<Page>
Exhibit 99.CODEETH
THE GLENMEDE FUND, INC.
THE GLENMEDE PORTFOLIOS
CODE OF ETHICS FOR PRINCIPAL EXECUTIVE AND
SENIOR FINANCIAL OFFICERS
The Boards of Directors/Trustees (the "Boards") of The Glenmede Fund, Inc. and
The Glenmede Portfolios (each a "Fund" and together, the "Funds")* have adopted
this Code of Ethics (the "Code") for certain senior officers of the Funds to
guide and remind such officers of their responsibilities to the relevant Fund
and to the shareholders of the series of each such Fund (the "Portfolios"). Such
officers are expected to act in accordance with the guidance and standards set
forth in this Code.
I. COVERED OFFICERS AND PURPOSE OF THE CODE
The Code applies to each Fund's President, who is the Fund's principal executive
officer, and Treasurer, who is the Fund's principal financial officer, and any
persons performing similar functions on behalf of each Fund, regardless of
whether such persons are employed by the Fund or a third party (the "Covered
Officers") 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 Fund 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 is obligated to use his or her best efforts to promote the
factors listed above, 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.
- --------
* Reference in this Code of Ethics to one or more Funds shall, as
applicable, mean that Fund to which the particular senior officer is an
officer, and that Fund that is under the jurisdiction of the particular
Board or Audit Committee. No provision in this Code of Ethics is
intended to impose any duty upon a particular Fund's senior officer,
Board or Audit Committee with respect to any other Fund.
** If a Covered Person becomes aware that information filed with the SEC
or made available to the public contains any false or misleading
information or omits to disclose necessary information, he or she shall
promptly report it to the relevant Fund's Audit Committee.
<Page>
II. ETHICAL HANDLING OF ACTUAL AND APPARENT CONFLICTS OF INTEREST
A. CONFLICTS OF INTEREST - GENERAL
1. A "conflict of interest" occurs when a Covered Officer's
private interest interferes with the interests of, or his or
her service to, the Fund and its shareholders, including if
a Covered Officer, or a member of his or her family,
receives improper personal benefits as a result of his or
her position with the Fund.
2. A conflict of interest generally arises if a Covered
Officer, or a member of his or her family, directly or
indirectly participates in any investment, interest,
association, activity or relationship that may impair or
appear to impair the Covered Officer's objectivity.
B. SCOPE
This Code does not, and is not intended to, repeat or
replace the following programs and procedures, and such
conflicts that fall outside of the parameters of this Code:
1. Certain conflicts of interest already are subject to
conflicts of interest provisions in the Investment Company
Act of 1940, as amended (the "1940 Act"), and the Investment
Advisers Act of 1940 (the "Advisers Act").
2. The Funds' and each investment adviser's compliance
programs and procedures that are designed to prevent, or
identify and correct, violations of these provisions.
C. TYPES OF CONFLICTS
1. CONTRACTUAL RELATIONSHIPS
Although typically not presenting an opportunity for improper
personal benefit, conflicts arise from, or as a result of, the
contractual relationship between a Fund, and its investment
adviser(s) of which the Covered Officers may also be officers or
employees. As a result, this Code recognizes that the Covered
Officers may, in the normal course of their duties (whether
formally for a Fund or for the investment adviser or for both),
be involved in establishing policies and implementing decisions
that will have different effects on a Fund and the investment
adviser. The participation of the Covered Officers in such
activities is inherent in the contractual relationship between a
Fund and the investment adviser and is consistent with the
performance by the Covered Officers of their duties as officers
of a Fund. Thus, if performed in conformity with the provisions
of the
2
<Page>
1940 Act and the Advisers Act, such activities will be deemed to
have been handled ethically.
2. OTHER INVESTMENT COMPANIES
In addition, it is recognized by the Funds' Boards that the
Covered Officers may also be officers or employees of one or more
other investment companies covered by this or other codes.
3. ADDITIONAL CONFLICTS
Other conflicts of interest may be covered by the Code, even if
such conflicts of interest are not subject to provisions in the
1940 Act and the Advisers Act.
D. PERSONAL INTERESTS
The major principle of this Code is that the personal interest of a
Covered Officer should not be placed improperly before the interest of
the particular Fund. The following list provides examples of conflicts
of interest under the Code, but Covered Officers should keep in mind
that this list is not exhaustive.
Each Covered Officer must:
- not use his or her 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;
- not 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;
- not use material non-public knowledge of portfolio transactions
made or contemplated for the Fund to trade personally or cause
others to trade personally in contemplation of the market effect
of such transactions; and
- report at least annually affiliations or other relationships with
the Fund, each investment adviser or the distributor, including
any related conflict of interest.
E. REPORTING OF CONFLICTS
1. Required Disclosures
If certain conflict of interest situations are engaged in by
Covered Officers or by members of their family, these
conflicts of interest must be promptly discussed with the
relevant Fund's Audit Committee. These conflicts of interest
include:
3
<Page>
- service as a director on the board of any public or
private company;
- the receipt of any non-nominal gifts in excess of
$250.00;
- 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, other than its investment
adviser, principal underwriter, administrator or
any affiliated person thereof;
- 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; and
- any other interest, relationship or matter that a
Covered Person or the Board determines, in his or
her reasonable judgement, warrants disclosure.
