CODE  of  ETHICS  REVISIONS.doc
                                        Revised  December  1999



            CODE OF ETHICS AND INSIDER TRADING POLICY AND PROCEDURES

                     Calvert Asset Management Company, Inc.
                           Calvert-Sloan, Advisers, L.L.C.
                           Calvert Distributors, Inc.

                 First Variable Rate Fund for Government Income
                            Calvert Tax-Free Reserves
                         Calvert Social Investment Fund
                                The Calvert Fund
                           Calvert Municipal Fund Inc.
                         Calvert World Values Fund, Inc.
                          Calvert Variable Series, Inc.
                              Calvert Cash Reserves
                          Calvert New World Fund, Inc.

The  Code  of Ethics and Insider Trading Policies and Procedures are designed to
protect  the  public  from  abusive  trading  practices  and to maintain ethical
standards  for  access persons when dealing with the public.   Active leadership
and  integrity of management dictates these principles be diligently implemented
and  monitored.  The  Code  of Ethics imposes the following general obligations:

- -     Information  concerning  the  purchase  and  sale of securities learned in
connection  with an access person's service, is property of the Fund, Adviser or
employer  and  may  not  be  used  for  personal  benefit.
- -     Fiduciary  duties  mandate  suitable investment opportunities be presented
first  to  the Fund, Adviser, or employer and should not be exercised even after
full  disclosure  for  personal  benefit.
- -     Material  inside  information  must  be  kept  confidential  and restricts
trading  of  securities.
- -     Front  running,  market  manipulation  and deceptive trading practices are
abusive  techniques  prohibited  by  these  procedures and may result, in fines,
termination  or  legal  actions  by  third  parties.
- -     Access persons may not purchase IPOs due to the high potential for abusive
trading  practices.
- -     Access  persons must not trade in securities with knowledge that the Fund,
Adviser,  Sub-Adviser  or  employer is considering to make a similar purchase or
sale  of  the  same  securities.
- -     Access  persons shall not engage in transactions that create a conflict of
interest including but not limited to inappropriately making decisions on behalf
of  a  Fund  regarding  securities or private placements personally owned by the
access  person.



Code  of  Ethics  Guidelines

The  legal  definition of a security is very broad and incorporates the purchase
and sale of public, private, registered and exempt from registration securities,
as  well  as derivatives.  To ease the burden of following these guidelines, the
Code  of  Ethics  reporting  and  disclosure obligations as well as preclearance
policies  do  not  apply  to  the  following:

1)     The  sale  and  purchase  of open-end mutual funds including money market
funds.
2)     The  sale  and  purchase  of  U.S.  Government,  U.S.  Government  agency
securities  and  municipal  securities  in  trade  amounts of less than $20,000.
3)     Acquisitions  through  stock  dividend  plans,  spin-offs  or  other
distributions  applied  to  all  holders  of  the  same  class  of  securities.
4)     Acquisitions  through  the  exercise  of  rights  issued  pro rata to all
holders.
5)     Acquisitions  through  gifts  or  bequests.
6)     Trades  in  any  S  &  P  500  company  of  500  shares  or  less.
7)     Trades  in  REITS  and  variable  insurance  products.


A.     Disclosure  of  Holdings & Duplicate Statements and Confirmations for the
purchase  and  sale  of  securities  or options on securities by access persons.

