Owner: Tim Fagan
Administrator: Tim Fagan
Last Revision Date: 02/05
Next Revision Date: 05/05
This is the code of ethics of:
o John Hancock Advisers, LLC
o Sovereign Asset Management Co.
o each open-end and closed-end fund advised by John Hancock Advisers, LLC
o John Hancock Funds, LLC
(together, called "John Hancock Funds")
1. General Principles
Each person within the John Hancock Funds organization is responsible
for maintaining the very highest ethical standards when conducting our
business. This means that:
o You have a fiduciary duty at all times to place the interests of
our clients first.
o All of your personal securities transactions must be conducted
consistent with this code of ethics and in such a manner as to avoid
any actual or potential conflict of interest or other abuse of your
position of trust and responsibility.
o You should not take inappropriate advantage of your position or
engage in any fraudulent or manipulative practice (such as
front-running or manipulative market timing) with respect to our
clients' accounts.
o You must treat as confidential any information concerning the
identity of security holdings and financial circumstances of
clients.
o You must comply with all applicable federal securities laws.
o You must promptly report any violation of this code of ethics that
comes to your attention to the Chief Compliance Officer, Timothy M.
Fagan, or the Chief Legal Officer, Susan S. Newton.
The General Principles discussed above govern all conduct, whether or
not the conduct is also covered by more specific standards and
procedures in this code of ethics. As described below under the
heading "Interpretation and Enforcement", failure to comply with the
code of ethics may result in disciplinary action, including
termination of employment.
2. To Whom Does This Code Apply?
This code of ethics applies to you if you are a director, officer or
employee of John Hancock Advisers, LLC, Sovereign Asset Management
Co., John Hancock Funds, LLC or a "John Hancock fund" (any fund
advised by John Hancock Advisers, LLC or Sovereign Asset Management
Co.). It also applies to you if you are an employee of John Hancock
Life Insurance Co. or its subsidiaries who participates in making
recommendations for, or receives information about, portfolio trades
or holdings of the John Hancock funds or accounts. Certain
provisions apply to trustees of the John Hancock mutual funds and
closed-end funds-see Appendix C for more information.
Please note that if a policy described below applies to you, it also
applies all accounts over which you have a beneficial interest.
Normally, you will be deemed to have a beneficial interest in your
personal accounts, those of a spouse, "significant other," minor
children or family members sharing a household, as well as all
accounts over which you have discretion or give advice or information.
"Significant others" are defined for these purposes as two people
who (1) share the same primary residence; (2) share living expenses;
and (3) are in a committed relationship and intend to remain in the
relationship indefinitely.
There are three main categories for persons covered by this code of
ethics, taking into account their positions, duties and access to
information regarding fund portfolio trades. You have been notified
about which of these categories applies to you, based on the
Investment Compliance Department's understanding of your current role.
If you have a level of investment access beyond your assigned
category, or if you are promoted or change duties and as a result
should more appropriately be included in a different category, it is
your responsibility to notify Timothy M. Fagan, Chief Compliance
Officer.
The basic definitions of the three main categories, with examples, are
provided below. The more detailed definitions of each category are
attached as Appendix A.
- --------------------------------------- -------------------------------------- --------------------------------------
"Investment Access" person "Regular Access" person "Non-Access" person
A person who regularly participates A person who regularly obtains A person who does not regularly
in a fund's investment process or information regarding (1) fund participate in a fund's investment
makes securities recommendations portfolio trades or (2) non-public process or obtain information
to clients. information regarding holdings or regarding fund portfolio trades.
securities recommendations to clients.
examples: examples: examples:
- --------- --------- ---------
o portfolio managers o personnel in Investment o wholesalers
o analysts Operations or Compliance o inside wholesalers who
o traders o most FFM personnel don't attend investment
o Technology personnel with "morning meetings"
access to investment systems o certain administrative
o attorneys and some legal personnel
administration personnel
o investment admin. personnel
- --------------------------------------- -------------------------------------- --------------------------------------
3. Which Accounts and Securities are Subject to the Code's Personal
Trading Restrictions?
If this code of ethics describes "Personal Trading Requirements" (i.e.
John Hancock Mutual Fund reporting requirement and holding period, the
preclearance requirement, the ban on short-term profits, the ban on
IPOs, the disclosure of private placement conflicts and the reporting
requirements) that apply to your access category as described above,
then the requirements apply to trades for any account over which you
have a beneficial interest. Normally, this includes your personal
accounts, those of a spouse, "significant other," minor children or
family members sharing your household, as well as all accounts over
which you have discretion or give advice or information. This
includes all brokerage accounts that contain securities (including
brokerage accounts that only contain securities exempt from
reporting). Accounts over which you have no direct or indirect
influence or control are exempt. To prevent potential violations of
this code of ethics, you are strongly encouraged to request
clarification for any accounts that are in question.
These personal trading requirements do not apply to the following
securities:
o Direct obligations of the U.S. government (e.g., treasury
securities);
o Bankers' acceptances, bank certificates of deposit, commercial
paper, and high quality short-term debt obligations, including
repurchase agreements;
o Shares of open-end mutual funds that are not advised or sub-advised
by John Hancock Advisers or by John Hancock or Manulife entities;
o Shares issued by money market funds; and
o Securities in accounts over which you have no direct or indirect
influence or control.
