<PAGE>
CREDIT SUISSE ASSET MANAGEMENT, LLC
CREDIT SUISSE ASSET MANAGEMENT SECURITIES, INC.
WARBURG PINCUS FUNDS
CREDIT SUISSE INSTITUTIONAL FUNDS
CSAM CLOSED-END FUNDS
CODE OF ETHICS
I. APPLICABILITY
This Code of Ethics establishes rules of conduct for ""Access Persons' (as
defined below) of Credit Suisse Asset Management, LLC, Credit Suisse Asset
Management Securities, Inc. (collectively referred to as "CSAM" and each U.S.
registered investment company that adopts this Code ("Covered Fund"" (CSAM and
the Covered Funds are collectively referred to as the "Covered Companies").
For purposes of this Code, "Access Person" shall mean:
- any "Advisory Person" -- any employee or officer of CSAM and any
natural person in a control relationship to a Covered Company
(except for a natural person who, but for his or her holdings in a
Covered Fund, would not be considered an Advisory Person, unless he
or she obtains information concerning recommendations made to the
Covered Fund with regard to the purchase or sale of securities by
the Covered Fund, in which case such person shall be considered an
Advisory Person only with respect to the Covered Fund); or
- any director, trustee or officer of a Covered Fund, whether or not
such person is an Advisory Person, in which case such person shall
be considered an Access Person only with respect to the Covered
Fund.
For purposes of this Code:
- the term "'security" shall include any option to purchase or sell,
any security that is convertible or exchangeable for, and any other
derivative interest relating to the security;
- the terms "purchase" and "sale' of a security shall include, among
other things, the writing of an option to purchase or sell a
security; and
- all other terms shall have the same meanings as under the Investment
Company Act of 1940 ("1940 Act"), unless indicated otherwise.
II. STATEMENT OF GENERAL PRINCIPLES
In conducting personal investment activities, all Access Persons are required
to act consistent with the following general fiduciary principles:
- the interests of CSAM clients, including Covered Funds, must always
be placed first, provided, however, that persons who are Access
Persons only with respect to certain Covered Funds shall place the
interests of such Covered Funds first;
<PAGE>
- all personal securities transactions must be conducted 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;
and
- Access Persons must not take inappropriate advantage of their
positions.
CSAM has a separate policy and procedures designed to detect and prevent
insider trading, which should be read together with this Code. Nothing
contained in this Code should be interpreted as relieving any Access Person
from the obligation to act in accordance with any applicable law, rule or
regulation or any other statement of policy or procedure adopted by any
Covered Company.
III. PROHIBITIONS
The following prohibitions and related requirements apply to Advisory Persons
and/or Access Persons (as stated) and accounts in which they have "Beneficial
Ownership" (as defined in Exhibit 1).
A. SHORT TERM TRADING. CSAM discourages Advisory Persons from short-term
trading (i.e., purchases and sales within a 60 day period), as such activity
could be viewed as being in conflict with CSAM's general fiduciary principles.
In no event, however, may an Advisory Person make a purchase and sale (or sale
and purchase) of a security, including shares of Covered Funds and other U.S.
registered investment companies (other than money market funds), within five
"'Business Days" (meaning days on which the New York Stock Exchange is open
for trading). CSAM reserves the right to extend this prohibition period for
the short-term trading activities of any or all Advisory Persons if CSAM
determines that such activities are being conducted in a manner that may be
perceived to be in conflict with CSAM's general fiduciary principles.
B. SIDE-BY-SIDE TRADING. No Access Person may purchase or sell (directly or
indirectly) any security for which there is a "buy" or "sell" order pending
for a CSAM client (except that this restriction does not apply to any Access
Person who is neither an Advisory Person nor an officer of a Covered Fund,
unless he or she knows, or in the ordinary course of fulfilling official
duties with a Covered Fund should know, that there is a 'buy" or 'sell" order
pending with respect to such security for a CSAM client), or that such Access
Person knows (or should know) at the time of such purchase or sale:
- is being considered for purchase or sale by or for any CSAM
client; or
- is being purchased or sold by or for any CSAM client.
