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[logo] PIONEER
Investments(R)
PIONEER FUNDS
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CODE OF ETHICS FOR SENIOR OFFICERS
Code of Ethics for Senior Officers
06/27/2003
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[logo] PIONEER
Investments(R)
PIONEER FUNDS
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TABLE OF CONTENTS
OVERVIEW.......................................................................2
PURPOSES OF THE CODE...........................................................2
RESPONSIBILITIES OF SENIOR OFFICERS............................................2
CONFLICTS OF INTEREST.....................................................2
CORPORATE OPPORTUNITIES...................................................3
CONFIDENTIALITY...........................................................3
FAIR DEALING WITH FUND SHAREHOLDERS, SUPPLIERS, AND COMPETITORS...........4
COMPLIANCE WITH LAW.......................................................4
DISCLOSURE................................................................4
ANNUAL CERTIFICATION...........................................................4
ENFORCEMENT OF THE CODE........................................................4
REPORTS OF VIOLATIONS.....................................................4
INVESTIGATION OF VIOLATIONS...............................................5
SANCTIONS FOR VIOLATIONS..................................................5
WAIVERS FROM THE CODE.....................................................5
OTHER POLICIES AND PROCEDURES..................................................5
SCOPE OF RESPONSIBILITIES......................................................6
AMENDMENTS.....................................................................6
CONFIDENTIALITY................................................................6
INTERNAL USE...................................................................6
EXHIBIT A - SENIOR OFFICERS OF THE PIONEER FUNDS...............................7
OVERVIEW
This Code of Ethics for Senior Officers (this "Code") sets forth the
policies, practices and values expected to be exhibited by Senior Officers
of the Pioneer Funds (collectively, the "Funds" and each, a "Fund"). This
Code does not apply generally to officers and employees of service
providers to the Funds, including Pioneer Investment Management, Inc.
("Pioneer"), unless such officers and employees are also Senior Officers.
The term "Senior Officers" shall mean the principal executive officer,
principal financial officer, principal accounting officer and controller of
the Funds, each of whom are set forth in Exhibit A to this Code..
The Director of Compliance of Pioneer is primarily responsible for
implementing and enforcing this Code, subject to the overall supervision of
the Board of Trustees of the Funds (the "Board"). The Director of
Compliance has the authority to interpret this Code and its applicability
to particular situations. Any questions about this Code should be directed
to the Director of Compliance.
PURPOSES OF THE CODE
The purposes of this Code are to:
o Promote honest and ethical conduct, including the ethical handling of
actual or apparent conflicts of interest between personal and
professional relationships;
o Promote full, fair, accurate, timely and understandable disclosure in
reports and documents that the Fund files with, or submits to, the SEC
and in other public communications made by the Fund;
o Promote compliance with applicable laws and governmental rules and
regulations;
o Promote the prompt internal reporting of violations of the Code to
an appropriate person or persons identified in the Code; and
o Establish accountability for adherence to the Code.
Each Senior 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.
RESPONSIBILITIES OF SENIOR OFFICERS
CONFLICTS OF INTEREST
A "conflict of interest" occurs when a Senior Officer's private interests
interfere in any way - or even appear to interfere - with the interests of,
or his/her service to, a Fund. A conflict can arise when a Senior Officer
takes actions or has interests that may make it difficult to perform his or
her Fund work objectively and effectively. Conflicts of interest also arise
when a Senior Officer, or a member of his/her family, receives improper
personal benefits as a result of his/her position with the Fund.