Except as noted above, the Personal Trading Requirements apply to all
securities, including:
o stocks or bonds;
o government securities that are not direct obligations of the U.S.
government, such as Fannie Mae or municipal securities;
o Shares of all closed-end funds;
o Options on securities, on indexes, and on currencies;
o All kinds of limited partnerships;
o Foreign unit trusts and foreign mutual funds;
o Private investment funds and hedge funds; and
o Futures, investment contracts or any other instrument that is
considered a "security" under the Investment Advisers Act.
Different requirements apply to shares of open-end mutual funds that
are advised or sub-advised by John Hancock Advisers or by John Hancock
or Manulife entities-see the section below titled "John Hancock Mutual
Funds Reporting Requirement and Holding Period".
4. Overview of Policies
- ------------------------------------------------------ ---------------------- ---------------------- ----------------------
Investment Regular Access Non-Access
Access Person Person Person
- ------------------------------------------------------ ---------------------- ---------------------- ----------------------
General principles yes yes yes
- ------------------------------------------------------ ---------------------- ---------------------- ----------------------
Policies outside the code
- ------------------------------------------------------ ---------------------- ---------------------- ----------------------
Conflict of interest policy yes yes yes
- ------------------------------------------------------ ---------------------- ---------------------- ----------------------
Inside information policy yes yes yes
- ------------------------------------------------------ ---------------------- ---------------------- ----------------------
Policy regarding dissemination of mutual fund
portfolio information yes yes yes
- ------------------------------------------------------ ---------------------- ---------------------- ----------------------
Policies in the code
- ------------------------------------------------------ ---------------------- ---------------------- ----------------------
Restriction on gifts yes yes yes
- ------------------------------------------------------ ---------------------- ---------------------- ----------------------
John Hancock mutual funds reporting
requirement and holding period yes yes yes
- ------------------------------------------------------ ---------------------- ---------------------- ----------------------
Pre-clearance requirement yes yes Limited
- ------------------------------------------------------ ---------------------- ---------------------- ----------------------
Heightened preclearance of securities transactions
for "Significant Personal Positions" yes yes no
- ------------------------------------------------------ ---------------------- ---------------------- ----------------------
Ban on short-term profits yes no no
- ------------------------------------------------------ ---------------------- ---------------------- ----------------------
Ban on IPOs yes no no
- ------------------------------------------------------ ---------------------- ---------------------- ----------------------
Disclosure of private placement conflicts yes no no
- ------------------------------------------------------ ---------------------- ---------------------- ----------------------
Seven day blackout period yes no no
- ------------------------------------------------------ ---------------------- ---------------------- ----------------------
Reports and other disclosures outside the code
- ------------------------------------------------------ ---------------------- ---------------------- ----------------------
Broker letter/duplicate confirms yes yes yes
- ------------------------------------------------------ ---------------------- ---------------------- ----------------------
Reports and other disclosures in the code
- ------------------------------------------------------ ---------------------- ---------------------- ----------------------
Annual recertification form yes yes yes
- ------------------------------------------------------ ---------------------- ---------------------- ----------------------
Initial/annual holdings reports yes yes no
- ------------------------------------------------------ ---------------------- ---------------------- ----------------------
Quarterly transaction reports yes yes no
- ------------------------------------------------------ ---------------------- ---------------------- ----------------------
5. Policies Outside the Code of Ethics
John Hancock Funds has certain policies that are not part of the code
of ethics, but are equally important. The two most important of these
policies are (1) the Company Conflict and Business Practice Policy;
and (2) the Inside Information Policy.
>> Company Conflict & Business Practice Policy
- ----------------------------------------
Applies to: Investment Access Persons
Regular Access Persons
Non-Access Persons
- ----------------------------------------
A conflict of interest occurs when your private interests interfere or
could potentially interfere with your responsibilities at work. You
must not place yourself or the company in a position of actual
or potential conflict.
This Policy for officers and employees covers a number of important
issues. For example, you cannot serve as a director of any company
without first obtaining the required written executive approval.
This Policy includes significant requirements to be followed if your
personal securities holdings overlap with John Hancock Funds
investment activity. For example, if you or a member of your family own:
o a 5% or greater interest in a company, John Hancock Funds and its
affiliates may not make any investment in that company;
o a 1% or greater interest in a company, you cannot participate in any
decision by John Hancock Funds and its affiliates to buy or sell
that company's securities;
o ANY interest in a company, you cannot recommend or participate in a
decision by John Hancock Funds and its affiliates to buy or sell
that company's securities unless your personal interest is fully
disclosed at all stages of the investment decision.
(This is just a summary of this requirement-please read Section IV of
the Company Conflict and Business Practices Policy for more detailed
information.)
Other important issues in this Policy include:
o personal investments or business relationships
o misuse of inside information
o receiving or giving of gifts, entertainment or favors
o misuse or misrepresentation of your corporate position
o disclosure of confidential or proprietary information
o antitrust activities
o political campaign contributions and expenditures on public officials
>> Inside Information Policy and Procedures
- ----------------------------------------
Applies to: Investment Access Persons
Regular Access Persons
Non-Access Persons
- ----------------------------------------
The antifraud provisions of the federal securities laws generally
prohibit persons with material non-public information from trading on
or communicating the information to others. Sanctions for
violations can include civil injunctions, permanent bars from the
securities industry, civil penalties up to three times the profits
made or losses avoided, criminal fines and jail sentences. While
Investment Access persons are most likely to come in contact with
material non-public information, the rules (and sanctions) in this
area apply to all John Hancock Funds personnel and extend to
activities both related and unrelated to your job duties.
