<PAGE>
EXHIBIT (P1)
WEBS INDEX FUND, INC.
CODE OF ETHICS
Effective May, 2000
WEBS Index Fund, Inc. (the WEBS Fund) is confident that its directors,
officers and employees act with integrity and good faith. The WEBS Fund
recognizes, however, that personal interests may conflict with the WEBS Fund's
interests where officers or directors:
. know about present or future portfolio transactions; or
. have the power to influence portfolio transactions; and
. engage in securities transactions for their personal account(s).
In an effort to prevent these conflicts and in accordance with Rule 17j-1
under the Investment Company Act of 1940, as amended, (the 1940 Act), the WEBS
Fund has adopted this Code of Ethics (the Code) to prohibit transactions and
conduct that create conflicts of interest, and to establish reporting
requirements and enforcement procedures. (Definitions of underlined terms are
----------
included in Appendix A).
I. About the WEBS Fund and the Advisor.
The WEBS Fund is a registered investment company that consists of multiple
investment portfolios (the Funds). Barclays Global Fund Advisors (the Advisor)
is the investment advisor for the Funds. The Advisor manages the Funds' assets
with a view to matching the performance of each Fund's corresponding benchmark
index as closely as possible. In buying and selling securities for the WEBS
Funds, the Advisor employs replication and representative sampling strategies.
Because of these investment methodologies, the personal securities activities of
the Directors and officers of the WEBS Fund are less likely to create a conflict
of interest than they may in investment companies that employ performance-based
or fundamental research-driven investment or other discretionary strategies.
Consequently, the WEBS Fund has considered, but not adopted, many of the
recommendations of the Investment Company Institute's Advisory Group on Personal
Trading.
II. About this Code of Ethics
A. Who is covered by the Code?
All WEBS Fund officers;
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All Directors, both interested and independent; and Natural persons
---------- -----------
in a control relationship to a Fund who obtain information
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concerning recommendations about the purchase or sale of any
----------------
security by a Fund (Natural Control Persons).
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B. What rules apply to me?
<PAGE>
This Code sets forth specific prohibitions regarding securities
----------
transactions and sets out certain reporting requirements. For the
reporting requirements that apply to you, please refer to Parts A -
D, as indicated below.
Independent Directors Part A
---------------------
Interested Directors Part B
--------------------
WEBS Fund Officers Part C
------------------
Natural Control Persons Part D
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III. Statement of General Principles.
In recognition of the trust and confidence placed in the WEBS Fund by its
shareholders, and because the WEBS Fund believes that its operations should
benefit its shareholders, the WEBS Fund has adopted the following general
principles:
A. The interests of our shareholders are paramount. Shareholder
interests must be placed before your own.
B. You must accomplish all personal securities transactions in a
manner that avoids a conflict between your personal interests and
those of the WEBS Fund and its shareholders.
C. You must avoid actions or activities that allow you or your family
to profit or benefit from your position with the WEBS Fund, or that
bring into question your independence or judgment.
IV. Prohibition Against Fraud, Deceit and Manipulation.
You cannot, in connection with the direct or indirect purchase or sale of a
security held or to be acquired by a Fund:
-------------------------------
A. employ any device, scheme or artifice to defraud the Fund;
B. make to the 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;
C. engage in any act, practice or course of business that operates or
would operate as a fraud or deceit upon the Fund;
D. engage in any manipulative practice with respect to the
Fund.
V. Review and Enforcement of the WEBS Fund's Code.
A. Appointment of a Review Officer.
<PAGE>
A review officer (the Review Officer) will be appointed by the
Chairman of the Board of Directors (Chairman) to perform the
duties described in this Section V.
B. The Review Officer's Duties and Responsibilities.
(1) The Review Officer shall notify each person who becomes an
Access Person of the WEBS Fund and is required to report under
-------------
the Code of their reporting obligations, no later than 10 days
before the first quarter in which such person is obligated to
begin reporting.
