DWS Investments
Principal Executive and Principal Financial Officer Code of Ethics
For the Registered Management Investment Companies
Listed on Appendix A
Effective Date
[January 31, 2005]
Table of Contents
Page Number
I. Overview.....................................................................3
II. Purposes of the Officer Code.................................................3
III. Responsibilities of Covered Officers.........................................4
A. Honest and Ethical Conduct...................................................4
B. Conflicts of Interest........................................................4
C. Use of Personal Fund Shareholder Information.................................6
D. Public Communications........................................................6
E. Compliance with Applicable Laws, Rules and Regulations.......................6
IV. Violation Reporting..........................................................7
A. Overview.....................................................................7
B. How to Report................................................................7
C. Process for Violation Reporting to the Fund Board............................7
D. Sanctions for Code Violations................................................7
V. Waivers from the Officer Code................................................7
VI. Amendments to the Code.......................................................8
VII. Acknowledgement and Certification of Adherence to the Officer Code...........8
IX. Recordkeeping................................................................8
X. Confidentiality..............................................................9
Appendices...........................................................................10
Appendix A:.......................................................................10
List of Officers Covered under the Code, by Board:................................10
DeAM Compliance Officer:..........................................................10
Name: Joseph Yuen.................................................................10
As of: July 19, 2006Appendix B: Acknowledgement and Certification............10
Appendix B: Acknowledgement and Certification.....................................11
Appendix C: Definitions..........................................................13
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I. Overview
This Principal Executive Officer and Principal Financial Officer Code
of Ethics ("Officer Code") sets forth the policies, practices, and
values expected to be exhibited in the conduct of the Principal
Executive Officers and Principal Financial Officers of the investment
companies ("Funds") they serve ("Covered Officers"). A list of Covered
Officers and Funds is included on Appendix A.
The Boards of the Funds listed on Appendix A have elected to implement
the Officer Code, pursuant to Section 406 of the Sarbanes-Oxley Act of
2002 and the SEC's rules thereunder, to promote and demonstrate honest
and ethical conduct in their Covered Officers.
Deutsche Asset Management, Inc. or its affiliates ("DeAM") serves as
the investment adviser to each Fund. All Covered Officers are also
employees of DeAM or an affiliate. Thus, in addition to adhering to the
Officer Code, these individuals must comply with DeAM policies and
procedures, such as the DeAM Code of Ethics governing personal trading
activities, as adopted pursuant to Rule 17j-1 under the Investment
Company Act of 1940.(1) In addition, such individuals also must comply
with other applicable Fund policies and procedures.
The DeAM Compliance Officer, who shall not be a Covered Officer and who
shall serve as such subject to the approval of the Fund's Board (or
committee thereof), is primarily responsible for implementing and
enforcing this Code. The Compliance Officer has the authority to
interpret this Officer Code and its applicability to particular
circumstances. Any questions about the Officer Code should be directed
to the DeAM Compliance Officer.
The DeAM Compliance Officer and his or her contact information can be
found in Appendix A.
II. Purposes of the Officer Code
The purposes of the Officer Code are to deter wrongdoing and to:
o promote honest and ethical conduct among Covered Officers,
including the ethical handling of actual or apparent conflicts
of interest between personal and professional relationships;
o promote full, fair, accurate, timely and understandable
disclosures in reports and documents that the Funds file with
or submit to the SEC (and in other public communications from
the Funds) and that are within the Covered Officer's
responsibilities;
o promote compliance with applicable laws, rules and
regulations;
o encourage the prompt internal reporting of violations of the
Officer Code to the DeAM Compliance Officer; and
o establish accountability for adherence to the Officer Code.
Any questions about the Officer Code should be referred to DeAM's
Compliance Officer.
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(1) The obligations imposed by the Officer Code are separate from, and in
addition to, any obligations imposed under codes of ethics adopted pursuant to
Rule 17j-1 under the Investment Company Act of 1940, and any other code of
conduct applicable to Covered Officers in whatever capacity they serve. The
Officer Code does not incorporate any of those other codes and, accordingly,
violations of those codes will not necessarily be considered violations of the
Officer Code and waivers granted under those codes would not necessarily require
a waiver to be granted under this Code. Sanctions imposed under those codes may
be considered in determining appropriate sanctions for any violation of this
Code.