To  assure  that  abusive  or  unethical  trading practices are not conducted by
access  persons,  access  persons  are  required to disclose personal securities
holdings  including  private placement holdings and send duplicate brokerage and
confirmation  statements  to  the attention of the Compliance Officer at Calvert
Group,  Ltd.,  4550  Montgomery Avenue, Bethesda, MD 20814.  Personal securities
holdings  must be disclosed at the point of hire and upon annual acknowledgement
of  these  procedures.  Duplicate  statements and confirmations are required for
any  access  person's  account  or  an  account over which the access person has
either  custody,  control  or  beneficial  ownership.  Account  statements  for
immediate family members are also required."Beneficial ownership" shall have the
same  meaning  as in Rule 16a-1(a)(2) under the Securities Exchange Act of 1934.
Generally,  a  person  has  a  beneficial  ownership in a security if he or she,
directly  or  indirectly,  through  any  contract,  arrangement,  understanding,
relationship or otherwise, has or shares a direct or indirect pecuniary interest
in  the  security,  [has or shares voting power (the power to vote or direct the
voting  of  the security) or investment power (the power to dispose of or direct
the  disposition of the security).]   Beneficial ownership" includes accounts of
a  spouse, minor children and relatives resident in the access person's home, as
well  as accounts of another person if by reason of any contract, understanding,
relationship, agreement or other arrangement the access person obtains therefrom
benefits  substantially  equivalent  to  those  of  ownership, e.g., as Trustee,
Settlor,  Beneficiary,  Power  of  Attorney.
  All  information  provided  to  the  Compliance  Officer will be confidential.

Statements  and  confirmations will be reviewed by the Compliance Officer or his
or  her  designee(s)  for  any  pattern  of  transactions  involving  parallel
transactions  (portfolio  and  individual  both  buying or both selling the same
security) generally within a 15 day period before or after the transaction date.
Among  the  factors  that  will  be  considered  in  the analysis of whether any
provision  of  the Code has been violated will be the number and dollar value of
the  transactions,  the trading volume of the securities in question, the length
of  time the security is held by the individual and the individual's involvement
in  the  investment process. While the focus of this procedure of the Code is on
"patterns",  it is important to note that a violation could result from a single
transaction  if  the  circumstances  warrant  a  finding  that  the  underlying
principles of fair dealing have been violated.  The Compliance Officer or his or
her  designee(s), will similarly review the personal securities holdings reports
provided  to  the  Compliance  Officer.

B.     Preclearance  Policy

Because  of  the  sensitive nature of securities trading, the Compliance Officer
will  notify  certain  access persons and investment personnel about the need to
follow  a  preclearance  policy.  Attachment A will be used by designated access
persons  seeking  preclearance  for  securities trades including preclearance by
investment  personnel  for  private  placement  transactions.  Those individuals
subject  to  the  preclearance  policy  will  not  be  exempt  from  the general
prohibitions  listed  in  the  Code  or  the Policies and Procedures designed to
prevent  insider  trading.  The  Compliance  Officer  will  review  with  the
Directors/Trustees  periodically  a  list  of  persons  who  are  subject to the
preclearance  policy  and  the  criteria  used  to  select  such  individuals.

The  preclearance  authorization  shall  be valid for a period of three business
days  unless a further extension of time is indicated by the Compliance Officer.




C.     Notification  of  Reporting  Obligation  -  Annual Certification to Board

Members  of  the  Legal  Department will be responsible for notifying all access
persons about the duty to forward trade confirmations to the Compliance Officer.
Once informed of the duty to forward trade confirmations, an access person has a
continuing  obligation  to provide such confirms, in a timely manner, until such
time  as notified otherwise.  Information compiled in Compliance Officer reports
is  available  for  inspection by the SEC or other regulatory authorities at any
time  during  the five-year period following the end of the fiscal year in which
each  report  is  made.

Annually, the Legal Department will prepare a written " Issues and Certification
Report"  for  the  Board  that:

- -     describes  any  issues  that  have arisen under this Code of Ethics or its
procedures  since  the last report, including information about material Code of
Ethics  or  procedure  violations  and  sanctions  imposed  in response to those
violations;  and
- -     certifies  to the Board that the adopted Code of Ethics and its procedures
provide  reasonably  necessary  measures  to  prevent  investment personnel from
violating  the  Code  and  applicable  procedures.

The Code of Ethics and any material changes to its provisions and/or  procedures
must  be  approved  by  a  majority  of  the  Board, including a majority of the
independent  directors.