C. BLACKOUT PERIODS. No Advisory Person may execute a securities transaction
within five Business Days before and one Business Day after a transaction in
that security for a CSAM client.
D. PUBLIC OFFERINGS. No Advisory Person may directly or indirectly acquire
Beneficial Ownership in any security in a public offering in the primary
securities market.
2
<PAGE>
E. PRIVATE PLACEMENTS. No Advisory Person may directly or indirectly acquire
or dispose of any Beneficial Ownership in any privately placed security
without the express prior written approval of a supervisory person designated
in Section IX of this Code ("Designated Supervisory Person").
Approval will take into account, among other factors, whether the investment
opportunity should be reserved for a CSAM client, whether the opportunity is
being offered to the Advisory Person because of his or her position with CSAM
or as a reward for past transactions and whether the investment creates or may
in the future create a conflict of interest.
F. SHORT SELLING. Advisory Persons are only permitted to engage in short
selling for hedging purposes. No Advisory Person may engage in any transaction
that has the effect of creating any net "'short exposure" in an individual
security.
G. FUTURES CONTRACTS. No Advisory Person may invest in futures contracts,
except through the purchase of options on futures contracts.
H. OPTIONS. No Advisory Person may write (i.e., sell) any options except for
hedging purposes and only if the option is fully covered.
I. TRADING, HEDGING AND SPECULATION IN CREDIT SUISSE GROUP SECURITIES.
Transactions by employees, officers and directors of CSAM in securities of
Credit Suisse Group ("CSG') are prohibited for each period beginning 15
calendar days before announcement of CSG yearly or half-yearly results and
ending two Business Days after the announcement. Employees, officers and
directors of CSAM may only hedge VESTED positions in CSG stock through short
sales or derivative instruments. Uncovered short exposure, through short sales
or otherwise, is not permitted without the express prior written approval of a
Designated Supervisory Person.
J. INVESTMENT CLUBS. No Advisory Person may participate in an "'investment
club' or similar activity.
K. DISCLOSURE OF INTEREST. No Advisory Person may recommend to or effect for
any CSAM client any securities transaction without having disclosed his or her
personal interest (actual or potential), if any, in the issuer of the
securities, including without limitation:
- any ownership or contemplated ownership of any privately placed
securities of the issuer or any of its affiliates;
- any employment, management or official position with the issuer or
any of its affiliates;
- any present or proposed business relationship between the Advisory
Person and the issuer or any of its affiliates; and
- any additional factors that may be relevant to a conflict of
interest analysis.
Where the Advisory Person has a personal interest in an issuer, a decision to
purchase or sell securities of the issuer or any of its affiliates by or for a
CSAM client shall be subject to an independent review by a Designated
Supervisory Person.
3
<PAGE>
L. GIFTS. No Advisory Person may seek or accept any gift of more than a DE
MINIMIS value (approximately $250 per year) from any person or entity that
does business with or on behalf of a CSAM client, other than reasonable,
business-related meals and tickets to sporting events, theater and similar
activities. If any Advisory Person is unsure of the appropriateness of any
gift, a Designated Supervisory Person should be consulted.
M. DIRECTORSHIPS AND OTHER OUTSIDE BUSINESS ACTIVITIES. No Advisory Person may
serve on the board of directors/trustees of any issuer without the express
prior written approval of a Designated Supervisory Person. Approval will be
based upon a determination that the board service would be consistent with the
interests of CSAM clients. Where board service is authorized, Advisory Persons
serving as directors will be isolated from those making investment decisions
regarding the securities of that issuer through 'informational barrier" or
other procedures specified by a Designated Supervisory Person.
No Advisory Person may be employed (either for compensation or in a voluntary
capacity) outside his or her regular position with CSAM or its affiliated
companies without the written approval of a Designated Supervisory Person.
IV. EXEMPT TRANSACTIONS
A. EXEMPTIONS FROM PROHIBITIONS.
1. Purchases and sales of securities issued or
guaranteed by the U.S. government or any agencies or
instrumentalities of the U.S. government, municipal
securities, and other non-convertible fixed income securities,
which are in each case rated investment grade, are exempt from
the prohibitions described in paragraphs C and D of Section
III if such transactions are made in compliance with the
preclearance requirements of Section V(B) below.
2. Any securities transaction, or series of related
transactions, which, because of the amount of securities
involved and the market capitalization of the issuer, appear
to present no reasonable likelihood of harm to, or conflict
with, a CSAM Client, is exempt from the prohibition described
in paragraph C of Section III if such transaction is made in
compliance with the preclearance requirements of Section V(B)
below.
B. EXEMPTIONS FROM PROHIBITIONS AND PRECLEARANCE. The prohibitions described
in paragraphs B through E of Section III and the preclearance requirements of
Section V(B) shall not apply to:
- purchases and sales of securities that are direct obligations of the
U.S. government;
- purchases and sales of securities of U.S. registered open-end
investment companies;
- purchases and sales of bankers' acceptances, bank certificates of
deposit, and commercial paper;
- purchases that are part of an automatic dividend reinvestment plan;
4
<PAGE>
- purchases and sales that are non-volitional on the part of either
the Access Person or the CSAM client;
- purchases and sales in any account maintained with a party that has
no affiliation with the Covered Companies and over which no Advisory
Person has, in the judgment of a Designated Supervisory Person after
reviewing the terms and circumstances, direct or indirect influence
or control over the investment or trading of the account; and
- purchases by the exercise of rights offered by an issuer pro rata to
all holders of a class of its securities, to the extent that such
rights were acquired from the issuer.
C. FURTHER EXEMPTIONS. Express prior written approval may be granted by a
Designated Supervisory Person if a purchase or sale of securities or other
outside activity is consistent with the purposes of this Code and Section
17(j) of the 1940 Act and rules thereunder (attached as Attachment A is a form
to request such approval). For example, a purchase or sale may be considered
consistent with those purposes if the purchase or sale is not harmful to a
CSAM client because such purchase or sale would be unlikely to affect a highly
institutional market, or because such purchase or sale is clearly not related
economically to the securities held, purchased or sold by the CSAM client.
V. TRADING, PRECLEARANCE, REPORTING AND OTHER COMPLIANCE PROCEDURES
A. TRADING THROUGH CSAM. No Advisory Person shall purchase or sell securities
for an account in which he or she has Beneficial Ownership other than through
the CSAM trading desk persons designated by a Designated Supervisory Person,
unless express prior written approval is granted by a Designated Supervisory
Person.
B. PRECLEARANCE. Except as provided in Section IV, before any Advisory Person
purchases or sells any security for any account in which he or she has
Beneficial Ownership, preclearance shall be obtained in writing from a
Designated Supervisory Person (attached as Attachment B is a form to request
such approval). If clearance is given for a purchase or sale and the
transaction is not effected on that Business Day, a new preclearance request
must be made.
C. REPORTING.
1. INITIAL CERTIFICATION. Within 10 days after the commencement of his or her
employment with CSAM or his or her affiliation with any Covered Fund, each
Access Person shall submit to a Designated Supervisory Person an initial
certification in the form of Attachment C to certify that:
- he or she has read and understood this Code of Ethics and
recognizes that he or she is subject to its requirements; and
- he or she has disclosed or reported all personal securities holdings
in which he or she has any direct or indirect Beneficial Ownership
and all accounts in which any securities are held for his or her
direct or indirect benefit.
2. ANNUAL CERTIFICATION. In addition, each Access Person shall submit to a
Designated Supervisory Person an annual certification in the form of
Attachment D to certify that:
5
<PAGE>
- he or she has read and understood this Code of Ethics and recognizes
that he or she is subject to its requirements;
- he or she has complied with all requirements of this Code of
Ethics; and
- he or she has disclosed or reported (a) all personal securities
transactions for the previous year and (b) all personal securities
holdings in which he or she has any direct or indirect Beneficial
Ownership and accounts in which any securities are held for his or
her direct or indirect benefit as of a date no more than 30 days
before the annual certification is submitted.