The Inside Information Policy and Procedures covers a number of
important issues, such as:
o The misuse of material non-public information
o The information barrier procedure
o The "restricted list" and the "watch list"
o broker letters and duplicate confirmation statements (see section 7
of this code of ethics)
>> Policy Regarding Dissemination of Mutual Fund Portfolio Information
- ----------------------------------------
Applies to: Investment Access Persons
Regular Access Persons
Non-Access Persons
- ----------------------------------------
Information about securities held in a mutual fund cannot be disclosed
except in accordance with this Policy, which generally requires time
delays of approximately one month and public posting of the
information to ensure that it uniformly enters the public domain.
6. Policies in the Code of Ethics
>> Restriction on Gifts
- ----------------------------------------
Applies to: Investment Access Persons
Regular Access Persons
Non-Access Persons
- ----------------------------------------
You and your family cannot accept preferential treatment or favors
(for example, gifts) from securities brokers or dealers or other
organizations with which John Hancock Funds might transact
business, except in accordance with the Company Conflict and Business
Practice Policy. For the protection of both you and John Hancock
Funds, the appearance of a possible conflict of interest must be
avoided. You should exercise caution in any instance in which business
travel and lodging are paid for by someone other than John Hancock
Funds. The purpose of this policy is to minimize the basis for any
charge that you used your John Hancock Funds position to obtain for
yourself opportunities which otherwise would not be offered to you.
Please see the Company Conflict and Business Practice Policy's
"Compensation and Gifts" section for additional details regarding
restrictions on gifts and exceptions for "nominal value" gifts.
>> John Hancock Mutual Funds Reporting Requirement and Holding Period
- ----------------------------------------
Applies to: Investment Access Persons
Regular Access Persons
Non-Access Persons
- ----------------------------------------
You must follow a reporting requirement and a holding period
requirement if you purchase either:
o a "John Hancock Mutual Fund" (i.e. a mutual fund that is advised by
John Hancock Advisers or by John Hancock or Manulife entity,
excluding the money market funds and any dividend reinvestment,
payroll deduction, systematic investment/withdrawal and other
program trades); or
o a "John Hancock Variable Product" (i.e. contacts funded by
insurance company separate accounts that use one or more portfolios
of Manufacturers Investment Trust or John Hancock Variable Series
Trust).
Reporting Requirement: You must report your holdings and your trades
in a John Hancock Mutual Fund or a John Hancock Variable Product.
This is not a preclearance requirement-you can report your holdings
after you trade by submitting duplicate confirmation statements to the
Investment Compliance Department. If you are an Investment Access
Person or a Regular Access Person, you must also make sure that your
holdings in a John Hancock Mutual Fund are included in your Initial
Holdings Report (upon hire) and Annual Holdings Report (each year
end).
If you purchase a John Hancock Variable Product, you must notify the
Investment Compliance Department. The Investment Compliance
Department will then obtain directly from the contract administrators
the personal trade and holdings information regarding the portfolios
underlying the Manulife or John Hancock variable insurance contracts.
The Investment Compliance Department will obtain personal securities
trade and holdings information in the 401(k) plans for John Hancock
Funds or John Hancock employees directly from the plan administrators.
Holding Requirement: You cannot profit from the purchase and sale of
a John Hancock Mutual Fund within 30 calendar days. The purpose of
this policy is to address the risk, real or perceived, of manipulative
market timing or other abusive practices involving short-term personal
trading in the John Hancock Mutual Funds. Any profits realized on
short-term trades must be surrendered by check payable to John Hancock
Advisers, LLC and will be contributed by John Hancock Advisers, LLC to
a charity, upon determination by the Compliance and Business Practices
Committee. If you give away a security, it is considered a sale. You
may request an exemption from this policy for involuntary sales due to
unforeseen corporate activity (such as a merger), or hardship reasons
(such as unexpected medical expenses) by sending an e-mail to Timothy
M. Fagan, Chief Compliance Officer.
>> Preclearance of Securities Transactions
- ----------------------------------------
Applies to: Investment Access Persons
Regular Access Persons
Also, for a limited category of trades:
--------------------------
Non-Access Persons
- ----------------------------------------
Limited Category of Trades for Non-Access Persons: If you are a
Non-Access person, you must preclear transactions in securities of any
closed-end funds advised by John Hancock Advisers, LLC. A Non-Access
person is not required to preclear other trades. However, please keep
in mind that a Non-Access person is required to report securities
transactions after every trade (even those that are not required to be
precleared) by requiring your broker to submit duplicate confirmation
statements, as described in section 7 of this code of ethics.
Investment Access persons and Regular Access persons: If you are an
Investment Access person or Regular Access person, you must "preclear"
(i.e.: receive advance approval of) any personal securities
transactions in the categories described above in the section "Which
Accounts and Securities are Subject to the Code's Personal Trading
Restrictions". Due to this preclearance requirement, participation in
investment clubs is prohibited.
Preclearance of private placements requires some special considerations
- -- the decision will take into account whether, for example: (1) the
investment opportunity should be reserved for John Hancock Funds
clients; and (2) it is being offered to you because of your position
with John Hancock Funds.
How to preclear: You preclear a trade by following the steps outlined
in the preclearance procedures, which are attached as Appendix B.
Please note that:
o You may not trade until clearance is received.
o Clearance approval is valid only for the date granted (i.e. the
preclearance date and the trade date should be the same.
o A separate procedure should be followed for requesting preclearance of
a private placement or a derivative, as detailed in Appendix B. The
Investment Compliance Department must maintain a five-year record of
all clearances of private placement purchases by Investment Access
persons, and the reasons supporting the clearances.
The preclearance policy is designed to proactively identify possible
"problem trades" that raise front-running, manipulative market timing
or other conflict of interest concerns (example: when an Investment
Access person trades a security on the same day as a John Hancock
fund).
>> Heightened Preclearance of Securities Transactions for "Significant
Personal Positions"
- ----------------------------------------
Applies to: Investment Access Persons
Regular Access Persons
- ----------------------------------------
If you are an Investment Access person or Regular Access person with a
personal securities position that is worth $100,000 or more, this is
deemed to be a "Significant Personal Position". This applies to any
personal securities positions in the categories described above in the
section "Which Accounts and Securities are Subject to the Code's
Personal Trading Restrictions". Before you make personal trades to
establish, increase or decrease a Significant Personal Position, you
must notify either the Chief Fixed Income Officer or the Chief Equity
Officer that (1) you intend to trade in a Significant Personal
Position and (2) confirm that you are not aware of any clients for
whom related trades should be completed first. You must receive their
pre-approval to proceed--their approval will be based on their
conclusion that your personal trade in a Significant Personal Position
will not "front-run" any action that John Hancock Funds should take
for a client. This Heightened Preclearance requirement is in addition
to, not in place of, the regular preclearance requirement described
above-you must also receive the regular preclearance before you trade.
>> Ban on Short-Term Profits
- ----------------------------------------
Applies to: Investment Access Persons
- ----------------------------------------
If you are an Investment Access person, you cannot profit from the
purchase and sale (or sale and purchase) of the same (or equivalent)
securities within 60 calendar days. This applies to any personal
securities trades in the categories described above in the section
"Which Accounts and Securities are Subject to the Code's Personal
Trading Restrictions".
You may invest in derivatives or sell short provided the transaction
period exceeds the 60-day holding period. If you give away a security,
it is considered a sale.
The purpose of this policy is to address the risk, real or perceived,
of front-running, manipulative market timing or other abusive
practices involving short-term personal trading. Any profits realized
on short-term trades must be surrendered by check payable to John
Hancock Advisers, LLC and will be contributed by John Hancock
Advisers, LLC to a charity, upon determination by the Compliance and
Business Practices Committee.
You may request an exemption from this policy for involuntary sales
due to unforeseen corporate activity (such as a merger), or hardship
reasons (such as unexpected medical expenses) by sending an e-mail to
Timothy M. Fagan, Chief Compliance Officer.
>> Ban on IPOs
- ----------------------------------------
Applies to: Investment Access Persons
- ----------------------------------------
If you are an Investment Access person, you may not acquire securities
in an initial public offering (IPO). You may not purchase any
newly-issued securities until the next business (trading) day after
the offering date. This applies to any personal securities trades in
the categories described above in the section "Which Accounts and
Securities are Subject to the Code's Personal Trading Restrictions".
There are two main reasons for this prohibition: (1) these purchases
may suggest that persons have taken inappropriate advantage of their
positions for personal profit; and (2) these purchases may create at
least the appearance that an investment opportunity that should have
been available to the John Hancock funds was diverted to the personal
benefit of an individual employee.
You may request an exemption for certain investments that do not
create a potential conflict of interest, such as: (1) securities of a
mutual bank or mutual insurance company received as compensation in a
demutualization and other similar non-voluntary stock acquisitions;
(2) fixed rights offerings; or (3) a family member's participation as
a form of employment compensation in their employer's IPO.
>> Disclosure of Private Placement Conflicts
- ----------------------------------------
Applies to: Investment Access Persons
- ----------------------------------------
If you are an Investment Access person and you own securities
purchased in a private placement, you must disclose that holding
when you participate in a decision to purchase or sell that same
issuer's securities for a John Hancock fund. This applies to any
private placement holdings in the categories described above in the
section "Which Accounts and Securities are Subject to the Code's
Personal Trading Restrictions". Private placements are securities
exempt from SEC registration under section 4(2), section 4(6) or rules
504 -506 of the Securities Act of 1933.
The investment decision must be subject to an independent review by
investment personnel with no personal interest in the issuer.
The purpose of this policy is to provide appropriate scrutiny in
situations in which there is a potential conflict of interest.
>> Seven Day Blackout Period
- ----------------------------------------
Applies to: Investment Access Persons
- ----------------------------------------
If you are a portfolio manager (or were identified to the Investment
Compliance Department as part of a portfolio management team) you are
prohibited from buying or selling a security within seven calendar
days before and after that security is traded for a fund that you
manage unless no conflict of interest exists in relation to that
security (as determined by the Compliance and Ethics Committee).
In addition, all investment access persons are prohibited from
knowingly buying or selling a security within seven calendar days
before and after that security is traded for a John Hancock fund
unless no conflict of interest exists in relation to that security.
This applies to any personal securities trades in the categories
described above in the section "Which Accounts and Securities are
Subject to the Code's Personal Trading Restrictions". If a John
Hancock fund trades in a security within seven calendar days before or
after you trade in that security, you may be required to demonstrate
that you did not know that the trade was being considered for that
John Hancock fund.
You will be required to sell any security purchased in violation of
this policy unless it is determined that no conflict of interest
exists in relation to that security (as determined by the Compliance
and Ethics Committee). Any profits realized on trades determined by
the Compliance and Ethics Committee to be in violation of this policy
must be surrendered by check payable to John Hancock Advisers, LLC and
will be contributed by John Hancock Advisers, LLC to a charity.
7. Reports and Other Disclosures Outside the Code of Ethics
>> Broker Letter/Duplicate Confirm Statements
- ----------------------------------------
Applies to: Investment Access Persons
Regular Access Persons
Non-Access Persons
- ----------------------------------------
As required by the Inside Information Policy, you must inform your
stockbroker that you are employed by an investment adviser or broker.
Your broker is subject to certain rules designed to prevent
favoritism toward your accounts. You may not accept negotiated
commission rates that you believe may be more favorable than the
broker grants to accounts with similar characteristics.
When a brokerage account is opened for which you have a beneficial
interest, before any trades are made, you must:
o Notify the broker-dealer with which you are opening an account that
you are a registered associate of JHF;
o Ask the firm in writing to have duplicate written confirmations of
any trade, as well as statements or other information concerning
the account, sent to the JHF Investment Compliance Department
(contact: Fred Spring), 10th Floor, 101 Huntington Avenue, Boston,
MA 02199; and
o Notify the JHF Investment Compliance Department, in writing, that
you have an account before you place any trades.
This applies to any personal securities trades in the categories
described above in the section "Which Accounts and Securities are
Subject to the Code's Personal Trading Restrictions" as well as trades
in John Hancock Mutual Funds and John Hancock Variable Products. The
Investment Compliance Department may rely on information submitted by
your broker as part of your reporting requirements under this code of
ethics.
8. Reports and Other Disclosures In the Code of Ethics
>> Initial Holdings Report and Annual Holdings Report
- ----------------------------------------
Applies to: Investment Access Persons
Regular Access Persons
- ----------------------------------------
You must file an initial holdings report within 10 calendar days after
becoming an Investment Access person or a Regular Access person. The
information must be current as of a date no more than 45 days prior to
your becoming an Investment Access person or a Regular Access person.
You must also file an annual holdings report (as of December
31st) within 45 calendar days after the calendar year end. This
applies to any personal securities holdings in the categories
described above in the section "Which Accounts and Securities are
Subject to the Code's Personal Trading Restrictions" as well as
holdings in John Hancock Mutual Funds and John Hancock Variable
Products.
Your reports must include:
o the title and type of security, and as applicable the exchange ticker
symbol or CUSIP number, number of shares, and principal amount of each
reportable security;
o the name of any broker, dealer or bank with which you maintain an
account; and
o the date that you submit the report.
>> Quarterly Transaction Reports
- ----------------------------------------
Applies to: Investment Access Persons
Regular Access Persons
- ----------------------------------------
You must file a quarterly transaction report within 30 calendar days
after the end of a calendar quarter if you are an Investment Access
person or a Regular Access person. This report must cover all
transactions during the past calendar quarter for any accounts and
personal securities trades in the categories described above in the
section "Which Accounts and Securities are Subject to the Code's
Personal Trading Restrictions" as well as transactions in John Hancock
Mutual Funds and John Hancock Variable Products. You must submit a
quarterly report even if you have no transactions during the quarter.
Your quarterly transaction report must include the following
information about these transactions:
o the date of the transaction, the title, and as applicable the
exchange ticker symbol or CUSIP number, interest rate and maturity
date, number of shares, and principal amount of each reportable
security involved;
o the nature of the transaction (i.e. purchase, sale or any other
type of acquisition or disposition);
o the price at which the transaction was effected;
o the name of the broker, dealer or bank with or through which the
transaction was effected; and
o the date that you submit the report.
>> Annual Certification
- ----------------------------------------
Applies to: Investment Access Persons
Regular Access Persons
Non-Access Persons
- ----------------------------------------
At least annually (or additionally when the code of ethics has been
significantly changed), you must provide a certification at a date
designated by the Investment Compliance Department that:
(1) you have read and understood this code of ethics;
(2) you recognize that you are subject to its policies; and
(3) you have complied with its requirements.
You are required to make this certification to demonstrate that you
understand the importance of these policies and your responsibilities
under the code of ethics.
9. Limited Access Persons
There is an additional category of persons called "Limited Access"
persons. This category consists only of directors of John Hancock
Advisers, LLC or the John Hancock funds who:
(a) are not also officers of John Hancock Advisers, LLC; and
(b) do not ordinarily obtain information about fund portfolio trades.
A more detailed definition of Limited Access persons, and a list of
the policies that apply to them, is attached as Appendix C.
10. Subadvisers
A subadviser to a John Hancock fund has a number of code of ethics
responsibilities, as described in Appendix D.
11. Reporting Violations
If you know of any violation of our code of ethics, you have a
responsibility to promptly report it. You should also report any
deviations from the controls and procedures that safeguard John
Hancock Funds and the assets of our clients. You can request
confidential treatment of your reporting action.
You can report violations to:
o Timothy M. Fagan, Chief Compliance Officer (617-375-6205); or
o Susan S. Newton, Chief Legal Officer (617-375-1702)
12. Interpretation and Enforcement
This code of ethics cannot anticipate every situation in which
personal interests may be in conflict with the interests of our
clients. You should be responsive to the spirit and intent of this
code of ethics as well as its specific provisions.