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III. Responsibilities of Covered Officers
A. Honest and Ethical Conduct
It is the duty of every Covered Officer to encourage and demonstrate
honest and ethical conduct, as well as adhere to and require adherence
to the Officer Code and any other applicable policies and procedures
designed to promote this behavior. Covered Officers must at all times
conduct themselves with integrity and distinction, putting first the
interests of the Fund(s) they serve. Covered Officers must be honest
and candid while maintaining confidentiality of information where
required by law, DeAM policy or Fund policy.
Covered Officers also must, at all times, act in good faith,
responsibly and with due care, competence and diligence, without
misrepresenting or being misleading about material facts or allowing
their independent judgment to be subordinated. Covered Officers also
should maintain skills appropriate and necessary for the performance of
their duties for the Fund(s). Covered Officers also must responsibly
use and control all Fund assets and resources entrusted to them.
Covered Officers may not retaliate against others for, or otherwise
discourage the reporting of, actual or apparent violations of the
Officer Code or applicable laws or regulations. Covered Officers should
create an environment that encourages the exchange of information,
including concerns of the type that this Code is designed to address.
B. Conflicts of Interest
A "conflict of interest" occurs when a Covered Officer's personal
interests interfere with the interests of the Fund for which he or she
serves as an officer. Covered Officers may not improperly use their
position with a Fund for personal or private gain to themselves, their
family, or any other person. Similarly, Covered Officers may not use
their personal influence or personal relationships to influence
decisions or other Fund business or operational matters where they
would benefit personally at the Fund's expense or to the Fund's
detriment. Covered Officers may not cause the Fund to take action, or
refrain from taking action, for their personal benefit at the Fund's
expense or to the Fund's detriment. Some examples of conflicts of
interest follow (this is not an all-inclusive list): being in the
position of supervising, reviewing or having any influence on the job
evaluation, pay or benefit of any immediate family member who is an
employee of a Fund service provider or is otherwise associated with the
Fund; or having an ownership interest in, or having any consulting or
employment relationship with, any Fund service provider other than DeAM
or its affiliates.
Certain conflicts of interest covered by this Code arise out of the
relationships between Covered Officers and the Fund that already are
subject to conflict of interest provisions in the Investment Company
Act and the Investment Advisers Act. For example, Covered Officers may
not individually engage in certain transactions (such as the purchase
or sale of securities or other property) with the Fund because of their
status as "affiliated persons" of the Fund. Covered Officers must
comply with applicable laws and regulations. Therefore, any violations
of existing statutory and regulatory prohibitions on individual
behavior could be considered a violation of this Code.
As to conflicts arising from, or as a result of the advisory
relationship (or any other relationships) between the Fund and DeAM, of
which the Covered Officers are also officers or employees, it is
recognized by the Board that, subject to DeAM's fiduciary duties to the
Fund, the Covered Officers will in the normal course of their duties
(whether formally for the Fund or for DeAM, or for both) be involved in
establishing policies and implementing decisions which will have
different effects on
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DeAM and the Fund. The Board recognizes that the participation of the
Covered Officers in such activities is inherent in the contract
relationship between the Fund and DeAM, and is consistent with the
expectation of the Board of the performance by the Covered Officers of
their duties as officers of the Fund.
Covered Officers should avoid actual conflicts of interest, and
appearances of conflicts of interest, between the Covered Officer's
duties to the Fund and his or her personal interests beyond those
contemplated or anticipated by applicable regulatory schemes. If a
Covered Officer suspects or knows of a conflict or an appearance of
one, the Covered Officer must immediately report the matter to the DeAM
Compliance Officer. If a Covered Officer, in lieu of reporting such a
matter to the DeAM Compliance Officer, may report the matter directly
to the Fund's Board (or committee thereof), as appropriate (e.g., if
the conflict involves the DeAM Compliance Officer or the Covered
Officer reasonably believes it would be futile to report the matter to
the DeAM Compliance Officer).
When actual, apparent or suspected conflicts of interest arise in
connection with a Covered Officer, DeAM personnel aware of the matter
should promptly contact the DeAM Compliance Officer. There will be no
reprisal or retaliation against the person reporting the matter.
Upon receipt of a report of a possible conflict, the DeAM Compliance
Officer will take steps to determine whether a conflict exists. In so
doing, the DeAM Compliance Officer may take any actions he or she
determines to be appropriate in his or her sole discretion and may use
all reasonable resources, including retaining or engaging legal
counsel, accounting firms or other consultants, subject to applicable
law.(2) The costs associated with such actions may be borne by the
Fund, if appropriate, after consultation with the Fund's Board (or
committee thereof). Otherwise, such costs will be borne by DeAM or
other appropriate Fund service provider.
