EXHIBIT 10(a)(1)

                   CODE OF ETHICS FOR PRINCIPAL EXECUTIVE AND
               SENIOR FINANCIAL OFFICERS OF NEUBERGER BERMAN FUNDS

I.   COVERED OFFICERS/PURPOSE OF THE CODE

This code of ethics ("Code") for the registered  investment companies within the
Neuberger  Berman Fund complex  (each,  a "Company")  applies to each  Company's
Principal   Executive  Officer,   Principal   Financial  Officer  and  Principal
Accounting  Officer (the "Covered  Officers,"  each of whom is listed in Exhibit
A). The purpose of the Code is to promote:

     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 a Company files with, or submits to, the Securities
         and Exchange Commission ("SEC") and in other public communications made
         by the Company;

     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.

II.  COVERED  OFFICERS SHOULD HANDLE  ETHICALLY  ACTUAL,  POTENTIAL AND APPARENT
     CONFLICTS OF INTEREST

     OVERVIEW. Each Covered Officer should adhere to a high standard of business
ethics  and  should be  sensitive  to  situations  that may give rise to actual,
potential and apparent conflicts of interest.

     An "actual  conflict of interest" occurs when a Covered  Officer's  private
interest  interferes  with the  interests  of,  or his or her  service  to,  the
Company.  For example,  a conflict of interest would arise if a Covered Officer,
or a member of his or her  family,  receives  improper  personal  benefits  as a
result of his or her position with the Company.

     A "potential  conflict of interest" occurs when a Covered Officer's private
interest is such that it might, under certain circumstances,  interfere with the
interests  of the Company or the  Officer's  service to the  Company,  but those
circumstances do not now exist.




     Appearances  may create an  "apparent  conflict of  interest"  even when an
actual conflict does not exist. For example, an apparent conflict may exist if a
Covered  Officer  owns a thinly  traded  security  that a series of a Company (a
"Fund") is buying, even if there is no actual conflict of interest.

     Certain  actual or  potential  conflicts  of interest  may arise out of the
relationships  between Covered  Officers and the Company and already are subject
to  conflict  of  interest  provisions  in the  Investment  Company  Act of 1940
("Investment  Company Act") and the Investment Advisers Act of 1940 ("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 a Fund  because of their status as  "affiliated  persons" of the
Company.  The compliance  programs and procedures of Neuberger Berman Management
Inc.,  Neuberger  Berman,  LLC  (collectively  referred  to as  the  "investment
adviser")  and each  Company are  designed to prevent,  or identify and correct,
violations  of these  provisions.  This Code does not,  and is not  intended to,
repeat or replace these programs and procedures, and such conflicts fall outside
of the parameters of this Code.

     Although  typically not  presenting an  opportunity  for improper  personal
benefit,  actual or potential  conflicts  may arise from, or as a result of, the
contractual relationship between the Company and the investment adviser of which
the Covered  Officers are also  officers or  employees.  As a result,  this Code
recognizes that the Covered  Officers will, in the normal course of their duties
(whether formally for the Company or for the investment  adviser,  or for both),
be involved in establishing  policies and implementing  decisions that will have
different  effects on the  adviser and the  Company.  The  participation  of the
Covered Officers in such activities is inherent in the contractual  relationship
between the  Company  and the  investment  adviser  and is  consistent  with the
performance by the Covered  Officers of their duties as officers of the Company.
Thus, if performed in conformity  with the provisions of the Investment  Company
Act and the Investment Advisers Act, such activities will be deemed to have been
handled  ethically.  In addition,  it is recognized by the Companies'  Boards of
Trustees/Directors  ("Boards") that the Covered Officers may also be officers or
employees  of one or more other  investment  companies  covered by this or other
codes.

     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. The overarching principle is that the personal interest
of a Covered Officer should not be placed  improperly before the interest of the
Company. The following list provides examples of conflicts of interest under the
Code,  but  Covered  Officers  should keep in mind that these  examples  are not
exhaustive.

     Each Covered Officer must not:

     o   use his or her personal influence or personal relationships  improperly
         to  influence  investment  decisions  or  financial  reporting  by  the

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         Company,  as for  example  where  the  Covered  Officer  would  benefit
         personally to the detriment of the Company;

     o   cause the  Company  to take  action,  or fail to take  action,  for the
         individual  personal  benefit of the  Covered  Officer  rather than the
         benefit the Company;

     o   retaliate  against  any other  Covered  Officer,  or any  employee of a
         Company,  its service  providers,  or the affiliated  persons of any of
         them, for good faith reports of potential violations of this Code.

     There are some actual or  potential  conflict of interest  situations  that
should  always be approved by the  Company's  Chief Legal  Officer1 if material.
Covered  Officers are  encouraged  to discuss  with the Chief Legal  Officer any
potential conflict the materiality of which is uncertain. Examples of reportable
conflicts include:

     o   service  as a director  on the board of any public or private  company,
         other than the Companies, their investment adviser, and its affiliates;

     o   the  receipt of any non-nominal  gifts,  i.e., those in excess of $100;

     o   the  receipt  of any  entertainment  from any  company  with  which the
         Company  has  current or  prospective  business  dealings  unless  such
         entertainment is business-related,  reasonable in cost,  appropriate as
         to time and place,  and not so  frequent  as to raise any  question  of
         impropriety;

     o   any ownership interest in, or any consulting or employment relationship
         with, any of the Company's service providers, other than its investment
         adviser or any affiliated person thereof; and

     o   a direct or indirect  financial  interest in  commissions,  transaction
         charges  or  spreads  paid  by  the  Company  for  effecting  portfolio
         transactions or for selling or redeeming  shares other than an interest
         arising from the Covered Officer's employment,  such as compensation or
         equity ownership.

