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EXHIBIT 11(a)(1)
SEPTEMBER 2003
(AS REVISED FEBRUARY, 2004)
CODE OF ETHICS FOR PRINCIPAL EXECUTIVE AND
PRINCIPAL FINANCIAL OFFICERS
I. COVERED OFFICERS/PURPOSE OF THE CODE
This code of ethics (this "Code") has been adopted by the funds
(collectively, "Funds" and each, "Fund") under supervision of the MFS Funds
Board and Compass Board of Trustees/Managers (the "Boards") and applies to the
Funds' Principal Executive Officer and Principal Financial Officer (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 the Funds file with, or submits to,
the Securities and Exchange Commission ("SEC") and in other
public communications made by the Funds;
- compliance by the Funds 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.
II. CONDUCT GUIDELINES
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. In addition, each Covered Officer should
not place his or her personal interests ahead of the Funds' interests and should
endeavor to act honestly and ethically. In furtherance of the foregoing, each
Covered Officer must:
- not use his or her personal influence or personal relationships
improperly to influence investment decisions or financial
reporting for any 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.
The following activities, which could create the appearance of a
conflict of interest, are permitted only with the approval of the Funds' Chief
Legal Officer ("CLO"):
- service as a director on the board of any "for profit" company;
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- running for political office;
- the receipt of any Fund business-related gift in excess of $300;
- the receipt of any entertainment from any company with which a
Fund 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 material ownership interest in, or any consulting or
employment relationship with, any Fund service providers (e.g.,
custodian banks, audit firms), other than the Funds' investment
adviser, principal underwriter, administrator or any affiliated
person thereof;
- 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 or
securities ownership.
III. DISCLOSURE AND COMPLIANCE
- Each Covered Officer should familiarize himself or 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 the Fund, including to the Fund's trustees and
auditors, and to governmental regulators and self-regulatory
organizations;
- each Covered Officer should, to the extent appropriate within his
or her area of Fund responsibility, consult with other officers
and employees of the Funds and the 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 within his or her area of Fund responsibility 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 (or thereafter as applicable, upon
becoming a Covered Officer), affirm in writing to the Boards that
he or she has received, read, and understands the Code;
- annually thereafter affirm to the Boards that he or she has
complied with the requirements of the Code;
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- annually report to the CLO affiliations and relationships which
are or may raise the appearance of a conflict of interest with
the Covered Officer's duties to the Funds, as identified in the
annual Trustee and Officer Questionnaire;
- not retaliate against any other Covered Officer or any officer or
employee of the Funds or their affiliated persons for reports of
potential violations that are made in good faith; and
- notify the CLO promptly if he or she knows of any violation of
this Code. Failure to do so is itself a violation of this Code.
The CLO is responsible for applying this Code to specific situations in which
questions are presented under it, granting waivers upon consultation with the
appropriate Board or its designee, investigating violations, and has the
authority to interpret this Code in any particular situation. The CLO will
report requests for waivers to the appropriate Board (or a designee thereof)
promptly upon receipt of a waiver request and will periodically report to the
appropriate Board any approvals granted since the last report.
The CLO will take all appropriate action to investigate any potential
violations reported to him or her and to report any violations to the
appropriate Board. If the Board 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 the investment adviser or its
board; or a recommendation to dismiss the Covered Officer.
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
superseded by this Code to the extent that they overlap or conflict with the
provisions of this Code. The Funds' and their investment adviser's codes of
ethics under Rule 17j-1 under the Investment Company Act and any other codes or
policies or procedures adopted by the Funds or their investment adviser or other
service providers are separate requirements and are not part of this Code.
VI. AMENDMENTS
Any amendments to this Code, other than amendments to Exhibit A, must
be approved or ratified by a majority vote of each Board, including a majority
of independent trustees.
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VII. CONFIDENTIALITY
All reports and records prepared or maintained pursuant to this Code
and under the direction of the CLO 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
appropriate Funds' Board, its counsel, counsel to the Board's independent
trustees and senior management and the board of directors of the Fund's
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.
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EXHIBIT A
PERSONS COVERED BY THIS CODE OF ETHICS
Funds' Principal Executive Officer: Robert J. Manning
Funds' Principal Financial Officer: Richard M. Hisey