Exhibit 99.a1
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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Exhibit 99.a1
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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Exhibit 99.a1
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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Exhibit 99.a1
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 99.a1
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