When any doubt exists regarding any code of ethics provision or
whether a conflict of interest with clients might exist, you should
discuss the transaction in advance with the Chief Compliance Officer
Timothy M. Fagan, (617-375-6205) or the Chief Legal Officer Susan
Newton (617-375-1702)). The code of ethics is designed to detect and
prevent fraud against clients and fund investors, and to avoid the
appearance of impropriety. If you feel inequitably burdened by any
policy, you should feel free to contact Timothy Fagan, Susan Newton or
the Compliance and Business Practices Committee. Exceptions may be
granted where warranted by applicable facts and circumstances. For
example, exemption for some Personal Trading Requirements may be
granted for transactions effected pursuant to an automatic investment
plan.
To provide assurance that policies are effective, the Investment
Compliance Department will monitor and check personal securities
transaction reports and certifications against fund portfolio
transactions. Additional administration and recordkeeping procedures
are described in Appendix E.
The Chief Compliance Officer has general administrative responsibility
for this code of ethics, and will administer procedures to review
personal trading reports. The Compliance and Business Practices
Committee of John Hancock Funds approves amendments to the code of
ethics and dispenses sanctions for violations of the code of ethics.
Accordingly, the Investment Compliance Department will refer
violations to the Complaince and Business Practices Committee for
review and appropriate action. The following factors will be
considered when the Compliance and Business Practices Committee
determines a fine or other disciplinary action:
o the person's position and function (senior personnel may be held to
a higher standard);
o the amount of the trade;
o whether the funds or accounts hold the security and were trading
the same day;
o whether the violation was by a family member.
o whether the person has had a prior violation and which policy was
involved.
o whether the employee self-reported the violation.
You can request reconsideration of any disciplinary action by
submitting a written request to the Compliance and Business Practices
Committee.
No less frequently than annually, a written report of all material
violations and sanctions, significant conflicts of interest and other
related issues will be submitted to the boards of directors of the
John Hancock funds for their review. Sanctions for violations could
include fines, limitation of personal trading activity, suspension or
termination of the violator's position with John Hancock Funds and/or
a report to the appropriate regulatory authority.
13. Education of Employees
The Investment Compliance Department will provide a paper copy or
electronic version of the code of ethics (and any amendments) to each
person subject to this code of ethics. The Investment Compliance
Department will also administer training of employees on the
principles and procedures of the code of ethics.
Appendix A: Categories of Personnel
You have been notified about which of these categories applies to you,
based on the Investment Compliance Department's understanding of your
current role. If you have a level of investment access beyond that
category, or if you are promoted or change duties and as a result
should more appropriately be included in a different category, it is
your responsibility to immediately notify the Chief Compliance Officer
Timothy M. Fagan, (617-375-6205) or the Code of Ethics Administrator
Fredrick Spring (617-375-4987).
1) Investment Access person: You are an Investment Access person
if you are an employee of John Hancock Advisers, LLC, a John Hancock
fund, or John Hancock Life Insurance Company or its subsidiaries who,
in connection with your regular functions or duties, makes or
participates in making recommendations regarding the purchase or sale
of securities by a John Hancock fund.
(examples: portfolio managers, analysts, traders)
2) Regular Access person: You are a Regular Access person if you
do not fit the definition of Investment Access Person, but you do fit
one of the following two sub-categories:
o You are an officer (vice president and higher) or director of John
Hancock Advisers, LLC or a John Hancock fund. (Some directors may
be Limited Access persons-please see Appendix C for this
definition.)
o You are an employee of John Hancock Advisers, LLC, a John Hancock
fund or John Hancock Life Insurance Co. or its subsidiaries , or a
director, officer (vice president and higher) or employee of John
Hancock Funds, LLC who has access to nonpublic information
regarding any clients' purchase or sale of securities, or nonpublic
information regarding the portfolio holdings of any reportable fund
or who is involved in making securities recommendations to clients,
or who has access to such recommendations that are nonpublic.
(examples: Investment Operations personnel, Investment Compliance
Department personnel, most Fund Financial Management personnel,
investment administrative personnel, Technology Resources personnel
with access to investment systems, attorneys and some legal
administration personnel)
3) Non-Access person: You are a non-access person if you are an
employee of John Hancock Advisers, LLC, John Hancock Funds, LLC or a
John Hancock fund who does not fit the definitions of any of the other
three categories (Investment Access Person, Regular Access Person or
Limited Access Person). To be a non-access person, you must not
obtain information regarding the purchase or sale of securities by a
John Hancock fund or nonpublic information regarding the portfolio
holdings in connection with your regular functions or duties.
(examples: wholesalers, inside wholesalers, certain administrative
staff)
4) Limited Access Person: Please see Appendix C for this
definition.
Appendix B: Preclearance Procedures
You should read the Code of Ethics to determine whether you must
obtain a preclearance before you enter into a securities transaction.
If you are required to obtain a preclearance, you should follow the
procedures detailed below.
1. Pre-clearance for Public Securities including Derivatives,
Futures, Options and Selling Short:
A request to pre-clear should be entered into the John Hancock
Personal Trading & Reporting System.
The John Hancock Personal Trading & Reporting System is located under
your Start Menu on your Desktop. It can be accessed by going to
Programs/Personal Trading & Reporting/ Personal Trading & Reporting
and by entering your Web Security Services user id and password.
If the John Hancock Personal Trading & Reporting System is not on your
Desktop, please contact the HELP Desk at (617) 572-6950 for
assistance.
The Trade Request Screen:
At times you may receive a message like "System is currently
unavailable". The system is scheduled to be offline from 8:00 PM until
7:00 AM each night.
