ALPINE EQUITY TRUST
ALPINE SERIES TRUST
ALPINE INCOME TRUST
CODE OF ETHICS FOR SENIOR OFFICERS
Preamble
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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 U.S. 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 Alpine Equity Trust and the
Alpine Series Trust (the "Trusts") have adopted this Code of Ethics.
Statement of Policy
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It is the obligation of the senior officers of the Trusts 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
Fund in senior officer positions. No Code of Ethics 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 letter of
applicable laws, rules and regulations, and to provide the type of clear and
complete disclosure and information each Trusts' shareholders have a right to
expect.
The purpose of this Code of Ethics (the "Code") is to promote high
standards of ethical conduct by Covered Persons (as defined below) in their
capacities as officers of the Trusts, 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 Trusts and its adviser have adopted or may adopt in the future with which
Trust officers are also required to comply (e.g., code of ethics relating to
personal trading and conduct).
Covered Persons
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This Code applies to those persons appointed by the each Trusts' Board of
Directors as Chief Executive Officer, President, Chief Financial Officer and
Chief Accounting Officer, or persons performing similar functions.
Promotion of Honest and Ethical Conduct
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In serving as an officer of a Trust, each Covered Person must maintain high
standards of honesty and ethical conduct and must encourage his colleagues who
provide services to the Trusts, whether directly or indirectly, to do the same.
Each Covered Person understands that as an officer of a Trust, he has a
duty to act in the best interests of the Trust and its shareholders. The
interests of the Covered Person's personal interests should not be allowed to
compromise the Covered Person from fulfilling his duties as an officer of the
Trust.
If a Covered Person believes that his personal interests are likely to
materially compromise his objectivity or his ability to perform the duties of
his role as an officer of a Trust, he should consult with the Trusts' chief
legal officer or outside counsel. Under appropriate circumstances, a Covered
Person should also consider whether to present the matter to the Trustees of the
Trusts or a committee thereof.
No Covered Person shall suggest that any person providing, or soliciting to
be retained to provide, services to a Trust 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
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No Covered Person shall create or further the creation of false or
misleading information in any SEC filing or report to Trust shareholders. No
Covered Person shall conceal or fail 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 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, Trust 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 Trust reports reveal, rather than conceal, each Trusts'
financial condition.
Each Covered Person shall seek to obtain additional resources if he
believes that available resources are inadequate to enable the Trust to provide
full, fair and accurate financial information and other disclosure to regulators
and Fund shareholders.
Each Covered Person shall inquire of other Trust 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 Trusts, so
that information can be gathered and assessed early enough to facilitate timely
filings and issuance of reports and required certifications.
Promotion of Compliance with Applicable Government Laws, Rules and Regulations
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Each Covered Person shall become and remain knowledgeable concerning the
laws and regulations relating to the Trusts and their operations and shall act
with competence and due care in serving as an officer of the Trusts. 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 Trusts.
Each Covered Person shall cooperate with the Trusts' 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 Trusts 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 Trusts or their operations.
Promoting Prompt Internal Reporting of Violations
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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 Fund's Audit Committee.
Any requests for a waiver from or an amendment to this Code shall be made
to the Chairman of the Fund's Audit Committee. All waivers and amendments shall
be disclosed as required by law.
Sanctions
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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 Fund's Audit Committee,
subject to review by the entire Board of Directors of the Fund.
Each Covered Person shall be required to certify annually whether he has
complied with this Code.
No Rights Created
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This Code of Ethics is a statement of certain fundamental principles,
policies and procedures that govern the Fund's senior officers in the conduct of
the Fund's 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
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The Fund 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 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 Board.
Amendments
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The Directors 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: June 18, 2003
CODE OF ETHICS FOR SENIOR OFFICERS
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I HEREBY CERTIFY THAT:
(1) I have read and I understand the Code of Ethics for Senior Officers
adopted by the Alpine Equity Trust, Alpine Series Trust and Alpine
Income Trust (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:
Name:
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Date:
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