Certain conflicts of interest arise out of the relationships between Senior
Officers and the Fund and already are subject to conflict of interest
provisions in the Investment Company Act of 1940, as amended (the "ICA"),
and the Investment Advisers Act of 1940, as amended (the "IAA"). For
example, Senior 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 Pioneer'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 such policies 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 Fund and Pioneer of which the Senior Officers are
also officers or employees. As a result, this Code recognizes that Senior
Officers will, in the normal course of their duties (whether formally for
the Fund 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 Fund. The participation of Senior Officers in such
activities is inherent in the contractual relationship between the Fund and
Pioneer and is consistent with the performance by the Senior Officers of
their duties as officers of the Fund and, if addressed in conformity with
the provisions of the ICA and the IAA, will be deemed to have been handled
ethically. In addition, it is recognized by the Board that Senior 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 of the ICA or the IAA. In reading
the following examples of conflicts of interest under the Code, Senior
Officers should keep in mind that such a list cannot ever be exhaustive or
cover every possible scenario. It follows that the overarching principle is
that the personal interest of a Senior Officer should not be placed
improperly before the interest of a Fund.
Each Senior Officer must:
o Not use his or her personal influence or personal relationships
improperly to influence investment decisions or financial
reporting by a Fund whereby the Senior Officer would benefit
personally to the detriment of the Fund;
o Not cause a Fund to take action, or fail to take action, for the
individual personal benefit of the Senior Officer rather than the
benefit of the Fund; and
o Report at least annually any affiliations or other relationships
that give rise to conflicts of interest.
There are some conflict of interest situations that should always be
approved by the Director of Compliance, his/her designee or the Board, if
material. Examples of these include:1
o Service as a director on the board of any public or private
company;
o The receipt of any gift with a value in excess of an amount
established from time to time by Pioneer's Director of Compliance
from any single non-relative person or entity (customary business
lunches, dinners and entertainment at which both the Senior
Officer and the giver are present, and promotional items of
insignificant value are exempt from this prohibition);
o The receipt of any entertainment from any company with which a
Fund 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;
o Any ownership interest in, or any consulting or employment
relationship with, any of a Fund's service providers, other than
its investment adviser, principal underwriter, administrator or
any affiliated person thereof; and
o A direct or indirect financial interest in commissions,
transaction charges or spreads paid by a Fund for effecting
portfolio transactions or for selling or redeeming shares other
than an interest arising from the Senior Officer's employment,
such as compensation or equity ownership.
CORPORATE OPPORTUNITIES
Senior Officers may not (a) take for themselves personally opportunities
that are discovered through the use of corporate property, information or
position; (b) use corporate property, information, or position for personal
gain; or (c) compete with the Funds. Senior Officers owe a duty to the
Funds to advance their legitimate interests when the opportunity to do so
arises.
CONFIDENTIALITY
Senior Officers should maintain the confidentiality of information
entrusted to them by the Funds, except when disclosure is authorized or
legally mandated. Confidential information includes all non-public
information that might be of use to competitors, or harmful to the Funds,
if disclosed.
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1 Any activity or relationship that would present a conflict for a Senior
Officer would likely also present a conflict for the Senior Officer if a member
of the Senior Officer's family engages in such an activity or has such a
relationship.
FAIR DEALING WITH FUND SHAREHOLDERS, SUPPLIERS, AND COMPETITORS
Senior Officers should endeavor to deal fairly with the Funds'
shareholders, suppliers, and competitors. Senior Officers should not take
unfair advantage of anyone through manipulation, concealment, abuse of
privileged information, misrepresentation of material facts, or any other
unfair-dealing practice. Senior Officers should not knowingly misrepresent,
or cause others to misrepresent, facts about a Fund to others, whether
within or outside the Fund, including to the Board, the Funds' auditors or
to governmental regulators and self-regulatory organizations.
COMPLIANCE WITH LAW
Each Senior Officer must not knowingly violate any law, rule and regulation
applicable to his/her activities as an officer of the Funds. In addition,
Senior Officers are responsible for understanding, and promoting compliance
with, the laws, rules and regulations applicable to his/her particular
position and by persons under the Senior Officer's supervision. Senior
Officers should endeavor not only to comply with the letter of the law, but
also with the spirit of the law.