Access Persons may comply with the initial and annual reporting requirements
by submitting account statements and/or Attachment E to a Designated
Supervisory Person within the prescribed periods. An Access Person who is not
an Advisory Person is not required to submit initial or annual certifications,
unless such Access Person is an officer of a Covered Fund.
Each Advisory Person shall annually disclose all directorships and outside
business activities (attached as Attachment F is a form for such disclosure).
3. QUARTERLY REPORTING. All Advisory Persons and each Access Person who is an
officer of a Covered Fund shall also supply a Designated Supervisory Person,
on a timely basis, with duplicate copies of confirmations of all personal
securities transactions and copies of periodic statements for all securities
accounts, including confirmations and statements for transactions and accounts
described in Section IV(B) above (exempt from prohibitions and preclearance).
This information must be supplied at least once per calendar quarter, within
10 days after the end of the calendar quarter.
Each Access Person who is neither an Advisory Person nor an officer of a
Covered Fund is required to report a transaction only if he or she, at the
time of that transaction, knew (or in the ordinary course of fulfilling
official duties with a Covered Fund should have known) that during the 15-day
period immediately before or after the date of the transaction the security
such person purchased or sold was purchased or sold by the Covered Fund or was
being considered for purchase or sale by the Covered Fund.
VI. COMPLIANCE MONITORING AND SUPERVISORY REVIEW
A Designated Supervisory Person will periodically review reports from the CSAM
trading desk (or, if applicable, confirmations from brokers) to assure that
all transactions effected by Access Persons for accounts in which they have
Beneficial Ownership are in compliance with this Code and Rule 17j-1 under the
1940 Act.
Material violations of this Code and any sanctions imposed shall be reported
not less frequently than quarterly to the board of directors of each relevant
Covered Fund and to the senior management of CSAM. At least annually, each
Covered Company shall prepare a written report to the board of
directors/trustees of each Covered Fund, and to the senior management of CSAM,
that:
6
<PAGE>
- describes issues that have arisen under the Code since the last
report, including, but not limited to, material violations of the
Code or procedures that implement the Code and any sanctions imposed
in response to those violations; and
- certifies that each Covered Company has adopted procedures
reasonably necessary to prevent Access Persons from violating the
Code.
Material changes to this Code of Ethics must be approved by the Board of
Directors of each Covered Fund no later than six months after the change is
adopted. That approval must be based on a determination that the changes are
reasonably necessary to prevent Access Persons from engaging in any conduct
prohibited by the Code and Rule 17j-1 under the 1940 Act. Board approval must
include a separate vote of a majority of the independent directors.
VII. SANCTIONS
Upon discovering that an Access Person has not complied with the requirements
of this Code, the senior management of the relevant Covered Company may impose
on that person whatever sanctions are deemed appropriate, including censure;
fine; reversal of transactions and disgorgement of profits; suspension; or
termination of employment.
VIII. CONFIDENTIALITY
All information obtained from any Access Person under this Code shall be kept
in strict confidence, except that reports of transactions will be made
available to the Securities and Exchange Commission or any other regulatory or
self-regulatory organization to the extent required by law or regulation.
IX. FURTHER INFORMATION
The Designated Supervisory Persons are Hal Liebes and James W. Bernaiche or
their designees in CSAM's legal and compliance department. Any questions
regarding the Code of Ethics should be directed to a Designated Supervisory
Person.
Dated: August 1, 2000
7
<PAGE>
EXHIBIT 1
CREDIT SUISSE ASSET MANAGEMENT, LLC
CREDIT SUISSE ASSET MANAGEMENT SECURITIES, INC.
WARBURG PINCUS FUNDS
CREDIT SUISSE INSTITUTIONAL FUNDS
CSAM CLOSED-END FUNDS
CODE OF ETHICS
DEFINITION OF BENEFICIAL OWNERSHIP
The term "Beneficial Ownership" as used in the attached Code of Ethics is to
be interpreted by reference to Rule 16a-l(a)(2) under the Securities Exchange
Act of 1934 ("Rule"). Under the Rule, a person is generally deemed to have
Beneficial Ownership of securities if the person (directly or indirectly),
through any contract, arrangement, understanding, relationship or otherwise,
has or shares a direct or indirect pecuniary interest in the securities.
