Exhibit 12(a)(1)
STREETTRACKS(R) INDEX SHARES FUNDS
CODE OF ETHICS FOR PRINCIPAL EXECUTIVE AND
SENIOR FINANCIAL OFFICERS
I. COVERED OFFICERS/PURPOSE OF THE CODE
This Code of Ethics (the "Code") shall apply to streetTRACKS(R) Index
Shares Funds (the "Trust") Principal Executive Officer, Principal Financial
Officer, Controller, Principal Accounting Officer and persons performing similar
functions (the "Covered Officers," each of whom is named in Exhibit A attached
hereto) 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 the Trust files with, or submits to, the Securities
and Exchange Commission ("SEC") and in other public communications
made by the Trust;
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 Officer should adhere to a high standard of business ethics
and should be sensitive to situations that may give rise to actual as well
as apparent conflicts of interest.
II. COVERED OFFICERS SHOULD HANDLE ETHICALLY ACTUAL AND APPARENT CONFLICTS OF
INTEREST
OVERVIEW. A "conflict of interest" occurs when a Covered Officer's private
interest interferes with the interests of, or his service to, the Trust. For
example, a conflict of interest would arise if a Covered Officer, or a member of
his family, receives improper personal benefits as a result of his position with
the Trust. Covered Officers must avoid conduct that conflicts, or appears to
conflict, with their duties to the Trust. All Covered Officers should conduct
themselves such that a reasonable observer would have no grounds for belief that
a conflict of interest exists. Covered Officers are not permitted to self-deal
or otherwise to use their positions with the Trust to further their own or any
other related person's business opportunities.
This Code does not, and is not intended to, repeat or replace the programs
and procedures or codes of ethics of the Trust's investment adviser or
distributor.
Although typically not presenting an opportunity for improper personal
benefit, conflicts may arise from, or as a result of, the contractual
relationship between the Trust and its service
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Exhibit 12(a)(1)
providers, including investment adviser, of which the Covered Officers may be
officers or employees. As a result, this Code recognizes that the Covered
Officers will, in the normal course of their duties (whether formally for the
Trust, the investment adviser, or other service providers), be involved in
establishing policies and implementing decisions that will have different
effects on the service providers and the Trust. The participation of the Covered
Officers in such activities is inherent in the contractual relationship between
the Trust and its service providers and is consistent with the performance by
the Covered Officers of their duties as officers of the Trust. Thus, if
performed in conformity with the provisions of the Investment Company Act of
1940, as amended ("Investment Company Act") and the Investment Advisers Act of
1940, as amended ("Investment Advisers Act"), such activities will be deemed to
have been handled ethically. In addition, it is recognized by the Trust's Board
of Trustees (the "Board") that the Covered Officers may also be officers or
employees of one or more other investment companies covered by this or other
codes.
The following list provides examples of conflicts of interest under the
Code, but Covered Officers should keep in mind that these examples are not
exhaustive. The overarching principle is that the personal interest of a Covered
Officer should not be placed improperly before the interest of the Trust.
* * * *
Each Covered Officer must not:
o use his personal influence or personal relationship improperly to
influence investment decisions or financial reporting by the Trust
whereby the Covered Officer would benefit personally to the detriment
of the Trust;
o cause the Trust to take action, or fail to take action, for the
individual personal benefit of the Covered Officer rather than the
benefit of the Trust; or
o retaliate against any other Covered Officer or any employee of the
Trust or its affiliated persons for reports of potential violations by
the Trust of applicable rules and regulations that are made in good
faith.
Each Covered Officer must discuss certain material conflict of
interest situations with the Trust's Audit Committee. Examples of such
situations include:
o service as a director, trustee, general partner, or officer of any
unaffiliated business organization. This rule does not apply to
charitable, civic, religious, public, political, or social
organizations, the activities of which do not conflict with the
interests of the Trust;
o the receipt of any non-nominal gifts (valued over $100.00);
o the receipt of any entertainment from any company with which the Trust
has 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 raise any question of impropriety;
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o any ownership interest in, or any consulting or employment
relationship with, any of the Trust's service providers, other than
its investment adviser, principal underwriter, administrator, transfer
agent, custodian or any affiliated person thereof; and
o a direct or indirect financial interest in commissions, transaction
charges or spreads paid by the Trust for effecting portfolio
transactions or for selling or redeeming shares other than an interest
arising from the Covered Officer's employment, such as compensation or
equity ownership.
