CODE OF ETHICS FOR PRINCIPAL EXECUTIVE AND SENIOR FINANCIAL OFFICERS
                              ADOPTED JULY 23, 2003



I.       This Code of Ethics (the "Code") for the investment companies within
         the Van Kampen complex identified in Exhibit A (collectively, "Funds"
         and each, a "Fund") applies to each Fund's Principal Executive Officer,
         President, Principal Financial Officer and Treasurer (or persons
         performing similar functions) ("Covered Officers" each of whom are set
         forth in Exhibit B) 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 company files with, or submits to,
                 the Securities and Exchange Commission ("SEC") and in other
                 public communications made by the Fund;

         o       compliance with applicable laws and governmental rules and
                 regulations;

         o       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. Any question about the
application of the Code should be referred to the General Counsel or his/her
designee (who is set forth in Exhibit C).

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, or appears to interfere, with the interests of, or
his service to, the Fund. 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 Fund.

         Certain conflicts of interest arise out of the relationships between
Covered Officers and the Fund and already are subject to conflict of interest
provisions in the Investment Company Act of 1940 ("Investment Company Act") and
the Investment Advisers Act of 1940 ("Investment Advisers Act"). For example,
Covered Officers may not individually engage in certain transactions (such as
the purchase or sale of securities or other property) with the Fund because of
their status as "affiliated persons" (as defined in the Investment Company Act)
of the Fund. The Fund's and its investment adviser's compliance programs and
procedures are designed to prevent, or identify and correct, violations of these
provisions. This Code does not, and is not intended to, repeat or replace these
programs and procedures, and such conflicts fall outside the parameters of this
Code, unless or until the General Counsel determines that any violation of such
programs and procedures is also a violation of this Code.









         Although typically not presenting an opportunity for improper personal
benefit, conflicts may arise from, or as a result of, the contractual
relationship between the Fund and its investment adviser of which the Covered
Officers are also 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 Fund or for the investment adviser, or for both), be involved
in establishing policies and implementing decisions that will have different
effects on the Fund and its investment adviser. The participation of the Covered
Officers in such activities is inherent in the contractual relationship between
the Fund and the investment adviser and is consistent with the performance by
the Covered Officers of their duties as officers of the Fund. Thus, if performed
in conformity with the provisions of the Investment Company Act and the
Investment Advisers Act, such activities will be deemed to have been handled
ethically. In addition, it is recognized by the Funds' Boards of
Directors/Trustees ("Boards") that the Covered Officers may also be officers or
employees of one or more other investment companies covered by this or other
codes.

         Other conflicts of interest are covered by the Code, even if such
conflicts of interest are not subject to provisions in the Investment Company
Act and the Investment Advisers Act. 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 Fund.

         Each Covered Officer must not:

         o       use his personal influence or personal relationships improperly
                 to influence investment decisions or financial reporting by the
                 Fund whereby the Covered Officer would benefit personally
                 (directly or indirectly) to the detriment of the Fund;

         o       cause the Fund to take action, or fail to take action, for the
                 individual personal benefit of the Covered Officer rather than
                 the benefit of the Fund; or

         o       use material non-public knowledge of portfolio transactions
                 made or contemplated for, or actions proposed to be taken by,
                 the Fund to trade personally or cause others to trade
                 personally in contemplation of the market effect of such
                 transactions.

         Each Covered Officer must, at the time of signing this Code, report to
the General Counsel all affiliations or significant business relationships
outside the Morgan Stanley complex and must update the report annually.

         Conflict of interest situations should always be approved by the
General Counsel and communicated to the relevant Fund or Fund's Board. Any
activity or relationship that would present such a conflict for a Covered
Officer would likely also present a conflict for the Covered Officer if an
immediate member of the Covered Officer's family living in the same household
engages in such an activity or has such a relationship. Examples of these
include:

         o       service or significant business relationships as a director on
                 the board of any public or private company;

         o       accepting directly or indirectly, anything of value, including
                 gifts and gratuities in excess of $100 per year from any person
                 or entity with which the Fund has current or prospective
                 business dealings, not including occasional







         o       meals or tickets for theatre or sporting events or other
                 similar entertainment; provided it is business-related,
                 reasonable in cost, appropriate as to time and place, and not
                 so frequent as to raise any question of impropriety;

         o       any ownership interest in, or any consulting or employment
                 relationship with, any of the Fund's service providers, other
                 than its investment adviser, principal underwriter, or any
                 affiliated person thereof; and

         o       a direct or indirect financial interest in commissions,
                 transaction charges or spreads paid by the Fund 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 should familiarize himself/herself with
                 the disclosure and compliance requirements generally applicable
                 to the Funds;