The term "pecuniary interest" is generally defined in the Rule to mean the
opportunity (directly or indirectly) to profit or share in any profit derived
from a transaction in the securities. A person is deemed to have an 'indirect
pecuniary interest' within the meaning of the Rule:
- in any securities held by members of the person's immediate family
sharing the same household; the term "immediate family" includes any
child, stepchild, grandchild, parent, stepparent, grandparent,
spouse, sibling, mother-in-law, father-in-law, son-in-law,
daughter-in-law, brother-in-law or sister-in-law, as well as
adoptive relationships;
- a general partner's proportionate interest in the portfolio
securities held by a general or limited partnership;
- a person's right to dividends that is separated or separable from
the underlying securities;
- a person's interest in certain trusts; and
- a person's right to acquire equity securities through the exercise
or conversion of any derivative security, whether or not presently
exercisable.(1)
For purposes of the Rule, a person who is a shareholder of a corporation or
similar entity is NOT deemed to have a pecuniary interest in portfolio
securities held by the corporation or entity, so long as the shareholder is
not a controlling shareholder of the corporation or the entity and does not
have or share investment control over the corporation's or the entity's
portfolio. The term "control" means the power to exercise a controlling
influence over management or policies, unless the power is solely the result
of an official position with the company.
------------------------
(1) The term "derivative security" is defined as any option, warrant,
convertible security, stock appreciation right or similar right with an
exercise or conversion privilege at a price related to an equity security
(or similar securities) with a value derived from the value of an equity
security.
<PAGE>
ATTACHMENT A
CREDIT SUISSE ASSET MANAGEMENT, LLC
CREDIT SUISSE ASSET MANAGEMENT SECURITIES, INC.
WARBURG PINCUS FUNDS
CREDIT SUISSE INSTITUTIONAL FUNDS
CSAM CLOSED-END FUNDS
CODE OF ETHICS
CODE OF ETHICS -- SPECIAL APPROVAL FORM
1. The following is a private placement of securities or other investment
requiring special approval in which I want to acquire or dispose of
Beneficial Ownership:
<TABLE>
<CAPTION>
NAME OF
PRIVATE
SECURITY OR
OTHER DATE TO BE AMOUNT TO RECORD PURCHASE HOW ACQUIRED
INVESTMENT ACQUIRED BE HELD OWNER PRICE (BROKER/ISSUER)
----------------------------------------------------------------------------------------------------------
<S> <C> <C> <C> <C> <C>
----------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------
</TABLE>
Would this investment opportunity be appropriate for a CSAM client?
___ Yes ___ No
2. I want to engage in the following outside business activity:
----------------------------------------------------------------------
----------------------------------------------------------------------
----------------------------------------------------------------------
3. I want special approval to place personal securities trades other than
through the CSAM trading desk (please describe):
----------------------------------------------------------------------
----------------------------------------------------------------------
----------------------------------------------------------------------
I certify, as applicable, that I (a) am not aware of any non-public
information about the issuer, (b) have made all disclosures required by the
Code of Ethics and (c) will comply with all reporting requirements of the Code.
-------------------- ----------------
Signature Date
--------------------
Print Name
___Approved
<PAGE>
___Not Approved
------------------------------ ----------------
Designated Supervisory Person Date
10
<PAGE>
ATTACHMENT B
CREDIT SUISSE ASSET MANAGEMENT, LLC
CREDIT SUISSE ASSET MANAGEMENT SECURITIES, INC.
WARBURG PINCUS FUNDS
CREDIT SUISSE INSTITUTIONAL FUNDS
CSAM CLOSED-END FUNDS
CODE OF ETHICS
CODE OF ETHICS -- PERSONAL TRADING PRECLEARANCE FORM
This form should be filled out COMPLETELY to expedite approval.
