Code of Ethics of
[] John Hancock Advisers, Inc.
[] each John Hancock fund
[] John Hancock Funds, Inc.
(together, called "John Hancock Funds")
July 1, 2000
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1. General Principles...........................................................................................2
2. To Whom Does This Code Apply?................................................................................2
3. Overview of Policies.........................................................................................3
4. Policies Outside the Code of Ethics..........................................................................4
>> Company Conflict & Business Practice Policy...............................................................4
>> Inside Information Policy.................................................................................4
5. Policies in the Code of Ethics...............................................................................5
>> Restriction on Gifts......................................................................................5
>> Preclearance of Securities Transactions...................................................................5
>> Ban on Short-Term Profits.................................................................................6
>> Ban on IPOs...............................................................................................6
>> Disclosure of Private Placement Conflicts.................................................................7
>> Seven Day Blackout Period.................................................................................7
6. Reports and Other Disclosures Outside the Code of Ethics.....................................................8
>> Broker Letter/Duplicate Confirm Statements................................................................8
7. Reports and Other Disclosures In the Code of Ethics..........................................................8
>> Initial Holdings Report and Annual Holdings Report........................................................8
>> Quarterly Transaction Reports.............................................................................9
>> Annual Certification......................................................................................9
8. Limited Access Persons.......................................................................................9
9. Subadvisers.................................................................................................10
10. Reporting Violations........................................................................................10
11. Interpretation and Enforcement..............................................................................10
Appendix A: Categories of Personnel..............................................................................12
Appendix B: Preclearance Procedures.............................................................................13
Appendix C: Limited Access Persons..............................................................................15
Appendix D: Subadvisers........................................................................................16
Appendix E: Administration and Recordkeeping....................................................................17
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General Principles
Each person within the John Hancock Funds organization is responsible for
maintaining the very highest ethical standards when conducting business. This
means that:
o You have a duty at all times to place the interests of our clients first.
o All of your personal securities transactions must be conducted consistent with
this code of ethics and in such a manner as to avoid any actual or potential
conflict of interest or other abuse of your position of trust and
responsibility.
o You should not take inappropriate advantage of your position or engage in any
fraudulent or manipulative practice (such as frontrunning) with respect to our
clients' accounts.
1. To Whom Does This Code Apply?
This code of ethics applies to you if you are a director, officer or employee of
John Hancock Advisers, Inc., John Hancock Funds, Inc. or a "John Hancock fund"
(any fund or account advised by John Hancock Advisers, Inc.). It also applies to
you if you are an employee of John Hancock Life Insurance Co. or its
subsidiaries who participates in making recommendations for, or receives
information about, portfolio trades of the John Hancock funds.
There are three main categories for persons covered by this code of ethics,
taking into account their positions, duties and access to information regarding
fund portfolio trades. You have been notified about which of these categories
applies to you, based on the Compliance Department's understanding of your
current role. If you have a level of investment access beyond your assigned
category, or if you are promoted or change duties and as a result should more
appropriately be included in a different category, it is your responsibility to
notify Bill Sylva, Director of Compliance.
The basic definitions of the three main categories, with examples, are provided
below. The more detailed definitions of each category are attached as Appendix
A.
---------------------------------------- -------------------------------------- --------------------------------------
"Investment Access" person "Regular Access" person "Non-Access" person
A person who regularly
obtains information regarding A person who does not
fund portfolio trades. regularly participate in a
A person who regularly fund's investment process or
participates in a fund's examples: obtain information regarding
investment process. ---------- fund portfolio trades.
o personnel in Investment
examples: Operations or Compliance
---------- examples:
o portfolio managers o most Fund Financial ---------
o analysts Management personnel, o wholesalers
o traders o inside wholesalers
o Technology Resources o certain administrative
personnel with access to personnel
investment systems
o attorneys and some legal
administration personnel
o investment administration
personnel
---------------------------------------- -------------------------------------- --------------------------------------
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2. Overview of Policies
Please refer to the following chart to determine which policies apply to your
category. These policies are described in detail below.