D.     Restrictions  as  to  Gifts,  Entertainment,  Favors  and  Directorships

1.     Gifts,  Entertainment  and  Favors. Access Persons must not make business
decisions  that are influenced or appear to be influenced by giving or accepting
gifts, entertainment or favors. Access persons are prohibited from receiving any
gift or other thing of more than de minimis value from any person or entity that
does  business  with  or  on  behalf  of  Calvert  Asset  Management  Company,
Calvert-Sloan  Advisers,  or  Calvert  Distributors  Inc.  Invitations  to  an
occasional  meal, sporting event or other similar activity will not be deemed to
violate  this restriction unless the occurrence of such events is so frequent or
lavish  as  to  suggest an impropriety.  The President/CEO of Calvert Group must
approve the acceptance of any gift, entertainment or favor with a per gift value
of  more  than  $100.00.

2.     Directorships.

(a)     General  Rule:

No access person, other than a Disinterested Fund Director/Trustee, may serve on
the  Board  of Directors of a publicly-held or private for-profit company absent
prior  written  approval  from the Calvert Group, Ltd. Board of Directors and/or
the  applicable  Fund's  Board  of  Directors/Trustees.  Disinterested
Directors/Trustees  must provide annual disclosure about directorships and other
potential  conflicts  of  interest.

             (b)  Applications  for  Approval:

Applications for approval to serve as a director of a publicly traded or private
for-profit  company  shall be directed, in writing, to the office of the General
Counsel  for prompt forwarding to the Calvert Group, Ltd. Board of Directors and
the  respective Fund's Board of Directors/Trustees. Authorization may be granted
where  it  is  determined  that  such board service would be consistent with the
interests  of  the  Funds  and  their  shareholders.


(c)  Subsequent  Investment  Management  Activities:

Whenever  an  access  person  is  granted  approval  to serve as a director of a
publicly-traded  or  private  for-profit  company,  he  or  she shall personally
refrain  from  participating  in  any  deliberation,  recommendations,  or
considerations  of  whether  or  not  to  recommend  that any securities of that
company  be  purchased,  sold  or  retained  in  the investment portfolio of any
Calvert  Group  Fund  or  Calvert  Asset  Management  Company  managed  account.


E.     Enforcement  and  Sanctions

     Each  violation  of  this  Code  shall  be  reported  to  the  Board  of
Directors/Trustees  of  the  applicable  Fund  or  entity  at or before the next
regular  meeting of the Board. Upon discovering or otherwise being informed of a
violation  of  this Code, the Board of Directors/Trustees may take any action it
deems  appropriate  including, inter alia, a letter of censure, termination with
respect  to  portfolio  management duties regarding the Fund, or recommending to
the operating companies, suspension or removal from office, imposition of a fine
or  termination  of  employment  of  the  violator.


F.     Recordkeeping

     Each entity shall maintain such lists, records, and reports as are required
by  law.




G.     Insider  Trading  Policy  and  Procedures


     1.  Scope  of  Policy  Statement

     This  Policy  Statement  is  drafted  broadly;  it  will  be  applied  and
interpreted  in  a  similar  manner. This Policy Statement applies to securities
trading  and  information  handling  by  all  access  persons.

     The  law of insider trading is unsettled; an individual legitimately may be
uncertain  about  the  application  of  the  Policy  Statement  in  a particular
circumstance.  Often,  a  single  question  can forestall disciplinary action or
complex  legal  problems. You should direct any questions relating to the Policy
Statement  to  an  attorney in the Calvert Group Legal Department. You must also
notify  an  attorney  in  the Legal Department if you have any reason to believe
that  a  violation  of  the  Policy Statement has occurred or is about to occur.

     2.  Policy  Statement  on  Insider  Trading

     Calvert  forbids  any  officer,  director\trustee or employee from trading,
either  personally  or  on  behalf  of others, including mutual funds managed by
Calvert,  on  material nonpublic information or communicating material nonpublic
information  to  others  in  violation  of  the  law. This conduct is frequently
referred  to  as  "insider  trading." Calvert's policy applies to each Fund, its
investment  advisor,  its principal underwriter, and every officer, director and
employee  thereof,  and extends to activities within and outside their duties at
Calvert. Every officer, director, trustee and employee must read and retain this
policy statement. Any questions regarding Calvert's policy and procedures should
be  referred  to  an  attorney  in  the  Calvert  Legal  Department. An officer,
director,  trustee  or  employee must notify an attorney in the Legal Department
immediately  if  they  have any reason to believe that a violation of the Policy
Statement  has  occurred  or  is  about  to  occur.

