Exhibit (a)(1)
CODE OF ETHICS FOR PRINCIPAL EXECUTIVE AND
SENIOR CIGNA FUNDS OFFICERS
I. Covered Officers/Purpose of the Code
CIGNA Funds' code of ethics (this "Code") for the investment
companies within the complex (collectively, "Funds" and each, "Fund")
applies to the Funds' Principal Executive Officer, Principal Financial
Officer and Principal Legal Officer (the "Covered Officers", each of whom
are set forth in Exhibit A) for the purpose of promoting:
o honest and ethical conduct, including the ethical handling of
actual or apparent conflicts of interest between personal and
professional relationships;
o full, fair, accurate, timely and understandable disclosure in
reports and documents that a Fund files with, or submits to, the
Securities and Exchange Commission ("SEC") and in other public
communications made by the Fund;
o compliance with applicable laws and governmental rules and
regulations;
o the prompt internal reporting of violations of the Code to an
appropriate person or persons identified in the Code; and
o 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") 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 Fund because of their status as "affiliated persons" of the Fund.
The Fund's and the investment adviser's compliance programs
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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. The Covered
Officers are officers or employees of an affiliate of the investment
adviser. As a result, this Code 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.
Other conflicts of interest are covered by this 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 Fund.
Each Covered Officer must:
o not use his personal influence or personal relationships
improperly to influence investment decisions or financial
reporting by the Company whereby the Covered Officer would
benefit personally to the detriment of the Company;
o 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 Company;
o not use material non-public knowledge of portfolio transactions
made or contemplated for the Company to trade personally or cause
others to trade personally in contemplation of the market effect
of such transactions;
o report at least annually on affiliations or other relationships
related to conflicts of interest that the Fund's Trustees and
Officers Questionnaire covers.
There are some conflict of interest situations that should always be
approved by the Chief Counsel to the investment adviser to the Funds if
material. Examples of these include:
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o any .ownership interest in, or any consulting or employment
relationship with, any of the Company's service providers, other
than its investment adviser, principal underwriter, administrator
or any affiliated person thereof;
o a direct or indirect financial interest in commissions,
transaction charges or spreads paid by the Company 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.
There are some conflicts of interest (e.g. receipt of gifts and
entertainment by Covered Officers, and service by Covered Officers as a
director of a company) that are covered by the code of ethics of CIGNA
Corporation, the adviser's parent. Each Covered Officer is subject to the
CIGNA Corporation code of ethics.
III. Disclosure and Compliance
o Each Covered Officer should familiarize himself with the
disclosure requirements generally applicable to the Funds;
o each Covered Officer should not knowingly misrepresent, or cause
others to misrepresent, facts about the Fund to others, whether
within or outside the Fund, including to the Fund trustees and
auditors, and to governmental regulators and self-regulatory
organizations;
o 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 submit to, the SEC
and in other public communications made by the Funds; and
o 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:
o 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;
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o annually thereafter affirm to the Board that he has complied with
the requirements of the Code;
o 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
o notify Chief Counsel of the investment adviser to the Funds
promptly if he knows any violation of this Code. Failure to do so
is itself a violation of this Code.
The Chief Counsel of the investment adviser or other designated senior
legal officer of the Fund's investment adviser 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 a Covered Officer will be
considered by the Audit Committee (the "Committee").
The Funds will follow these procedures in investigating and enforcing
this Code:
o the Chief Counsel or other designated senior legal officer will
take all appropriate action to investigate any potential
violations reported to him;
o if, after such investigation, the Chief Counsel believes that no
violation has occurred, the Chief Counsel is not required to take
any further action;
o any matter that could reasonably be deemed to be a violation will
be reported to the Committee;
o if the 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 investment adviser
or its board; or a recommendation to dismiss the Covered Officer;
o The Committee will be responsible for granting waivers, as
appropriate; and
o 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
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registered investment companies thereunder. Insofar as other policies or
procedures of CIGNA Corporation, 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 codes of ethics under Rule 17j-1 under the Investment Company Act
contain 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, including a
majority of independent directors.
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 and its counsel. The
foregoing shall not limit the ability of the Board of Trustees of the Funds
or the Committee to respond to matters arising under this Code as they
shall deem appropriate.
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 of any Fund, as to any fact,
circumstance, or legal conclusion.
Date: December 10, 2003
Exhibit (a)(1)
Exhibit A
Persons covered by this Code of Ethics:
Richard H. Forde - Chairman of the Board and President
Alfred A. Bingham III - Vice President and Treasurer
Jeffrey S. Winer - Vice President and Secretary