(2) The Review Officer will, on a quarterly basis, compare all
reported personal securities transactions with the Funds'
----------
completed portfolio transactions and a list of securities being
----------------
considered for purchase (i.e., trade lists) by the Advisor
-----------------------
during the quarter to determine whether a Code violation may
have occurred. The Review Officer may request additional
information or take any other appropriate measure that the
Review Officer decides is necessary to aid in this
determination. Before determining that a person has violated
the Code, the Review Officer must give the person an
opportunity to supply explanatory material.
(3) If the Review Officer finds that a Code violation may have
occurred, the Review Officer must create and submit a written
report regarding the possible violation, together with the
confidential quarterly report and any explanatory material
provided by the person, to the Chairman and legal counsel
(Counsel) for the WEBS Fund. The Chairman and Counsel will
determine whether the person violated the Code.
(4) No person is required to participate in a determination of
whether he or she has committed a Code violation or discuss the
imposition of any sanction against himself or herself.
(5) If required, the Review Officer will submit his or her own
reports (as required) to an alternate Review Officer who will
fulfill the duties of the Review Officer with respect to such
reports. If a securities transaction of the Review Officer is
----------
under review for a possible violation, an officer of the WEBS
Fund will act for the alternate Review Officer for purposes of
this Section V.
C. Exceptions.
In the event that a person subject to the Code believes that he
or she is unable to comply with certain provisions of the Code,
the person must notify the Review Officer in writing, setting
forth the reasons why he or she cannot comply with the Code.
The Review Officer, in his or her discretion, may exempt this
person from any such provisions of the Code if the
<PAGE>
Review Officer determines that (a) the services of the person are
valuable to the WEBS Fund or the Advisor; (b) the failure to grant
this exemption will result in an undue burden on the person or
prevent the person from being able to render services to the WEBS
Fund or the Advisor; and (c) granting the exemption does not
detrimentally affect the shareholders of the WEBS Fund or the
Advisor. The Review Officer will prepare a report documenting the
nature of any exemption granted, the persons involved and the
reasons for granting such exemption.
Any person granted an exemption with respect to a particular
transaction must furnish the Review Officer with a written report
concerning that transaction within three days of the transaction.
D. Sanctions.
If the Chairman and Counsel determine that a person violated the
Code pursuant to paragraph B.(3) above, disciplinary action may be
taken and sanctions may be imposed.
VI. Recordkeeping.
The WEBS Fund will maintain records as set forth below. These records will
be maintained in accordance with Rule 31a-2 under the 1940 Act and the following
requirements. They will be available for examination by representatives of the
Securities and Exchange Commission and other regulatory agencies.
A. A copy of this Code and any other code adopted by the WEBS Fund
which is, or at any time within the past five years has been, in
effect will be preserved in an easily accessible place.
B. A record of any Code violation and of any sanctions taken will be
preserved in an easily accessible place for a period of at least
five years following the end of the fiscal year in which the
violation occurred.
C. A copy of each Quarterly, Initial and Annual Report submitted under
this Code, including any information provided in lieu of such
reports, will be preserved for a period of at least five years from
the end of the fiscal year in which it is made, for the first two
years in an easily accessible place.
D. A record of all persons, currently or within the past five years,
who are or were required to submit reports under this Code, and a
list of those who are or were responsible for reviewing these
reports, will be maintained in an easily accessible place.
E. A copy of each annual issues report and accompanying verification,
as required by Section VIII.C of this Code, must be maintained for
at least five years from the end of
<PAGE>
the fiscal year in which it is made, for the first two years
in any easily accessible place.
VII. Interrelationship with Investment Adviser's Code of Ethics.
A. General Principle.
A person who is both an access person of the WEBS Fund and an
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access person of the Advisor is only required to report under
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and otherwise comply with the Advisor's or principal
underwriter's Rule 17j-1 code of ethics, provided that such
code has been adopted pursuant to and in compliance with Rule
17j-1. Such persons, however, are still subject to the
principles and prohibitions contained in Sections III and IV
hereof.
