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Exhibit 99.CODE ETH
BOSTON ADVISORS TRUST AND LEBENTHAL FUNDS, INC.
CODE OF ETHICS FOR PRINCIPAL EXECUTIVE AND
SENIOR FINANCIAL OFFICERS
I. COVERED OFFICERS/PURPOSE OF THE CODE
This code of ethics (the "Code") applies to the Principal Executive
Officer and Principal Financial Officer (the "Covered Officers," each of whom
are set forth in EXHIBIT A) of each of Boston Advisors Trust and Lebenthal
Funds, Inc. (the "Funds") 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 Funds;
- 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 Funds.
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 Funds.
Certain conflicts of interest arise out of the relationships between
Covered Officers and the Funds 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 ("Investment 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 the Funds because of
their status as "affiliated persons" of the Funds. The Funds' and the investment
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 arise from, or as a result of, the contractual relationship
between the Funds and the investment adviser, of which the Covered Officers are
also officers or employees. As a result, this Code
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recognizes that the Covered Officers will, in the normal course of their duties
(whether formally for the Funds or for the adviser, or for both), be involved in
establishing policies and implementing decisions that will have different
effects on the adviser and the Funds. The participation of the Covered Officers
in such activities is inherent in the contractual relationship between the Funds
and the adviser and is consistent with the performance by the Covered Officers
of their duties as officers of the Funds. Thus, if performed in conformity with
the provisions of the Investment Company Act and the Investment Advisers Act,
such activities will be deemed to have been handled ethically. In addition, it
is recognized by the Funds' Board of Trustees or Directors (each a "Board") that
the Covered Officers may also be officers 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 Investment 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 Funds.
* * * *
Each Covered Officer must:
- not use his personal influence or personal relationships improperly
to influence investment decisions or financial reporting by the
Funds whereby the Covered Officer would benefit personally to the
detriment of the Funds;
- not cause the Funds to take action, or fail to take action, for the
individual personal benefit of the Covered Officer rather than the
benefit of the Funds; and
- not use material non-public knowledge of portfolio transactions made
or contemplated for the Funds to trade personally or cause others to
trade personally in contemplation of the market effect of such
transactions.
There are some potential conflict of interest situations that should be
discussed with the Funds' counsel in order to determine whether these situations
pose a material risk of causing detriment to the Funds. Examples of these
include:
- service as a director on the board of any public or private company;
- the receipt of any non-nominal gifts from any company with which the
Funds have current or prospective business dealings, to the extent
the situation is not addressed by a Fund's 17j-1 Code of Ethics or
the investment adviser's Code of Ethics;
- the receipt of any entertainment from any company with which the
Funds have 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
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to raise any question of impropriety, to the extent the situation is
not addressed by a Fund's 17j-1 Code of Ethics or the investment
adviser's Code of Ethics;
- any ownership interest in, or any consulting or employment
relationship with, any of the Funds' service providers, other than
its investment adviser, principal underwriter, administrator or any
affiliated person thereof; and
- a direct or indirect financial interest in commissions, transaction
charges or spreads paid by the Funds 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
- Each Covered Officer should familiarize himself with the disclosure
requirements generally applicable to the Funds;
- each Covered Officer should not knowingly misrepresent, or cause
others to misrepresent, facts about the Funds to others, whether
within or outside the Funds, including to the 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 adviser with the goal of promoting full, fair,
accurate, timely and understandable disclosure in the reports and
documents the Funds file with, or submits to, the SEC and in other
public communications made by the Funds;
- each Covered Officer should comply with his or her obligations under
any Disclosure Controls and Procedures, whether or not committed
writing and approved by the Board, and certification requirements
relating to the reports on Form N-CSR (certified shareholder
reports) that a Fund is required to file; 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 (or thereafter as applicable, upon
becoming a Covered Officer), 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;
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- not retaliate against any other Covered Officer or any employee of
the Funds or their affiliated persons for reports of potential
violations that are made in good faith; and
- notify the Chair of the Audit Committee promptly if he knows of any
violation of this Code. Failure to do so is itself a violation of
this Code.
The Chair of the Audit Committee, in the case of Boston Advisors Trust,
and the Qualified Legal Compliance Committee ("QLCC"), in the case of Lebenthal
Funds, Inc. 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.(1) Any approvals or waivers(2) sought by the
Covered Officers must be considered by the Chair of the Audit Committee or the
QLCC.
The Funds will follow these procedures in investigating and enforcing
this Code:
- the Chair of the Audit Committee or the QLCC will take all
appropriate action to investigate any potential violations reported
to him or it;
- if, after such investigation, the Chair of the Audit Committee or
the QLCC believes that no violation has occurred, he or it is not
required to take any further action;
- if the Chair of the Audit Committee or the QLCC determines that a
violation has occurred, he or it will inform and make a
recommendation to the full Board, which will consider appropriate
action, which may include (i) review of, and appropriate
modifications to, applicable policies and procedures; (ii)
notification to appropriate personnel of the investment adviser or
its board; or (iii) a recommendation to dismiss the Covered Officer;
- the Chair of the Audit Committee or the QLCC 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
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(1) The Chair of the Audit Committee is authorized to consult, as appropriate,
with counsel to the Funds and/or counsel to the Independent Directors/Trustees,
and is encouraged to do so.
(2) Item 2 of Form N-CSR defines "waiver" as "the approval by the registrant of
a material departure from a provision of the code of ethics" and "implicit
waiver," which must also be disclosed, as "the registrant's failure to take
action within a reasonable period of time regarding a material departure from a
provision of the code of ethics that has been made known to an executive
officer" of the registrant.
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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 and principal underwriter's codes of ethics under Rule
17j-1 under the Investment Company Act, and any other codes of conduct
applicable to such entities, are separate requirements applying to the Covered
Officers and others, 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 the Board.
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 Funds' counsel, counsel to the Independent
Trustees or Directors and the Board (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 the Funds, as to any fact,
circumstance, or legal conclusion.
Adopted: February 24, 2004
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EXHIBIT A
Persons Covered by this Code of Ethics
Michael J. Vogelzang, President and Chief Executive Officer
Alexandra Lebenthal, Chair of the Lebenthal Funds, Inc.
Ronald A. Maggiacomo, Treasurer
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