CODE OF ETHICS FOR
PRINCIPAL EXECUTIVE AND SENIOR FINANCIAL OFFICERS
THE DIVERSIFIED INVESTORS FUND GROUP,
THE DIVERSIFIED INVESTORS FUNDS GROUP II,
DIVERSIFIED INVESTORS STRATEGIC VARIABLE FUNDS AND
DIVERSIFIED INVESTORS PORTFOLIOS
The Diversified Investors Funds Group, The Diversified Investors Funds Group II,
The Diversified Investors Strategic Variable Funds and Diversified Investors
Portfolios (collectively, the "Funds") have adopted this Code of Ethics to
effectuate compliance with Section 406 under the Sarbanes-Oxley Act of 2002 and
the rules adopted to implement Section 406.
This Code applies to each Fund's principal executive officer, principal
financial officer, principal accounting officer or controller, or persons
performing similar functions ("Covered Officers"). A listing of positions
currently within the ambit of Covered Officers is attached Exhibit A.
1. Purpose Of The Code. This Code sets forth standards and procedures
that are reasonably designed to deter wrongdoing and promote:
o honest and ethical conduct, including the ethical handling of
actual or apparent conflicts of interest between personal and
professional relationships;
o full, fair, accurate, timely, and understandable disclosure in
reports and documents that a Fund files with, or submits to, the
U.S. Securities and Exchange Commission ("SEC") and in other
public communications made by the Fund;
o compliance with applicable governmental laws, rules and
regulations;
o the prompt internal reporting of violations of this Code to the
party or parties identified below; and
o accountability for adherence to this Code.
2. Duties Of Covered Officers. It is the responsibility of the Covered
Officers, by their words and actions, to foster a corporate culture
that encourages honest and ethical conduct, including the ethical
resolution of, and appropriate disclosure of, conflicts of interest.
The Covered Officers should work to assure a working environment that
is characterized by respect for law and compliance with applicable
rules and regulations. The Covered Officers must:
o act with integrity;
o familiarize themselves with the disclosure requirements generally
applicable to the Funds and, to the extent appropriate within the
Covered Officer's area of responsibility, take appropriate steps
with the goal of promoting full, fair, accurate, timely and
understandable disclosure in reports and documents the Funds file
with the SEC and in other public communications made by the Funds;
o not knowingly misrepresent, or cause others to misrepresent, facts
about the Funds; and
o not use personal influence or personal relationships improperly to
influence investment decisions or financial reporting by the Funds
whereby the Covered Officer would benefit personally to the
detriment of the Funds;
o not cause the Funds to take action, or fail to take action, for
the individual personal benefit of the Covered Officer rather than
the benefit of the Funds; and
o not use material non-public knowledge of portfolio transactions
made or contemplated for the Funds to trade personally or cause
others to trade personally in contemplation of the market effect
of such transactions.
3. Other Potential Conflicts. Any potential conflict of interest or
appearance of conflict of interest must be discussed by a Covered
Officer with the General Counsel of Diversified Investment Advisors,
Inc. (the "GC"), including:
o service as a director on the board of directors or
trustees of any public or private company (other than a
not-for-profit organization);
o the receipt of any non-nominal gifts; and
o the receipt of any entertainment from any company with which the
Funds have current or prospective business dealings unless such
entertainment is business-related, reasonable in cost, appropriate
as to time and place, and not so frequent as to raise any question
of impropriety.
4. Reporting. Upon receipt of this Code, and annually thereafter, the
Covered Officers must sign an acknowledgement stating that he or she
has received, read and understands the Code.
5. Violations. Any person who becomes aware of an apparent violation of
this Code must report it to the GC. The GC is authorized to investigate
any such violations and report his or her findings to the Chairperson
of the Audit Committees of the Funds. The Chairperson may report
violations of the Code to
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the Board of Trustees if he or she believes such reporting is
appropriate. The Chairperson may also determine the appropriate
sanction for any violations of this Code, including removal
from office, provided that removal from office shall only be carried
out with the approval of the Boards of Trustees of the Funds.
6. Amendments. Technical, administrative or other non-substantive
amendments to this Code must be approved by the Chairperson of the
Audit Committees of the Funds and any material amendment must be
approved by the Board of Trustees. Amendments must be filed with the
SEC as required by applicable rules. All amendments must be in
writing.
7. Relationship To Codes of Ethics. The Funds and its principal service
providers have adopted codes of ethics under Rule 17j-1 under the
Investment Company Act of 1940. Those codes are separate requirements
and are not part of this Code.
8. Confidentiality. All reports and records prepared or maintained
pursuant to this Code shall be 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.
Attachment
OfficersCodeofEthics
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Exhibit A
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PERSONS COVERED BY THIS CODE OF ETHICS
Mark Mullin, Principal Executive Officer
Joseph Carusone, Principal Financial Officer
Suzanne Montemurro, Assistant Treasurer
OfficersCodeofEthics