B. Procedures.
The Advisor must:
(1) Submit to the Board of Directors a copy of its code of
ethics adopted pursuant to Rule 17j-1;
(2) Promptly furnish to the WEBS Fund, upon request, copies
of any reports made under its code of ethics by any
person who is also covered by the WEBS Fund's Code; and
(3) Promptly report to the WEBS Fund in writing any material
amendments to its code of ethics, along with the
certification described under Section VIII.C hereof.
VIII. Miscellaneous.
A. Confidentiality.
The WEBS Fund will endeavor to maintain the confidentiality of
all personal securities transactions reports and any other
information filed with the WEBS Fund under this Code. Such
reports and related information, however, may be produced to
the Securities and Exchange Commission and other regulatory
agencies.
B. Interpretation of Provisions.
The Board of Directors may from time to time adopt such
interpretations of this Code as it deems appropriate.
C. Annual Issues Report and Accompanying Certification.
At least annually, each of the Review Officer, the Advisor,
any other investment advisor to a Fund (including any sub-
advisor) and the WEBS Fund's principal underwriter (if
applicable) must provide the following to the Board:
<PAGE>
(1) a report that describes any issues that arose during the
previous year under the applicable code of ethics and any
procedures thereto, including any material code or procedural
violations and any resulting sanctions; and
(2) a certification that it has adopted procedures necessary to
prevent its access persons from violating its code of ethics.
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The Review Officer, Advisor, other advisors and principal
underwriter (if applicable) may report to the Board more
frequently as they deem necessary or appropriate and shall do so
as requested by the Board.
D. Initial and Annual Acknowledgment.
The Review Officer shall promptly provide all persons covered by
this Code with a copy of the Code. In addition, all persons
covered by this Code must complete the Acknowledgment attached as
Appendix D hereto within 10 days of becoming an access person of
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the WEBS Fund and must submit an Acknowledgment to the Review
Officer each year thereafter.
Adopted: May 2, 2000
<PAGE>
PART A
Independent Directors
I. Quarterly Reports
Each quarter, you must report any securities transactions, as well as any
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securities accounts you established during the quarter. You must submit
your report to the Review Officer no later than 10 days after the end of
each calendar quarter. A Quarterly Report is included as Appendix B.
If you had no reportable transactions and did not open any securities
accounts during the quarter, you are still required to submit a report.
Please note on your report that you had no reportable items during the
quarter, and return it, signed and dated.
You need not submit a Quarterly Report if the report would duplicate
information contained in broker trade confirmations or account statements
received by the WEBS Fund, provided that all required information is
contained in the broker trade confirmations or account statements and is
received by the Review Officer no later than 10 days after the end of the
calendar quarter. Please see the Review Officer for more information.
II. What Must Be Included In Your Quarterly Reports?
(A) You must report all transaction in securities that: (i) you
----------
directly or indirectly beneficially own or (ii) because of the
------------ ---
transaction, you acquire direct or indirect beneficial ownership. The
--------------------
report must also list each securities account you established during
the quarter in which any securities were held for your direct or
indirect benefit.
(B) Reports of individual securities transactions are required only if
----------
you knew at the time of the transaction or, in the ordinary course of
fulfilling your official duties as a Director, should have known, that
during the 15 day period immediately preceding or following the date
of your transaction, the same security was purchased or sold, or was
--------
being considered for purchase or sale, by a Fund.
-------------------------------------
Note: The "should have known" standard does not:
----
. imply a duty of inquiry;
. presume you should have deduced or extrapolated from
discussions or memoranda dealing with a Fund's
investment strategies; or
. impute knowledge from your awareness of a Fund's
portfolio holdings, market considerations, benchmark
index or investment policies, objectives and
restrictions.
<PAGE>
III. What May Be Excluded from Your Quarterly Reports?
You are not required to include the following securities, transactions or
accounts on your Quarterly Reports:
(A) Purchases or sales effected for any account over which you have no
direct or indirect influence or control.
(B) Purchases you made solely with the dividend proceeds received in a
dividend reinvestment plan or that are part of an automatic payroll
deduction plan, where you purchased a security issued by your
--------
employer.
