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STATE STREET RESEARCH FUNDS
FINANCIAL OFFICER CODE OF PROFESSIONAL CONDUCT
INTRODUCTION
The reputation and integrity of the State Street Research Funds (the
"Funds") are valuable assets that are vital to the Funds' success. Each
Fund's senior financial officers ("SFOs") are responsible for conducting the
Fund's business in a manner that demonstrates a commitment to the highest
standards of integrity. A Fund's SFOs include the principal executive
officer, the principal financial officer, comptroller or principal accounting
officer, and any person who performs a similar function.
The Sarbanes-Oxley Act of 2002 (the "Act") effected sweeping corporate
disclosure and financial reporting reform on public companies, including
mutual funds, to address corporate malfeasance and assure investors that the
companies in which they invest are accurately and completely disclosing
financial information. Under the Act, all public companies (including the
Funds) must either have a code of ethics for their SFOs, or disclose why they
do not. The Act was intended to foster corporate environments that encourage
employees to question unethical and potentially illegal business practices.
Each Fund has chosen to adopt a financial officer code of ethics to encourage
its SFOs to act ethically and to question potentially unethical or illegal
practices, and to strive to ensure that the Fund's financial disclosures are
complete, accurate, and understandable. This Code of Ethics should be read in
conjunction with the Fund's other policy statements, including the Code of
Ethics adopted pursuant to Rule 17j-1 under the Investment Company Act of
1940.
PURPOSES OF THE CODE
The purposes of this Code are:
- To promote honest and ethical conduct among the Fund's SFOs,
including the ethical handling of actual or apparent conflicts
of interest between personal and professional relationships;
- To assist SFOs to recognize and avoid conflicts of interest,
including disclosure to an appropriate person of any material
transaction or relationship that reasonably could be expected to
give rise to such a conflict;
- To promote full, fair, accurate, timely, and understandable
disclosure in reports and documents that the Fund files with, or
submits to, the SEC and in other public communications the Fund
makes;
- To promote compliance with applicable laws, rules and
regulations;
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- To encourage the prompt internal reporting to an appropriate
person of violations of the Code; and
- To establish accountability for adherence to the Code.
QUESTIONS ABOUT THIS CODE
The Board of Trustees of each Fund has designated the Secretary of the Fund
to be the Compliance Officer for the implementation and administration of the
Code. You should direct your questions about this Code to the Compliance
Officer.
CONDUCT GUIDELINES
Each Fund has adopted the following guidelines under which its SFOs
must perform their duties and conduct the business affairs of the Funds.
Persons subject to this requirement include the principal executive officer,
the principal financial officer, comptroller or principal accounting officer,
and any person who performs a similar function. However, the Fund expects
that ALL persons who participate in the preparation of any part of the Fund's
financial statements follow these guidelines:
- ETHICAL AND HONEST CONDUCT IS OF PARAMOUNT IMPORTANCE. The
Fund's SFOs must act with honesty and integrity and avoid
violations of this Code, including actual or apparent conflicts
of interest with the Fund in personal and professional
relationships.
- SFOS MUST DISCLOSE MATERIAL TRANSACTIONS OR RELATIONSHIPS. The
Fund's SFOs must disclose to the Fund's Compliance Officer any
material transaction or relationship that reasonably could be
expected to give rise to any violations of the Code, including
actual or apparent conflicts of interest with the Fund. You
should disclose these transactions or relationships whether you
are involved or have only observed the transaction or
relationship. If it is not possible to disclose the matter to the
Compliance Officer, it should be disclosed to the Fund's Chief
Financial Officer or Chief Executive Officer.
- STANDARDS FOR QUALITY OF INFORMATION SHARED WITH FUND SERVICE
PROVIDERS. The Fund's SFOs must at all times seek to provide
information to the Fund's other employees and service providers
(adviser, administrator, outside auditor, outside counsel,
custodian, ETC.) that is accurate, complete, objective, relevant,
timely, and understandable.