---------------------------------------------------- ---------------------- ---------------------- ----------------------
Investment Access Regular Access Non-Access
Person Person Person
---------------------------------------------------- ---------------------- ---------------------- ----------------------
General principles yes yes yes
---------------------------------------------------- ---------------------- ---------------------- ----------------------
Policies outside the code
---------------------------------------------------- ---------------------- ---------------------- ----------------------
Conflict of interest policy yes yes yes
---------------------------------------------------- ---------------------- ---------------------- ----------------------
Inside information policy yes yes yes
---------------------------------------------------- ---------------------- ---------------------- ----------------------
Policies in the code
---------------------------------------------------- ---------------------- ---------------------- ----------------------
Restriction on gifts yes yes yes
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Pre-clearance requirement yes yes Limited
---------------------------------------------------- ---------------------- ---------------------- ----------------------
Ban on short-term profits yes no no
---------------------------------------------------- ---------------------- ---------------------- ----------------------
Ban on IPOs yes no no
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Disclosure of private placement conflicts yes no no
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Seven day blackout period yes no no
-------------------------------------------------------------- ------------ ---------------------- ----------------------
Reports and other disclosures outside the code
---------------------------------------------------- ---------------------- ---------------------- ----------------------
Broker letter/duplicate confirms yes yes yes
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Reports and other disclosures in the code
---------------------------------------------------- ---------------------- ---------------------- ----------------------
Annual recertification form yes yes yes
---------------------------------------------------- ---------------------- ---------------------- ----------------------
Initial/annual holdings reports yes yes no
---------------------------------------------------- ---------------------- ---------------------- ----------------------
Quarterly transaction reports yes yes no
---------------------------------------------------- ---------------------- ---------------------- ----------------------
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Policies Outside the Code of Ethics
John Hancock Funds has certain policies that are not part of the code of ethics,
but are equally important. The two most important of these policies are (1) the
Company Conflict and Business Practice Policy; and (2) the Inside Information
Policy.
>> Company Conflict & Business Practice Policy
--------------------------------------------------------
A conflict of interest occurs when your private interests
interfere or could potentially interfere with your Applies to: Investment Access Persons
responsibilities at work. You must not place yourself Regular Access Persons
or the company in a position of actual or potential Non-Access Persons
conflict. The Conflict and Business Practice --------------------------------------------------------
Policy covers a number of important issues, such as:
o outside activities (employment, directorships, volunteer work, etc.)
o personal investments or business relationships
o misuse of inside information
o receiving or giving of gifts, entertainment or favors
o misuse or misrepresentation of your corporate position
o disclosure of confidential or proprietary information
o antitrust activities
o political campaign contributions and expenditures on public officials
>> Inside Information Policy and Procedures
--------------------------------------------------------
The antifraud provisions of the federal securities laws
generally prohibit persons with material non-public Applies to: Investment Access Persons
information from trading on or communicating the Regular Access Persons
information to others. Sanctions for violations Non-Access Persons
can include civil injunctions, permanent bars from the --------------------------------------------------------
securities industry, civil penalties up to three times the profits made
or losses avoided, criminal fines and jail sentences. While Investment Access
persons are most likely to come in contact with material non-public information,
the rules (and sanctions) in this area apply to all John Hancock Funds personnel
and extend to activities both related and unrelated to your job duties.