1. Security:
----------------------------------
Ticker:
----------------------------------
___Purchase ___Sale
2. Number of shares/bonds/units/contracts:
------------------------
3. Account Name/Short name:
-------------------------------
4. Brokerage Firm AND Account Number:
------------------------
5. Why do you want to purchase or sell? Is this an opportunity appropriate for
CSAM clients?
----------------------------------------------------------------------------
6. Are you aware of a CSAM Advisory Person who is buying or selling or who
plans to buy or sell this security for his or her personal accounts or
CSAM clients?
____ Yes ____ No
If yes, who?
----------------------------------------------------------------------------
7. If the amount is less than ___ 1000 shares, is the issuer market
capitalization greater than $2.5 billion?
___Yes ___No
I certify that I (a) am not aware of any non-public information about the
issuer, (b) have made all disclosures required by the Code of Ethics and this
trade otherwise complies with the Code, including the prohibition on
investments in initial public offerings, and (c) will comply with all
reporting requirements of the Code.
------------------------------- ----------------
Signature of Advisory Person Date
------------------------------- ----------------
Print Name
___ Approved
___ Not Approved
------------------------------- ----------------
Designated Supervisory Person Date - VALID THIS
BUSINESS DAY ONLY.
<PAGE>
ATTACHMENT C
CREDIT SUISSE ASSET MANAGEMENT, LLC
CREDIT SUISSE ASSET MANAGEMENT SECURITIES, INC.
WARBURG PINCUS FUNDS
CREDIT SUISSE INSTITUTIONAL FUNDS
CSAM CLOSED-END FUNDS
CODE OF ETHICS
INITIAL CERTIFICATION
I certify that I:
- have read and understood (1) the Code of Ethics for Credit Suisse
Asset Management, LLC, Credit Suisse Asset Management Securities,
Inc., the Warburg Pincus Funds, the Credit Suisse Institutional
Funds and the CSAM Closed-End Funds, (2) the Legal and Compliance
Manual for Credit Suisse Asset Management, LLC, (3) the Global
Compliance Policy Manual for Credit Suisse Asset Management and (4)
the Credit Suisse Asset Management, LLC Policy and Procedures
Designed to Detect and Prevent Insider Trading and recognize that I
am subject to their requirements; and
- have disclosed or reported all personal securities holdings in which
I had any direct or indirect Beneficial Ownership and accounts in
which any securities were held for my direct or indirect benefit as
of the date I commenced employment with CSAM or the date I became
affiliated with a Covered Fund.
------------------------------- ----------------
Signature of Access Person Date
-------------------------------
Print Name
<PAGE>
ATTACHMENT D
CREDIT SUISSE ASSET MANAGEMENT, LLC
CREDIT SUISSE ASSET MANAGEMENT SECURITIES, INC.
WARBURG PINCUS FUNDS
CREDIT SUISSE INSTITUTIONAL FUNDS
CSAM CLOSED-END FUNDS
CODE OF ETHICS
ANNUAL CERTIFICATION
I certify that I:
- have read and understood (1) the Code of Ethics for Credit Suisse
Asset Management, LLC, Credit Suisse Asset Management Securities,
Inc., the Warburg Pincus Funds, the Credit Suisse Institutional
Funds and the CSAM Closed-End Fund, (2) the Legal and Compliance
Manual for Credit Suisse Asset Management, LLC, (3) the Global
Compliance Policy Manual for Credit Suisse Asset Management and (4)
the Credit Suisse Asset Management, LLC Policy and Procedures
Designed to Detect and Prevent Insider Trading (collectively, the
"Compliance Policies) and recognize that I am subject to their
requirements;
- have complied with all requirements of the Compliance Policies in
effect during the year ended December 31, 2___; and
- have disclosed or reported all personal securities transactions for
the year ended December 31, 2___ and all personal securities
holdings in which I had any direct or indirect Beneficial Ownership
and all accounts in which any securities were held for my direct or
indirect benefit as of December 31, 2___
------------------------------- ----------------
Signature of Access Person Date
-------------------------------
Print Name
<PAGE>
ATTACHMENT E
CREDIT SUISSE ASSET MANAGEMENT, LLC
CREDIT SUISSE ASSET MANAGEMENT SECURITIES, INC.