- STANDARDS FOR QUALITY OF INFORMATION INCLUDED IN PERIODIC
REPORTS. The Fund's SFOs must at all times endeavor to ensure
full, fair, timely, accurate, and understandable disclosure in the
Fund's periodic reports.
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- COMPLIANCE WITH LAWS. THe Fund's SFOs must comply with the
federal securities laws and other applicable laws and rules, such
as the Internal Revenue Code.
- STANDARD OF CARE. The Fund's SFOs must at all times act in good
faith, responsibly, and with due care, competence and diligence,
without misrepresenting material facts or allowing your
independent judgement to be subordinated.
- CONFIDENTIALITY OF INFORMATION. The Fund's SFOs must at all
times respect the confidentiality of information acquired in the
course of their professional duties, except when authorized by the
Fund to disclose it or where disclosure is otherwise legally
mandated. You may not use confidential information acquired in the
course of your work for personal advantage.
- SHARING OF INFORMATION AND ETHICAL STANDARDS. The Fund's SFOs
should share information with relevant parties to keep them
informed of the business affairs of the Fund, as appropriate, and
maintain skills important and relevant to the Fund's needs.
- PROMOTE ETHICAL CONDUCT. The Fund's SFOs should at all times
proactively promote ethical behavior among peers in the work
environment.
- STANDARDS FOR RECORDKEEPING. The Fund's SFOs must at all times
endeavor to ensure that the Fund's books and records are
thoroughly and accurately maintained to the best of their
knowledge in a manner consistent with applicable laws and this
Code.
WAIVERS OF THIS CODE
You may request a waiver of a provision of this Code by submitting
your request in writing to the Compliance Officer for appropriate review. For
example, if a family member works for a service provider that prepares the
Fund's financial statements, you may have a potential conflict of interest in
reviewing those statements and should seek a waiver of this Code to review
the work. An executive officer of the Fund or the Audit Committee will decide
whether to grant a waiver. All waivers of this Code must be disclosed to the
Fund's shareholders to the extent required by SEC rules.
ANNUAL CERTIFICATION
To the extent necessary, the Fund's Compliance Officer will provide
guidance on the conduct required by this Code and the manner in which
violations must be reported and waivers must be requested. Each SFO will be
asked to certify on an annual basis that he/she is in full compliance with
this Code.
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REPORTING SUSPECTED VIOLATIONS
SFOs who observe, learn of, or, in good faith, suspect a violation of
the Code MUST immediately report the violation to the Compliance Officer,
another member of the Fund's senior management, or to the Audit Committee of
the Board. An example of a possible Code violation is the preparation and
filing of financial disclosure that omits material facts, or that is accurate
but is written in a way that obscures its meaning.
Because service providers such as the adviser, outside accounting
firm, and custodian provide much of the work relating to the Fund's financial
statements, the Fund's SFOs should be alert for actions by service providers
that may be illegal, or that could be viewed as dishonest or unethical
conduct. A SFO should report these actions to the Compliance Officer even if
you know, or think, that the service provider has its own code of ethics for
its SFOs or employees.
SFOs who report violations or suspected violations in good faith will
not be subject to retaliation of any kind. Reported violations will be
investigated and addressed promptly and will be treated confidentially to the
extent possible.
VIOLATIONS OF THE CODE
Dishonest or unethical conduct or conduct that is illegal will
constitute a violation of this Code, regardless of whether this Code refers
to that particular conduct. A violation of this Code may result in
disciplinary action, up to and including termination of employment. A variety
of laws apply to the Fund and its operations, including the Securities Act of
1933, the Investment Company Act of 1940, state laws relating to duties owned
by Fund directors/trustees and officers, and criminal laws. The federal
securities laws generally prohibit the Fund from making material
misstatements in its prospectus and other documents filed with the SEC, or
from omitting to state a material fact. These material misstatements and
omissions include financial statements that are misleading or omit material
facts.
The Fund must and will report all suspected criminal violations to the
appropriate authorities for possible prosecution, and will investigate,
address and report, as appropriate, non-criminal violations.
ADOPTED MAY 7, 2003