EXHIBIT 12(a)(1)
CODE OF ETHICS
CREDIT SUISSE FUNDS
CREDIT SUISSE INSTITUTIONAL FUNDS
CREDIT SUISSE CLOSED-END FUNDS
CODE OF ETHICS FOR SENIOR OFFICERS
Preamble
Section 406 of the Sarbanes-Oxley Act of 2002 directs that
rules be adopted disclosing whether a company has a code of ethics for senior
financial officers. The Securities and Exchange Commission (the "SEC") has
adopted rules requiring annual disclosure of an investment company's code of
ethics applicable to the company's principal executive as well as principal
financial officers, if such a code has been adopted. In response, the above
Funds (each a "Fund", and together the "Funds") have adopted this Code of
Ethics.
Statement of Policy
It is the obligation of the senior officers of the Funds to
provide full, fair, timely and comprehensible disclosure--financial and
otherwise--to Fund shareholders, regulatory authorities and the general public.
In fulfilling that obligation, senior officers must act ethically, honestly and
diligently. This Code is intended to enunciate guidelines to be followed by
persons who serve the Funds in senior officerships. No Code can address every
situation that a senior officer might face; however, as a guiding principle,
senior officers should strive to implement the spirit as well as the
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letter of applicable laws, rules and regulations, and to provide the type of
clear and complete disclosure and information Fund shareholders have a right to
expect.
The purpose of this Code of Ethics is to promote high
standards of ethical conduct by Covered Persons (as defined below) in their
capacities as officers of the Funds, to instruct them as to what is considered
to be inappropriate and unacceptable conduct or activities for officers and to
prohibit such conduct or activities. This Code supplements other policies that
the Funds and their adviser have adopted or may adopt in the future with which
Fund officers are also required to comply (e.g., code of ethics relating to
personal trading and conduct).
Covered Persons
This Code of Ethics applies to those persons appointed by the
Fund's Board of Directors as Chief Executive Officer, President, Chief Financial
Officer and Chief Accounting Officer, or persons performing similar functions.
It is recognized that each of such persons currently is a full-time employee of
Credit Suisse Asset Management LLC ("CSAM"), each Fund's investment adviser.
Promotion of Honest and Ethical Conduct
In serving as an officer of the Funds, each Covered Person
must maintain high standards of honesty and ethical conduct and must encourage
his colleagues who provide services to the Funds, whether directly or
indirectly, to do the same.
Each Covered Person understands that as an officer of a Fund,
he has a duty to act in the best interests of the Fund and its shareholders. The
interests of other CSAM clients or CSAM itself or the Covered Person's personal
interests should not be allowed to compromise the Covered
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Person's fulfilling his duties as an officer of the Fund. The governing Boards
of the Funds recognize that the Covered Persons are also officers or employees
of CSAM. Furthermore, the governing Boards of the Funds recognize that, subject
to the Covered Person's fiduciary duties to the Funds, the Covered Persons will
in the normal course of their duties (whether formally for the Funds or for
CSAM, or for both) be involved in establishing policies and implementing
decisions that will have different effects on CSAM and the Funds. The governing
Boards of the Funds recognize that the participation of the Covered Persons in
such activities is inherent in the contractual relationship between the Funds
and CSAM and/or its affiliates, and is consistent with the expectation of the
governing Boards of the performance by the Covered Persons of their duties as
officers of the Funds.
If a Covered Person believes that his responsibilities as an
officer or employee of CSAM are likely to materially compromise his objectivity
or his ability to perform the duties of his role as an officer of the Funds, he
should consult with CSAM's general counsel, the Funds' chief legal officer or
outside counsel, or counsel to the independent Directors/Trustees of the
relevant Fund or Funds. Under appropriate circumstances, a Covered Person should
also consider whether to present the matter to the Directors/Trustees of the
relevant Fund or Funds or a committee thereof.
No Covered Person shall suggest that any person providing, or
soliciting to be retained to provide, services to a Fund give a gift or an
economic benefit of any kind to him in connection with the person's retention or
the provision of services.
Promotion of Full, Fair, Accurate, Timely and Understandable Disclosure
No Covered Person shall create or further the creation of
false or misleading information in any SEC filing or report to Fund
shareholders. No Covered Person shall conceal or fail
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to disclose information within the Covered Person's possession legally required
to be disclosed or necessary to make the disclosure made not misleading. If a
Covered Person shall become aware that information filed with the SEC or made
available to the public contains any false or misleading information or omits to
disclose necessary information, he shall promptly report it to CSAM's general
counsel or Fund counsel, who shall advise such Covered Person whether corrective
action is necessary or appropriate.
