<PAGE>
Exhibit (p)(2)
THE PRUDENTIAL INVESTMENT CORPORATION
PRUDENTIAL INVESTMENTS FUND MANAGEMENT LLC
PRUDENTIAL INVESTMENT MANAGEMENT SERVICES LLC
CODE OF ETHICS ADOPTED PURSUANT TO RULE 17j-1
UNDER THE INVESTMENT COMPANY ACT OF 1940
(THE CODE)
1. PURPOSES
--------
The Code has been adopted by the Board of Directors/Trustees or the
Duly Appointed Officer-In-Charge of the Prudential Mutual Fund (hereinafter,
referred to as the "Fund"), the Manager, the Adviser/Subadviser, and the
Principal Underwriter in accordance with Rule 17j-1(c) under the Investment
Company Act of 1940 (the Act) and in accordance with the following general
principles:
(1) THE DUTY AT ALL TIMES TO PLACE THE INTERESTS OF
SHAREHOLDERS FIRST.
Investment company personnel should scrupulously
avoid serving their own personal interests ahead of
shareholders' interests in any decision relating to their
personal investments.
(2) THE REQUIREMENT THAT ALL PERSONAL SECURITIES TRANSACTIONS
BE CONDUCTED CONSISTENT WITH THE CODE AND IN SUCH A MANNER AS
TO AVOID ANY ACTUAL OR POTENTIAL CONFLICT OF INTEREST OR ANY
ABUSE OF AN INDIVIDUAL'S POSITION OF TRUST AND RESPONSIBILITY.
Investment company personnel must not only seek to
achieve technical compliance with the Code but should strive
to abide by its spirit and the principles articulated herein.
(3) THE FUNDAMENTAL STANDARD THAT INVESTMENT COMPANY PERSONNEL
SHOULD NOT TAKE INAPPROPRIATE ADVANTAGE OF THEIR POSITIONS.
Investment company personnel must avoid any situation
that might compromise, or call into question, their exercise
of fully independent
Revised 2/11/2000
<PAGE>
judgment in the interest of shareholders, including, but not
limited to the receipt of unusual investment opportunities,
perquisites, or gifts of more than a DE MINIMIS value from
persons doing or seeking business with the Fund.
Rule 17j-1 under the Act generally proscribes fraudulent or
manipulative practices with respect to a purchase or sale of a security held or
to be acquired (as such term is defined in Section 2.) by an investment company,
if effected by an associated person of such company.
The purpose of the Code is to establish procedures consistent with the
Act and Rule 17j-1 to give effect to the following general prohibitions as set
forth in Rule 17j-1(b) as follows:
(a) It shall be unlawful for any affiliated person of or
Principal Underwriter for a registered investment company, or any
affiliated person of an investment adviser of or principal underwriter
for a registered investment company in connection with the purchase or
sale, directly or indirectly, by such person of a security held or to
be acquired, by such registered investment company:
(1) To employ any device, scheme or artifice
to defraud such registered investment company;
(2) To make to such registered investment
company any untrue statement of a material fact or omit to
state to such registered investment company 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 which operates or would operate as a fraud or
deceit upon any such registered investment company; or
2
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<PAGE>
(4) To engage in any manipulative practice with
respect to such registered investment company.
2. DEFINITIONS
-----------
(a) "Access Person" means any director/trustee, officer,
general partner or Advisory Person (including any Investment Personnel,
as that term is defined herein) of the Fund, the Manager, the
Adviser/Subadviser, or the Principal Underwriter.
(b) "Adviser/Subadviser" means the Adviser or Subadviser
of the Fund or both as the context may require.
(c) "Advisory Person" means (i) any employee of the Fund,
Manager or Adviser/Subadviser (or of any company in a control
relationship to the Fund, Manager or Adviser/Subadviser) 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 the Fund, or whose functions relate to the making of
any recommendations with respect to such purchases or sales; and (ii)
any natural person in a control relationship to the Fund who obtains
information concerning recommendations made to the Fund with regard to
the purchase or sale of a security.