[GRAPHIC: Trade Request Screen]
Ticker/Security Cusip: Fill in this one of these fields with the
proper information of the security you want to buy or sell. Then click
the [Lookup] button. Select one of the hyperlinks for the desired
security, and the system will populate the proper fields Ticker,
Security Cusip, Security Name and Security Type automatically on the
Trade Request Screen.
If You Don't Know the Ticker, Cusip, or Security Name:
If you do not know the full ticker, you may type in the first few
letters followed by an asterisk * and click the [Lookup] button. For
example, let's say you want to buy some shares of Intel, but all you
can remember of the ticker is that it begins with int, so you enter
int* for Ticker. If any tickers beginning with int are found, they are
displayed on a new screen. Select the hyperlink of the one you want,
and the system will populate Security Cusip, Security Name and
Security Type automatically on the Trade Request Screen. If you do not
know the full cusip, you may type in the first few numbers followed by
an asterisk * and click the [Lookup] button. For example, let's say
you want to buy some shares of Microsoft, but all you can remember of
the cusip is that it begins with 594918, so you enter 594918* for
Ticker. If any cusips beginning with 594918 are found, they are
displayed on a new screen. Select the hyperlink of the one you want,
and the system will fill in Ticker, Security Name and Security Type
automatically on the Trade Request Screen. If you do not know the
Ticker but have an idea of what the Security Name is, you may type in
an asterisk, a few letters of the name and an asterisk * and click the
[Lookup] button. For example, let's say you want to buy some shares of
American Brands, so you enter *amer* for Security Name. Any securities
whose names have amer in them are displayed on a new screen, where you
are asked to select the hyperlink of the one you want, and the system
will fill in Ticker, Cusip and Security Type automatically on the
Trade Request Screen.
Other Items on the Trade Request Screen:
Brokerage Account: Click on the dropdown arrow to the right of the
Brokerage Account field to choose the account to be used for the
trade.
Transaction Type: Choose one of the values displayed when you click
the dropdown arrow to the right of this field.
Trade Date: You may only submit trade requests for the current date.
Note: One or more of these fields may not appear on the Request Entry
screen if the information is not required. Required fields are
determined by the Investment Compliance Department.
Click the [Submit Request] button to send the trade request to your
Investment Compliance department.
Once you click the [Submit Request] button, you will be asked to
confirm the values you have entered. Review the information and click
the [Confirm] button if all the information is correct. After which,
you will receive immediate feedback in your web browser. (Note: We
suggest that you print out this confirmation and keep it as a record
of the trade you have made). After this, you can either submit another
trade request or logout.
Attention Investment Access Persons: If the system identifies a
potential violation of the Ban on Short Term Profits Rule, your
request will be sent to the Investment Compliance Department for
review and you will receive feedback via the e-mail system.
Starting Over:
To clear everything on the screen and start over, click the [Clear
Screen] button.
Exiting Without Submitting the Trade Request:
If you decide not to submit the trade request before clicking the
[Submit Request] button, simply exit from the browser by clicking the
[X] button on the upper right or by pressing [Alt+F4], or by clicking
the Logout hyperlink on the lower left side of the screen.
Ticker/Security Name Lookup Screen:
You arrive at this screen from the Trade Request Screen, where you've
clicked the [Lookup] button (see above, "If You Don't Know the Ticker,
Cusip, or Security Name"). If you see the security you want to trade,
you simply select its corresponding hyperlink, and you will
automatically return to the Trade Request Screen, where you finish
making your trade request. If the security you want to trade is not
shown, that means that it is not recognized by the system under the
criteria you used to look it up. Keep searching under other names
(click the [Return to Request] button) until you are sure that the
security is not in the system. If you determine that the desired
security is not in the system, please contact a member of the
Investment Compliance department to add the security for you. Contacts
are listed below:
Fred Spring x54987
Adding Brokerage Accounts:
To access this functionality, click on the Add Brokerage Account
hyperlink on the left frame of your browser screen. You will be
prompted to enter the Brokerage Account Number, Brokerage Account
Name, Date Opened, and Broker. When you click the [Create New
Brokerage Account] button, you will receive a message that informs you
whether the account was successfully created.
[GRAPHIC: Add Brokerage Account screen]
3. Pre-clearance for Private Placements and Initial Public Offerings:
You may request a preclearance of private placement securities or an
Initial Public Offering by contacting Fred Spring via Microsoft
Outlook (please "cc." Tim Fagan on all such requests). Please keep in
mind that the code of ethics prohibits Investment Access persons from
purchasing securities in an initial public offering.
The request must include:
|_| the associate's name;
|_| the associate's John Hancock Funds' company;
|_| the complete name of the security;
|_| the seller and whether or not the seller is one with whom the
associate does business on a regular basis;
|_| any potential conflict, present or future, with fund trading activity
and whether the security might be offered as inducement to later
recommend publicly traded securities for any fund; and
|_| the date of the request.
Clearance of private placements or initial public offerings may be
denied if the transaction could create the appearance of impropriety.
Clearance of initial public offerings will also be denied if the
transaction is prohibited for a person due to his or her access
category under the code of ethics.
Appendix C: Limited Access Persons
There are two types of Limited Access Persons-(1) Certain directors of
the Adviser and (2) the Independent Trustees/Directors of the Funds.
(1) Certain Directors of the Adviser:
You are a Limited Access person if you are a director of John Hancock
Advisers, LLC or Sovereign Asset Management Co. and you meet the three
following criteria:
(a) you are not also an officer of John Hancock Advisers, LLC,
Sovereign Asset Management Co. or a John Hancock fund;
(b) you do not have access to nonpublic information regarding any
clients' purchase or sale of securities, or nonpublic information
regarding the portfolio holdings of any John Hancock fund or account;
and
(c) you are not involved in making securities recommendations to
clients and do not have access to such recommendations that are
nonpublic.
