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BT Investment Funds
BT Institutional Funds
BT Adviser Funds
BT Investment Portfolios
Stand Alone NY Business Trusts
BT Pyramid Funds
Deutsche Asset Management VIT Funds
Morgan Grenfell Investment Trust
Consolidated Code of Ethics
I. General
Rule 17j-1 under the Investment Company Act of 1940 (the "1940 Act") makes it
unlawful for investment company personnel and other "Access Persons" to engage
in "fraudulent, deceptive or manipulative" practices in connection with their
personal transactions in securities when those securities are held or to be
acquired by an investment company. The Rule also requires every investment
company, the investment company's investment Adviser and, in certain cases, the
investment company's principal underwriter, to adopt a Code of Ethics containing
provisions "reasonably necessary to prevent" such prohibited practices.
This document constitutes the Code of Ethics required by Rule 17j-1 for the
"Funds", as defined in Appendix A. Appendix A also provides certain other
definitions for entities which are referenced in this Code of Ethics.
II. Definitions
For purposes of this Code, the following terms have the meanings set forth as
follows:
A. "Access Person" means:
1. Any director, trustee or officer of a Fund, Adviser or
Sub-Adviser(1);
2. Every "Advisory Person" of a Fund, Adviser or Sub-Adviser. An
"Advisory Person" is:
(a) any 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 by a Fund, or whose functions relate to
the making of any recommendations with respect to
such Purchases or Sales; and
(b) any natural person in a Control relationship to a
Fund, Adviser or Sub-Adviser who obtains information
concerning recommendations made to the Fund with
regard to the Purchase or Sale of a Security by the
Fund; and
3. Any director, trustee or officer of the Distributor who in the
ordinary course of his or her business makes, participates in
or obtains information regarding the Purchase or Sale of
Securities for the Funds or whose functions or duties as part
of the ordinary course of his or her business relate to the
making of any recommendation to the Funds regarding any
Purchase or Sale of Securities.
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B. "Beneficial Ownership" of a Security is to be determined in the same
manner as it is for purposes of Section 16a1-(a)(2) of the Securities
Exchange Act of 1934. This means that a person should generally
consider himself or herself the beneficial owner of any securities of
which he or she shares in the profits, even if he or she has no
influence on voting or disposition of the securities.
C. "Control" shall have the same meaning as that set forth in Section
2(a)(9) of the 1940 Act. Section 2(a)(9) defines "control" as the power
to exercise a controlling influence over the management or policies of
a company, unless such power is solely the result of an official
position with such company. Ownership of 25% or more of a company's
outstanding voting securities is presumed to give the holder thereof
control over the company. Such presumption may be countered by the
facts and circumstances of a given situation.
D. "Covered Persons" means any officer, director, trustee or employee of
the Funds, Adviser, Sub-Advisers or Distributor.
E. "Disinterested Director" means a director or trustee of a Fund who is
not an "interested person" of the Fund within the meaning of Section 2
(a)(19) of the Investment Company Act of 1940.
F. "Purchase or Sale of a Security" means obtaining or disposing of
"Beneficial Ownership" of that Security and includes, among other
things, the writing of an option to purchase or sell a Security.
G. "Security" shall have the same meaning as that set forth in Section
2(a)(36) of the 1940 Act, except that it shall not include direct
obligations of the Government of the United States, bankers'
acceptances, bank certificates of deposit, commercial paper and high
quality short-term debt instruments (including repurchase agreements)
and shares issued by registered, open-end investment companies.
III. General Principles Applicable to Covered Persons
A. Introduction
Although certain provisions of this Code of Ethics apply only to Access
Persons, all Covered Persons are subject to the prohibitions of Rule
17j-1 against fraudulent, deceptive and manipulative practices and to
the general fiduciary principles as set forth in III.B. and III.C.
below.
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Every Covered Person should appreciate the need to behave in an ethical
manner with respect to the Funds. In particular, all Covered Persons
who are involved in any way with the activities of a Fund should be
wary of any potential conflicts between their duty of loyalty to a Fund
and their own financial interests, particularly with respect to their
own securities trading activities. Covered Persons should take care to
preserve the confidentiality of the Funds' business affairs. Covered
Persons who are not "Access Persons" but who become aware of proposed
fund securities transactions should not engage in transactions in those
same securities without the permission of the Secretary of the Fund.
Otherwise, Covered Persons who are not Access Persons are not limited
in their personal securities transactions by this Code, but such
Covered Persons are encouraged to consult with the Secretary of the
Funds if they have any doubts about the applicability of the Code of
Ethics to any proposed transaction.
B. Statement of General Fiduciary Principles
The following principles are the policy of the Funds and are the
obligations of all Covered Persons:
1. It is the duty of all Covered Persons at all times to place
the interests of Fund shareholders first.
