Owner: Frank Knox
Administrator: Frank Knox
Last Revision Date: 04/05
Next Revision Date: 05/06
May 1, 2005
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 and fund investors first.
o All of your personal securities transactions must be conducted
consistent with the provisions of this code of ethics that apply to you
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 or
fund investors.
o You must treat as confidential any information concerning the
identity of security holdings and financial circumstances of clients or
fund investors.
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 of your company.
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 trustee/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. In some cases only a limited number of provisions will apply
to you, based on your access category. For example, only a limited number
of provisions apply to independent trustees/directors 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 the Chief
Compliance Officer of your company.
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 has A person who does not regularly
in a fund's investment process or access to (1) fund portfolio participate in a fund's investment
makes securities recommendations trades or (2) non-public process or obtain information
to clients. information regarding holdings or regarding fund portfolio trades.
or 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 these requirements -- 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 the reporting requirement and the holding period
requirement specified below 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); 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).
The John Hancock mutual funds reporting requirement and the holding period
requirement are excluded for the money market funds and any dividend
reinvestment, payroll deduction, systematic investment/withdrawal and other
program trades.
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 for sales due to hardship reasons
(such as unexpected medical expenses) by sending an e-mail to the Chief
Compliance Officer of your company.
>> 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 for sales due to
hardship reasons (such as unexpected medical expenses) by sending an e-mail
to the Chief Compliance Officer of your company.
>> 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 to the Chief Compliance Officer of
your company. 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.
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 and fund
investors. 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 or fund investors might exist, you should
discuss the situation in advance with the Chief Compliance Officer of your
company. 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 your Chief Compliance Officer or the Compliance and
Business Practices Committee. Exceptions may be granted where warranted by
applicable facts and circumstances. For example, exemption from 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 of your company has general administrative
responsibility for this code of ethics as it applies to the access persons
of your company; an appropriate Compliance Department 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 employee/officer sanctions for violations of the
code of ethics. The Boards of Trustees/Directors of the mutual funds and
closed-end funds also approve amendments to the code of ethics and
dispenses sanctions for access persons of the Funds who are not
employees/officers. Accordingly, the Investment Compliance Department will
refer violations to the Compliance and Business Practices Committee and/or
the Boards of Trustees/Directors of the John Hancock funds, respectively,
for review and appropriate action. The following factors will be
considered when determining 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.
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
(but are not limited to) 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 of your
company.
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 trustee/director of
John Hancock Advisers, LLC or a John Hancock fund, unless you qualify as
a Limited Access person-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 have access to 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." Frank Knox 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 (i.e the selling party if identified and/or the
broker-dealer or placement agent) and whether or not the associate does
business with those individuals or entities 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 or to trade through
a particular broker-dealer or placement agent; and
|_| the date of the request.
Clearance of private placements or initial public offerings may be denied
for any appropriate reason, such as 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
o 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 Fredrick Spring at fspring@jhancock.com and/or Frank Knox at
Frank_Knox@manulifeusa.com.
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*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 the Chief Compliance Officer of your company 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.