CODE OF ETHICS FOR PRINCIPAL EXECUTIVE AND SENIOR
            FINANCIAL OFFICERS OF THE GUARDIAN-SPONSORED MUTUAL FUNDS


                            Adopted November 13, 2003


I. Covered Officers/Purpose of the Code

This code of ethics ("Code") for the Guardian-Sponsored Mutual Funds (each, a
"Fund," and collectively, the "Funds") applies to the Funds' Principal Executive
Officer, Principal Financial Officer and Controller (each, a "Covered Officer")
set forth on Exhibit A. The purpose of the Code is to promote:


     .    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 apparent as well as
actual 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 or her service to, the Funds.
For example, a conflict of interest would arise if a Covered Officer, or a
member of his or her family, receives improper personal benefits as a result of
his or her 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 the securities laws,
including the Investment Company Act and the Investment Advisers Act. This Code
does not, and is not intended to, repeat or replace those programs and
procedures. Although typically not presenting an opportunity for improper
personal benefit, conflicts of interest usually 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 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 Directors/Trustees ("Board") that the Covered
Officers may also be officers or employees 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 some examples of conflicts
of interest under the Code. 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 or her 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;

     .    cause the Funds to take action, or fail to take action, for the
          individual personal benefit of the Covered Officer rather than the
          benefit the Funds; or

     .    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 conflict of interest situations that should be discussed with the
senior legal officer of the Funds (the "Chief Legal Officer"). Examples of these
include:

     .    service as a director on the board of any company;

     .    the receipt of any gifts in excess of $100;

     .    the receipt of any entertainment from any company with which the Funds
          have current or prospective business dealings unless such
          entertainment is business-related, or is reasonable in cost,
          appropriate as to time and place, and not so frequent as to raise any
          question of impropriety;

     .    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:

     .    be familiar with the disclosure requirements generally applicable to
          the Funds and, to the extent appropriate within his or her 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;

     .    not knowingly misrepresent, or cause others to misrepresent, facts
          about the Funds to others, whether within or outside the Funds,
          including to the Funds' directors and auditors, and to governmental
          regulators and self-regulatory organizations; and

     .    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 or she has
          received, read, and understands the Code and will comply with it;

     .    annually thereafter affirm to the Board that he or she has complied
          with the requirements of the Code;

     .    report at least annually to the Board any direct or indirect interest
          arising out of any transaction, contract, arrangement or understanding
          between the Covered Officer or any of his or her immediate family
          members and: a Fund, Guardian Investor Services LLC, Guardian Baillie
          Gifford Limited, UBS Global Asset Management - Americas, any of their
          officers or affiliates, or any person controlling, controlled by or
          under common control of any of the above entities, the value of which
          exceeds $60,000;

     .    notify the Chief Legal Officer promptly if he or she knows of any
          violation of this Code. Failure to do so is itself a violation of this
          Code; and

     .    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.

The Chief Legal Officer 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 a particular situation. However, any approvals or waivers
sought by a Covered Officer must be considered by the Nominating and Governance
Committee of the Board (the "Committee"), which will, in its discretion, make a
recommendation to the Board.

The Funds will follow these procedures in investigating and enforcing this Code:

     .    the Chief Legal Officer will take all appropriate actions to
          investigate any reported potential violations;

     .    if, after such investigation, the Chief Legal Officer believes that no
          violation has occurred, no further action is required to be taken;



     .    any matter that the Chief Legal Officer believes is a violation will
          be reported to the Committee;

     .    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;

     .    the Board 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 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, sub-advisers' and principal
underwriter's codes of ethics under Rule 17j-1 under the Investment Company Act,
and the more detailed policies and procedures of those codes, 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 the Chief Legal Officer, the Board and counsel to
the independent Directors/Trustees of the Funds.

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 Funds, as to any fact,
circumstance, or legal conclusion.



                                    EXHIBIT A



Thomas G. Sorell              Principal Executive Officer

Frank L. Pepe                 Principal Financial Officer

Nydia Morrison                Controller