<Page>
FPA CAPITAL FUND, INC.
FPA FUNDS TRUST
FPA NEW INCOME, INC.
FPA PARAMOUNT FUND, INC.
FPA PERENNIAL FUND, INC.
SOURCE CAPITAL, INC.
CODE OF ETHICS FOR SENIOR EXECUTIVE
AND FINANCIAL OFFICERS
I. Introduction
The Board of Directors/Trustees of each registered investment company that is
managed, sponsored, and distributed by First Pacific Advisors, Inc. ("FPA")
(each an "FPA Fund" and collectively the "FPA Funds") has adopted this code of
ethics ("Code") as required by the Section 406 of the Sarbanes-Oxley Act. The
Code applies to the individuals in positions listed on Exhibit A ("Covered
Officers"). All Covered Officers, along with employees of FPA, are subject to
separate and distinct obligations from this Code under a Code of Ethics adopted
pursuant to Rule 17j-1 under the Investment Company Act of 1940 ("17j-1 Code of
Ethics"), policies to prevent the misuse of non-public information, and other
internal compliance guidelines and policies that may be in effect from time to
time.
This Code is designed to promote:
- Honest and ethical conduct, including the ethical handling of
conflicts of interest;
- Full, fair, accurate, timely, and understandable disclosure in
reports and documents that an FPA Fund files with, or submits to,
the U.S. Securities and Exchange Commission, or in other public
communications made by the FPA Funds or FPA;
- Compliance with applicable laws, governmental rules, and regulations;
- Prompt internal reporting to those identified in the Code of
violations of the Code; and
- Accountability for adherence to the Code.
II. Actual or Apparent Conflicts of Interest
A. Covered Officers should conduct all activities in accordance with the
following principles:
1. Shareholders' interests come first. In the course of fulfilling
their duties and responsibilities to FPA Fund shareholders,
Covered Officers must at all times place the interests of FPA
Fund shareholders
<Page>
first, and avoid serving their own personal
interests ahead of the interests of FPA Fund shareholders.
2. Conflicts of interest must be avoided. Covered Officers must
avoid any situation involving an actual or potential conflict of
interest with respect to their duties and responsibilities to FPA
Fund shareholders.
3. Compromising situations must be avoided. Covered Officers must
not take advantage of their position of trust and responsibility.
Covered Officers must avoid any situation that might compromise
or call into question their exercise of full independent judgment
in the best interests of FPA Fund shareholders.
All activities of Covered Officers should be guided by and adhere to these
fiduciary standards regardless of whether the activity is specifically described
in this Code.
B. Restricted Activities
1. Gifts. Under no circumstances shall any Covered Officer
accept money, stocks, bonds, notes, etc. from any entity
that does business with or on behalf of the FPA Funds. No
Covered Officer shall accept any other type of gift or other
thing of more than de minimis value ($250) from any person
or entity that does business with or on behalf of the FPA
Funds. Written documentation of any gift or other thing with
an estimated value of more than $100 should be submitted
within ten days of receipt and approved by J. Richard Atwood
or Christopher H. Thomas.
2. Prohibition on misuse of FPA Funds' property. Covered
Officers are prohibited from making use of time, equipment,
services, personnel or property of any FPA Fund for any
purposes other than the performance of their duties and
responsibilities in connection with the FPA Funds.
III. Disclosure and Compliance
A. Each Covered Officer should be familiar with the disclosure
requirements generally applicable to the FPA Funds.
B. Each Covered Officer should not knowingly misrepresent, or cause other
to misrepresent, facts about the FPA Funds to others, including to the
FPA Funds' directors/trustees and auditors, or to government
regulators and self-regulatory organizations.
<Page>
C. Each Covered Officer should, to the extent appropriate within the
Covered Officer's area of responsibility, consult with other officers
and employees of FPA and of an FPA Fund with the goal of promoting
full, fair, accurate, timely and understandable disclosure in the
reports and documents the FPA Fund files with, or submits to, the SEC
and in other public communications made by an FPA Fund.
D. It is the responsibility of each Covered Officer to promote compliance
with the standards and restrictions imposed by applicable laws, rules,
regulations, and the 17j-1 Code of Ethics.
IV. Reporting and Responsibility
A. Each Covered Officer must:
1. Upon adoption or amendment of the Code (or thereafter as
applicable, upon becoming a Covered Officer), affirm in writing
that he or she has received, read, and understands the Code;
2. Affirm at least annually in writing that he or she has complied
with the requirements of the Code;
3. Not retaliate against any other Covered Officer or any employee
of FPA for reports of potential violations of the Code that are
made in good faith; and
4. Notify J. Richard Atwood or Christopher H. Thomas promptly if the
Covered Officer knows of any violations of this Code.
B. The FPA Funds will use the following procedures in investigating and
enforcing this Code:
1. J. Richard Atwood or Christopher H. Thomas is responsible for
applying this Code to specific situations and has the authority
to interpret this Code in any particular situation. All
determinations made by J. Richard Atwood or Christopher H. Thomas
will be reported to the Board of Directors/Trustees of the FPA
Funds in an annual report regarding activities subject to the
Code.
2. J. Richard Atwood or Christopher H. Thomas will take all
appropriate action to investigate any potential violations of the
Code that are reported.
<Page>
3. If, after investigation, J. Richard Atwood or Christopher H.
Thomas believes that no material violation of the Code has
occurred, no further action is required to be taken.
4. Any matter that J. Richard Atwood or Christopher H. Thomas
believes is a material violation of the Code will be reported to
the Board of Directors/Trustees of the FPA Funds.
5. If the Board of Directors/Trustees of the FPA Funds concurs that
a material violation of the Code has occurred, the Board will
consider appropriate action. Appropriate action may include
reassignment, suspension, or dismissal of the applicable Covered
Officer(s), or any other sanctions the Board deems appropriate.
Appropriate action may also include review of, and appropriate
modifications to, applicable policies and procedures.
6. Any changes to or waiver 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 conduct adopted by the FPA 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 FPA Funds, FPA, or other service providers govern
or purport to govern the behavior or activities of the Covered Officers, they
are superseded by this Code to the extent that they overlap or conflict with the
provisions of this Code.
FPA's and the FPA Funds' 17j-1 Code of Ethics, policies to prevent the misuse of
non-public information, and other internal compliance guidelines and policies
that may be in effect from time to time are separate requirements applying to
the Covered Officers and others, and are not part of this Code.
VI. Amendments
This Code may not be amended except by the approval of a majority vote of the
FPA Funds' Boards of Directors/Trustees. All amendments must be in writing and
communicated promptly to the Covered Officers, who shall affirm receipt of the
amended Code in accordance with Section IV.A.1.
VII. Confidentiality
All reports and records prepared or maintained pursuant to this Code shall 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
<Page>
FPA Funds' Boards of Directors/Trustees, and J. Richard Atwood or Christopher H.
Thomas.
Date: December 8, 2003
<Page>
EXHIBIT A
TO THE FPA CAPITAL FUND, INC.
FPA FUNDS TRUST
FPA NEW INCOME, INC.
FPA PARAMOUNT FUND, INC.
FPA PERENNIAL FUND, INC.
SOURCE CAPITAL, INC.
CODE OF ETHICS FOR SENIOR EXECUTIVE
AND FINANCIAL OFFICERS
COVERED OFFICERS OF FPA FUNDS:
President & CIO
President & Portfolio Manager
Executive VP & Portfolio Manager
Senior VP & Fixed-Income Manager
Vice Presidents
Treasurer
Secretary
Assistant Treasurer