The Inside Information Policy and Procedures covers a number of important
issues, such as:
o The misuse of material non-public information
o The information barrier procedure
o The "restricted list" and the "watch list"
o broker letters and duplicate confirmation statements (see section 5 of this
code of ethics)
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4. Policies in the Code of Ethics
>> Restriction on Gifts
--------------------------------------------------------
You and your family cannot accept preferential treatment
or favors from securities brokers or dealers or other Applies to: Investment Access Persons
organizations with which John Hancock Funds might Regular Access Persons
transact business. For the protection of both you and John Non-Access Persons
Hancock Funds, the appearance of a possible conflict of --------------------------------------------------------
interest must be avoided. You should exercise caution in any instance in which
business travel and lodging are paid for by someone other than John Hancock
Funds. The purpose of this policy is to minimize the basis for any charge that
you used your John Hancock Funds position to obtain for yourself opportunities
which otherwise would not be offered to you. Please see the Company Conflict and
Business Practice Policy's "Compensation and Gifts" section for additional
details regarding restrictions on gifts and exceptions for "nominal value" gifts.
>> Preclearance of Securities Transactions
--------------------------------------------------------
If you are an Investment Access person or Regular Access
person, you must "preclear" (i.e.: receive advance Applies to: Investment Access Persons
approval of) any personal securities transactions. The Regular Access Persons
preclearance policy applies to trades for your personal
accounts, those of a spouse, "significant other," minor Also, for a limited category of trades:
children or family members sharing your household, as well as --------------------------
all accounts over which you have discretion or give Non-Access Persons
advice or information. Due to this preclearance requirement, --------------------------------------------------------
participation in investment clubs is prohibited.
The following securities are exempt from the preclear policy: (1) direct
obligations of the U.S. Government, (2) shares of all open-end mutual funds, (3)
bankers' acceptances, bank certificates of deposit, commercial paper and high
quality short-term debt instruments, including repurchase agreements.
If you are a Non-Access person, you must preclear transactions in securities of
any closed-end funds advised by John Hancock Advisers, Inc.
A Non-Access person is not required to preclear other trades. However, please
keep in mind that a Non-Access person is required to report securities
transactions after every trade (even those that are not required to be
precleared) by submitting duplicate confirmation statements, as described in
section 5 of this code of ethics.
The preclearance policy is designed to proactively identify possible "problem
trades" that raise frontrunning or other conflict of interest concerns (example:
when an Investment Access person trades a security on the same day as a John
Hancock fund). Please keep in mind that even if you receive a preclearance, or
are exempt from preclearing a securities transaction, you are still prohibited
from engaging in any fraud or manipulative practice (such as frontrunning) with
respect to a John Hancock fund.
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You preclear a trade by following the steps outlined in the preclearance
procedures, which are attached as Appendix B. Please note that:
o You may not trade until clearance is received.
o Clearance approval is valid only for the date granted.
o A separate procedure should be followed for requesting preclearance of a
private placement or a derivative, as detailed in Appendix B. The Compliance
Department must maintain a five-year record of all clearances of private
placement purchases by Investment Access persons, and the reasons supporting the
clearances.
>> Ban on Short-Term Profits
--------------------------------------------------------
If you are an Investment Access person, you cannot profit
from the purchase and sale (or sale and purchase) of the Applies to: Investment Access Persons
same (or equivalent) securities within 60 calendar days.
The purpose of this policy is to address the risk, real --------------------------------------------------------
or perceived, of frontrunning or other abusive practices involving
short-term personal trading. Any profits realized on short-term trades must be
surrendered by check payable to John Hancock Advisers, Inc. and will be
contributed by John Hancock Advisers, Inc. to a charity.
This policy applies to trades for your personal accounts, those of a spouse,
"significant other," minor children or family members sharing a household, as
well as all accounts over which you have discretion or give advice or
information. If you give away a security, it is considered a sale.
You may invest in derivatives or sell short provided the transaction period
exceeds the 60-day holding period.
You may request an exemption from this policy for involuntary sales due to
unforeseen corporate activity (such as a merger), or hardship reasons (such as
unexpected medical expenses) by sending an e-mail to Bill Sylva, Director of
Compliance.