     The  term  "insider trading" is not defined in the federal securities laws,
but  generally  is used to refer to the use of material nonpublic information to
trade in securities (whether or not one is an "insider") or to communications of
material  nonpublic  information  to  others.

     While  the  law  concerning  insider trading is not static, it is generally
understood  that  the  law  prohibits:

     a)  trading  by  an  insider,  while  in  possession  of  material
     nonpublic  information;  or

     b)  trading  by  a  non-insider,  while in possession of material nonpublic
information,  where  the  information either was disclosed to the non-insider in
violation  of  an insider's duty to keep it confidential or was misappropriated;
or

     c)  communicating  material  nonpublic  information  to  others.

          i.  Who  is  an  Insider?

          The  concept  of "insider" is broad.  It includes officers, directors,
trustees  and employees of a company.  In addition, a person can be a "temporary
insider"  if  he  or  she enters into a special confidential relationship in the
conduct  of  a  company's affairs and as a result is given access to information
solely  for  the  company's  purposes.  A  temporary  insider can include, among
others,  a company's attorneys, accountants, consultants, bank lending officers,
and  the  employees  of  such  organizations.  In addition, Calvert may become a
temporary  insider  of  a  company  it  advises  or  for which it performs other
services.  According  to the Supreme Court, the company must expect the outsider
to  keep  the  disclosed nonpublic information confidential and the relationship
must  at  least  imply  such  a  duty  before the outsider will be considered an
insider.

          ii.  What  is  Material  Information?

          Trading  on inside information is not a basis for liability unless the
information  is  material.  "Material  Information"  generally  is  defined  as
information  for  which  there  is  a  substantial  likelihood that a reasonable
investor  would consider it important in making his or her investment decisions,
or  information  that  is reasonably certain to have a substantial effect on the
price  of  a  company's  securities.  Information  that  officers, directors and
employees  should  consider  material includes, but is not limited to:  dividend
changes,  earnings estimates, changes in previously released earnings estimates,
significant  merger  or  acquisition  proposals or agreements, major litigation,
liquidation  problems,  and  extraordinary  management  developments.

Material  information  also may relate to the market for a company's securities.
Information  about  a  significant  order to purchase or sell securities may, in
some  contexts,  be  deemed  material.  Similarly,  prepublication  information
regarding  reports  in  the  financial  press  also  may be deemed material. For
example,  the  Supreme  Court upheld the criminal convictions of insider trading
defendants  who  capitalized on prepublication information about the Wall Street
Journal's  Heard  on  the  Street  column.

It  is  conceivable  that  similar advance reports of securities to be bought or
sold  by  a  large,  influential  institutional investor, such as a Fund, may be
deemed  material  to  an  investment  in  those  portfolio  securities.  Advance
knowledge  of  important proposed government regulation, for example, could also
be  deemed  material  information regarding companies in the regulated industry.

          iii.  What  is  Nonpublic  Information?

Information  is nonpublic until it has been disseminated broadly to investors in
the market place. Tangible evidence of such dissemination is the best indication
that the information is public.  For example, information is public after it has
become  available  to the general public through a public filing with the SEC or
some  other governmental agency, the Dow Jones "tape" or the Wall Street Journal
or  some other publication of general circulation, and after sufficient time has
passed  so  that  the  information  has  been  disseminated  widely

          iv.  Penalties  for  Insider  Trading

          Penalties  for  trading  on  or  communicating  material  nonpublic
information  are  severe, both for individuals involved in such unlawful conduct
and  their  employers.  A  person can be subject to some or all of the penalties
below  even  if  he  or  she  does  not  personally  benefit from the violation.
Penalties  include:

- -     civil  injunctions
- -     treble  damages
- -     disgorgement  of  profits
- -     jail  sentences
- -     fines  for the person who committed the violation of up to three times the
profit gained or loss avoided, whether or not the person actually benefited, and
- -     fines for the employer or other controlling person of up to the greater of
$1,000,000  or  three  times  the  amount  of the profit gained or loss avoided.