2. All personal securities transactions must be conducted in such
manner as to avoid any actual or potential conflict of
interest or any abuse of an individual's position of trust and
responsibility.
3. Covered Persons must not take inappropriate advantage of their
positions or the information they acquire, with or on behalf
of a Fund, Adviser, Sub-Adviser and/or Distributor, to the
detriment of shareholders of the Funds.
C. Fraudulent Practices
Rule 17j-1 makes it unlawful for any Covered Person, in connection with
a Fund with which such Covered Person has a relationship, to:
1. employ any device, scheme or artifice to defraud a Fund;
2. make to a Fund any untrue statement of a material fact or omit
to state to the Fund a material fact necessary in order to
make the statements made, in light of the circumstances under
which they are made, not misleading;
3. engage in any act, practice or course of business which
operates or would operate as a fraud or deceit upon a Fund; or
4. engage in any manipulative practice with respect to a Fund.
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IV. Requirements Applicable to Disinterested Directors
A. Exceptions to Quarterly Transaction Report Requirement. Not
withstanding the provisions of IV.B., a Disinterested Director is
required to complete a Quarterly Transaction Report only if the
Disinterested Director knew or, in the ordinary course of fulfilling
his official duties as a Fund director or trustee should have known,
that during the 15-day period immediately before or after the
director's or trustee's transaction, such Security is or was Purchased
or Sold, or considered for Purchase or Sale, by a Fund.(2)
B. Quarterly Transaction Reports. Subject to the exception set forth in
IV.A., no later than 10 days following the end of the calendar quarter
to which such report relates, each Disinterested Director shall report
to the Secretary of the Funds the following information on the form
attached as Appendix B to this Code:
With respect to transactions in any Security in which such
Disinterested Director has, or by reason of such transaction acquires,
any direct or indirect Beneficial Ownership in the Security:
o the date of the transaction, title, interest rate (if
applicable), number of shares and principal amount of each
Security involved;
o the type of transaction (i.e., purchase, sale or any other
type of acquisition or disposition);
o the price of the Security at which the transaction was
effected;
o the name of the broker, dealer or bank with or through whom
the transaction was effected;
o the date the report was submitted.
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V. Requirements Applicable to Adviser, Sub-Adviser and Distributors
A. The requirements of this Code of Ethics are not applicable to any
Access Person who is subject to a separate Code of Ethics adopted by an
Advisor, Sub-Advisor or Distributor of a Fund (as such terms are
defined in Appendix A), provided that:
1. such Code of Ethics complies with the requirements of Rule
17j-1 and has been approved by the Board of Directors or
Trustees of the Fund; and
2. such Advisor, Sub-Advisor or Distributor has certified to the
Board of Directors or Trustees of the Fund that it has adopted
procedures reasonably necessary to prevent Access Persons from
violating such Code of Ethics.
B. Each Advisor, Sub-Advisor and Distributor shall:
1. submit to the Fund a copy of its Code of Ethics adopted
pursuant to Rule 17j-1;
2. promptly report to the Fund in writing any material amendments
to such Code;
3. furnish to the Fund upon request (and in any event no less
than quarterly) written reports which:
a. describe any issues arising under its Code of Ethics
or procedures during the period specified including
(but not limited to) information about material
violations of the Code or procedures and sanctions
imposed in response to material violations; and
b. certify that it has adopted procedures reasonably
necessary to prevent Access Persons from violating
its Code.
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APPENDIX A
ENTITY DEFINITIONS
"Fund" shall mean each of the following and any series of the following
hereafter designated:
BT Investment Funds
Cash Management Investment
Intermediate Tax Free - Investment Class
Tax Free Money Investment
NY Tax Free Money Investment
Treasury Money Investment
International Equity
Mid Cap - Investment Class
Lifecycle Long Range - Investment Class
Lifecycle Mid Range - Investment Class
Lifecycle Short Range - Investment Class
Small Cap - Investment Class
Quantitative Equity - Investment Class
Quantitative Equity - Institutional Class
PreservationPlus Income
Global Equity Fund
BT Institutional Funds
Cash Management Institutional
Cash Reserves Institutional
Treasury Money Institutional
International Equity Institutional Class I
International Equity Institutional Class II
Equity 500 Index Premier
Liquid Assets Institutional
Daily Assets Institutional
Treasury Assets Institutional
Global Equity Fund
BT Advisor Funds
EAFE Equity Index - Premier Class
Small Cap Index - Premier Class
U.S. Bond Index - Premier Class
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BT Investment Portfolios
Liquid Assets Portfolio
Asset Management Portfolio II
Asset Management Portfolio III
Small Cap Portfolio
U.S. Bond Index Portfolio
Small Cap Index Portfolio
EAFE(R)Equity Index Portfolio