(d) "Beneficial Ownership" will be interpreted in the
same manner as it would be under Securities Exchange Act
Rule 16a-1(a)(2) in determining which security holdings of a person
are subject to the reporting and short-swing profit provisions of
Section 16 of the Securities Exchange Act of 1934 and the rules and
regulations thereunder, except that the determination of direct or
indirect beneficial ownership will apply to all securities which an
Access Person has or acquires (EXHIBIT A).
(e) "Complex" means the group of registered investment
companies for which Prudential Investments Fund Management LLC serves
as Manager; provided, however, that with respect to Access Persons of
the Subadviser (including any unit or subdivision thereof), "Complex"
means the group of registered investment companies in the Complex
advised by the Subadviser or unit or subdivision thereof.
(f) "Compliance Officer" means the person designated by
the Manager, the Adviser/Subadviser, or Principal Underwriter
(including his or her designee) as having responsibility for compliance
with the requirements of the Code.
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<PAGE>
(g) "Control" will have the same meaning as that set
forth in Section 2(a)(9) of the Act.
(h) "Disinterested Director/Trustee" means a
Director/Trustee of the Fund who is not an "interested person" of the
Fund within the meaning of Section 2(a)(19) of the Act.
An interested Director/Trustee who would not otherwise be
deemed to be an Access Person, shall be treated as a Disinterested
Director/Trustee for purposes of compliance with the provisions of the
Code.
(i) "Initial Public Offering" means an offering of
securities registered under the Securities Act of 1933, the issuer of
which, immediately before the registration, was not subject to the
reporting requirements of sections 13 or 15(d) of the Securities
Exchange Act of 1934.
(j) "Investment Personnel" means: (a) Portfolio Managers
and other Advisory Persons who provide investment information and/or
advice to the Portfolio Manager(s) and/or help execute the Portfolio
Manager's(s') investment decisions, including securities analysts and
traders ; and (b) any natural person in a control relationship to the
Fund who obtains information concerning recommendations made to the
Fund with regard to the purchase or sale of a security.
(k) "Manager" means Prudential Investments Fund
Management, LLC.
(l) "Portfolio Manager" means any Advisory Person who
has the direct responsibility and authority to make investment
decisions for the Fund.
(m) "Private placement" means a limited offering that is
exempt from registration under the Securities Act of 1933 pursuant to
section 4(2) or section 4(6) or pursuant to rule 504, rule 505 or rule
506 under such Securities Act.
(n) "Security" will have the meaning set forth in
Section 2(a)(36) of the Act, except that it will not include shares of
registered open-end investment companies, direct obligations of the
Government of the United States, , short-term debt securities which are
"government securities" within the meaning of Section 2(a)(16) of the
Act, bankers' acceptances, bank certificates of deposit, commercial
paper and such other money
4
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<PAGE>
market instruments as are designated by the Compliance Officer. For
purposes of the Code, an "equivalent Security" is one that has a
substantial economic relationship to another Security. This would
include, among other things, (1) a Security that is exchangeable for
or convertible into another Security, (2) with respect to an equity
Security, a Security having the same issuer (including a private issue
by the same issuer) and any derivative, option or warrant relating to
that Security and (3) with respect to a fixed-income Security, a
Security having the same issuer, maturity, coupon and rating.
(o) "Security held or to be acquired" means any Security
or any equivalent Security which, within the most recent 15 days:
(1) is or has been held by the Fund; or (2) is being considered by the
Fund or its investment adviser for purchase by the Fund.
3. APPLICABILITY
-------------
The Code applies to all Access Persons and the Compliance Officer shall
provide each Access Person with a copy of the Code. The prohibitions described
below will only apply to a transaction in a Security in which the designated
Access Person has, or by reason of such transaction acquires, any direct or
indirect Beneficial Ownership. The Compliance Officer will maintain a list of
all Access Persons who are currently, and within the past five years, subject to
the Code.
4. PROHIBITED PURCHASES AND SALES
------------------------------
A. INITIAL PUBLIC OFFERINGS
No Investment Personnel may acquire any Securities in an initial public
offering. For purposes of this restriction, "Initial Public Offerings" shall not
include offerings of government and municipal securities.
B. PRIVATE PLACEMENTS
No Investment Personnel may acquire any Securities in a private
placement
5
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<PAGE>
without prior approval.