>> Ban on IPOs
--------------------------------------------------------
If you are an Investment Access person, you may not
acquire securities in an initial public offering. You Applies to: Investment Access Persons
may not purchase any newly issued securities until the next
business (trading) day after the offering date. This policy --------------------------------------------------------
applies to trades for your personal accounts, those of a spouse,
"significant other," minor children or family members sharing your household, as
well as all accounts over which you have discretion or give advice or
information.
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There are two main reasons for this prohibition: (1) these purchases may suggest
that persons have taken inappropriate advantage of their positions for personal
profit; and (2) these purchases may create at least the appearance that an
investment opportunity that should have been available to the John Hancock funds
was diverted to the personal benefit of an individual employee.
You may request an exemption for certain investments that do not create a
potential conflict of interest, such as: (1) securities of a mutual bank or
mutual insurance company received as compensation in a demutualization and other
similar non-voluntary stock acquisitions; or (2) fixed rights offerings.
>> Disclosure of Private Placement Conflicts
--------------------------------------------------------
If you are an Investment Access person and you own
securities purchased in a private placement, you must Applies to: Investment Access Persons
disclose that holding when you participate in a decision
to purchase or sell that same issuer's securities for a --------------------------------------------------------
John Hancock fund. Private placements are securities exempt from SEC registration
under section 4(2), section 4(6) or rules 504 -506 of the Securities Act of 1933.
The investment decision must be subject to an independent review by investment
personnel with no personal interest in the issuer. This policy applies to
holdings in your personal accounts, those of a spouse, "significant other,"
minor children or family members sharing your household, as well as all accounts
over which you have discretion or give advice or information.
The purpose of this policy is to provide appropriate scrutiny in situations in
which there is a potential conflict of interest.
>> Seven Day Blackout Period
--------------------------------------------------------
If you are a portfolio manager (or were identified to the
Compliance Department as part of a portfolio management Applies to: Investment Access Persons
team) you are prohibited from buying or selling a security
within seven calendar days before and after that security --------------------------------------------------------
is traded for a fund that you manage unless no conflict
of interest exists in relation to that security.
In addition, all investment access persons are prohibited from knowingly buying
or selling a security within seven calendar days before and after that security
is traded for a John Hancock fund unless no conflict of interest exists in
relation to that security. If a John Hancock fund trades in a security within
seven calendar days before or after you trade in that security, you may be
required to demonstrate that you did not know that the trade was being
considered for that John Hancock fund.
You will be required to sell any security purchased in violation of this policy
unless it is determined that no conflict of interest exists in relation to that
security. Any profits realized on trades during a seven day blackout period must
be surrendered by check payable to John Hancock Advisers, Inc. and will be
contributed by John Hancock Advisers, Inc. to a charity.
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This policy applies to holdings in your personal accounts, those of a spouse,
"significant other" or family members sharing your household, as well as all
accounts over which you have discretion or give advice or information.
5. Reports and Other Disclosures Outside the Code of Ethics
>> Broker Letter/Duplicate Confirm Statements
--------------------------------------------------------
As required by the Inside Information Policy, you must
inform your stockbroker that you are employed by an Applies to: Investment Access Persons
investment adviser or broker. Your broker is subject Regular Access Persons
to certain rules designed to prevent favoritism Non-Access Persons
toward your accounts. You may not accept negotiated --------------------------------------------------------
commission rates that you believe may be more favorable than the
broker grants to accounts with similar characteristics. When you open a
brokerage account, before any trades are made, you must:
o notify Bill Sylva, Director of Compliance, so that the Compliance
Department can send to the broker a letter notifying the broker of the
requirement to send duplicate confirmation statements and certain other
requirements.
o ensure that your broker sends duplicate confirmations and copies of all
periodic statements on a timely basis to the Compliance Department, 4th
Floor, 101 Huntington Ave., Boston, MA 02199.
These requirements apply to holdings in your personal accounts, those of a
spouse, "significant other," minor children or family members sharing your
household, as well as all accounts over which you have discretion or give advice
or information.