(C) Purchases effected on the exercise of rights issued by an issuer
pro rata to all holders of a class of its securities, as long as you
----------
acquired these rights from the issuer, and sales of such rights.
(D) Purchases or sales which are non-volitional, including purchases
or sales upon exercise of written puts or calls and sales from a
margin account to a bona fide margin call.
(E) Purchases of direct obligations of the U.S. Government, bankers'
acceptances, bank certificates of deposit, commercial paper, high
----
quality short-term debt instruments, including repurchase agreements,
-----------------------------------
and shares issued by registered, open-end investment companies other
than the WEBS Fund.
You may include a statement in your report that the report shall not be
construed as your admission that you have any direct or indirect beneficial
----------
ownership in a security included in the report.
--------- --------
<PAGE>
PART B
Interested Directors
I. Initial and Annual Report of Securities Holdings and Accounts.
You must provide the Review Officer with a complete listing of your securities
accounts and any securities you beneficially own as of the date you first become
---------- ------------ ---
subject to the Code's reporting requirements. You must submit the initial list
within 10 days of the date you first became subject to the reporting
requirements. Each following year, you must submit a revised list to the Review
Officer showing your securities accounts and any securities you beneficially own
---------- ------------ ---
as of a date no more than 30 days before you submit the list. An Initial Report
and an Annual Report are included as Appendix C.
II. Quarterly Reports.
Each quarter, you must report any securities transactions, as well as any
----------
securities accounts you established during the quarter. You must submit your
report to the Review Officer no later than 10 days after the end of each
calendar quarter. A Quarterly Report is included as Appendix B.
If you had no reportable transactions and did not open any securities accounts
during the quarter, you are still required to submit a report. Please note on
your report that you had no reportable items during the quarter, and return it,
signed and dated.
You need not submit a Quarterly Report if the report would duplicate information
contained in broker trade confirmations or account statements received by the
WEBS Fund, provided that all required information is contained in the broker
trade confirmations or account statements and is received by the Review Officer
no later than 10 days after the end of the calendar quarter. Please see the
Review Officer for more information.
III. What Must Be Included In Your Reports?
You must report all transactions in securities that: (i) you directly or
----------
indirectly beneficially own or (ii) because of the transaction, you acquire
------------ ---
direct or indirect beneficial ownership. You also must list on the report each
--------------------
account in which any securities were held for your direct or indirect benefit.
IV. What May Be Excluded from Your Reports?
You are not required to include the following securities, transactions or
accounts on your reports:
(A) Purchases or sales effected for any account over which you have no
direct or indirect influence or control.
(B) Purchases you made solely with the dividend proceeds received in a
dividend reinvestment plan or that are part of an automatic payroll
deduction plan, where you purchased a security issued by your
--------
employer.
<PAGE>
(C) Purchases effected on the exercise of rights issued by an issuer
pro rata to all holders of a class of its securities, as long as you
----------
acquired these rights from the issuer, and sales of such rights.
(D) Purchases or sales which are non-volitional, including purchases
or sales upon exercise of written puts or calls and sales from a
margin account to a bona fide margin call.
(E) Purchases of direct obligations of the U.S. Government, bankers'
acceptances, bank certificates of deposit, commercial paper, high
----
quality short-term debt instruments, including repurchase agreements,
-----------------------------------
and shares issued by registered, open-end investment companies.
You may include a statement in your report that the report shall not be
construed as your admission that you have any direct or indirect beneficial
----------
ownership in a security included in the report.
--------- --------
<PAGE>
PART C
WEBS Fund Officers
I. Initial and Annual Report of Securities Holdings and Accounts.
You must provide the Review Officer with a complete listing of your securities
accounts and any securities you beneficially own as of the date you first became
---------- ------------ ---
subject to the Code's reporting requirements. You must submit the initial list
within 10 days of the date you first became subject to the reporting
requirements. Each following year, you must submit a revised list to the Review
Officer showing your securities accounts and any securities you beneficially own
---------- ------------ ---
as of a date no more than 30 days before you submit the list. An Initial Report
and an Annual Report are included as Appendix C.