(i) Prior approval must be obtained in accordance with
the preclearance procedure described in Section 6 below. Such
approval will take into account, among other factors, whether the
investment opportunity should be reserved for the Fund and its
shareholders and whether the opportunity is being offered to the
Investment Personnel by virtue of his or her position with the Fund.
The Adviser/Subadviser shall maintain a record of such prior approval
and reason for same, for at least 5 years after the end of the fiscal
year in which the approval is granted.
(ii) Investment Personnel who have been authorized to
acquire Securities in a private placement must disclose that
investment to the chief investment officer (including his or her
designee) of the Adviser/Subadviser (or of any unit or subdivision
thereof) or the Compliance Officer when they play a part in any
subsequent consideration of an investment by the Fund in the issuer.
In such circumstances, the Fund's decision to purchase Securities of
the issuer will be subject to an independent review by appropriate
personnel with no personal interest in the issuer.
C. BLACKOUT PERIODS
(i) Except as provided in Section 5 below, Access
Persons are prohibited from executing a Securities transaction on a
day during which any investment
6
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<PAGE>
company in the Complex has a pending "buy" or "sell" order in the same
or an equivalent Security and until such time as that order is
executed or withdrawn; provided, however, that this prohibition shall
not apply to Disinterested Directors/Trustees except if they have
actual knowledge of trading by any fund in the Complex and, in any
event, only with respect to those funds on whose boards they sit.
This prohibition shall also not apply to Access Persons of the
Subadviser who do not, in the ordinary course of fulfilling his or her
official duties, have access to information regarding the purchase and
sale of Securities for the Fund and are not engaged in the day-to-day
operations of the Fund; provided that Securities investments effected
by such Access Persons during the proscribed period are not effected
with knowledge of the purchase or sale of the same or equivalent
Securities by any fund in the Complex.
A "pending 'buy' or 'sell' order" exists when a decision to
purchase or sell a Security has been made and communicated.
(ii) Portfolio Managers are prohibited from buying or
selling a Security within seven calendar days before or after the Fund
trades in the same or an equivalent Security. Nevertheless, a personal
trade by any Investment Personnel shall not prevent a Fund in the same
Complex from trading in the same or an equivalent security. However,
such a transaction shall be subject to independent review by the
Compliance Officer.
(iii) If trades are effected during the periods proscribed
in (i) or (ii)
7
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<PAGE>
above, except as provided in (iv) below with respect to (i) above, any
profits realized on such trades will be promptly required to be
disgorged to the Fund.
(iv) A transaction by Access Persons (other than
Investment Personnel) inadvertently effected during the period
proscribed in (i) above will not be considered a violation of the Code
and disgorgement will not be required so long as the transaction was
effected in accordance with the preclearance procedures described in
Section 6 below and without prior knowledge of trading by any fund
in the Complex in the same or an equivalent Security.
D. SHORT-TERM TRADING PROFITS
Except as provided in Section 5 below, Investment Personnel are
prohibited from profiting from a purchase and sale, or sale and purchase, of
the same or an equivalent Security within any 60 calendar day period. If
trades are effected during the proscribed period, any profits realized on
such trades will be immediately required to be disgorged to the Fund.
E. SHORT SALES
No Access Person may sell any security short which is owned by any Fund
in the Complex. Access Persons may, however make short sales when he/she owns an
equivalent amount of the same security.
F. OPTIONS
No Access Person may write a naked call option or buy a naked put
option on a security owned by any Fund in the Complex. Access Persons may
purchase options on securities not held by any Fund in the Complex, or purchase
call options or write put
8
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<PAGE>
options on securities owned by any Fund in the Complex, subject to preclearance
and the same restrictions applicable to other Securities. Access Persons may
write covered call options or buy covered put options on a Security owned by
any Fund in the Complex at the discretion of the Compliance Officer.
G. INVESTMENT CLUBS
No Access Person may participate in an investment club.
5. EXEMPTED TRANSACTIONS
---------------------
Subject to preclearance in accordance with Section 6 below with respect
to subitems (b), (e), (f), (g) and (i) hereof, the prohibitions of Sections 4(C)
and 4(D) will not apply to the following:
(a) Purchases or sales of Securities effected in any
account over which the Access Person has no direct or indirect
influence or control or in any account of the Access Person which is
managed on a discretionary basis by a person other than such Access
Person and with respect to which such Access Person does not in fact
influence or control such transactions.
