<Page>
THE LORD ABBETT FAMILY OF FUNDS
SARBANES-OXLEY CODE OF ETHICS
FOR THE PRINCIPAL EXECUTIVE OFFICER
AND SENIOR FINANCIAL OFFICERS
I. COVERED OFFICERS/PURPOSE OF THE CODE
THE LORD ABBETT FAMILY OF FUNDS' code of ethics (the "Code") for the
investment companies within the complex (collectively, "Funds" and each
individually a "Fund"), applies to each Fund's Principal Executive Officer and
Senior Financial Officers (the "Covered Officers", each of whom is set forth in
Exhibit A) for the purpose of promoting:
- honest and ethical conduct, including the ethical handling of actual or
apparent conflicts of interest between personal and professional
relationships;
- full, fair, accurate, timely and understandable disclosure in reports and
documents that a registrant files with, or submits to, the SEC and in
other public communications made by the Funds;
- compliance with applicable laws and governmental rules and regulations;
- the prompt internal reporting of violations of the Code to an appropriate
person or persons identified in the Code; and
- 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 ANY 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/her service to, a
Fund. For example, a conflict of interest would arise if a Covered Officer, or a
member of his/her family, receives improper personal benefits as a result of
his/her position with a Fund.
Certain conflicts of interest arise out of the relationships between
Covered Officers and a Fund and already are subject to conflict of interest
provisions in the Investment Company Act of 1940 and the Investment Advisers Act
of 1940. 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" of the investment
adviser to each of the Funds. The compliance programs and procedures of Lord,
Abbett & Co. LLC ("Lord Abbett") are designed to prevent, or identify and
correct, violations of such requirements. This Code does not, and is not
intended to, repeat or replace these programs and procedures, and such conflicts
fall outside of the parameters of this Code.
1
<Page>
Although typically not presenting an opportunity for improper personal
benefit, conflicts arise from, or as a result of, the contractual relationship
between each of the Funds and Lord Abbett of which the Covered Officers are also
members. As a result, this Code recognizes that the Covered Officers will, in
the normal course of their duties (whether formally for a Fund or for Lord
Abbett, or for both), be involved in establishing policies and implementing
decisions which will have different effects on Lord Abbett and each of the
Funds. The participation of the Covered Officers in such activities is inherent
in the contractual relationship between each of the Funds and Lord Abbett and is
consistent with the performance by the Covered Officers of their duties as
officers of one or more Funds and, if addressed in conformity with the
provisions of the Investment Company Act and the Investment Advisers Act, will
be deemed to have been handled ethically. In addition, it is recognized by the
Boards of Directors/Trustees of the Funds that the Covered Officers are also
officers of the other Lord Abbett investment companies covered by this and by a
separate code of ethics.
Other conflicts of interest are covered by this Code, even if such
conflicts of interest are not subject to provisions in the Investment Company
Act and the Investment Advisers Act. In reading the following examples of
conflicts of interest under this Code, Covered Officers should keep in mind that
such a list cannot ever be exhaustive by covering every possible scenario. It
follows that the overarching principle is that the personal interest of a
Covered Officer should not be placed improperly before the interest of a Fund.
* * * *
Each Covered Officer must:
- not use his/her personal influence or personal relationships improperly
to influence investment decisions or financial reporting by a Fund
whereby the Covered Officer would benefit personally to the detriment of
the Fund; and
- not cause a Fund to take action, or fail to take action, for the
individual personal benefit of the Covered Officer rather than the
benefit the Fund.
There are some potential conflict of interest situations that should be
discussed with Lord Abbett's General Counsel if material. Examples of these
include:
- service as a director on the board of any public company;
- any direct ownership interest in, or any consulting or employment
relationship with, any of the Funds' service providers, other than
Lord Abbett or any affiliated person of Lord Abbett;
- a direct or indirect financial interest in commissions, transaction
charges or spreads paid by a 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 as a member of
Lord Abbett.
2
<Page>
III. DISCLOSURE & COMPLIANCE
- Each Covered Officer should familiarize him/herself with the disclosure
requirements generally applicable to the Funds;
- each Covered Officer should not knowingly misrepresent, or cause others
to misrepresent, facts about a Fund to others, whether within or outside
Lord Abbett or a Fund, including to a Fund's independent
directors/trustees and auditors, and to governmental regulators and
self-regulatory organizations;
- each Covered Officer should, to the extent appropriate within his/her
area of responsibility, consult with other officers and employees of the
Funds and Lord Abbett 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
- 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:
- upon adoption of the Code, affirm in writing to the Audit Committee (the
"Committee") of a Fund that he/she has received, read, and understands
the Code;
- annually thereafter affirm to the Committee that he/she has complied with
the requirements of the Code;
- report at least annually such affiliations or other relationships related
to conflicts of interest as covered by the Funds' Annual Directors &
Officers Questionnaire;
- not retaliate against any employee or member of Lord Abbett for reports
of potential violations that are made in good faith; and
- notify Lord Abbett's General Counsel promptly if he/she alleges any
violation of this Code. Failure to do so is itself a violation of this
Code.
Lord Abbett's 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. The General
Counsel may consult, as appropriate, with the Committee, and/or counsel to the
Independent Directors, and is encouraged to do so. However, any approvals or
waivers sought by the Covered Persons will be considered by the Committee.
3
<Page>
Each of the Funds will follow these procedures in investigating and
enforcing this Code:
- Lord Abbett's General Counsel will take all appropriate action to
investigate any potential violations reported to him;
- if, after such investigation, the General Counsel believes that no
violation has occurred, the General Counsel is not required to take any
further action, but he shall discuss with the Committee at its next
regularly scheduled meeting his investigation and conclusion;
- any matter that the General Counsel believes is a violation will be
reported to the Committee;
- if the Committee concurs that a violation has occurred, it will consider
appropriate action, which may include review of, and appropriate
modifications to, applicable policies and procedures; notification to
appropriate personnel of Lord Abbett; or a recommendation to dismiss the
Covered Officer;
- the Committee will be responsible for granting waivers, as appropriate;
and
- 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 and the rules and forms
applicable to registered investment companies thereunder. Insofar as other
policies or procedures of the Funds, the Funds' 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
superceded by this Code to the extent that they overlap or conflict with the
provisions of this Code. The Funds' and Lord Abbett's codes of ethics under Rule
17j-1 under the Investment Company Act are separate requirements applying to the
Covered Officers and others, and are not part of this Code.
VI. AMENDMENTS
Except as to the individuals listed in Exhibit A, this Code may not be
amended except in written form, which is specifically approved or ratified by a
majority vote of a Fund's independent directors/trustees.
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
4
<Page>
otherwise required by law or this Code, such matters shall not be disclosed to
anyone other than the Committee and its counsel.
VIII. INTERNAL USE
The Code is intended solely for the internal use by each of the Funds and
does not constitute an admission, by or on behalf of any Fund, as to any fact,
circumstance, or legal conclusion.
Date: June 19, 2003
5
<Page>
EXHIBIT A
<Table>
<Caption>
Persons Covered by this Code of Ethics Position With Funds
- -------------------------------------- -------------------
Robert S. Dow Principal Executive Officer Chief Executive Officer and
President; Chairman of the
Boards of Directors/Trustees
Joan A. Binstock Principal Financial Officer Chief Financial Officer and
Vice President
Tracie E. Ahern Principal Accounting Officer Treasurer and Vice President
Bernard J. Grzelak Principal Accounting Officer Assistant Treasurer
</Table>
6