          In addition, any violation of this policy statement can be expected to
result  in  serious  sanctions  by Calvert, up to and including dismissal of the
persons  involved.





3.     Identifying  Inside  Information

          Before  a  Calvert  employee  executes any trade for him/herself or on
behalf  of  others,  including  investment  companies managed by Calvert, in the
securities  of  a  company  about  which  the employee may have potential inside
information,  the  following  questions  should  be  considered:

     a)     Is  the  information material?  Is this information that an investor
would  consider  important  in  making his or her investment decisions?  Is this
information  that  would substantially affect the market price of the securities
if  generally  disclosed?

     b)     Is the information nonpublic?  How was the information obtained?  To
whom  has this information been provided?  Has the information been disseminated
broadly  to investors in the marketplace by being published in Reuters, The Wall
Street Journal or other publications of general circulation?  Is it on file with
the  Securities  and  Exchange  Commission?

     If,  after  consideration of the above, it is found that the information is
material  and nonpublic, or if there are questions as to whether the information
is  material  and  nonpublic,  the  following  steps  should  be  taken:

     a)     Report  the  matter  immediately  to  the  Compliance  Officer or an
attorney  in  the  Legal  Department.

     b)     The  securities  should  not  be  purchased  or sold by the officer,
director,  trustee or employee for him/herself or on behalf of others, including
investment  companies  managed  by  Calvert.

     c)     The  information  should  not  be  communicated  inside  or  outside
Calvert,  other  than  to  the  Legal  Department.

     d)     After  the  issue  has  been  reviewed,  the  Legal  Department will
instruct  the  officer,  director,  or  employee  as  to whether to continue the
prohibitions  against  trading  and  communication,  or  allowing  the trade and
communication  of  the  information.


4.     Contacts  with  Public  Companies.

     For  Calvert, contacts with public companies represent an important part of
our  research efforts. Calvert may make investment decisions on the basis of the
firm's  conclusions  formed  through  such  contacts  and  analysis  of
publicly-available  information. Difficult legal issues arise, however, when, in
the course of these contacts, a Calvert employee or other person subject to this
Policy  Statement  becomes  aware of material, nonpublic information. This could
happen,  for  example,  if  a  company's  chief  financial  officer  prematurely
discloses quarterly results to an analyst or an investor relation representative
makes  a selective disclosure of adverse news to a handful of investors. In such
situation,  Calvert  must  make  a  judgment  as to its further conduct. For the
protection  of  the  company  and  its employees, the Legal Department should be
contacted  if  an employee believes that he/she has received material, nonpublic
information.


5.     Tender  Offers

     Tender  offers represent a particular concern in the law of insider trading
for  two  reasons.  First,  tender  offer  activity often produces extraordinary
gyrations  in  the price of the target company's securities. Trading during this
time  period  is  more  likely  to  attract regulatory attention (and produces a
disproportionate  percentage  of  insider  trading  cases).  Second, the SEC has
adopted a rule which expressly forbids trading and "tipping" while in possession
of  material,  nonpublic  information regarding a tender offer received from the
tender offeror, the target company or anyone acting on behalf of either. Calvert
employees and others subject to this Policy Statement should exercise particular
caution any time they become aware of nonpublic information relating to a tender
offer.


6.     Education

     Another  aspect  of Calvert's compliance procedures will be to keep Calvert
personnel  and  other access persons informed. This memorandum serves as a basic
primer  on  what  constitutes  inside information and periodic memoranda will be
distributed,  particularly  when a significant case dealing with the subject has
been  decided.


     All  new  employees  will  be  given  a  copy of this statement and will be
required  to read it and agree to its conditions. All employees will be required
to  confirm their understanding and acknowledgment of the statement on an annual
basis.