WARBURG PINCUS FUNDS
CREDIT SUISSE INSTITUTIONAL FUNDS
CSAM CLOSED-END FUNDS
CODE OF ETHICS
PERSONAL SECURITIES ACCOUNT DECLARATION
ALL ACCESS PERSONS MUST COMPLETE EACH APPLICABLE ITEM (1, 2, 3 OR 4) AND SIGN
BELOW.
1. The following is a list of securities/commodities accounts in which I have
Beneficial Ownership:
BROKER/DEALER ACCOUNT TITLE AND NUMBER
-------------------------------------------------------------------------------
-------------------------------------------------------------------------------
-------------------------------------------------------------------------------
-------------------------------------------------------------------------------
-------------------------------------------------------------------------------
2. The following is a list of securities/commodities accounts in which I had
Beneficial Ownership that have been opened or closed in the past year:
BROKER/DEALER ACCOUNT TITLE AND NUMBER
-------------------------------------------------------------------------------
-------------------------------------------------------------------------------
-------------------------------------------------------------------------------
-------------------------------------------------------------------------------
-------------------------------------------------------------------------------
3. The following is a list of any other securities or other investment holdings
in which I have Beneficial Ownership (FOR SECURITIES HELD IN ACCOUNTS OTHER
THAN THOSE DISCLOSED IN RESPONSE TO ITEMS 1 AND 2):
<TABLE>
<CAPTION>
NAME OF
PRIVATE
SECURITY OR
OTHER DATE TO BE AMOUNT TO RECORD PURCHASE HOW ACQUIRED
INVESTMENT ACQUIRED BE HELD OWNER PRICE (BROKER/ISSUER)
----------------------------------------------------------------------------------------------------------
<S> <C> <C> <C> <C> <C>
----------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------
</TABLE>
4. I do not have Beneficial Ownership in any securities/commodities accounts or
otherwise have Beneficial Ownership of any securities or other instruments
subject to the Code of Ethics. (Please initial.)
----------
Initials
I declare that the information given above is true and accurate:
-------------------------------- ----------------
Signature of Access Person Date
--------------------------------
Print Name
<PAGE>
ATTACHMENT F
CREDIT SUISSE ASSET MANAGEMENT, LLC
CREDIT SUISSE ASSET MANAGEMENT SECURITIES, INC.
WARBURG PINCUS FUNDS
CREDIT SUISSE INSTITUTIONAL FUNDS
CSAM CLOSED-END FUNDS
CODE OF ETHICS
OUTSIDE BUSINESS ACTIVITIES
Outside business activities include, but are not limited to, the following:
- self-employment;
- receiving compensation from another person or company;
- serving as an officer, director, partner, or consultant of another
business organization (including a family owned company); and
- becoming a general or limited partner in a partnership or owning any
stock in a business, unless the stock is publicly traded and no
control relationship exists.
Outside business activities include serving with a governmental (federal, state
or local) or charitable organization whether or not for compensation.
ALL ADVISORY PERSONS MUST COMPLETE AT LEAST ONE CHOICE (1 OR 2) AND SIGN BELOW.
1. The following are my outside business activities:
<TABLE>
<CAPTION>
OUTSIDE BUSINESS DESCRIPTION OF APPROVED BY DESIGNATED
ACTIVITY ACTIVITY SUPERVISORY PERSON (YES/NO)
---------------------------------------------------------------------------------
<S> <C> <C>
---------------------------------------------------------------------------------
---------------------------------------------------------------------------------
---------------------------------------------------------------------------------
---------------------------------------------------------------------------------
---------------------------------------------------------------------------------
---------------------------------------------------------------------------------
</TABLE>
2. I am not involved in any outside business activities. (Please initial)
----------
Initials
I declare that the information given above is true and accurate:
------------------------------- ----------------
Signature of Advisory Person Date
-------------------------------
Print Name