PreservationPlus Portfolio
PreservationPlus Income Portfolio
Global Equity Portfolio
Quantitative Equity Portfolio
Daily Assets Portfolio
Stand Alone NY Business Trusts
Cash Management Portfolio
Intermediate Tax Free Portfolio
Tax Free Money Portfolio
NY Tax Free Money Portfolio
Treasury Money Portfolio
International Equity Portfolio
Equity 500 Index Portfolio
Capital Appreciation Portfolio
Asset Management Portfolio
BT Pyramid Mutual Funds
Money Market Investment
Equity 500 Index Investment
Asset Management - Premier Class
Equity Appreciation - Institutional Class
PreservationPlus - Investment Class
PreservationPlus - Institutional Class
PreservationPlus - Institutional Service Class
Deutsche Asset Management VIT Funds
International Equity
Small Cap
EAFE(R)Equity Index
U.S. Bond Index
Equity 500 Index
Small Cap Index
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Morgan Grenfell Investment Trust
International Select Equity
European Equity
International Small Cap Equity
Emerging Markets Equity
Global Fixed Income
International Fixed Income
Emerging Markets Debt
(each of the foregoing, an "MGIT International Fund")
Fixed Income
Municipal Bond
Short-Term Fixed Income
Short-Term Municipal Bond
High Yield Bond Fund
Smaller Companies
MicroCap
(each of the foregoing, an "MGIT Domestic Fund")
DP Trust
Bankers Trust Co. (an "Adviser") is the investment adviser to each of the BT
Investment Funds, the BT Institutional Funds, the BT Adviser Funds, the BT
Investment Portfolios, the Stand Alone NY Business Trusts the BT Pyramid Mutual
Funds and the Deutsche Asset Management VIT Funds. Deutsche Asset Management
Investment Services Limited (an "Adviser") is the investment adviser to each of
the MGIT International Funds except European Equity. Deutsche Asset Management,
Inc. (an "Adviser") is the investment adviser to each of the MGIT Deutsche Asset
Domestic Funds and European Equity and the DP Trust.
ICC Distributors, Inc. (a "Distributor") is the principal underwriter for each
of the Funds except the Deutsche Asset Management VIT Funds, for which Provident
Distributors, Inc. (a "Distributor") serves as the principal underwriter.
Bankers Trust Company (an "Administrator") is the administrator of each of the
BT Investment Funds, the BT Institutional Funds, the BT Adviser Funds, the BT
Investment Portfolios, the Stand Alone NY Business Trusts and the BT Pyramid
Mutual Funds. PFPC Inc. (an "Administrator") is the administrator of the VIT
Funds. Deutsche Asset Management, Inc. (an "Administrator") is the Administrator
for each of the MGIT International Funds, each of the MGIT Domestic Funds and
the DP Trust.
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APPENDIX B
QUARTERLY PERSONAL SECURTIES TRANSACTIONS REPORT FOR DISINTERESTED DIRECTORS
A Disinterested Director is required to complete this report ONLY IF the
Director knew or, in the ordinary course of fulfilling his official duties as a
Fund director or trustee should have known, that during the 15-day period
immediately before or after the director's or trustee's transaction, such
Security is or was Purchased or Sold, or considered for Purchase or Sale, by a
Fund.
Reports are due within 10 calendar days after the end of the calendar quarter.*
Name of Reporting Person:
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Calendar Quarter Ended:
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Securities Transactions
<TABLE>
<CAPTION>
Number of
Shares, Name of Disclaim
Principal Broker, Beneficial
Name of Amount, Maturity Dealer or Ownership?
Issuer and Date and Bank (indicate by
Date of Title of Interest Rate Type of Effecting "X")
Transaction Security (if applicable) Transaction Price Transaction * *
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<S> <C> <C> <C> <C> <C> <C>
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I certify that I have included on this report all securities transactions
required to be reported pursuant to the Code of Ethics.
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Signature Date
Please return this form to Felicia Emry, Deutsche Asset Management Mutual Funds
Compliance, One South Street, Baltimore, Maryland 21202. Questions should be
directed to Felicia Emry at 410-895-3826.
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1 If an Advisor or Sub-Advisor is primarily engaged in a business other than
advising funds or advisory clients within the meaning of Section (a)(1)(B)
of Rule 17j-1 under the 1940 Act, "Access Person" means any director,
officer or Advisory Person of an Advisor or Sub-Advisor who, with respect to
a Fund for which such entity acts as Advisor or Sub-Advisor, makes any
recommendation, participates in the determination of which recommendation
shall be made, or whose principal function or duties relate to the
determination of which recommendation shall be made or who, in connection
with his or her duties, obtains any information concerning securities
recommendations being made by such investment advisor or sub-advisor to the
Fund.
2 This reporting requirement shall not be applicable to securities traded by
passively managed index funds.
* This reporting requirement shall not be applicable to trading activity in
passively managed index funds
** If you do not want this report to be construed as an admission that you have
Beneficial Ownership of a particular security, please indicate this by
marking an "X" in the box.
