EXHIBIT 99.(CODEETH)
ALLIANZ GLOBAL INVESTORS OF AMERICA
CODE OF ETHICS PURSUANT TO SECTION 406 OF THE SARBANES-OXLEY
ACT OF 2002 FOR PRINCIPAL EXECUTIVE AND SENIOR FINANCIAL
OFFICERS
AUGUST 19, 2003
(AS REVISED ON OCTOBER 1, 2004)
I. COVERED PERSONS/PURPOSE OF THE CODE
This Code of Ethics (this "Code") pursuant to Section 406 of the Sarbanes-Oxley
Act of 2002 has been adopted by the registered investment companies (each a
"Fund" and, collectively, the "Funds") listed on EXHIBIT A and, except as
provided in Section VI below, applies to each Fund's Principal Executive
Officer, Principal Financial Officer and Principal Accounting Officer (the
"Covered Officers") and each Trustee of the Fund who is an "interested person"
of the Fund (as defined in Section 2(a)(19) of the Investment Company Act of
1940) because such Trustee is an interested person of the Fund's investment
adviser or principal underwriter ("Covered Trustees" and, together with the
Covered Officers, the "Covered Persons"). Each Covered Person is identified in
EXHIBIT B.
This Code has been adopted for the purpose of promoting:
o honest and ethical conduct, including the ethical handling of actual or
apparent conflicts of interest between personal and professional
relationships;
o full, fair, accurate, timely and understandable disclosure in reports and
documents that a Fund files with, or submits to, the Securities and
Exchange Commission ("SEC") and in other public communications made by a
Fund;
o compliance with applicable laws and governmental rules and regulations;
o the prompt internal reporting of violations of the Code to an appropriate
person or persons identified in the Code; and
o accountability for adherence to the Code.
Each Covered Person should adhere to a high standard of business ethics and
should be sensitive to situations that may give rise to conflicts of interest.
II. COVERED PERSONS SHOULD HANDLE ETHICALLY ANY ACTUAL OR APPARENT CONFLICTS
OF INTEREST
OVERVIEW. A "conflict of interest" occurs when a Covered Person's private
interest interferes with the interests of, or his service to, the relevant Fund.
For example, a conflict of interest would arise if a Covered Person, or a member
of the Covered Person's family, receives improper personal benefits as a result
of the Covered Person's position with the relevant Fund.
Certain conflicts of interest arise out of the relationships between Covered
Persons and the relevant Fund and already are subject to conflict of interest
provisions and procedures in the Investment Company Act of 1940 (including the
regulations thereunder, the "1940 Act") and the Investment Advisers Act of 1940
(including the regulations thereunder, the "Investment Advisers Act"). Indeed,
conflicts of interest are endemic for certain registered management investment
companies and those conflicts are both substantially and procedurally dealt with
under the 1940 Act. For example, Covered Persons may not engage in certain
transactions with a Fund because of their status as "affiliated persons" of such
Fund. The compliance program of each Fund and the compliance programs of its
investment advisers (including sub-advisers), principal underwriter and
administrator or sub-administrator (each a "Service Provider" and, collectively,
the "Service Providers") are reasonably designed to prevent, or identify and
correct, violations of many of those provisions, although they are not designed
to provide absolute assurance as to those matters. This Code does not, and is
not intended to, repeat or replace these programs and procedures, and such
conflicts fall outside of the parameters of this Code. See also Section V of
this Code.
Although typically not presenting an opportunity for improper personal benefit,
conflicts arise from, or as a result of, the contractual relationship between a
Fund and its Service Providers of which the Covered Persons are also officers or
employees. As a result, this Code recognizes that the Covered Persons will, in
the normal course of their duties (whether for the Funds or for a Service
Provider, or for both), be involved in establishing policies and implementing
decisions that will have different effects on the Service Providers and the
Funds. The participation of the Covered Persons in such activities is inherent
in the contractual relationships between the Funds and their Service Providers
and is consistent with the performance by the Covered Persons of their duties as
officers of the relevant Fund. Thus, if performed in conformity with the
provisions of the 1940 Act, the Investment Advisers Act, other applicable law
and the relevant Fund's constitutional documents, such activities will be deemed
to have been handled ethically. Frequently, the 1940 Act establishes, as a
mechanism for dealing with conflicts, disclosure to and approval by the
Directors/Trustees of a Fund who are not "interested persons" of such Fund under
the 1940 Act. In addition, it is recognized by the Funds' Boards of
Directors/Trustees ("Boards") that the Covered Persons may also be officers or
employees of one or more other investment companies covered by this or other
codes and that such service, by itself, does not give rise to a conflict of
interest.