III. DISCLOSURE AND COMPLIANCE
o Each Covered Officer will monitor the compliance of the Trust and the
Trust's service providers with federal or state statutes, regulations
or administrative procedures that affect the operation of the Trust.
o Each Covered Officer should not knowingly misrepresent, or cause
others to misrepresent, facts about the Trust to others, whether
within or outside the Trust, including to the Trust's Board, Trust's
Audit Committee and the Trust's independent auditors, and to
governmental regulators and self-regulators and self-regulatory
organizations.
o Each Covered Officer should, to the extent appropriate within his or
her area of responsibility, consult with other officers and employees
of the Trust and its service providers with the goal of promoting
full, fair, accurate, timely and understandable disclosure in the
reports and documents the Trust files with, or submits to, the SEC and
in other public communications made by the Trust.
o Each Covered Officer will exhibit and promote the highest standards of
honest and ethical conduct through the establishment and operation of
policies and procedures that encourage professional integrity in all
aspects of the Trust's operations.
IV. REPORTING AND ACCOUNTABILITY
Each Covered Officer must:
o upon adoption of this Code (or thereafter as applicable, upon becoming
a Covered Officer), sign and return a report in the form of Exhibit B
to the Trust's compliance officer affirming that he or she has
received, read, and understands the Code;
o annually sign and return a report in the form of Exhibit C to the
Trust's compliance officer as an affirmation that he or she has
complied with the requirements of the Code; and
o notify the Trust's Audit Committee promptly if he or she knows of any
violation of this Code. Failure to do so is itself a violation of this
Code.
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Exhibit 12(a)(1)
The Trust's Audit Committee is responsible for applying this Code to
specific situations in which questions are presented under it and has the
authority to interpret this Code in any particular situation including any
approvals or waivers sought by the Covered Persons.
The Audit Committee will follow these procedures in investigating and
enforcing this Code:
o The Audit Committee will take all appropriate actions to investigate
any potential violations reported to the Committee.
o If, after such investigation, the Audit Committee believes that no
violation has occurred, the Audit Committee is not required to take
any further action.
o Any matter that the Audit Committee believes is a violation of this
Code will be reported to the full Board.
o If the Board concurs that a violation has occurred, it will notify the
appropriate personnel of the applicable service provider and may
dismiss the Covered Officer as an officer of the Trust.
o The Audit Committee will be responsible for granting waivers of
provisions of this Code, as appropriate.
o Any changes to or waivers of this Code will, to the extent required,
be disclosed as provided by SEC rules.
V. OTHER POLICIES AND PROCEDURES
This Code shall be the sole code of ethics adopted by the Trust for
purposes of Section 406 of the Sarbanes-Oxley Act of 2002 and the rules and
forms applicable to registered investment companies thereunder. Insofar as other
policies or procedures of the Trust, the Fund's investment adviser, principal
underwriter, or other service providers govern or purport to govern the behavior
or activities of the Covered Officers who are subject to this Code, they are
superseded by this Code to the extend that they overlap or conflict with the
provisions of this Code. The Trust's, investment adviser's and principal
underwriter's codes of ethics under Rule 17j-1 under the Investment Company Act
and the investment adviser's more detailed policies and procedures are separate
requirements applying to the Covered Officers and others, and are not part of
this Code.
VI. AMENDMENTS
Any amendments to this Code, other than amendments to Exhibit A, must be
approved or ratified by a majority vote of the Board, including a majority of
Independent Trustees.
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Exhibit 12(a)(1)
VII. 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 other than the Trust's Board or Audit
Committee.
VIII. INTERNAL USE
The Code is intended solely for the internal use by the Trust and does
not constitute an admission, by or on behalf of Trust, as to any fact,
circumstance, or legal conclusion.
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Exhibit 12(a)(1)
Exhibit A
Persons Covered by this Code of Ethics as of May 23, 2005:
<Table>
<Caption>
TITLE NAME
President and Principal Executive Officer James Ross
Vice President Michael P. Riley
Treasurer and Principal Financial Officer Gary French
</Table>
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Exhibit 12(a)(1)
EXHIBIT B
INITIAL CERTIFICATION FORM
This is to certify that I have read and understand the Code of Ethics for
Principal Executive and Senior Financial Officers of streetTRACKS(R) Index
Shares Funds, dated July 1, 2004, and that I recognize that I am subject to the
provisions thereof and will comply with the policy and procedures stated
therein.
Please sign your name here:
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Please print your name here:
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Please date here:
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Exhibit 12(a)(1)
EXHIBIT C
ANNUAL CERTIFICATION FORM
This is to certify that I have read and understand the Code of Ethics
for Principal Executive and Senior Financial Officers of the streetTRACKS(R)
Index Shares Funds dated July 1, 2004, (the "Code") and that I recognize that I
am subject to the provisions thereof and will comply with the policy and
procedures stated therein.
This is to further certify that I have complied with the requirements
of the Code during the period of _____________ through ______________.
Please sign your name here:
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Please print your name here:
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Please date here:
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