(b) Purchases or sales of Securities (or their
equivalents) which are not eligible for purchase or sale by any fund
in the Complex.
(c) Purchases or sales of Securities which are
non-volitional on the part of either the Access Person or any fund in
the Complex.
(d) Purchases of Securities which are part of an
automatic dividend reinvestment plan.
(e) Purchases effected upon the exercise of rights
issued by an issuer PRO RATA to all holders of a class of its
Securities, to the extent such rights were acquired from such issuer,
and sales of such rights so acquired.
(f) Any equity Securities transaction, or series of
related transactions effected over a 30 calendar day period, involving
500 shares or less in the aggregate, if (i) the Access Person has no
prior knowledge
9
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<PAGE>
of activity in such security by any fund in the Complex and (ii) the
issuer is listed on The New York Stock Exchange or has a market
capitalization (outstanding shares multiplied by the current price per
share) greater than $1 billion (or a corresponding market
capitalization in foreign markets).
(g) Any fixed-income Securities transaction, or series of
related transactions effected over a 30 calendar day period, involving
100 units ($100,000 principal amount) or less in the aggregate, if the
Access Person has no prior knowledge of transactions in such Securities
by any fund in the Complex.
(h) Any transaction in index options effected on a
broad-based index (See Exhibit B.)(1)
(i) Purchases or sales of Securities which receive the
prior approval of the Compliance Officer (such person having no
personal interest in such purchases or sales), based on a determination
that no abuse is involved and that such purchases and sales are not
likely to have any economic impact on any fund in the Complex or on its
ability to purchase or sell Securities of the same class or other
Securities of the same issuer.
(j) Purchases or sales of Unit Investment Trusts.
6. PRECLEARANCE
------------
Access Persons (other than Disinterested Directors/Trustees) must
preclear all personal Securities investments with the exception of those
identified in subparts (a), (c), (d), (h) and (j) of Section 5 above.
All requests for preclearance must be submitted to the Compliance
Officer for approval. All approved orders must be executed no later than
5:00 p.m. local time on the business day following the date preclearance is
granted. If any order is not timely executed, a request for preclearance
must be resubmitted.
7. REPORTING
---------
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<PAGE>
(a) Disinterested Directors/Trustees shall report to the
Secretary of the Fund or the Compliance Officer the information described in
Section 7(b) hereof with respect to transactions in any Security in which
such Disinterested Director/Trustee has, or by reason of such transaction
acquires, any direct or indirect Beneficial Ownership in the Security ONLY if
such Disinterested Director/Trustee, at the time of that transaction knew or,
in the ordinary course of fulfilling his or her official duties as a
Director/Trustee of the Fund, should have known that, during the 15-day
period immediately preceding or subsequent to the date of the transaction in
a Security by such Director/Trustee, such Security is or was purchased or
sold by the Fund or was being considered for purchase or sale by the Fund,
the Manager or Adviser/Subadviser; provided, however, that a Disinterested
Director/Trustee is not required to make a report with respect to
transactions effected in any account over which such Director/Trustee does
not have any direct or indirect influence or control or in any account of the
Disinterested Director/Trustee which is managed on a discretionary basis by a
person other than such Director/Trustee and with respect to which such
Director/Trustee does not in fact influence or control such transactions. The
Secretary of the Fund or the Compliance Officer shall maintain such reports
and such other records to the extent required by Rule 17j-1 under the Act.
(b) Every report required by Section 7(a) hereof shall be made
not later than ten days after the end of the calendar quarter in which the
transaction to which the report relates was effected, and shall contain the
following information:
-------------------------------------------------------------------------------
(1) Exhibit B will be amended by the Compliance Officer as necessary.
11
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<PAGE>
(i) The date of the transaction, the title and the number of
shares, and the principal amount of each Security involved;
(ii) The nature of the transaction (I.E., purchase, sale or any
other type of acquisition or disposition);
(iii) The price at which the transaction was effected;
(iv) The name of the broker, dealer or bank with or through whom
the transaction was effected; and
(v) The date that the report is submitted.