II. Quarterly Reports.
Each quarter, you must report any securities transactions, as well as any
----------
securities accounts you established during the quarter. You must submit your
report to the Review Officer no later than 10 days after the end of each
calendar quarter. A Quarterly Report is included as Appendix B.
If you had no reportable transactions and did not open any securities accounts
during the quarter, you are still required to submit a report. Please note on
your report that you had no reportable items during the quarter, and return it,
signed and dated.
You need not submit a Quarterly Report if the report would duplicate information
contained in broker trade confirmations or account statements received by the
WEBS Fund, provided that all required information is contained in the broker
trade confirmations or account statements and is received by the Review Officer
no later than 10 days after the end of the calendar quarter. Please see the
Review Officer for more information.
III. What Must Be Included In Your Reports?
You must report all transactions in securities that: (i) you directly or
----------
indirectly beneficially own or (ii) because of the transaction, you acquire
------------ ---
direct or indirect beneficial ownership. You also must list on the report each
--------------------
account in which any securities were held for your direct or indirect benefit.
IV. What May Be Excluded from Your Reports?
You are not required to include the following securities, transactions or
accounts on your reports:
(A) Purchases or sales effected for any account over which you have no
direct or indirect influence or control.
(B) Purchases you made solely with the dividend proceeds received in a
dividend reinvestment plan or that are part of an automatic payroll
deduction plan, where you purchased a security issued by your
--------
employer.
<PAGE>
(C) Purchases effected on the exercise of rights issued by an issuer
pro rata to all holders of a class of its securities, as long as you
----------
acquired these rights from the issuer, and sales of such rights.
(D) Purchases or sales which are non-volitional, including purchases
or sales upon exercise of written puts or calls and sales from a
margin account to a bona fide margin call.
(E) Purchases of direct obligations of the U.S. Government, bankers'
acceptances, bank certificates of deposit, commercial paper, high
----
quality short-term debt instruments, including repurchase agreements,
-----------------------------------
and shares issued by registered, open-end investment companies.
You may include a statement in your report that the report shall not be
construed as your admission that you have any direct or indirect beneficial
----------
ownership in a security included in the report.
--------- --------
<PAGE>
PART D
Natural Control Persons
I. Initial and Annual Report of Securities Holdings and Accounts.
You must provide the Review Officer with a complete listing of your securities
accounts and any securities you beneficially own as of the date you first became
---------- ------------ ---
subject to the Code's reporting requirements. You must submit the initial list
within 10 days of the date you first became subject to the reporting
requirements. Each following year, you must submit a revised list to the Review
Officer showing your securities accounts and any securities you beneficially own
---------- ------------ ---
as of a date no more than 30 days before you submit the list. An Initial Report
and an Annual Report are included as Appendix C.
II. Quarterly Reports.
Each quarter, you must report any securities transactions, as well as any
----------
securities accounts you established during the quarter. You must submit your
report to the Review Officer no later than 10 days after the end of each
calendar quarter. A Quarterly Report is included as Appendix B.
If you had no reportable transactions and did not open any securities accounts
during the quarter, you are still required to submit a report. Please note on
your report that you had no reportable items during the quarter, and return it,
signed and dated.
You need not submit a Quarterly Report if the report would duplicate information
contained in broker trade confirmations or account statements received by the
WEBS Fund, provided that all required information is contained in the broker
trade confirmations or account statements and is received by the Review Officer
no later than 10 days after the end of the calendar quarter. Please see the
Review Officer for more information.
III. What Must Be Included In Your Reports?
You must report all transactions in securities that: (i) you directly or
----------
indirectly beneficially own or (ii) because of the transaction, you acquire
------------ ---
direct or indirect beneficial ownership. You also must list on the report each
--------------------
account in which any securities were held for your direct or indirect benefit.
IV. What May Be Excluded from Your Reports?
You are not required to include the following securities, transactions or
accounts on your reports:
(A) Purchases or sales effected for any account over which you have no
direct or indirect influence or control.