6. Reports and Other Disclosures In the Code of Ethics
>> Initial Holdings Report and Annual Holdings Report
--------------------------------------------------------
You must file an initial holdings report within 10 calendar
days after becoming an Investment Access person or a Applies to: Investment Access Persons
Regular Access person. You must also file an annual Regular Access Persons
holdings report (as of December 31st) within 30 calendar
days after the calendar year end. These reports must cover --------------------------------------------------------
all holdings in your personal accounts, those of a spouse, "significant other,"
minor children or family members sharing your household, as well as all accounts
over which you have discretion or give advice or information. You must report:
o holdings of all securities except: (1) direct obligations of the U.S.
Government, (2) shares of open-end mutual funds, (3) bankers'
acceptances, bank certificates of deposit, commercial paper and high
quality short-term debt instruments, including repurchase agreements.
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o all brokerage accounts that contain securities (including brokerage
accounts that only contain securities exempt from reporting, such as
shares of open-end mutual funds).
>> Quarterly Transaction Reports
--------------------------------------------------------
You must file a quarterly transaction report within 10
calendar days after the end of a calendar quarter if you Applies to: Investment Access Persons
are an Investment Access person or a Regular Access Regular Access Persons
person. This report must cover all transactions during
the past calendar quarter in your personal accounts, those --------------------------------------------------------
of a spouse, "significant other," minor children or family members sharing your
household, as well as all accounts over which you have discretion or give advice
or information.
You must report:
o transactions in all securities except: (1) direct obligations of the
U.S. Government, (2) open-end mutual funds, (3) bankers' acceptances,
bank certificates of deposit, commercial paper and high quality
short-term debt instruments, including repurchase agreements.
o the opening of any brokerage account that contains securities
(including brokerage accounts that only contain securities exempt from
reporting, such as shares of open-end mutual funds).
>> Annual Certification
--------------------------------------------------------
You must provide an annual certification at a date
designated by the Compliance Department that: (1) you Applies to: Investment Access Persons
have read and understood this code of ethics; (2) Regular Access Persons
you recognize that you are subject to its policies; Non-Access Persons
and (3) you have complied with its requirements. You --------------------------------------------------------
are required to make this certification to demonstrate that you understand the
importance of these policies and your responsibilities under the Code.
7. Limited Access Persons
There is an additional category of persons called "Limited Access" persons. This
category consists only of directors of John Hancock Advisers, Inc. or the John
Hancock funds who:
(a) are not also officers of John Hancock Advisers, Inc.; and
(b) do not ordinarily obtain information about fund portfolio trades.
A more detailed definition of Limited Access persons, and a list of the policies
that apply to them, is attached as Appendix C.
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8. Subadvisers
A subadviser to a John Hancock fund has a number of responsibilities under this
code of ethics, as described in Appendix D.
9. Reporting Violations
If you know of any violation of our code of ethics, you have a responsibility to
immediately report it. You should also report any deviations from the controls
and procedures that safeguard John Hancock Funds and the assets of our clients.
You can report confidentially to:
o Bill Sylva, Director of Compliance (375-1798); or
o Your manager or department head
10. Interpretation and Enforcement
This code of ethics cannot anticipate every situation in which personal
interests may be in conflict with the interests of our clients. You should be
responsive to the spirit and intent of this code of ethics as well as its
specific provisions.
When any doubt exists regarding any code of ethics provision or whether a
conflict of interest with clients might exist, you should discuss the
transaction beforehand with the Director of Compliance, Bill Sylva, at 375-1798.
The code of ethics is designed to detect and prevent fraud against clients and
fund investors, and to avoid the appearance of impropriety. If you feel
inequitably burdened by any policy, you should feel free to contact the Director
of Compliance (Bill Sylva) or the Ethics Committee. Exceptions may be granted
where warranted by applicable facts and circumstances.