(c) Any such report may contain a statement that the report
shall not be construed as an admission by the person making such report
that he or she has any direct or indirect Beneficial Ownership in the
Security to which the report relates.
8. RECORDS OF SECURITIES TRANSACTIONS AND POST-TRADE REVIEW
--------------------------------------------------------
Access Persons (other than Disinterested Directors/Trustees) are
required to direct their brokers to supply, on a timely basis, duplicate
copies of confirmations of all personal Securities transactions and copies of
periodic statements for all Securities accounts in which such Access Persons
have a Beneficial Ownership interest to the Compliance Officer. Such
instructions must be made upon becoming an Access Person and promptly as new
accounts are established, but no later than ten days after the end of a
calendar quarter, with respect to any account established by the Access
Person in which any securities were held during the quarter for the direct or
indirect beneficial interest of the Access Person. Notification must be made
in writing and a copy of the notification must be submitted to Compliance.
This notification will include the broker, dealer or bank with which the
account was established and the date the account was established.
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<PAGE>
Compliance with this Code requirement will be deemed to satisfy the
reporting requirements imposed on Access Persons under Rule 17j-1(d),
provided, however, that such confirmations and statements contain all the
information required by Section 7. b. hereof and are furnished within the
time period required by such section.
The Compliance Officer will periodically review the personal
investment activity and holdings reports of all Access Persons (including
Disinterested Directors/Trustees with respect to Securities transactions
reported pursuant to Section 7 above).
9. DISCLOSURE OF PERSONAL HOLDINGS
-------------------------------
Within ten days after an individual first becomes an Access Person
and thereafter on an annual basis, each Access Person (other than
Disinterested Directors/Trustees) must disclose all personal Securities
holdings. Such disclosure must be made in writing and be as of the date the
individual first became an Access Person with respect to the initial report
and by January 30 of each year, including holdings information as of December
31, with respect to the annual report. All such reports shall include the
following: title, number of shares and principal amount of each security
held, name of broker, dealer or bank with whom these securities are held and
the date of submission by the Access Person.
10. GIFTS
-----
Access Persons are prohibited from receiving any gift or other
thing of more than $100 in value from any person or entity that does
business with or on behalf of the Fund. Occasional business meals or
entertainment (theatrical or sporting events, etc.) are permitted so long as
they are not excessive in number or cost.
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<PAGE>
11. SERVICE AS A DIRECTOR
---------------------
Investment Personnel are prohibited from serving on the boards of
directors of publicly traded companies, absent prior authorization based upon
a determination that the board service would be consistent with the interests
of the Fund and its shareholders. In the limited instances that such board
service is authorized, Investment Personnel will be isolated from those
making investment decisions affecting transactions in Securities issued by
any publicly traded company on whose board such Investment Personnel serves
as a director through the use of "Chinese Wall" or other procedures designed
to address the potential conflicts of interest.
12. CERTIFICATION OF COMPLIANCE WITH THE CODE
-----------------------------------------
Access Persons are required to certify annually as follows:
(i) that they have read and understood the Code;
(ii) that they recognize that they are subject to the Code;
(iii) that they have complied with the requirements of the Code; and
(iv) that they have disclosed or reported all personal Securities
transactions required to be disclosed or reported pursuant to
the requirements of the Code.
13. CODE VIOLATIONS
---------------
All violations of the Code will be reported to the Board of
Directors/Trustees of the Fund on a quarterly basis. The Board of
Directors/Trustees may take such action as it deems appropriate.
14. REVIEW BY THE BOARD OF DIRECTORS/TRUSTEES
-----------------------------------------
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The Board of Directors/Trustees will be provided with an annual report
which at a minimum:
(i) certifies to the Board that the Fund, Manager, Investment
Adviser/Subadviser, and Principal Underwriter has adopted procedures
reasonably necessary to prevent its Access persons from violating its Code.
(ii) summarizes existing procedures concerning personal investing and
any changes in the procedures made during the preceding year;
(iii) identifies material Code or procedural violations and sanctions
imposed in response to those material violations; and
(iv) identifies any recommended changes in existing restrictions or
procedures based upon the Fund's experience under the Code, evolving industry
practices, or developments in applicable laws and regulations.
The Board will review such report and determine if any further action
is required.