                                                  Attachment  A



                               [GRAPHIC  OMITED]

     MEMO


To:     Legal  Department;  Compliance


From:


Re:     Prior  Approval  of  Access  Person  Trading  in  Securities


The  following  proposed security(ies) transaction(s) was (were) reviewed by the
Fund,  or  designated  employee  of  the  Advisor  (Chief  Investment Officer or
Director  of  Research)  pursuant  to  Calvert  Group's  Code  of  Ethics:

Name  of  Advisory  Person:




Security  (ies)  to  be  Purchased  or  Sold:







Basis  of  Approval  or  Denial:








Fund  or  Advisor  Designee  Signature






Signature  Page






            CODE OF ETHICS AND INSIDER TRADING POLICY AND PROCEDURES
                              ACKNOWLEDGEMENT FORM


I  have  read  and understand Calvert Group's Code of Ethics and Insider Trading
Policy  and  Procedures  and  will  comply in all respects with such procedures.









     Signature                                   Date




     Print  Name




                                  ATTACHMENT B

   ACCESS PERSONS SUBJECT TO PRECLEARANCE FOR SECURITIES TRANSACTIONS INCLUDING
                               PRIVATE PLACEMENTS


Michael  Abramo
Fatima  Batalvi
Susan  Bender
Ying-Wei  Chen
Tom  Dailey
Ivy  Duke
Patrick  Faul
Victor  Frye
David  Gibson
Ceasar  Gonzales
Donna  Gomez
Greg  Habeeb
Dan  Hayes
Hui  Ping  Ho
Mohammed  Javaid
Anu  Khondokar
Tracy  Knight
Barbara  Krumsiek
Emmett  Long
Reno  Martini
Gary  Miller
John  Nichols
Matt  Nottingham
Kendra  Plemmons
Carmen  Reid
Chris  Santos
Bill  Tartikoff
Laurie  Webster
Ron  Wolfsheimer
Mike  Yuhas

      INVESTMENT PERSONNEL SUBJECT SOLEY TO PRIVATE PLACEMENT PRECLEARANCE

Members  of  the  Special  Equities Committee of the Board of Directors/Trustees













The  term  "entity" will be used for any organization adopting these procedures.
For  those  organizations  which  are  investment companies as defined under the
Investment  Company Act of 1940, the term "Fund" may also be used if applicable.
Access  person means any director/trustee, officer, general partner, or employee
of  any  entity  adopting  these procedures who participates in the selection of
securities  (other  than  high  social  impact  securities  or  special  equity
securities)  or  who  has access to information regarding impending purchases or
sales  [See  rule  17  j-1(e)].  The  General  Counsel or Compliance Officer may
designate  any  person, including an independent contractor or consultant, as an
access person, who, as such, shall provide signed acknowledgement of the receipt
of  these  procedures  and their applicability. A current list of access persons
and  investment personnel subject to preclearance or other requirements shall be
maintained  by  the  Compliance  Officer.
For this purpose, "securities" include options on securities and securities that
are  convertible into or exchangeable for securities held or to be acquired by a
fund.  A  security  is  being  considered for purchase once a recommendation has
been  documented,  communicated and under serious evaluation by the purchaser or
seller.  Evidence  of  consideration  may  include  such  things  as  approved
recommendations  in  current  research reports, pending or active order tickets,
and  a  watch  list  of  securities  under  current  evaluation.
Disinterested Directors and/or Trustees as defined by the Investment Company Act
of  1940, are excluded from the duplicate statement and confirmation requirement
unless  the  General  Counsel or Compliance Officer imposes a different standard
due  to  an entity's active trading strategy and/or the information available to
the  Disinterested  Directors  and/or  Trustees.

All account information is subject to regulatory review. The trade confirmations
of  persons  other  than disinterested directors or trustees may be disclosed to
other  senior  officers  of the Fund or to legal counsel as deemed necessary for
compliance  purposes  and  to  otherwise  administer  the  Code  of  Ethics.