To provide assurance that policies are effective, the Compliance Department will
monitor and check personal securities transaction reports and certifications
against fund portfolio transactions. Other internal auditing procedures may be
adopted from time to time. Additional administration and recordkeeping
procedures are described in Appendix E.
The Director of Compliance will refer violations to the Ethics Committee of John
Hancock Funds for review and appropriate action. The following factors will be
considered when the Ethics Committee determines a fine or other disciplinary
action:
o the person's position and function (senior personnel may be held to a higher
standard);
o the amount of the trade;
o whether the funds or accounts hold the security and were trading the same day;
o whether the violation was by a family member.
o whether the person has had a prior violation and which policy was involved.
o whether the employee self-reported the violation.
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You can request reconsideration of any disciplinary action by submitting a
written request to the Ethics Committee.
No less frequently than annually, a written report of all material violations
and sanctions, significant conflicts of interest and other related issues will
be submitted to the boards of directors of the John Hancock funds for their
review. Violations by NASD registered persons are reported to the NASD
Compliance Officer at John Hancock Life Insurance Company. Sanctions for
violations could include fines, limitation of personal trading activity,
suspension or termination of the violator's position with John Hancock Funds
and/or a report to the appropriate regulatory authority.
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Appendix A: Categories of Personnel
You have been notified about which of these categories applies to you, based on
the Compliance Department's understanding of your current role. If you have a
level of investment access beyond that category, or if you are promoted or
change duties and as a result should more appropriately be included in a
different category, it is your responsibility to immediately notify Bill Sylva,
Director of Compliance.
1) Investment Access person: You are an Investment Access person if you are an
employee of John Hancock Advisers, Inc., a John Hancock fund, or John
Hancock Life Insurance Company or its subsidiaries who, in connection with
your regular functions or duties, makes or participates in making
recommendations regarding the purchase or sale of securities by a John
Hancock fund.
(examples: portfolio managers, analysts, traders)
2) Regular Access person: You are a Regular Access person if:
o You are an officer (vice president and higher) or director of John
Hancock Advisers, Inc. or a John Hancock fund. (Some directors may be
Limited Access persons--please see Appendix C for this definition.)
o You are:
-an employee of John Hancock Advisers, Inc., a John Hancock
fund or John Hancock Life Insurance Co. or its subsidiaries ,
or -a director, officer (vice president and higher) or
employee of John Hancock Funds, Inc.
who: (i) in connection with your regular functions or duties,
makes, participates in, or obtains information regarding the
purchase or sale of securities by a John Hancock fund; or (ii)
your functions relate to the making of any recommendation to
the fund regarding the purchase or sale of securities by a
John Hancock fund.
(examples: Investment Operations personnel, Compliance Department
personnel, most Fund Financial Management personnel, investment
administrative personnel, Technology Resources personnel with access to
investment systems, attorneys and some legal administration personnel)
3) Non-Access person: You are a non-access person if you are an employee of
John Hancock Advisers, Inc., John Hancock Funds, Inc. or a John Hancock
fund who does not fit the definitions of any of the other three categories
(Investment Access Person, Regular Access Person or Limited Access Person).
To be a non-access person, you must not obtain information regarding the
purchase or sale of securities by a John Hancock fund in connection with
your regular functions or duties.
(examples: wholesalers, inside wholesalers, certain administrative staff)
4) Limited Access Person: Please see Appendix C for this definition.
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Appendix B: Preclearance Procedures
CODE OF ETHICS
PRE-CLEARANCE PROCEDURES
You should read the Code of Ethics to determine whether you must obtain a
preclearance before you enter into a securities transaction. If you are required
to obtain a preclearance, you should follow the procedures detailed below.
1. Pre-clearance for Public Securities:
A request to pre-clear should be entered into the pre-clear database on the day
before the requested trade date.