         o       each Covered Officer must not knowingly misrepresent, or cause
                 others to misrepresent, facts about the Fund to others, whether
                 within or outside the Fund, including to the Fund's
                 Directors/Trustees and auditors, or to governmental regulators
                 and self-regulatory organizations;

         o       each Covered Officer should, to the extent appropriate within
                 his area of responsibility, consult with other officers and
                 employees of the Funds and their investment advisers with the
                 goal of promoting full, fair, accurate, timely and
                 understandable disclosure in the reports and documents the
                 Funds file with, or submit to, the SEC and in other public
                 communications made by the Funds; and

         o       it is the responsibility of each Covered Officer to promote
                 compliance with the standards and restrictions imposed by
                 applicable laws, rules and regulations.

IV.      REPORTING AND ACCOUNTABILITY

         Each Covered Officer must:

         o       upon adoption of the Code (thereafter as applicable, upon
                 becoming a Covered Officer), affirm in writing to the Boards
                 that he has received, read and understands the Code;

         o       annually thereafter affirm to the Boards that he has complied
                 with the requirements of the Code;

         o       not retaliate against any other Covered Officer, other officer
                 or any employee of the Funds or their affiliated persons for
                 reports of potential violations that are made in good faith;
                 and

         o       notify the General Counsel promptly if he/she knows or suspects
                 of any violation of this Code. Failure to do so is itself a
                 violation of this Code.

         The General Counsel 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. However, any waivers(1) sought by a Covered Officer must
be considered by the Board of the relevant Fund or Funds.

         The Funds will follow these procedures in investigating and enforcing
this Code:

         o       the General Counsel will take all appropriate action to
                 investigate any potential violations reported to him;

         o       if, after such investigation, the General Counsel believes that
                 no violation has occurred, the General Counsel is not required
                 to take any further action;

         o       any matter that the General Counsel believes is a violation
                 will be reported to the relevant Fund's Audit Committee;

         o       if the directors/trustees/managing general partners who are not
                 "interested persons" as defined by the Investment Company Act
                 (the "Independent Directors/Trustees/Managing General
                 Partners") of the relevant Fund concur that a violation has
                 occurred, they will consider appropriate action, which may
                 include review of, and appropriate modifications to, applicable
                 policies and procedures; notification to appropriate personnel
                 of the investment adviser or its board; or a recommendation to
                 dismiss the Covered Officer or other appropriate disciplinary
                 actions;

         o       the Independent Directors/Trustees/Managing General Partners of
                 the relevant Fund will be responsible for granting waivers of
                 this Code, as appropriate; and

         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 Funds 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 Funds, the Funds' investment advisers, principal
underwriters, 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 extent that they overlap or conflict
with the provisions of this Code unless any provision of this Code conflicts
with any applicable federal or state law, in which case the requirements of such
law will govern. The Funds' and their investment advisers' and principal
underwriters' codes of ethics under Rule 17j-1 under the Investment Company Act
and Morgan Stanley's Code of Ethics 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 Exhibits A, B
or C, must be approved or ratified by a majority vote of the Board of each
Fund, including a majority of Independent Directors/Trustees/Managing General
Partners.



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(1) Item 2 of Form N-CSR defines "waiver" as "the approval by the registrant of
a material departure from a provision of the code of ethics."





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 Independent
Directors/Trustees/Managing General Partners of the relevant Fund or Funds and
their counsel, the relevant Fund or Funds and their counsel and the relevant
investment adviser and its counsel.

VIII.    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



I have read and understand the terms of the above Code. I recognize the
responsibilities and obligations incurred by me as a result of my being subject
to the Code. I hereby agree to abide by the above Code.


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Date:
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                                    EXHIBIT A
                                    FUND LIST

                          Van Kampen Series Fund, Inc.
                             on behalf of its series
                         Van Kampen American Value Fund
                      Van Kampen Emerging Markets Debt Fund
                        Van Kampen Emerging Markets Fund
                          Van Kampen Equity Growth Fund
                      Van Kampen European Value Equity Fund
                          Van Kampen Focus Equity Fund
                    Van Kampen Global Equity Allocation Fund
                       Van Kampen Global Value Equity Fund
                      Van Kampen Growth and Income Fund II
                      Van Kampen International Magnum Fund
                         Van Kampen Japanese Equity Fund
                         Van Kampen Mid Cap Growth Fund
                        Van Kampen Global Franchise Fund
                              Van Kampen Value Fund
                      Van Kampen Worldwide High Income Fund

                        Van Kampen U.S. Government Trust
                             on behalf of its series
                         Van Kampen U.S. Government Fund

