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Exhibit 99.CODE
TCW CONVERTIBLE SECURITIES FUND, INC.
TCW CONVERTIBLE SECURITIES FUNDS, INC.
TCW PREMIER FUNDS
CODE OF ETHICS FOR CHIEF EXECUTIVE AND
PRINCIPAL FINANCIAL & ACCOUNTING OFFICERS
I. COVERED OFFICERS/PURPOSE OF THE CODE
This code of ethics (the "Code") for the TCW Convertible Securities
Fund, Inc., TCW Convertible Securities Funds, Inc. and TCW Premier Funds
(collectively, the "Funds" and each, a "Company") applies to the Company's
President & Chief Executive Officer and Treasurer and Principal Financial &
Accounting Officer (the "Covered Officers" each of whom are set forth in Exhibit
A) for the purpose of deterring wrongdoing and 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
Securities and Exchange Commission ("SEC") and in other public
communications made by the Company;
- 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 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, a Company.
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 in a Company.
Certain conflicts of interest arise out of the relationships between
Covered Officers and each Company 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 ("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 a Company because of
their status as "affiliated persons" of each Company pursuant to Section 17 of
the Investment Company Act. Each Company's and its investment adviser's
compliance programs
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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 of the parameters
of this Code.
Although typically not presenting an opportunity for improper personal
benefit, conflicts arise from, or as a result of, the contractual relationship
between each Company and the investment adviser of which the Covered Officers
are also officers. As a result, this Code recognizes that the Covered Officers
will, in the normal course of their duties (whether formally for a Company or
for the investment adviser, or for both), be involved in establishing policies
and implementing decisions which will have different effects on the investment
adviser and each Company. The participation of the Covered Officers in such
activities is inherent in the contractual relationship between each Company and
the investment adviser and is consistent with the performance by the Covered
Officers of their duties as officers of a Company and, if addressed in
conformity with the provisions of the Investment Company Act and the Advisers
Act, will be deemed to have been handled ethically. In addition, it is
recognized by the Board of Directors or Trustees of each Company (each, a
"Board") 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 Advisers Act. In reading the following examples of conflicts of
interest under the 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 Company.
Each Covered Officer must:
- not use his personal influence or personal relationships improperly to
influence investment decisions or financial reporting by a Company
whereby the Covered Officer would benefit personally to the detriment
of the Company;
- not cause a Company to take action, or fail to take action, for the
individual personal benefit of the Covered Officer rather than the
benefit of the Company;
- not use material non-public knowledge of portfolio transactions made or
contemplated for a Company to trade personally or cause others to trade
personally in contemplation of the market effect of such transactions;
- report at least annually any directorships or other affiliations with
other public companies.
There are some conflict of interest situations that must be approved by
the Chairman and either the general counsel of a Company (the "General Counsel")
or the Chief Compliance Officer of the investment adviser. Examples of these
include:
- service as a director on the board of any public company;
- service as an executor, trustee, guardian, conservator, general partner
or other fiduciary, or any appointment as a consultant in connection
with fiduciary or active money management matters exclusive of
appointments involving personal estates;
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- the receipt of any entertainment from any company with which a Company
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 to raise any question of impropriety;
- any ownership interest in, or any consulting or employment relationship
with, any of a Company's service providers, other than its investment
adviser, principal underwriter or any affiliated person thereof except
that nothing herein shall prevent a Covered Officer from acquiring
publicly traded securities of a service provider in a market
transaction;
- a direct or indirect financial interest in commissions, transaction
charges or spreads paid by a Company 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.
In addition, Covered Officers should refrain from accepting gifts of
more than a DE MINIMIS value from providers of goods and services to a Company.
III. DISCLOSURE & COMPLIANCE
- Each Covered Officer should familiarize himself with the disclosure
requirements generally applicable to each Company;
- each Covered Officer should not knowingly misrepresent, or cause others
to misrepresent, facts about a Company to others, whether within or
outside the Company, including to a Company's Board and auditors, and
to governmental regulators and self-regulatory organizations;
- each Covered Officer should, to the extent appropriate within his area
of responsibility, consult with other officers and employees of the
Funds and the investment adviser 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 Board that he has
received, read, and understands the Code;
- annually thereafter affirm to the Board that he has complied with the
requirements of the Code;
- not retaliate against any Covered Officer or employees of the Funds or
their affiliated persons for reports of potential violations that are
made in good faith; and
- notify the General Counsel promptly if he knows of any violation of
this Code. Failure to do so is itself a violation of this Code.
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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 approvals or
waivers sought by the Covered Officer will be considered by the Audit Committee
of each Company (the "Committee").
The Funds will follow these procedures in investigating and enforcing
this Code.
- the 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;
- 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 inform
the Board, which 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;
- 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' investment adviser or principal
underwriter, 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 their 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 set forth in TCW Code of Ethics
contained in the TCW Employee Handbook are separate requirements applying to the
Covered Officers and others, and are not part of this Code.
VI. AMENDMENTS
Except as to Exhibit A, this Code may not be amended except in written
form, which is specifically approved or ratified by a majority vote of a
Company's board, including a majority of independent directors or 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 otherwise required by
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law or this Code, such matters shall not be disclosed to anyone other than the
appropriate Board and their counsel and counsel to the Funds.
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 Company, as to any fact,
circumstance, or legal conclusion.
Date: July 16, 2003
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EXHIBIT A
Persons Covered by this Code of Ethics
Alvin R. Albe, Jr.
David S. DeVito
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