The database is located in Microsoft Outlook under the Tools option, Preclear
Personal Trades. It can be accessed by entering your social security number in
the appropriate field. If Microsoft Outlook is unavailable, please contact the
HELP Desk at 101 Huntington Avenue at (617) 375-4357 for assistance.
The following data must be entered:
|_| name of security to trade
|_| ticker symbol
|_| cusip number (9 alpha-numeric characters)
|_| trade type
|_| purchase date (required when selling a security)
|_| brokerage firm
|_| brokerage account number
When you have entered all data, select SEND REQUEST which is located in the top
right corner of the screen.
You will normally be notified by 11:00 A.M. Boston time on the requested trade
date via Microsoft Outlook as to whether clearance has been granted.
If you have any questions or require assistance entering a trade, please call
Mary Ellen Logee at (617) 375-4967 or Fred Spring at (617) 375-4987 in the
Investment Compliance Department.
YOU MAY NOT TRADE UNTIL CLEARANCE IS RECEIVED. Clearance approval is valid only
for the date granted.
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2. Pre-clearance Procedures for Derivatives, Futures, Options and Selling Short:
To request preclearance of short sales or transactions in futures, options and
other derivatives, you must contact Bill Sylva via Microsoft Outlook (please
"cc." Mary Ellen Logee on all such requests). The request must include:
|_| the associate's name;
|_| the associate's John Hancock Funds' company;
|_| the date of request;
|_| the complete name of the security;
|_| a description of the security including its relationship to an underlying
common stock or stock index;
|_| the duration or description of the contract or exercise period;
|_| any potential conflict, present or future, with funds' trading activity
and whether the security might be offered an inducement to later recommend
publicly traded securities for any fund;
|_| the seller and whether or not the seller is one with whom the associate
does business on a regular basis.
Clearance of such securities may be denied if the transaction could create the
appearance of impropriety.
3. Pre-clearance for Private Placements and Initial Public Offerings:
You may request a preclearance of private placement securities or an Initial
Public Offering by contacting Bill Sylva via Microsoft Outlook (please "cc."
Mary Ellen Logee on all such requests). Please keep in mind that the code of
ethics prohibits Investment Access persons from purchasing securities in an
initial public offering.
The request must include:
|_| the associate's name;
|_| the associate's John Hancock Funds' company;
|_| the complete name of the security;
|_| the seller and whether or not the seller is one with whom the associate does
business on a regular basis;
|_| any potential conflict, present or future, with fund trading activity and
whether the security might be offered as inducement to later recommend
publicly traded securities for any fund; and
|_| the date of the request.
Clearance of private placements or initial public offerings may be denied if the
transaction could create the appearance of impropriety. Clearance of initial
public offerings will also be denied if the transaction is prohibited for a
person due to his or her access category under the code of ethics.
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Appendix C: Limited Access Persons
You are a Limited Access person if you are a director of John Hancock Advisers,
Inc. or a John Hancock fund and you meet the two following criteria:
(a) you are not an officer of John Hancock Advisers, Inc.; and
(b) you do not obtain information in the ordinary course of business
regarding the purchase or sale of securities by a John Hancock fund.
(examples: certain directors of John Hancock Advisers, Inc. or a John Hancock fund)
The following policies apply to your category. These policies are described in
detail in the code of ethics.
o Fundamental concept
o Inside information policy and procedures*
o Broker letter/Duplicate Confirms*
o Initial/annual holdings reports*
o Quarterly transaction reports*
o Annual recertification*
*Exception: If you are an independent director of a John Hancock fund:
-----------
o you are exempt from the broker letter/duplicate confirms requirement
o you are exempt from the inside information policy and procedures
o you do not have to file an initial holdings report.
o you do not have to file an annual holdings report.
o you do not have to file a quarterly transaction report unless you
knew (or should have known) that during the 15 calendar days
before or after you trade a security, either:
(i) a John Hancock fund purchased or sold the same security, or
(ii) a John Hancock fund or John Hancock Advisers, Inc. considered
purchasing or selling the same security.