                            Van Kampen Tax Free Trust
                             on behalf of its series
                     Van Kampen Insured Tax Free Income Fund
                   Van Kampen Strategic Municipal Income Fund
                   Van Kampen California Insured Tax Free Fund
                        Van Kampen Municipal Income Fund
               Van Kampen Intermediate Term Municipal Income Fund
                    Van Kampen New York Tax Free Income Fund
                   Van Kampen California Municipal Income Fund
                    Van Kampen Michigan Tax Free Income Fund
                    Van Kampen Missouri Tax Free Income Fund
                      Van Kampen Ohio Tax Free Income Fund

                                Van Kampen Trust
                             on behalf of its series
                           Van Kampen High Yield Fund

                             Van Kampen Equity Trust
                             on behalf of its series
                             Van Kampen Utility Fund
                             Van Kampen Growth Fund
                        Van Kampen Aggressive Growth Fund
                         Van Kampen Small Cap Value Fund
                          Van Kampen Select Growth Fund
                      Van Kampen Small Company Growth Fund
                        Van Kampen Small Cap Growth Fund
                       Van Kampen Value Opportunities Fund

                           Van Kampen Tax-Exempt Trust
                             on behalf of its Series
                      Van Kampen High Yield Municipal Fund


                                EXHIBIT A (CONT.)
                                    FUND LIST

                           Van Kampen Equity Trust II




                             on behalf of its Series
                           Van Kampen Technology Fund
                       Van Kampen International Advantage

                  Van Kampen Pennsylvania Tax Free Income Fund
                         Van Kampen Tax Free Money Fund
                            Van Kampen Comstock Fund
                         Van Kampen Corporate Bond Fund
                         Van Kampen Emerging Growth Fund
                           Van Kampen Enterprise Fund
                          Van Kampen Equity Income Fund
                      Van Kampen Government Securities Fund
                        Van Kampen Growth and Income Fund
                             Van Kampen Harbor Fund
                   Van Kampen High Income Corporate Bond Fund
                   Van Kampen Limited Maturity Government Fund
                              Van Kampen Pace Fund
                     Van Kampen Real Estate Securities Fund
                             Van Kampen Reserve Fund
                            Van Kampen Exchange Fund

                        Van Kampen Life Investment Trust
                           on behalf of its Portfolios
                           Aggressive Growth Portfolio
                               Comstock Portfolio
                            Emerging Growth Portfolio
                              Enterprise Portfolio
                              Government Portfolio
                           Growth and Income Portfolio
                             Money Market Portfolio

                        Van Kampen Municipal Income Trust
                      Van Kampen California Municipal Trust
                          Van Kampen High Income Trust
                         Van Kampen High Income Trust II
                   Van Kampen Investment Grade Municipal Trust
                           Van Kampen Municipal Trust
                  Van Kampen California Quality Municipal Trust
                   Van Kampen Florida Quality Municipal Trust
                   Van Kampen New York Quality Municipal Trust
                     Van Kampen Ohio Quality Municipal Trust
                 Van Kampen Pennsylvania Quality Municipal Trust
                     Van Kampen Trust for Insured Municipals
                Van Kampen Trust for Investment Grade Municipals
           Van Kampen Trust for Investment Grade California Municipals
            Van Kampen Trust for Investment Grade Florida Municipals
           Van Kampen Trust for Investment Grade New Jersey Municipals
            Van Kampen Trust for Investment Grade New York Municipals
          Van Kampen Trust for Investment Grade Pennsylvania Municipals
                     Van Kampen Municipal Opportunity Trust
                   Van Kampen Advantage Municipal Income Trust
            Van Kampen Advantage Pennsylvania Municipal Income Trust
                   Van Kampen Strategic Sector Municipal Trust

                                EXHIBIT A (CONT.)
                                    FUND LIST

                     Van Kampen Value Municipal Income Trust
               Van Kampen California Value Municipal Income Trust
              Van Kampen Massachusetts Value Municipal Income Trust
                Van Kampen New York Value Municipal Income Trust
                  Van Kampen Ohio Value Municipal Income Trust







              Van Kampen Pennsylvania Value Municipal Income Trust
                    Van Kampen Municipal Opportunity Trust II
                 Van Kampen Advantage Municipal Income Trust II
                    Van Kampen Select Sector Municipal Trust
                           Van Kampen Senior Loan Fund
                         Van Kampen Senior Income Trust
                              Van Kampen Bond Fund
                             Van Kampen Income Trust


                                    EXHIBIT B

                                COVERED OFFICERS

                         Mitchell M. Merin -- President
  Ronald E. Robison -- Executive Vice President and Principal Executive Officer
    John L. Sullivan -- Vice President, Chief Financial Officer and Treasurer


                                    EXHIBIT C

                           GENERAL COUNSEL'S DESIGNEE

                               A. Thomas Smith III