Each Covered Person, consistent with his responsibilities,
shall exercise appropriate supervision over, and shall assist, relevant Fund
service providers in developing financial information and other disclosure that
complies with relevant law and presents information in a clear, comprehensible
and complete manner. Each Covered Person shall use his best efforts within his
area of expertise to assure that Fund reports reveal, rather than conceal, the
relevant Fund's financial condition.
Each Covered Person shall seek to obtain additional resources
if he believes that available resources are inadequate to enable the Funds to
provide full, fair and accurate financial information and other disclosure to
regulators and Fund shareholders.
Each Covered Person shall inquire of other Fund officers and
service providers, as appropriate, to assure that information provided is
accurate and complete and presented in an understandable format using
comprehensible language.
Each Covered Person shall diligently perform his services to
the Funds, so that information can be gathered and assessed early enough to
facilitate timely filings and issuance of reports and required certifications.
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Promotion of Compliance with Applicable Government Laws, Rules and Regulations
Each Covered Person shall become and remain knowledgeable
concerning the laws and regulations relating to the Funds and their operations
and shall act with competence and due care in serving as an officer of the
Funds. Each Covered Person with specific responsibility for financial statement
disclosure will become and remain knowledgeable concerning relevant auditing
standards, generally accepted accounting principles, FASB pronouncements and
other accounting and tax literature and developments.
Each Covered Person shall devote sufficient time to fulfilling
his responsibilities to the Funds, recognizing that he will devote substantial
time to providing services to other CSAM clients and will perform other
activities as an employee of CSAM.
Each Covered Person shall cooperate with a Fund's independent
auditors, regulatory agencies and internal auditors in their review or
inspection of the Fund and its operations.
No Covered Person shall knowingly violate any law or
regulation relating to the Funds or their operations or seek to illegally
circumvent any such law or regulation.
No Covered Person shall engage in any conduct involving
dishonesty, fraud, deceit or misrepresentation involving the Funds or their
operations.
Promoting Prompt Internal Reporting of Violations
Each Covered Person shall promptly report his own violations
of this Code and violations by other Covered Persons of which he is aware to the
Chairman of the relevant Fund's Audit Committee.
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Any requests for a waiver from or an amendment to this Code
shall be made to the Chairman of the relevant Fund's Audit Committee. All
waivers and amendments shall be disclosed as required by law.
Sanctions
Failure to comply with this Code will subject the violator to
appropriate sanctions, which will vary based on the nature and severity of the
violation. Such sanctions may include censure, suspension or termination of
position as an officer of the Fund. Sanctions shall be imposed by the relevant
Fund's Audit Committee, subject to review by the entire Board of
Directors/Trustees of the Fund.
Each Covered Person shall be required to certify annually
whether he has complied with this Code.
No Rights Created
This Code of Ethics is a statement of certain fundamental
principles, policies and procedures that govern the Funds' senior officers in
the conduct of the Funds' business. It is not intended to and does not create
any rights in any employee, investor, supplier, competitor, shareholder or any
other person or entity.
Recordkeeping
The Funds will maintain and preserve for a period of not less
than six (6) years from the date such action is taken, the first two (2) years
in an easily accessible place, a copy of the information or materials supplied
to the Board (1) that provided the basis for any amendment or
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waiver to this Code and (2) relating to any violation of the Code and sanctions
imposed for such violation, together with a written record of the approval or
action taken by the relevant Board.
Amendments
The Directors/Trustees will make and approve such changes to
this Code of Ethics as they deem necessary or appropriate to effectuate the
purposes of this Code.
Dated: May 17, 2005
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CODE OF ETHICS FOR SENIOR OFFICERS:
I HEREBY CERTIFY THAT:
(1) I have read and I understand the Code of Ethics for Senior Officers
adopted by the Credit Suisse Funds, the Credit Suisse Institutional
Funds and the Credit Suisse Closed-End Funds (the "Code of Ethics");
(2) I recognize that I am subject to the Code of Ethics;
(3) I have complied with the requirements of the Code of Ethics during the
calendar year ending December 31, _______; and
(4) I have reported all violations of the Code of Ethics required to be
reported pursuant to the requirements of the Code during the calendar
year ending December 31, _______.
Set forth below exceptions to items (3) and (4), if any:
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Name:
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Date: