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                                                             Exhibit 99.CODE ETH

                     THE NEW AMERICA HIGH INCOME FUND, INC.

                   CODE OF ETHICS FOR PRINCIPAL EXECUTIVE AND
                            SENIOR FINANCIAL OFFICERS

I. COVERED OFFICERS/PURPOSE OF THE CODE

This code of ethics (this "Code") for The New America High Income Fund, Inc.
("Fund") applies to the Fund's Principal Executive Officer, Principal Financial
Officer/Chief Financial Officer, Principal Accounting Officer, Vice President,
Treasurer and Manager of Accounting and Compliance (the "Covered Officers" each
of whom are 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 Securities and
      Exchange Commission ("SEC") and in other public communications made by the
      Fund;

   -  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, the Fund. 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 with
the Fund.

Certain conflicts of interest arise out of the relationships between Covered
Officers and the Fund and already are subject to conflict of interest provisions
in the Investment Company Act of 1940 ("Investment Company Act"). 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 Fund. The Fund's compliance programs
and procedures are designed to prevent, or identify and correct, violations of
these provisions. This Code does not, and is not

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intended to, repeat or replace these programs and procedures, and such conflicts
fall outside of the parameters of this Code.

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. The
following list provides examples of conflicts of interest under the Code, but
Covered Officers should keep in mind that these examples are not exhaustive.

The overarching principle is that the personal interest of a Covered Officer
should not be placed improperly before the interest of the Fund.

Each Covered Officer must not:

   -  use his personal influence or personal relationships improperly to
      influence investment decisions or financial reporting by the Fund whereby
      the Covered Officer would benefit personally to the detriment of the Fund;
      and

   -  cause the Fund to take action, or fail to take action, for the individual
      personal benefit of the Covered Officer rather than the benefit the Fund;

   -  retaliate against any other Covered Officer or any employee of the Fund's
      investment adviser or their affiliated persons for reports made in good
      faith of potential violations.

There are some conflict of interest situations that should always be discussed
with the AUDIT AND NOMINATING COMMITTEE CHAIRMAN if material. Examples of these
include:

   -  service as a director on the board of any company that files periodic
      reports with the SEC;

   -  the receipt of any gifts in excess of $100;

   -  the receipt of any entertainment from any company with which the 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 ownership interest in, or any consulting or employment relationship
      with, any of the Fund's service providers; and

   -  a direct or indirect financial interest in commissions, transaction
      charges or spreads paid by the 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 equity ownership.

III. DISCLOSURE AND COMPLIANCE

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      Each Covered Officer should:

   -  familiarize himself with the disclosure requirements generally applicable
      to the Fund;

   -  not knowingly misrepresent, or cause others to misrepresent, facts about
      the Fund to others, whether within or outside the Fund, including the
      Fund's Directors and independent accountants, and to governmental
      regulators and self-regulatory organizations;

   -  to the extent appropriate within the Covered Officer's area of
      responsibility, consult with other officers and employees of the Fund's
      investment adviser with the goal of promoting full, fair, accurate, timely
      and understandable disclosure in the reports and documents the Fund files
      with, or submits to, the SEC and in other public communications made by
      the Fund; and

   -  to the extent appropriate given the Covered Officer's scope of
      responsibility, assume responsibility for promoting compliance with the
      standards and restrictions imposed by applicable laws, rules and
      regulations.

IV. REPORTING AND ACCOUNTABILITY

Each Covered Officer must:

   -  report at least annually a list of affiliations or other relationships
      related to conflicts of interest in response to the Fund's annual
      Directors and Officers Questionnaire;

   -  upon adoption of the Code, including amendments to the Code (or thereafter
      as applicable, upon becoming a Covered Officer), affirm in writing to the
      Directors that the Covered Officer has received, read and understands the
      Code;

   -  annually thereafter affirm to the Directors that the Covered Officer has
      complied with the requirements of the Code; and

   -  notify the Audit and Nominating Committee Chairman promptly if the Covered
      Officer knows of any violation of this Code. Failure to do so is itself a
      violation of this Code.

The Audit and Nominating Committee Chairman 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 a Covered Officer will be considered by the
Independent Directors (the "Committee").

The Fund will follow these procedures in investigating and enforcing this Code:

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   -  the Audit and Nominating Committee Chairman is responsible for identifying
      and documenting "waivers" and "implicit waivers";

   -  the Audit and Nominating Committee Chairman will take all appropriate
      action to investigate any potential violations reported to Audit and
      Nominating Committee Chairman;

   -  if, after investigating a potential violation, the Audit and Nominating
      Committee Chairman believes that no violation has occurred, the Audit and
      Nominating Committee Chairman is not required to take any further action;

   -  any matter that the Audit and Nominating Committee Chairman believes is a
      violation will be reported to the Committee;

   -  if the Committee concurs that a violation has occurred, it will make a
      recommendation to the Directors, which will consider appropriate action,
      which may include review of, and appropriate modifications to, applicable
      policies and procedures; 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 currently in effect.

V. OTHER POLICIES AND PROCEDURES

This Code shall be the sole code of ethics adopted by the Fund 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 Fund, 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 conflict with the provisions of this Code. The
Fund's code of ethics under Investment Company Act Rule 17j-1 is a separate
requirement applying to the Covered Officers and others, and is not part of this
Code.

VI. AMENDMENTS

Any material changes to this Code, other than amendments to Exhibit A, must be
approved by a majority vote of the Directors, including a majority of
Independent Directors. Any non-material changes to this Code, other than
amendments to Exhibit A, must be ratified by a majority vote of the Directors,
including a majority of Independent Directors.

VII. CONFIDENTIALITY

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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 law or this Code, such matters shall not be
disclosed to anyone other than the Board of Directors and its counsel, including
counsel for the Independent Directors.

VIII. INTERNAL USE

The Code is intended solely for the internal use by the Fund and does not
constitute an admission, by or on behalf of the Fund, as to any fact,
circumstance, or legal conclusion.


Effective Date:  December 18, 2003

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                                    EXHIBIT A
                                COVERED OFFICERS


Robert F. Birch             President and Principal Executive Officer

Ellen E. Terry              Principal Financial Officer and Principal Accounting
                            Officer

Ellen E. Terry              Vice President and Treasurer

Paul E. Saidnawey           Manager of Accounting and Compliance

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