After full review of a report of a possible conflict of interest, the
DeAM Compliance Officer may determine that no conflict or reasonable
appearance of a conflict exists. If, however, the DeAM Compliance
Officer determines that an actual conflict exists, the Compliance
Officer will resolve the conflict solely in the interests of the Fund,
and will report the conflict and its resolution to the Fund's Board (or
committee thereof). If the DeAM Compliance Officer determines that the
appearance of a conflict exists, the DeAM Compliance Officer will take
appropriate steps to remedy such appearance. In lieu of determining
whether a conflict exists and/or resolving a conflict, the DeAM
Compliance Officer instead may refer the matter to the Fund's Board (or
committee thereof), as appropriate. However, the DeAM Compliance
Officer must refer the matter to the Fund's Board (or committee
thereof) if the DeAM Compliance Officer is directly involved in the
conflict or under similar appropriate circumstances.
After responding to a report of a possible conflict of interest, the
DeAM Compliance Officer will discuss the matter with the person
reporting it (and with the Covered Officer at issue, if different) for
purposes of educating those involved on conflicts of interests
(including how to detect and avoid them, if appropriate).
Appropriate resolution of conflicts may restrict the personal
activities of the Covered Officer and/or his family, friends or other
persons.
Solely because a conflict is disclosed to the DeAM Compliance Officer
(and/or the Board or Committee thereof) and/or resolved by the DeAM
Compliance Officer does not mean that the conflict or its resolution
constitutes a waiver from the Code's requirements.
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(2) For example, retaining a Fund's independent accounting firm may require
pre-approval by the Fund's audit committee.
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Any questions about conflicts of interests, including whether a
particular situation might be a conflict or an appearance of one,
should be directed to the DeAM Compliance Officer.
C. Use of Personal Fund Shareholder Information
A Covered Officer may not use or disclose personal information about
Fund shareholders, except in the performance of his or her duties for
the Fund. Each Covered Officer also must abide by the Funds' and DeAM's
privacy policies under SEC Regulation S-P.
D. Public Communications
In connection with his or her responsibilities for or involvement with
a Fund's public communications and disclosure documents (e.g.,
shareholder reports, registration statements, press releases), each
Covered Officer must provide information to Fund service providers
(within the DeAM organization or otherwise) and to the Fund's Board
(and any committees thereof), independent auditors, government
regulators and self-regulatory organizations that is fair, accurate,
complete, objective, relevant, timely and understandable.
Further, within the scope of their duties, Covered Officers having
direct or supervisory authority over Fund disclosure documents or other
public Fund communications will, to the extent appropriate within their
area of responsibility, endeavor to ensure full, fair, timely, accurate
and understandable disclosure in Fund disclosure documents. Such
Covered Officers will oversee, or appoint others to oversee, processes
for the timely and accurate creation and review of all public reports
and regulatory filings. Within the scope of his or her responsibilities
as a Covered Officer, each Covered Officer also will familiarize
himself or herself with the disclosure requirements applicable to the
Fund, as well as the business and financial operations of the Fund.
Each Covered Officer also will adhere to, and will promote adherence
to, applicable disclosure controls, processes and procedures, including
DeAM's Disclosure Controls and Procedures, which govern the process by
which Fund disclosure documents are created and reviewed.
To the extent that Covered Officers participate in the creation of a
Fund's books or records, they must do so in a way that promotes the
accuracy, fairness and timeliness of those records.
E. Compliance with Applicable Laws, Rules and Regulations
In connection with his or her duties and within the scope of his or her
responsibilities as a Covered Officer, each Covered Officer must comply
with governmental laws, rules and regulations, accounting standards,
and Fund policies/procedures that apply to his or her role,
responsibilities and duties with respect to the Funds ("Applicable
Laws"). These requirements do not impose on Covered Officers any
additional substantive duties. Additionally, Covered Officers should
promote compliance with Applicable Laws.
If a Covered Officer knows of any material violations of Applicable
Laws or suspects that such a violation may have occurred, the Covered
Officer is expected to promptly report the matter to the DeAM
Compliance Officer.
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IV. Violation Reporting
A. Overview
Each Covered Officer must promptly report to the DeAM Compliance
Officer, and promote the reporting of, any known or suspected
violations of the Officer Code. Failure to report a violation may be a
violation of the Officer Code.