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<PAGE>
EXPLANATORY NOTES TO CODE
-------------------------
1. No comparable Code requirements have been imposed upon
Prudential Mutual Fund Services LLC, the Fund's transfer agent, or those of
its directors or officers who are not Directors/Trustees or Officers of the
Fund since they are deemed not to constitute Access Persons or Advisory
Persons as defined in paragraphs (e)(1) and (2) of Rule 17j-1.
Dated: February 29, 2000
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<PAGE>
EXHIBIT A
---------
DEFINITION OF BENEFICIAL OWNERSHIP
----------------------------------
The term "beneficial ownership" of securities would include not only
ownership of securities held by an access person for his or her own benefit,
whether in bearer form or registered in his or her own name or otherwise, but
also ownership of securities held for his or her benefit by other (regardless
of whether or how they are registered) such as custodians, brokers,
executors, administrators, or trustees (including trusts in which he or she
has only a remainder interest), and securities held for his or her account by
pledges, securities owned by a partnership in which he or she should regard
as a personal holding corporation. Correspondingly, this term would exclude
securities held by an access person for the benefit of someone else.
Ordinarily, this term would not include securities held by executors
or administrators in estates in which an access person is a legatee or
beneficiary unless there is a specific legacy to such person of such
securities or such person is the sole legatee or beneficiary and there are
other assets in the estate sufficient to pay debts ranking ahead of such
legacy, or the securities are held in the estate more than a year after the
decedent's death.
Securities held in the name of another should be considered as
"beneficially" owned by an access person where such person enjoys "benefits
substantially equivalent to ownership". The SEC has said that although the
final determination of beneficial ownership is a question to be determined in
the light of the facts of the particular case, generally a person is regarded
as the beneficial owner of securities held in the name of his or her spouse
and their minor children. Absent special circumstances such relationship
ordinarily results in such person obtaining benefits substantially equivalent
to ownership, e.g., application of the income derived from such securities to
maintain a common home, to meet expenses which such person otherwise would
meet from other sources, or the ability to exercise a controlling influence
over the purchase, sale or voting of such securities.
An access person also may be regarded as the beneficial owner of
securities held in the name of another person, if by reason of any contact,
understanding, relationship, agreement or other arrangement, he obtains
therefrom benefits substantially equivalent to those of ownership. Moreover,
the fact that the holder is a relative or relative of a spouse and sharing
the same home as an access person may in itself indicate that the access
person would obtain benefits substantially equivalent to those of ownership
from securities held in the name of such relative. Thus, absent
countervailing facts, it is expected that securities held by relatives who
share the same home as an access person will be treated as being beneficially
owned by the access person.
An access person also is regarded as the beneficial owner of
securities held in the name of a spouse, minor children or other person, even
though he does not obtain therefrom the aforementioned benefits of ownership,
if he can vest or revest title in himself at once or at some future time.
<PAGE>
EXHIBIT B
---------
INDEX OPTIONS ON A BROAD-BASED INDEX
<TABLE>
Caption
TICKER SYMBOL DESCRIPTION
<S> <C>
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NIK Nikkei 300 Index CI/Euro
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OEX S&P 100 Close/Amer Index
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OEW S&P 100 Close/Amer Index
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OEY S&P 100 Close/Amer Index
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SPB S&P 500 Index
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SPZ S&P 500 Open/Euro Index
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SPX S&P 500 Open/Euro Index
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SXZ S&P 500 (Wrap)
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SXB S&P 500 Open/Euro Index
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RUZ Russell 2000 Open/Euro Index
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RUT Russell 2000 Open/Euro Index
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MID S&P Midcap 400 Open/Euro Index
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NDX NASDAQ- 100 Open/Euro Index
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NDU NASDAQ- 100 Open/Euro Index
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NDZ NASDAQ- 100 Open/Euro Index
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NDV NASDAQ- 100 Open/Euro Index
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NCZ NASDAQ- 100 Open/Euro Index
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SML S&P Small Cap 600
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TPX U.S. Top 100 Sector
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SPL S&P 500 Long-Term Close
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ZRU Russell 2000 L-T Open./Euro
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VRU Russell 2000 Long-Term Index
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</TABLE>
