to the rate at which Covered
Securities are purchased or sold, as the case may be, under such a plan
during any period in which the Covered Security is being considered for
purchase or sale by any Investment Company or Institutional Account;
4.4 Purchases of Covered Securities effected upon the exercise of rights
issued by an issuer pro rata to all holders of a class of its Covered
Securities, to the extent such rights were acquired by the Access
Person from the issuer, and sales of such rights so acquired;
4.5 Purchases or sales of Covered Securities which receive the prior
approval of the Review Officer, after disclosure to and review by the
Review Officer of all material information and provided that such prior
approval is based on the reasonable conclusion that the proposed
purchase or sale would not be in violation of the spirit of this Code
or would not cause any injury to any Investment Company or
Institutional Account;
4.6 Purchases or sales of Covered Securities made in good faith on behalf
of another Investment Company or Institutional Account, it being
understood by, and disclosed to, the Investment Companies and
Institutional Accounts that Pioneer may make contemporaneous investment
decisions and cause to be effected contemporaneous executions on behalf
of one or more Investment Companies and Institutional Accounts and that
such executions may increase or decrease the price at which Covered
Securities are purchased or sold for the Investment Companies and
Institutional Accounts;
4.7 Tenders of Covered Securities pursuant to tender offers which are
expressly conditioned on the tender offer's acquisition of all of the
Covered Securities of the same class; and
4.8 Except as otherwise provided in Section 3.3, purchases or sales of
Covered Securities for a Fiduciary Account as to which the Access
Person is a fiduciary.
SECTION 5
POLICIES AND PROCEDURES TO PREVENT INSIDER TRADING VIOLATIONS
All employees of Pioneer or any affiliate, including Access Persons other than
Independent Trustees, are subject to Pioneer's Policies and Procedures to
Prevent Insider Trading Violations, in addition to the
8
<PAGE>
requirements of this Code. Any violation of the Insider Trading Policy which
adversely affects any Investment Company or Institutional Account shall be
deemed to be a violation of this Code.
SECTION 6
CONFIDENTIALITY
All information obtained from any Access Person hereunder shall be kept in
strict confidence by Pioneer, except that reports of Covered Securities
transactions hereunder will be made available to the Investment Companies and
Institutional Accounts and to the Commission or any other regulatory or
self-regulatory organization to the extent required by law or regulation or to
the extent Pioneer considers necessary or advisable in cooperating with an
investigation or inquiry by the Commission or any other regulatory or
self-regulatory organization.
SECTION 7
INTERPRETATION
The Board of Trustees, on behalf of an Investment Company, as well as Pioneer,
may from time to time adopt such interpretations of this Code as it deems
appropriate.
SECTION 8
EXCEPTIONS TO THE CODE
Although exceptions to the Code will rarely, if ever, be granted, Pioneer
Investments' Chairman, after consultation with the Review Officer, may make
exceptions on a case by case basis, to any of the provisions of this Code upon a
determination that the conduct at issue involves a negligible opportunity for
abuse or otherwise merits an exemption from the Code. All such exceptions must
be received in writing by the Access Person before becoming effective. The
Review Officer shall report the exception to the Board of Trustees of the
Investment Companies at the next regularly scheduled Board meeting.
SECTION 9
ADOPTION OF PROCEDURES TO ADMINISTER THE CODE
Pioneer has adopted procedures to administer the Code of Ethics and Pioneer's
Policies and Procedures to Prevent Insider Trading. Pioneer shall administer
such procedures in accordance with applicable rules and regulations adopted by
the Commission, and all Access Persons are required to comply with such
procedures.
Approved: March 7, 2000
Effective: March 7, 2000
9