DISCLOSURE
Each Senior Officer should familiarize himself or herself with the
disclosure requirements generally applicable to the Funds. Each Senior
Officer should, to the extent appropriate within his area of
responsibility, consult with other officers of the Funds and Pioneer with
the goal of promoting full, fair, accurate, timely and understandable
disclosure in the reports and documents a Fund files with, or submits to,
the SEC and in other public communications made by the Funds.
ANNUAL CERTIFICATION
Each Senior Officer must, upon adoption of the Code, affirm in writing to
the Director of Compliance that he or she has received, read, and
understands the Code. Annually thereafter, each Senior Officer must affirm
that he or she has complied with the requirements of the Code.
ENFORCEMENT OF THE CODE
REPORTS OF VIOLATIONS
A Senior Officer must notify Pioneer's Director of Compliance promptly if
he or she knows of any violation of this Code by any Senior Officer.
Failure to do so is itself a violation of this Code.
INVESTIGATION OF VIOLATIONS
Upon notification of a violation, or suspected violation, Pioneer's
Director of Compliance will take all appropriate action to investigate any
potential violations reported to him/her. If, after such investigation,
Pioneer's Director of Compliance believes that no violation has occurred,
Pioneer's Director of Compliance is not required to take any further
action. The Director of Compliance shall not have an affirmative duty to
monitor the compliance with this Code by any Senior Officer or to design
procedures designed to identity any violations of this Code. Any matter
that Pioneer's Director of Compliance believes is a violation will be
reported to the Independent Trustees. If the Independent Trustees concur
that a violation has occurred, they will inform and make a recommendation
to the full Board of Trustees. The Board of Trustees shall be responsible
for determining appropriate action. The Funds will not retaliate against
any Senior Officer for reports of potential violations that are made in
good faith and without malicious intent.
Pioneer's Director of Compliance 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. While
Pioneer's Director of Compliance shall make inquiries regarding any
potential conflict of interest that is brought to the attention of the
Director of Compliance, he or she shall not be responsible for uncovering
or developing a compliance system designed to uncover actual or potential
conflicts of interest to which this Code may apply.
SANCTIONS FOR VIOLATIONS
Violations of this Code will be taken seriously and could result in
disciplinary action. In response to known violations of the Code, the Board
may impose such sanctions as it deems appropriate within the scope of its
authority over Senior Officers, including termination as an officer of the
Funds.
WAIVERS FROM THE CODE
The Independent Trustees will consider any approvals or waivers sought by
any Senior Officer.
The Independent Trustees will be responsible for granting waivers, as
appropriate. Any changes to or waivers of this Code will, to the extent
required, be disclosed as provided by SEC rules.
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 companies thereunder. The Funds',
Pioneer's, and Pioneer Funds Distributor, Inc.'s codes of conduct under
Rule 17j-1 under the ICA are separate requirements applying to the Senior
Officers and others, and are not a part of this Code.
SCOPE OF RESPONSIBILITIES
A Senior Officer's responsibilities under this Code are limited to Fund
matters over which the Senior Officer has direct responsibility or control,
matters in which the Senior Officer routinely participates, and matters
with which the Senior Officer is otherwise involved. In addition, Senior
Officers are responsible for matters of which the Senior Officer has actual
knowledge.
This Code is not intended to apply to any conduct between a Senior Officer
and a person which whom the Senior Officer has a long standing or bona fide
personal relationship, notwithstanding the fact such person may be
affiliated with an entity that has business relationships with the Funds.
If a Senior Officer is uncertain whether any relationship qualifies as a
long-standing or bona fide personal relationship, the Senior Officer should
consult with the Director of Compliance.
AMENDMENTS
This Code may not be amended except in written form, which is specifically
approved or ratified by a majority vote of the Fund's Board of Trustees,
including a majority of the Independent Trustees.
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 of Trustees and their
counsel or to the Fund's adviser's Legal and Compliance Department.
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.
EXHIBIT A - SENIOR OFFICERS OF THE PIONEER FUNDS
John F. Cogan, Jr.-- President (principal executive officer)
Vincent Nave-- Treasurer (principal financial officer)