This policy applies to holdings in your personal accounts, those of
a spouse, "significant other" or family members sharing your
household, as well as all accounts over which you have discretion
or give advice or information. If this situation occurs, it is your
responsibility to contact Bill Sylva, Director of Compliance, at
(617) 375-1798 and he will assist you with the requirements of the
quarterly transaction report.
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Appendix D: Subadvisers
A subadviser to a John Hancock fund has a number of responsibilities under this
code of ethics. If John Hancock Advisers, Inc. determines that a subadviser has
failed to comply with the provisions of Rule 17j-1, John Hancock Advisers, Inc.
may deem the subadviser's directors, officers or employees to be subject to this
code of ethics.
>> Approval of Code of Ethics
Each subadviser to a John Hancock fund must provide a copy of its code of ethics
to the trustees of the relevant John Hancock funds for approval initially and
within 60 calendar days of any material amendment. The trustees will give their
approval if they determine that the code:
o contains provisions reasonably necessary to prevent the subadviser's
Access Persons (as defined in Rule 17j-1) from engaging in any conduct
prohibited by Rule 17j-1;
o requires the subadviser's Access Persons to make reports to at least
the extent required in Rule 17j-1(d);
o requires the subadviser to institute appropriate procedures for review
of these reports by management or compliance personnel (as contemplated
by Rule 17j-1(d)(3));
o provides for notification of the subadviser's Access Persons in accordance
with Rule 17j-1(d)(4); and
o requires the subadviser's Access Persons who are Investment Personnel t
obtain the pre-clearances required by Rule 17j-1(e);
>> Reports and Certifications
Each subadviser must provide an annual report and certification to John Hancock
Advisers, Inc. and the fund's trustees in accordance with Rule 17j-1(c)(2)(ii).
The subadviser must also provide other reports or information that John Hancock
Advisers, Inc. may reasonably request.
>> Recordkeeping Requirements
The subadviser must maintain all records for its Access Persons as required by
Rule 17j-1(f).
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Appendix E: Administration and Recordkeeping
>> Adoption and Approval
The trustees of a John Hancock fund must approve the code of ethics of an
adviser, subadviser or principal underwriter before initially retaining its
services.
Any material change to a code of ethics of a John Hancock fund, John Hancock
Funds, Inc., John Hancock Advisers, Inc. or a subadviser to a fund must be
approved by the trustees of the John Hancock fund, including a majority of
trustees who are not interested persons, no later than six months after adoption
of the material change.
>> Administration
No less frequently than annually, John Hancock Funds, Inc., John Hancock
Advisers, Inc., each subadviser and each John Hancock fund will furnish to the
trustees of each John Hancock fund a written report that:
o describes issues that arose during the previous year under the code
of ethics or the related procedures, including, but not limited to,
information about material code or procedure violations, and
o certifies that each entity has adopted procedures reasonably
necessary to prevent its access persons from violating its code of
ethics.
>> Recordkeeping
The Compliance Department will maintain:
o a copy of the current code of ethics for John Hancock Funds, Inc., John
Hancock Advisers, Inc., and each John Hancock fund, and a copy of each
code of ethics in effect at any time within the past five years.
o a record of any violation of the code of ethics, and of any action taken
as a result of the violation, for six years.
o a copy of each report made by an Access person under the code of ethics,
for six years (the first two years in a readily accessible place).
o a record of all persons, currently or within the past five years, who are
or were required to make reports under the code of ethics. This record
will also indicate who was responsible for reviewing these reports.
o a copy of each code of ethics report to the trustees, for six years (the
first two years in a readily accessible place).
o a record of any decision, and the reasons supporting the decision, to
approve the acquisition by an Investment Access person of initial public
offering securities or private placement securities, for six years.
s:\corporate secretary\compliance 2000\code of ethics2000
</TABLE>
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