2. Recommended Disclosures
There are potential conflict of interest situations, which
may be engaged in by Covered Officers or by members of their
family, that should be discussed with the relevant Fund's
Audit Committee. A Covered Person should use reasonable
judgement to determine if a conflict, other than conflicts
listed under section E(1), is material and warrants
disclosure to the Audit Committee.
III. COMPLIANCE AND DISCLOSURE
A. COMPLIANCE
Each Covered Officer should:
1. familiarize himself or herself with the disclosure requirements
generally applicable to the Fund;
2. not knowingly misrepresent, or cause others to misrepresent, facts
about the Fund to others, whether within or outside the Fund,
including to the Directors/Trustees of the
4
<Page>
relevant Fund and auditors, governmental regulators and
self-regulatory organizations and any other organization;
3. to the extent appropriate within his or her area of
responsibility, consult with other officers and employees of the
Fund, investment advisers and other service providers 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
4. promote compliance with the standards and restrictions imposed by
applicable laws, rules and regulations.
B. DISCLOSURE
Unless otherwise required by law, this Code shall be disclosed as
required by the SEC.
IV. 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 on
the certification attached hereto as Appendix A 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 and reported any
violations of the Code;
- not retaliate against any other Covered Officer or any employee of
the Funds, affiliated persons of the Fund or the Fund's service
providers for reports of potential violations that are made in
good faith; and
- notify the Chairman of the relevant Fund's Audit Committee
promptly if he or she knows of any violation of this Code. Failure
to do so is itself a violation of this Code.
5
<Page>
V. REPORTING PROCEDURES
1. RESPONSIBILITY***
- Each Fund's Audit Committee 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.
- Each Fund's Audit Committee may consult Fund counsel in
order to effectively discharge its responsibilities.
2. INVESTIGATION PROCEDURES***
The Funds will follow these procedures in investigating and
enforcing the Code:
- The relevant Fund's Audit Committee will take all
appropriate action to investigate any potential violations
of the Code;
- If, after such investigation, the Audit Committee believes
that no violation has occurred, the Audit Committee is not
required to take any further action;
- Any matter that the Audit Committee believes is a violation
of this Code will be reported to the relevant Board; and
- If the Board concurs that a violation has occurred, it
will take action which it considers appropriate. Such
action may include a review of, and appropriate
modifications to, applicable policies and procedures;
notification to appropriate personnel of each service
provider or its governing body; or a recommendation to
dismiss the Covered Officer.
3. WAIVERS
Any approvals or waivers, implicit or otherwise, sought by a
Covered Person will be considered by the relevant Fund's Audit
Committee. Such 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.
A waiver is the approval of a material departure from a provision
of this Code. An implicit waiver is a Fund's failure to take
action within a reasonable period of time regarding a material
departure from a provision of this Code that has been made known
to the Audit Committee of such Fund.
- ----------
*** The Audit Committee may delegate its reporting procedures,
responsibilities and investigation procedures to the Chairman of such
Audit Committee.
6
<Page>
VI. 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, each investment adviser, distributor, 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 its investment advisers' and distributor's codes of ethics under Rule
17j-1 under the 1940 Act are separate requirements applying to the Covered
Officers and others, and are not part of this Code.
VII. AMENDMENTS
Any amendments to this Code must be approved or ratified by a majority vote of
the relevant Fund's Board, including a majority of disinterested
Directors/Trustees, as that term is defined by the 1940 Act.
VIII. CONFIDENTIALITY AND RECORDKEEPING
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 relevant Fund's Audit Committee.
Subject to the confidentiality provisions above, the Funds will maintain and
preserve for a period of not less than six (6) years from the date of submission
or action is taken, the first two (2) years in an easily accessible place, a
copy of the Covered Officer's annual certifications, and information or
materials supplied to the relevant Board that provided the basis for any
amendment to this Code, and any information or materials supplied to the
relevant Audit Committee that provided the basis for any or waiver to this Code
or relating to any violation of the Code and sanctions imposed for such
violation, together with a written record of the approval or action taken by the
relevant Board.
IX. 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.
Adopted: September 10, 2003
7
<Page>
APPENDIX A
THE GLENMEDE FUND, INC.
THE GLENMEDE PORTFOLIOS
CERTIFICATION AND ACKNOWLEDGMENT OF RECEIPT OF CODE OF ETHICS FOR
PRINCIPAL OFFICERS AND SENIOR FINANCIAL OFFICERS
I acknowledge and certify that I have received a copy of the Code of Ethics for
Principal Officers and Senior Financial Officers of The Glenmede Fund, Inc. and
The Glenmede Portfolios (the "Code"). I understand and agree that it is my
responsibility to read and familiarize myself with the policies and procedures
contained in the Code and to abide by those policies and procedures.
I acknowledge my commitment to comply with the Code.
APPLICABLE NEXT YEAR:
I acknowledge that I complied with the Code for the one-year period ended
__________.
I acknowledge that I reported all violations of this Code of Ethics for the
one-year period ended ___________ of which I am aware.
(PLEASE SUBMIT ON A SEPARATE PIECE OF PAPER, EXCEPTIONS TO THESE
ACKNOWLEDGEMENTS.)
- ---------------------------------- ----------------------------------
Officer Name (Please Print) Officer Signature
----------------------------------
Date
8