Exhibit (a)(1)
THE DREYFUS FAMILY OF FUNDS
CODE OF ETHICS FOR PRINCIPAL EXECUTIVE
AND SENIOR FINANCIAL OFFICERS
1. Covered Officers/Purpose of the Code
This code of ethics (the "Code") for the investment companies within
the complex (each, a "Fund") applies to each Fund's Principal Executive
Officer, Principal Financial Officer, Principal Accounting Officer or
Controller, or other persons performing similar functions, each of whom is
listed on Exhibit A (the "Covered Officers"), for the purpose of promoting:
o honest and ethical conduct, including the ethical handling of actual or
apparent conflicts of interest between personal and professional
relationships;
o full, fair, accurate, timely and understandable disclosure in reports and
documents that the Fund files with, or submits to, the Securities and
Exchange Commission (the "SEC") and in other public communications made by
the Fund;
o compliance with applicable laws and governmental rules and regulations;
o the prompt internal reporting of violations of the Code to an appropriate
person or persons identified in the Code; and
o accountability for adherence to the Code.
Each Covered Officer should adhere to a high standard of business
ethics and should be sensitive to situations that may give rise to actual as
well as apparent conflicts of interest.
2. Covered Officers Should Handle Ethically Actual and Apparent Conflicts
of Interest
OVERVIEW. A "conflict of interest" occurs when a Covered Officer's
private interest interferes with the interests of, or his service to, the
Fund. For example, a conflict of interest would arise if a Covered Officer,
or a member of his family, receives improper personal benefits as a result of
his position with the Fund.
Certain conflicts of interest arise out of the relationships between
Covered Officers and the Fund and already are subject to conflict of interest
provisions in the Investment Company Act of 1940, as amended (the "Investment
Company Act"), and the Investment Advisers Act of 1940, as amended (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. The compliance programs and procedures of
the Fund and the Fund's investment adviser (the "Adviser") are designed to
prevent, or identify and correct, violations of these provisions. The Code
does not, and is not intended to, repeat or replace these programs and
procedures, and the circumstances they cover fall outside of the parameters
of the Code.
Although typically not presenting an opportunity for improper personal
benefit, conflicts arise from, or as a result of, the contractual
relationship between the Fund and the Adviser of which the Covered Officers
are also officers or employees. As a result, the Code recognizes that the
Covered Officers, in the ordinary course of their duties (whether formally
for the Fund or for the Adviser, or for both), will be involved in
establishing policies and implementing decisions that will have different
effects on the Adviser and the Fund. The participation of the Covered
Officers in such activities is inherent in the contractual relationship
between the Fund and the Adviser and is consistent with the performance by
the Covered Officers of their duties as officers of the Fund and, if
addressed in conformity with the provisions of the Investment Company Act and
the Investment Advisers Act, will be deemed to have been handled ethically.
In addition, it is recognized by the Fund's Board that the Covered Officers
also may be officers or employees of one or more other investment companies
covered by this or other codes of ethics.
Other conflicts of interest are covered by the Code, even if such
conflicts of interest are not subject to provisions in the Investment Company
Act and the Investment Advisers Act. Covered Officers should keep in mind
that the Code cannot enumerate every possible scenario. The overarching
principle of the Code is that the personal interest of a Covered Officer
should not be placed improperly before the interest of the Fund.
Each Covered Officer must:
o not use his personal influence or personal relationships improperly to
influence investment decisions or financial reporting by the Fund whereby
the Covered Officer would benefit personally to the detriment of the Fund;
o not cause the Fund to take action, or fail to take action, for the
individual personal benefit of the Covered Officer rather than the benefit
of the Fund; and
o not retaliate against any employee or Covered Officer for reports of
potential violations that are made in good faith.
3. Disclosure and Compliance
o Each Covered Officer should familiarize himself with the disclosure
requirements generally applicable to the Fund within his area of
responsibility;
o each Covered Officer should not knowingly misrepresent, or cause others to
misrepresent, facts about the Fund to others, whether within or outside
the Fund, including to the Fund's Board members and auditors, and to
governmental regulators and self-regulatory organizations; and
o each Covered Officer should, to the extent appropriate within his area of
responsibility, consult with other officers and employees of the Fund and
the Adviser with the goal of promoting full, fair, accurate, timely and
understandable disclosure in the reports and documents the Fund files
with, or submits to, the SEC and in other public communications made by
the Fund; and
o it is the responsibility of each Covered Officer to promote compliance
with the standards and restrictions imposed by applicable laws, rules and
regulations.
4. Reporting and Accountability
Each Covered Officer must:
o upon adoption of the Code (or thereafter, as applicable, upon becoming a
Covered Officer), affirm in writing to the Board that he has received,
read, and understands the Code;
o annually thereafter affirm to the Board that he has complied with the
requirements of the Code; and
o notify the Adviser's General Counsel (the "General Counsel") promptly if
he knows of any violation of the Code. Failure to do so is itself a
violation of the Code.
The General Counsel is responsible for applying the Code to specific
situations in which questions are presented under it and has the authority to
interpret the Code in any particular situation. However, waivers sought by
any Covered Officer will be considered by the Fund's Board.
The Fund will follow these procedures in investigating and enforcing
the Code:
o the General Counsel will take all appropriate action to investigate any
potential violations reported to him;
o if, after such investigation, the General Counsel believes that no
violation has occurred, the General Counsel is not required to take any
further action;
o any matter that the General Counsel believes is a violation will be
reported to the Board;
o if the Board concurs that a violation has occurred, it will consider
appropriate action, which may include: review of, and appropriate
modifications to, applicable policies and procedures; notification to
appropriate personnel of the Adviser or its board; or dismissal of the
Covered Officer;
o the Board will be responsible for granting waivers, as appropriate; and
o any waivers of or amendments to the Code, to the extent required, will be
disclosed as provided by SEC rules.
5. Other Policies and Procedures
The Code shall be the sole code of ethics adopted by the Fund for
purposes of Section 406 of the Sarbanes-Oxley Act of 2002 and the rules and
forms applicable to registered investment companies thereunder. The Fund's,
its principal underwriter's and the Adviser's codes of ethics under Rule
17j-1 under the Investment Company Act and the Adviser's additional policies
and procedures, including its Code of Conduct, are separate requirements
applying to the Covered Officers and others, and are not part of the Code.
6. Amendments
The Code may not be amended except in written form which is
specifically approved or ratified by a majority vote of the Fund's Board,
including a majority of independent Board members.
7. Confidentiality
All reports and records prepared or maintained pursuant to the Code
will be considered confidential and shall be maintained and protected
accordingly. Except as otherwise required by law or the Code, such matters
shall not be disclosed to anyone other than the appropriate Funds and their
counsel, the appropriate Boards (or Committees) and their counsel and the
Adviser.
8. Internal Use
The Code is intended solely for the internal use by the Fund and does
not constitute an admission, by or on behalf of the Fund, as to any fact,
circumstance, or legal conclusion.
Dated as of: JULY 1, 2003
------------------
EXHIBIT A
Persons Covered by the Code of Ethics
Stephen E. Canter President (Principal Executive
Officer)
(Principal Financial
James Windels Treasurer and Accounting Officer)