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Exhibit 99.Code of Ethics
THE BEAR STEARNS FUNDS
CODE OF CONDUCT FOR
PRINCIPAL EXECUTIVE OFFICER AND PRINCIPAL FINANCIAL OFFICER
I. COVERED OFFICERS/PURPOSE OF THE CODE
This Code of Conduct (the "Code") applies to the Principal Executive
Officer and Principal Financial Officer of The Bear Stearns Funds ("BSF") (the
"Covered Officers"), each of whom is set forth in Exhibit A, for the purpose of
promoting:
1. Honest and ethical conduct, including the ethical handling of
actual or apparent conflicts of interest between personal and
professional relationships;
2. 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 BSF's other
public communications;
3. Compliance with applicable laws and governmental rules and
regulations;
4. The prompt internal reporting of violations of the Code to an
appropriate person or persons identified in the Code; and
5. 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
A. OVERVIEW. A "conflict of interest" occurs when a Covered Officer's
private interest interferes with the interests of, or his or her service to,
BSF. For example, a conflict of interest would arise 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 BSF.
Certain conflicts of interest that could arise out of the relationships
between Covered Officers and BSF already are subject to conflict of interest
provisions in the Investment Company Act of 1940, as amended (the "1940 Act")
and the Investment Advisers Act of 1940, as amended (the "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 BSF because
of their status as "affiliated persons" of BSF. BSF's and its adviser's
compliance programs 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 may arise or result from the contractual relationship between
BSF and the adviser and the
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administrator, whose officers or employees also serve as Covered Officers. As a
result, this Code recognizes that the Covered Officers will, in the normal
course of their duties (whether formally for BSF or for the adviser or the
administrator, or for both), be involved in establishing policies and
implementing decisions that will have different effects on the adviser, the
administrator and BSF. The participation of the Covered Officers in such
activities is inherent in the contractual relationship between the adviser, the
administrator and BSF and is consistent with the performance by the Covered
Officers of their duties as officers of BSF. Thus, if performed in conformity
with the provisions of the 1940 Act and the Advisers Act, such activities will
be deemed to have been handled ethically. In addition, BSF's Board of Trustees
(the "Board") recognizes that the Covered Officers also may 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 1940 Act and the
Advisers 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
Company.
B. Each Covered Officer must:
1. Not use his personal influence or personal relationships
improperly to influence investment decisions or financial
reporting by BSF whereby the Covered Officer would benefit
personally to the detriment of BSF;
2. Not cause BSF to take action, or fail to take action, for the
individual personal benefit of the Covered Officer rather than the
benefit of BSF;
3. Report at least annually outside business affiliations or other
relationships (e.g., officer, director, governor, trustee,
part-time employment) other than his or her relationship to BSF,
the adviser or the administrator.
C. There are some conflict of interest situations that may be
discussed with the Compliance Officer who, for purposes of this Code, shall be
the Compliance Officer of Bear Stearns Asset Management Inc., if material.
Examples of these include:
1. Service as a director on the board of any public or private
company;
2. The receipt, as an officer of BSF, of any gift in excess of $100;
3. The receipt of any entertainment from any company with which BSF
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;
4. Any ownership interest in, or any consulting or employment
relationship with, any of BSF's service providers, other than its
adviser, principal underwriter, administrator or any affiliated
person thereof; or
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5. A direct or indirect financial interest in commissions,
transaction charges or spreads paid by BSF 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
A. Each Covered Officer should familiarize himself or herself with
the disclosure requirements generally applicable to BSF.
B. Each Covered Officer should not knowingly misrepresent, or cause
others to misrepresent, facts about BSF to others, whether within or outside
BSF, including to the Board and auditors, and to governmental regulators and
self-regulatory organizations.
C. Each Covered Officer should, to the extent appropriate within his
or her area of responsibility, consult with other officers and employees of BSF,
the adviser and the administrator with the goal of promoting full, fair,
accurate, timely and understandable disclosure in the reports and documents BSF
file with, or submit to, the SEC and in BSF's other public communications.
D. 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
A. Each Covered Officer must:
1. Upon adoption of the Code (or thereafter as applicable, upon
becoming a Covered Officer), affirm in writing to the appropriate
Board that he or she has received, read, and understands the Code;
2. Annually thereafter affirm to the appropriate Board that he or she
has complied with the requirements of the Code;
3. Not retaliate against any other Covered Officer or any employee of
BSF or its affiliated persons for reports of potential violations
that are made in good faith; and
4. Notify the Compliance Officer promptly if he or she knows of any
violation of this Code. Failure to do so is itself a violation of
this Code.
B. The Compliance Officer 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 Board, or an
appropriate committee thereof, shall consider any requests for waivers from this
Code. To the extent required, BSF shall disclose any such waivers, as provided
by SEC rules.
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C. BSF will adhere to the following procedures in investigating and
enforcing this Code:
1. The Compliance Officer will take all appropriate action to
investigate any potential violations reported to him or her;
2. If, after such investigation, the Compliance Officer believes that
no violation has occurred, no further action is required;
3. Any matter that the Compliance Officer believes is a violation
shall be reported to the Board or the appropriate committee; and
4. If the appropriate committee concurs that a violation has
occurred, it will inform and make a recommendation to 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 adviser
or the administrator or their management; or a recommendation to
dismiss the Covered Officer.
V. OTHER POLICIES AND PROCEDURES
This Code shall be the sole code of conduct adopted by BSF for purposes
of Section 406 of the Sarbanes-Oxley Act and the rules and forms applicable to
registered investment companies relating to that section. Insofar as other
policies or procedures of BSF, BSF's 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.
BSF's and its adviser's and principal underwriter's Codes of Ethics under Rule
17j-1 under the 1940 Act and the adviser's insider trading policies are separate
policies that apply to the Covered Officers and others, and are not part of this
Code.
VI. APPROVAL AND AMENDMENTS
A majority of the Board, including a majority of the Trustees who are not
"interested persons" (as defined in the 1940 Act) (the "Independent Trustees"),
shall initially approve this Code and any amendments thereto, other than
amendments to Exhibit A. To the extent required, BSF shall disclose any changes
to this Code, as provided by SEC rules.
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 law or this Code, such matters shall not be
disclosed to anyone other than the Board; BSF's officers, adviser, administrator
or counsel; or counsel to the Independent Trustees.
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VIII. INTERNAL USE
The Code is intended solely for the internal use by BSF and does not
constitute an admission, by or on behalf of BSF, as to any fact, circumstance,
or legal conclusion.
Adopted: September 4, 2003
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EXHIBIT A
PERSONS COVERED BY THIS CODE OF CONDUCT
1. Principal Executive Officer: Barry Sommers, President
2. Principal Financial Officer: Frank J. Maresca, Treasurer
Effective as of May 13, 2004