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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
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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
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definitions for entities which are referenced in this Code of Ethics.
II. Definitions
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For purposes of this Code, the following terms have the meanings set forth as
follows:
A. "Access Person" means:
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1. Any director, trustee or officer of a Fund, Adviser or Sub-Adviser/1/;
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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.
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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.
B. "Beneficial Ownership" of a Security is to be determined in the same manner
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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)
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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
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Funds, Adviser, Sub-Advisers or Distributor.
E. "Disinterested Director" means a director or trustee of a Fund who is not
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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
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"Beneficial Ownership" of that Security and includes, among other things,
the writing of an option to purchase or sell a Security.
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G. "Security" shall have the same meaning as that set forth in Section
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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
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A. Introduction
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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.
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
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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.
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C. Fraudulent Practices
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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.
IV. Requirements Applicable to Disinterested Directors
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A. Exceptions to Quarterly Transaction Report Requirement. Not withstanding
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the provisions of IV.B., a Disinterested Director is required to complete a
Quarterly Transaction Report only if the Disinterested Director knew or, in
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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.,
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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:
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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:
the date of the transaction, title, interest rate (if applicable),
number of shares and principal amount of each Security involved;
the type of transaction (i.e., purchase, sale or any other type of
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acquisition or disposition);
the price of the Security at which the transaction was effected;
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/2/ This reporting requirement shall not be applicable to securities traded by
passively managed index funds.
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the name of the broker, dealer or bank with or through whom the
transaction was effected;
the date the report was submitted.
V. Requirements Applicable to Adviser, Sub-Adviser and Distributors
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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
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A), provided that:
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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
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ENTITY DEFINITIONS
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"Fund" shall mean each of the following and any series of the following
hereafter designated:
BT Investment Funds
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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
Preservation Plus Income
Global Equity Fund
BT Institutional Funds
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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
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EAFE Equity Index - Premier Class
Small Cap Index - Premier Class
U.S. Bond Index - Premier Class
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BT Investment Portfolios
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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
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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
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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
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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
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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
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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
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QUARTERLY PERSONAL SECURTIES TRANSACTIONS REPORT FOR
DISINTERESTED DIRECTORS
A Disinterested Director is required to complete this report ONLY IF the
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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: ______________________________________________
Calendar Quarter Ended: ________________________________________________
Securities Transactions
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<TABLE>
<CAPTION>
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Number of Number of Disclaim
Name of Shares Broker, Beneficial
Date of Issuer and Principal Type of Dealer of Ownership?
Transaction Title of Amount, Transaction Price Bank (indicate by
Security Maturity Date Effecting "X")
and Interest Transaction -
Rate (if
applicable)
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<S> <C> <C> <C> <C> <C> <C>
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</TABLE>
I certify that I have included on this report all securities transactions
required to be reported pursuant to the Code of Ethics.
_____________________________ ____________________________
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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* 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.
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