Other conflicts of interest are covered by the Code, even if such conflicts of
interest are not the subject of provisions of the 1940 Act and the Investment
Advisers
Act. The following list provides examples of conflicts of interest under the
Code, but Covered Persons should bear in mind that these examples are not
exhaustive. The overarching principle is that the personal interest of a Covered
Person should not be placed improperly before the interest of the relevant Fund,
unless the personal interest has been disclosed to and approved by other
officers of such Fund or such Fund's Independent Trustees.
* * * *
Each Covered Person must not:
o use his personal influence or personal relationships improperly to
influence investment decisions or financial reporting by the relevant Fund
whereby the Covered Person would benefit personally to the detriment of
such Fund;
o cause the relevant Fund to take action, or fail to take action, for the
individual personal benefit of the Covered Person rather than the benefit
such Fund; or
o retaliate against any other Covered Person or any employee of the Funds or
their Service Providers for reports of potential violations that are made
in good faith.
There are some conflict of interest situations that should always be approved by
the President of the relevant Fund (or, with respect to activities of the
President, by the Chairman of the relevant Fund). These conflict of interest
situations are listed below:
o service on the board of directors or governing board of a publicly traded
entity;
o acceptance of any investment opportunity or of any material gift or
gratuity from any person or entity that does business, or desires to do
business, with the relevant Fund. For these purposes, material gifts do not
include (i) gifts from a single giver so long as their aggregate annual
value does not exceed the equivalent of $100.00 or (ii) attending business
meals, business related conferences, sporting events and other
entertainment events at the expense of a giver, so long as the expense is
reasonable and both the Covered Person and the giver are present.
o any ownership interest in, or any consulting or employment relationship
with, any entities doing business with the relevant Fund, other than a
Service Provider or an affiliate of a Service Provider. This restriction
shall not apply to or otherwise limit the ownership of publicly traded
securities so long as the Covered Person's ownership does not exceed more
than 2% of the outstanding securities of the relevant class.
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o a direct or indirect financial interest in commissions, transaction charges
or spreads paid by the relevant Fund for effecting portfolio transactions
or for selling or redeeming shares other than an interest arising from the
Covered Person's employment with a Service Provider or its affiliate. This
restriction shall not apply to or otherwise limit the ownership of publicly
traded securities so long as the Covered Person's ownership does not exceed
more than 2% of the particular class of security outstanding.
III. DISCLOSURE AND COMPLIANCE
o No Covered Person should knowingly misrepresent, or cause others to
misrepresent, facts about the relevant Fund to others, whether within or
outside such Fund, including to such Fund's Board and auditors, and to
governmental regulators and self-regulatory organizations;
o each Covered Person should, to the extent appropriate within his area of
responsibility, consult with other officers and employees of the Funds and
the Service Providers or with counsel to the Funds with the goal of
promoting full, fair, accurate, timely and understandable disclosure in the
registration statements or periodic reports that the Funds file with, or
submit to, the SEC (which, for sake of clarity, does not include any sales
literature, omitting prospectuses, or "tombstone" advertising prepared by
the relevant Fund's principal underwriter(s)); and
o it is the responsibility of each Covered Person to promote compliance with
the standards and restrictions imposed by applicable laws, rules and reg
IV. REPORTING AND ACCOUNTABILITY
Each Covered Person must:
o upon adoption of the Code (or thereafter as applicable, upon becoming a
Covered Person), affirm in writing to the relevant Fund that he has
received, read, and understands the Code;
o provide full and fair responses to all questions asked in any Trustee and
Officer Questionnaire provided by the relevant Fund as well as with respect
to any supplemental request for information; and
o notify the President of the relevant Fund promptly if he is convinced to a
moral certainty that there has been a material violation of this Code (with
respect to violations by a President, the Covered Person shall report to
the Chairman of the relevant Fund).
The President of each Fund is responsible for applying this Code to specific
situations in which questions are presented under it and, in consultation with
the Fund's
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Chief Compliance Officer ("CCO"), has the authority to interpret this Code in
any particular situation. However, any approvals or waivers sought by the
President will be considered by the Chairman of the relevant Fund.