(B) Purchases you made solely with the dividend proceeds received in a
dividend reinvestment plan or that are part of an automatic payroll
deduction plan, where you purchased a security issued by your
--------
employer.
<PAGE>
(C) Purchases effected on the exercise of rights issued by an issuer
pro rata to all holders of a class of its securities, as long as you
----------
acquired these rights from the issuer, and sales of such rights.
(D) Purchases or sales which are non-volitional, including purchases
or sales upon exercise of written puts or calls and sales from a
margin account to a bona fide margin call.
(E) Purchases of direct obligations of the U.S. Government, bankers'
acceptances, bank certificates of deposit, commercial paper, high
----
quality short-term debt instruments, including repurchase agreements,
-----------------------------------
and shares issued by registered, open-end investment companies.
You may include a statement in your report that the report shall not be
construed as your admission that you have any direct or indirect beneficial
----------
ownership in a security included in the report.
--------- --------
V. Pre-Approval of Investments in IPOs or Limited Offerings.
You may not directly or indirectly acquire beneficial ownership in any
--------------------
securities in an IPO or limited offering without obtaining prior approval from
--- ----------------
the Review Officer. The Review Officer must review each request for approval
and record the decision regarding the request. Each such record must include
the Review Officer's reasons supporting the decision. The WEBS Fund must
maintain a record of any decision, and the reasons supporting the decision, to
approve these investments for at least five years after the end of the fiscal
year in which the approval is granted.
<PAGE>
APPENDIX A
Definitions
General Note
The definitions and terms used in this Code of Ethics are intended to mean the
same as they do
under the 1940 Act and the other federal securities laws. If a definition
hereunder
conflicts with the definition in the 1940 Act or other federal securities laws,
or if a term
used in this Code is not defined, you should follow the definitions and meanings
in the 1940 Act or other federal securities laws, as applicable.
Access person means any director, trustee or officer of a fund or of a fund's
-------------
investment adviser; any employee of a fund or its investment adviser (or of any
company in a control relationship to the fund or investment adviser) who, in
connection with his or her regular functions or duties, makes, participates in,
or obtains information regarding the purchase or sale of securities by a fund
---------------- ----------
or whose functions relate to the making of any recommendations with respect to
such purchases or sales; and any natural person in a control relationship to a
-------
fund or its investment adviser, who obtains information concerning
recommendations made to the fund with regard to the purchase or sale of
----------------
securities by the fund.
----------
Beneficial ownership means the same as it does under Section 16 of the
--------------------
Securities Exchange Act of 1934, as amended and Rule 16a-1(a)(2) thereunder.
You should generally consider yourself the "beneficial owner" of any securities
in which you have a direct or indirect pecuniary (monetary) interest. In
addition, you should consider yourself the beneficial owner of securities held
by your spouse, your minor children, a relative who shares your home, or other
persons by reason of any contract, arrangement, understanding or relationship
that provides you with sole or shared voting or investment power.
Control means the same as it does under 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 of such securities control over the company. This presumption may be
countered by the facts and circumstances of a given situation.
High quality short-term debt instrument means any instrument that has a maturity
---------------------------------------
at issuance of less than 366 days and that is rated in one of the two highest
rating categories by a nationally recognized statistical rating organization
(e.g., Moody's Investors Service).
Independent Director means a director of the WEBS Fund who is not an "interested
--------------------
person" of the WEBS Fund within the meaning of Section 2(a)(19) of the 1940 Act.
Interested Director means a Director of the WEBS Fund who is an "interested
-------------------
person" of the WEBS Fund within the meaning of Section 2(a)(19) of the 1940 Act.
<PAGE>
IPO (i.e., initial public offering) means an offering of securities registered
---
under the Securities Act of 1933, as amended (the "Securities Act") 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.
Limited offering means an offering that is exempt from registration under the
----------------
Securities Act pursuant to Section 4(2), Section 4(6), Rule 504, Rule 505 or
Rule 506 (e.g., private placements).
Purchase or sale of a security includes, among other things, the writing of an
------------------------------
option to purchase or sell a security.