(examples: directors of John Hancock Advisers, LLC or Sovereign Asset
Management Co. who are not involved in the daily operations of the
adviser)
If you are a Limited Access Person who fits this definition, the
following policies apply to your category. These policies are
described in detail in the code of ethics.
o General principles
o Inside information policy and procedures
o Broker letter/Duplicate Confirms
o Initial/annual holdings reports
o Quarterly transaction reports
o Annual recertification
Preclearance requirement LIMITED: You only need to preclear any
direct or indirect acquisition of beneficial ownership in any security
in an initial public offering (an IPO) or in a limited offering (i.e.
a private placement). To request preclearance of these securities,
contact Timothy Fagan at tfagan@jhancock.com and/or Fredrick Spring at
fspring@jhancock.com.
- ---------------
*A Limited Access Person may complete this requirement under the code
of ethics of another Manulife/John Hancock adviser or fund by the
applicable regulatory deadlines and arrange for copies of the required
information to be sent to the John Hancock Funds Compliance
Department.
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(2) The Independent Trustees/Directors of the Funds: If you are an
independent trustee/director to a John Hancock fund (i.e. not an
"interested person" of the fund within the meaning of the Investment
Company Act of 1940), the following policies apply to your category.
These policies are described in detail in the code of ethics.
o General principles
o Annual recertification
o Quarterly transaction report, but only if you knew (or should have
known) that during the 15 calendar days before or after you trade a
security, either:
(i) a John Hancock fund purchased or sold the same security, or
(ii) a John Hancock fund or John Hancock Advisers, LLC considered
purchasing or selling the same security.
This policy applies to holdings in your personal accounts, those of a
spouse, "significant other" or family members sharing your household,
as well as all accounts over which you have discretion or give advice
or information. If this situation occurs, it is your responsibility
to contact Timothy M. Fagan, Chief Compliance Officer, at (617)
375-6205 and he will assist you with the requirements of the quarterly
transaction report.
This means that the independent trustees of the funds will not usually
be required to file a quarterly transaction report-they are only
required to file in the situation described above.
Appendix D: Subadvisers
Each subadviser to a John Hancock fund is subject to its own code of
ethics, which must meet the requirements of Rule 17j-1 and Rule
204A-1.
Approval of Code of Ethics
Each subadviser to a John Hancock fund must provide a copy of its code
of ethics to the trustees of the relevant John Hancock funds for
approval initially and within 60 calendar days of any material
amendment. The trustees will give their approval if they determine
that the code:
o contains provisions reasonably necessary to prevent the
subadviser's Access Persons (as defined in Rule 17j-1) from
engaging in any conduct prohibited by Rule 17j-1;
o requires the subadviser's Access Persons to make reports to at
least the extent required in Rule 17j-1(d);
o requires the subadviser to institute appropriate procedures for
review of these reports by management or compliance personnel (as
contemplated by Rule 17j-1(d)(3));
o provides for notification of the subadviser's Access Persons in
accordance with Rule 17j-1(d)(4); and
o requires the subadviser's Access Persons who are Investment
Personnel to obtain the pre-clearances required by Rule 17j-1(e);
Reports and Certifications
Each subadviser must provide an annual report and certification to
John Hancock Advisers, LLC and the fund's trustees in accordance with
Rule 17j-1(c)(2)(ii). The subadviser must also provide other reports
or information that John Hancock Advisers, LLC may reasonably request.
Recordkeeping Requirements
The subadviser must maintain all records for its Access Persons as
required by Rule 17j-1(f).
Appendix E: Administration and Recordkeeping
Adoption and Approval
The trustees of a John Hancock fund must approve the code of ethics of
an adviser, subadviser or affiliated principal underwriter before
initially retaining its services.
Any material change to a code of ethics of a John Hancock fund, John
Hancock Funds, LLC, John Hancock Advisers, LLC or a subadviser to a
fund must be approved by the trustees of the John Hancock fund,
including a majority of trustees who are not interested persons, no
later than six months after adoption of the material change.
Administration
No less frequently than annually, John Hancock Funds, LLC, John
Hancock Advisers, LLC, each subadviser and each John Hancock fund will
furnish to the trustees of each John Hancock fund a written report
that:
o describes issues that arose during the previous year under the code of
ethics or the related procedures, including, but not limited to,
information about material code or procedure violations, and
o certifies that each entity has adopted procedures reasonably necessary
to prevent its access persons from violating its code of ethics.
Recordkeeping
The Investment Compliance Department will maintain:
o a copy of the current code of ethics for John Hancock Funds, LLC,
John Hancock Advisers, LLC, and each John Hancock fund, and a copy
of each code of ethics in effect at any time within the past five
years.
o a record of any violation of the code of ethics, and of any action
taken as a result of the violation, for six years.
o a copy of each report made by an Access person under the code of
ethics, for six years (the first two years in a readily accessible
place).
o a record of all persons, currently or within the past five years,
who are or were required to make reports under the code of ethics.
This record will also indicate who was responsible for reviewing
these reports.
o a copy of each code of ethics report to the trustees, for six years
(the first two years in a readily accessible place).
o a record of any decision, and the reasons supporting the decision,
to approve the acquisition by an Investment Access person of
initial public offering securities or private placement securities,
for six years.