The Funds will follow these procedures in investigating and enforcing this Code:
o the President will take all appropriate action to investigate any potential
material violations reported to him, which actions may include the use of
internal or external counsel, accountants or other personnel;
o if, after such investigation, the President believes that no material
violation has occurred, the President is not required to take any further
action;
o any matter that the President believes is a material violation will be
reported to the Fund's CCO;
o if the CCO concurs that a material violation has occurred, it will inform
and make a recommendation to the Fund's Board of Trustees, which will
consider appropriate action, which may include review of, and appropriate
modifications to applicable policies and procedures; notification to
appropriate personnel of a Service Provider or its board; or a
recommendation to dismiss the Covered Officer or remove a Covered Trustee;
and
o the Board of Trustees may grant waivers under this Code, as it deems
appropriate.
V. PUBLIC DISCLOSURE OF CHANGES AND WAIVERS
Any amendments to or waivers under this Code relating to a Covered Officer will,
to the extent required by the SEC's rules, be disclosed on the Fund's website or
in the Fund's N-CSR; amendments to or waivers under this Code relating to a
Covered Trustee but not a Covered Officer will NOT be so disclosed.(1)
VI. OTHER POLICIES AND PROCEDURES
This Code shall be the sole code of ethics adopted by the Funds for purposes of
Section 406 of the Sarbanes-Oxley Act and the rules and forms applicable to
registered investment companies thereunder. Insofar as other policies or
procedures of the Funds or the Funds' Service Providers govern or purport to
govern the behavior or activities of the Covered Persons who are subject to this
Code, they are superseded by this Code to the extent that they conflict with the
provisions of this Code. The Funds' and their Service Providers's codes of
ethics under Rule 17j-1 under the 1940 Act and the Service
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(1) The amendment to this Code applying the Code's provisions to Covered
Trustees is not required to be disclosed. See, E.G., Item 2(c) of Form
N-CSR.
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Providers's more detailed compliance policies and procedures are separate
requirements applying to the Covered Persons and others, and are not part of
this Code.
VII. AMENDMENTS
Any material amendments to this Code, other than amendments to Exhibit A, must
be approved or ratified by a majority vote of the Board.
VIII. CONFIDENTIALITY
All reports and records prepared or maintained pursuant to this Code will be
considered confidential and shall be maintained and protected accordingly.
Except as otherwise required by law or this Code, such matters shall not be
disclosed to anyone except as permitted by the Board.
IX. INTERNAL USE
The Code is intended solely for the internal use by the Funds and does not
constitute an admission, by or on behalf of any Fund, as to any fact,
circumstance, or legal conclusion.
Date:
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EXHIBIT A
REGISTERED INVESTMENT COMPANIES
Allianz Funds
Allianz Global Investors Fund Management Sponsored Closed-End Funds
Fixed Income Shares
Premier VIT
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EXHIBIT B
COVERED PERSONS
ALLIANZ FUNDS
Covered Officers: E. Blake Moore, Jr., John P. Hardaway
Covered Trustee: David Flattum
FIXED INCOME SHARES
Covered Officers: Brian S. Shlissel, Lawrence G. Altadonna
Covered Trustee: David Flattum
ALLIANZ GLOBAL INVESTORS FUND MANAGEMENT SPONSORED CLOSED-END FUNDS
Covered Officers: Brian S. Shlissel, Lawrence G. Altadonna
Covered Trustee: David Flattum
PREMIER VIT
Covered Officers: Brian S. Shlissel, Lawrence G. Altadonna
Covered Trustee: Brian S. Shlissel
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EX-99.A
EXHIBIT A
REGISTERED INVESTMENT COMPANIES
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PIMCO Municipal Income Fund I/II/III
PIMCO California Municipal Income Fund I/II/III
PIMCO New York Municipal Income Fund I/II/III
PIMCO Corporate Income Fund
PIMCO Corporate Opportunity Fund
Nicholas-Applegate Convertible & Income Fund
PIMCO High Income Fund
Nicholas-Applegate Convertible & Income Fund II
PIMCO Floating Rate Income Fund
Municipal Advantage Fund Inc.
Fixed Income Shares
NFJ Dividend, Interest & Premium Strategy Fund
Nicholas-Applegate International & Premium Strategy Fund
Pimco Global Stocksplus & Income Fund
Pimco Floating Rate Strategy Fund
Premier VIT
EXHIBIT B
PERSONS COVERED BY THIS CODE OF ETHICS
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PRINCIPAL EXECUTIVE PRINCIPAL FINANCIAL PRINCIPAL ACCOUNTING
OFFICER OFFICER OFFICER
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Brian S. Shlissel Lawrence G. Altadonna Lawrence G. Altadonna
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Note that the listed officers are "Covered Officers" of each of the Fund listed
on Exhibit A.