--------
Security has the meaning set forth in Section 2(a)(36) of the 1940 Act, except
--------
that it does not include direct obligations of the U.S. Government, bankers'
acceptances, bank certificates of deposit, commercial paper, high quality short-
-------------------
term debt instruments, including repurchase agreements, shares issued by
---------------------
registered open-end investment companies or securities of an issuer whose
securities trade in a country or market in which a Fund does not invest.
A security held or to be acquired by a Fund means: (i) any security that within
------------------------------- --------
the most recent 15 days is or has been held by the Fund or is being or has been
-----------------
considered by the Advisor for purchase by the Fund and (ii) any option to
----------
purchase or sell, and any security convertible into or exchangeable for, a
security.
--------
A security is being purchased by a Fund from the time a purchase or sale program
-------- ---------------
has been communicated to the person who places buy and sell orders for the Fund
until the program has been fully completed or terminated.
A security is being considered for purchase by a Fund when the Advisor
-------- -----------------------------
identifies a security as such. For purposes of this Code, the Advisor considers
securities on its "trade lists" as those "being considered for purchase."
WEBS Fund officer means any person lawfully elected by the Board and authorized
-----------------
to act on behalf of the WEBS Fund.
<PAGE>
APPENDIX B
Quarterly Report
Name of Reporting Person: ___________________________
Calendar Quarter Ended: ______________
Date Report Due: ______ 10, ____
Date Report Submitted:_____________
<TABLE>
<CAPTION>
Securities Transactions
------------------------------------------------------------------------------------------------
Principal
Amount, Name of
Name of No. of Maturity Broker,
Issuer Shares Date and Dealer or
Date of and (if Interest Type of Bank
Transaction Title of applicable) Rate Transaction Price Effecting
Security (if Transaction
applicable)
------------------------------------------------------------------------------------------------
<S> <C> <C> <C> <C> <C> <C>
------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
</TABLE>
If you have no securities transactions to report for the quarter, please check
here.
If you do not want this report to be construed as an admission that you have
beneficial ownership of one or more securities reported above, please describe
below and indicate which securities are at issue. _____
_______________________________________________________________________________
_______________________________________________________________________________
_______________
Securities Accounts
If you established a securities account during the quarter, please provide the
following information:
<TABLE>
<CAPTION>
-----------------------------------------------------------------------------------------------------------
Name of Broker, Dealer or Bank Date Account was Name(s) on and Type of
Established Account
-----------------------------------------------------------------------------------------------------------
<S> <C> <C>
-----------------------------------------------------------------------------------------------------------
-----------------------------------------------------------------------------------------------------------
-----------------------------------------------------------------------------------------------------------
</TABLE>
If you did not establish a securities account during the quarter, please check
here.
I certify that I have included on this report all securities transactions and
accounts required to be reported pursuant to the Code of Ethics.
Signature: ____________________ Date: __________________
<PAGE>
APPENDIX C
Initial and Annual Reports of Securities and Accounts
INITIAL HOLDINGS REPORT
Name of Reporting Person: _________________
Date Person Became Subject to the Code's Reporting Requirements: ________
Information in Report Dated As Of: ____________
Date Report Due: __________
Date Report Submitted: __________
<TABLE>
<CAPTION>
Securities Holdings
---------------------------------------------------------------------------------------------------------
Name of Issuer and No. of Shares Principal Amount, Maturity Date and Interest
Title of Security (if applicable) Rate (if applicable)
---------------------------------------------------------------------------------------------------------
<S> <C> <C>
---------------------------------------------------------------------------------------------------------
---------------------------------------------------------------------------------------------------------
---------------------------------------------------------------------------------------------------------
---------------------------------------------------------------------------------------------------------
---------------------------------------------------------------------------------------------------------
---------------------------------------------------------------------------------------------------------
---------------------------------------------------------------------------------------------------------
</TABLE>
If you have no securities holdings to report, please check here.
If you do not want this report to be construed as an admission that you have
beneficial ownership of one or more securities reported above, please describe
below and indicate which securities are at issue.