III. DISCLOSURE AND COMPLIANCE

     o   Each  Covered  Officer  must  familiarize  himself or herself  with the
         disclosure  requirements  generally  applicable  to the Company and the
         Company's Disclosure Controls and Procedures;

     o   each Covered Officer must not knowingly  misrepresent,  or cause others
         to misrepresent,  facts about the Company to others,  whether within or
         outside the Company, including to the Company's  trustees/directors and
         auditors,   and  to   governmental   regulators   and   self-regulatory
         organizations;

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1    The Board of each  Company has  appointed  Philip R. Carroll as Chief Legal
     Officer.

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     o   each Covered Officer should,  to the extent  appropriate  within his or
         her area of  responsibility,  consult with other officers and employees
         of the Companies and the adviser with the goal of promoting full, fair,
         accurate,  timely and  understandable  disclosure  in the  reports  and
         documents the  Companies  file with, or submit to, the SEC and in other
         public communications made by the Companies; and

     o   each Covered  Officer should promote  compliance with the standards and
         restrictions imposed by applicable laws, rules and regulations.

IV.  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 or she has
         received, read, and understands the Code;

     o   annually  thereafter  affirm to the Board  that he or she has  complied
         with the requirements of the Code;

     o   report  on  the  Company's  Questionnaire  for  Trustees/Directors  and
         Officers,  where responsive to appropriate questions, all categories of
         affiliations or other relationships  giving rise to actual or potential
         conflicts of interest; and

     o   notify the Chief Legal Officer  promptly if he or she is aware of facts
         and  circumstances  that he or she knows are a violation  of this Code.
         Failure to do so is itself a violation of this Code.

     The Chief Legal Officer is  responsible  for applying this Code to specific
situations in which  questions  are presented  under it and has the authority to
interpret  this Code in any  particular  situation.2  However,  any approvals or
waivers3  sought by the  Principal  Executive  Officer will be considered by the
Independent Trustees/ Directors of the affected Company (the "Committee").

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2    The Chief Legal  Officer is  authorized to consult,  as  appropriate,  with
     counsel to the Company and counsel to the  Independent  Trustees/Directors,
     and is encouraged to do so.
3    Item 2 of Form N-CSR defines "waiver" as "the approval by the registrant of
     a material  departure from a provision of the code of ethics" and "implicit
     waiver" as "the  registrant's  failure to take action  within a  reasonable
     period of time regarding a material  departure from a provision of the code
     of  ethics  that  has  been  made  known to an  executive  officer"  of the
     registrant. Both waivers and implicit waivers must be disclosed publicly.


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     The Companies will follow these procedures in  investigating  and enforcing
this Code:

     o   The Chief Legal Officer will take all appropriate action to investigate
         any potential violations reported to him or her.

     o   The Chief Legal Officer will report to the Committee the outcome of the
         investigation, including the facts of the initial report, the scope and
         outcome  of the  investigation,  and  whether  or not the  Chief  Legal
         Officer believes that a violation occurred.

     o   The person who initially  reported the matter will be informed that the
         matter has been investigated and reported to the Committee.

     o   If the Committee concurs that a violation has occurred,  it will inform
         and make a recommendation to the Board, which will consider appropriate
         action, which may include review of, and appropriate  modifications to,
         applicable   policies  and  procedures;   notification  to  appropriate
         personnel of the investment  adviser or its board; or a  recommendation
         to dismiss the Covered Officer.

     o   The Committee will be responsible for granting waivers, as appropriate.

     o   Any changes to or waivers of this Code will, to the extent required, be
         disclosed as provided by SEC rules.

V.   OTHER POLICIES AND PROCEDURES

     This Code  shall be the sole code of ethics  adopted by the  Companies  for
purposes  of  Section  406 of the  Sarbanes-Oxley  Act and the  rules  and forms
applicable  to  registered  investment  companies  thereunder.  Insofar as other
policies or procedures of the Companies,  the investment adviser, the Companies'
principal  underwriter,  or other  service  providers  purport to apply a lesser
standard  to the  behavior  or  activities  of the  Covered  Officers,  they are
superseded  by this Code to the extent that they  overlap or  conflict  with the
provisions of this Code. The Companies'  and the investment  adviser's  codes of
ethics  under Rule 17j-l under the  Investment  Company  Act and the  investment
adviser's more detailed  policies and  procedures set forth in Neuberger  Berman
Management Inc.'s Compliance  Manual are separate  requirements  applying to the
Covered Officers and others, and are not preempted by this Code.

VI.  AMENDMENTS

     Any  amendments to this Code,  other than  amendments to Exhibit A, must be
approved or ratified  by a majority  vote of the Board,  including a majority of
Independent Trustees/Directors.

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VII. CONFIDENTIALITY

     All reports and records  prepared or maintained  pursuant to this Code will
be considered  confidential  and shall be maintained and protected  accordingly.
Except as  otherwise  required by law or this Code,  such  matters  shall not be
disclosed  to anyone  other  than the  appropriate  Company,  its Board (and any
Committee of the Board) and their counsel.

VIII.  INTERNAL USE

         The Code is intended solely for internal use by the Companies and does
not constitute an admission, by or on behalf of any Company, as to any fact,
circumstance, or legal conclusion.


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EXHIBIT A

Persons Covered by this Code of Ethics:

Peter E.  Sundman, Chairman and Chief Executive Officer

Barbara Muinos, Treasurer and Principal Financial and Accounting Officer


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