Examples of violations of the Officer Code include, but are not limited
to, the following:
o Unethical or dishonest behavior
o Obvious lack of adherence to policies surrounding review and
approval of public communications and regulatory filings
o Failure to report violations of the Officer Code
o Known or obvious deviations from Applicable Laws
o Failure to acknowledge and certify adherence to the Officer
Code
The DeAM Compliance Officer has the authority to take any and all
action he or she considers appropriate in his or her sole discretion to
investigate known or suspected Code violations, including consulting
with the Fund's Board, the independent Board members, a Board
committee, the Fund's legal counsel and/or counsel to the independent
Board members. The Compliance Officer also has the authority to use all
reasonable resources to investigate violations, including retaining or
engaging legal counsel, accounting firms or other consultants, subject
to applicable law.(3) The costs associated with such actions may be
borne by the Fund, if appropriate, after consultation with the Fund's
Board (or committee thereof). Otherwise, such costs will be borne by
DeAM.
B. How to Report
Any known or suspected violations of the Officer Code must be promptly
reported to the DeAM Compliance Officer.
C. Process for Violation Reporting to the Fund Board
The DeAM Compliance Officer will promptly report any violations of the
Code to the Fund's Board (or committee thereof).
D. Sanctions for Code Violations
Violations of the Code will be taken seriously. In response to reported
or otherwise known violations, DeAM and the relevant Fund's Board may
impose sanctions within the scope of their respective authority over
the Covered Officer at issue. Sanctions imposed by DeAM could include
termination of employment. Sanctions imposed by a Fund's Board could
include termination of association with the Fund.
V. Waivers from the Officer Code
A Covered Officer may request a waiver from the Officer Code by
transmitting a written request for a waiver to the DeAM Compliance
Officer.(4) The request must include the rationale for the request and
must explain how the waiver would be in furtherance of the standards of
conduct described in and underlying purposes of the Officer Code. The
DeAM Compliance Officer will present this information
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(3) For example, retaining a Fund's independent accounting firm may require
pre-approval by the Fund's audit committee.
(4) Of course, it is not a waiver of the Officer Code if the Fund's Board (or
committee thereof) determines that a matter is not a deviation from the Officer
Code's requirements or is otherwise not covered by the Code.
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to the Fund's Board (or committee thereof). The Board (or committee)
will determine whether to grant the requested waiver. If the Board (or
committee) grants the requested waiver, the DeAM Compliance Officer
thereafter will monitor the activities subject to the waiver, as
appropriate, and will promptly report to the Fund's Board (or committee
thereof) regarding such activities, as appropriate.
The DeAM Compliance Officer will coordinate and facilitate any required
public disclosures of any waivers granted or any implicit waivers.
VI. Amendments to the Code
The DeAM Compliance Officer will review the Officer Code from time to
time for its continued appropriateness and will propose any amendments
to the Fund's Board (or committee thereof) on a timely basis. In
addition, the Board (or committee thereof) will review the Officer Code
at least annually for its continued appropriateness and may amend the
Code as necessary or appropriate.
The DeAM Compliance Officer will coordinate and facilitate any required
public disclosures of Code amendments.
VII. Acknowledgement and Certification of Adherence to the Officer Code
Each Covered Officer must sign a statement upon appointment as a
Covered Officer and annually thereafter acknowledging that he or she
has received and read the Officer Code, as amended or updated, and
confirming that he or she has complied with it (see Appendix B:
Acknowledgement and Certification of Obligations Under the Officer
Code).
Understanding and complying with the Officer Code and truthfully
completing the Acknowledgement and Certification Form is each Covered
Officer's obligation.
The DeAM Compliance Officer will maintain such Acknowledgements in the
Fund's books and records.
VIII. Scope of Responsibilities
A Covered Officer's responsibilities under the Officer Code are limited
to:
(1) Fund matters over which the Officer has direct responsibility
or control, matters in which the Officer routinely
participates, and matters with which the Officer is otherwise
involved (i.e., matters within the scope of the Covered
Officer's responsibilities as a Fund officer); and
(2) Fund matters of which the Officer has actual knowledge.
IX. Recordkeeping
The DeAM Compliance Officer will create and maintain appropriate
records regarding the implementation and operation of the Officer Code,
including records relating to conflicts of interest determinations and
investigations of possible Code violations.
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X. Confidentiality
All reports and records prepared or maintained pursuant to this Officer
Code shall be considered confidential and shall be maintained and
protected accordingly. Except as otherwise required by law or this
Officer Code, such matters shall not be disclosed to anyone other than
the DeAM Compliance Officer, the Fund's Board (or committee thereof),
legal counsel, independent auditors, and any consultants engaged by the
Compliance Officer.
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Appendices
Appendix A:
List of Officers Covered under the Code, by Board:
=========================================== ============================== =========================== ============================
Fund Board Principal Executive Officers Principal Financial Treasurer
Officers
- ------------------------------------------- ------------------------------ --------------------------- ----------------------------
Chicago Michael Clark Paul Schubert Paul Schubert
- ------------------------------------------- ------------------------------ --------------------------- ----------------------------
New York Michael Clark Paul Schubert Paul Schubert
- ------------------------------------------- ------------------------------ --------------------------- ----------------------------
Hedge Strategies Fund Pam Kiernan Marielena Glassman Marielena Glassman
- ------------------------------------------- ------------------------------ --------------------------- ----------------------------
Germany* Michael Clark Paul Schubert Paul Schubert
- ------------------------------------------- ------------------------------ --------------------------- ----------------------------
Topiary BPI Pam Kiernan Marielena Glassman Marielena Glassman
=========================================== ============================== =========================== ============================
* Central Europe and Russia, European Equity, and New Germany Funds
DeAM Compliance Officer:
Name: Joseph Yuen
DeAM Department: Compliance
Phone Numbers: 212-454-7443
Fax Numbers: 212-454-4703
As of: July 19, 2006
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Appendix B: Acknowledgement and Certification
Initial Acknowledgement and Certification
of Obligations Under the Officer Code
- --------------------------------------------------------------------------------
Print Name Department Location Telephone
1. I acknowledge and certify that I am a Covered Officer under
the Scudder Fund Principal Executive and Financial Officer
Code of Ethics ("Officer Code"), and therefore subject to all
of its requirements and provisions.
2. I have received and read the Officer Code and I understand the
requirements and provisions set forth in the Officer Code.
3. I have disclosed any conflicts of interest of which I am aware
to the DeAM Compliance Officer.
4. I will act in the best interest of the Funds for which I serve
as an officer and have maintained the confidentiality of
personal information about Fund shareholders.
5. I will report any known or suspected violations of the Officer
Code in a timely manner to the DeAM Compliance Officer.
-----------------------------------------------------------------------
Signature Date
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Annual Acknowledgement and Certification
of Obligations Under the Officer Code
- --------------------------------------------------------------------------------
Print Name Department Location Telephone
1. I acknowledge and certify that I am a Covered Officer under
the DWS Investments Principal Executive and Financial Officer
Code of Ethics ("Officer Code"), and therefore subject to all
of its requirements and provisions.
2. I have received and read the Officer Code, and I understand
the requirements and provisions set forth in the Officer Code.
3. I have adhered to the Officer Code.
4. I have not knowingly been a party to any conflict of interest,
nor have I had actual knowledge about actual or apparent
conflicts of interest that I did not report to the DeAM
Compliance Officer in accordance with the Officer Code's
requirements.
5. I have acted in the best interest of the Funds for which I
serve as an officer and have maintained the confidentiality of
personal information about Fund shareholders.
6. With respect to the duties I perform for the Fund as a Fund
officer, I believe that effective processes are in place to
create and file public reports and documents in accordance
with applicable regulations.
7. With respect to the duties I perform for the Fund as a Fund
officer, I have complied to the best of my knowledge with all
Applicable Laws (as that term is defined in the Officer Code)
and have appropriately monitored those persons under my
supervision for compliance with Applicable Laws.
8. I have reported any known or suspected violations of the
Officer Code in a timely manner to the DeAM Compliance
Officer.
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Signature Date
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Appendix C: Definitions
Principal Executive Officer
Individual holding the office of President of the Fund or series of
Funds, or a person performing a similar function.
Principal Financial Officer
Individual holding the office of Treasurer of the Fund or series of
Funds, or a person performing a similar function.
Registered Investment Management Investment Company
Registered investment companies other than a face-amount certificate
company or a unit investment trust.
Waiver
A waiver is an approval of an exemption from a Code requirement.
Implicit Waiver
An implicit waiver is the failure to take action within a reasonable
period of time regarding a material departure from a requirement or
provision of the Officer Code that has been made known to the DeAM
Compliance Officer or the Fund's Board (or committee thereof).
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