________________________________________________________________________________
________________________________________________________________________________
______
<TABLE>
<CAPTION>
Securities Accounts
--------------------------------------------------------------------------------------------------
Name of Broker, Dealer or Bank Name(s) on and Type of Account
--------------------------------------------------------------------------------------------------
<S> <C>
--------------------------------------------------------------------------------------------------
--------------------------------------------------------------------------------------------------
--------------------------------------------------------------------------------------------------
</TABLE>
If you have no securities accounts to report, please check here.
I certify that I have included on this report all securities holdings and
accounts required to be reported pursuant to the Code of Ethics.
Signature: ____________________ Date: __________________
APPENDIX C CONTINUED
ANNUAL HOLDINGS REPORT
Name of Reporting Person:________________________________
<PAGE>
Information in Report Dated As of:____________
Date Report Due: __________
Date Report Submitted: _____________
Calendar Year Ended: December 31, _____
<TABLE>
<CAPTION>
Securities Holdings
-----------------------------------------------------------------------------------------------------------
Name of Issuer and No. of Shares Principal Amount, Maturity Date and Interest Rate
Title of Security (if applicable) (if applicable)
-----------------------------------------------------------------------------------------------------------
<S> <C> <C>
-----------------------------------------------------------------------------------------------------------
-----------------------------------------------------------------------------------------------------------
-----------------------------------------------------------------------------------------------------------
-----------------------------------------------------------------------------------------------------------
---------------------------------------------------------------------------------------------------------
---------------------------------------------------------------------------------------------------------
---------------------------------------------------------------------------------------------------------
</TABLE>
If you have no securities holdings to report for the year, please check here.
If you do not want this report to be construed as an admission that you have
beneficial ownership of one or more securities reported above, please describe
below and indicate which securities are at issue.
________________________________________________________________________________
________________________________________________________________________________
__________________
<TABLE>
<CAPTION>
Securities Accounts
----------------------------------------------------------------------------------------------------------
Name of Broker, Dealer or Bank Date Account Was Name(s) on and Type of Account
Established
----------------------------------------------------------------------------------------------------------
<S> <C> <C>
----------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------
</TABLE>
If you have no securities accounts to report for the year, please check here.
I certify that I have included on this report all securities transactions and
accounts required to be reported pursuant to the Code of Ethics.
Signature: ____________________ Date: __________________
<PAGE>
APPENDIX D
Acknowledgment
TO: Review Officer
RE: Acknowledgment of Code of Ethics
--------------------------------------------------------------------------------
------------------------------------------
Initial Acknowledgment: Please check here if this is an initial acknowledgment.
I CERTIFY THAT (1) I HAVE RECEIVED, READ AND UNDERSTAND THE CODE OF ETHICS, (2)
I AM AWARE THAT I AM SUBJECT TO THE PROVISIONS OF THIS CODE, (3) I WILL COMPLY
WITH THIS CODE, AND (4) I WILL REPORT ALL HOLDINGS, TRANSACTIONS AND ACCOUNTS
THAT I AM REQUIRED TO REPORT PURSUANT TO THIS CODE.
--------------------------------------------------------------------------------
---------------------------------------------
Annual Acknowledgment: Please check here if this is an annual acknowledgment.
I CERTIFY THAT (1) I HAVE RECEIVED, READ AND UNDERSTAND THE CODE OF ETHICS, (2)
I AM AWARE THAT I AM SUBJECT TO THE PROVISIONS OF THIS CODE, (3) I HAVE COMPLIED
WITH THIS CODE AT ALL TIMES DURING THE PREVIOUS CALENDAR YEAR, AND (4) I HAVE,
DURING THE PREVIOUS CALENDAR YEAR, REPORTED ALL HOLDINGS, TRANSACTIONS AND
ACCOUNTS THAT I AM REQUIRED TO REPORT PURSUANT TO THIS CODE.
--------------------------------------------------------------------------------
--------------------------------------------
Name (print): ________________________
Position: ____________________________
Signature: ___________________________
Date Submitted: ______________________
Date Due: ___________________________
