EX-99.CODE ETH

The "Code"

The Code of Ethics applies to the principal executive, financial and accounting
officers of The Phoenix Companies, Inc. ("PNX"). It constitutes the main part of
the Phoenix Code of Conduct, which has applied to all employees of PNX and its
subsidiaries for many years. We plan to continue to revise both codes from time
to time as needed to keep them viable, relevant and in compliance with all
applicable legislative and regulatory requirements.

Commitment to Shareholders

Phoenix is committed to providing shareholder value. One way we do this is by
observing the highest standards of legal and ethical conduct in all of our
business dealings.

Conflicts of Interest

Phoenix expects every employee, officer and director to maintain the highest
moral and ethical standards and to avoid conflicts of interest in conducting
business activities. A "conflict of interest" occurs when an individual's
private interest interferes, or even appears to interfere, in any way with the
interests of the corporation as a whole. A conflict situation can arise when an
employee, officer or director takes actions or has interests that may make it
difficult to perform his or her work for the Company objectively and
effectively. Conflicts of interest also arise when an employee, officer or
director, or a member of his or her family, receives improper personal benefits
as a result of his or her position in the Company.

Employees requested to serve on the Board of Directors of another company by
Phoenix owe a fiduciary duty to Phoenix as well as to the company on whose Board
of Directors he or she serves. Where conflicts of interest arise between the
interests of Phoenix and the other company, the employee should consult
Phoenix's General Counsel for guidance. Moreover, no employee requested to serve
on the Board of Directors of another company shall accept fees or other
compensation for Board service. In the event the company for which an employee
serves as a director requires directors to receive fees, any remuneration
received by the employee shall be donated to a charitable organization. The
Company will offset any tax consequences incurred by the employee.



All conflicts of interest must be disclosed in writing to the Chief Compliance
Officer. Employees, officers and directors are required to file a Conflict of
Interest Statement annually. Any conflicts of interest that arise following
completion of the Conflict of Interest Statement must be promptly reported to
the Chief Compliance Officer in writing.

Corporate Opportunities

Employees, officers and directors owe a duty to the Company to advance its
legitimate interests when the opportunity to do so arises. Consequently,
employees, officers and directors are prohibited from engaging in the following
activities:

..    Taking for themselves personal opportunities that are discovered through
     the use of corporate property, information or position;

..    Using Company property, information or position for personal gain; and

..    Competing with the Company.

Insider Trading and Personal Trading

Federal securities laws and Company policy prohibit the purchase or sale of
securities while in possession of material non-public information and prohibit
passing such information on to others. No employee, officer or director may buy
or sell Phoenix securities if he or she has material non-public information.
This restriction also applies to an employee's spouse, other adults living in
the employee's household, and minor children. Employees and their family members
also must avoid passing non-public information on to third parties.



Information is "material" if a reasonable investor would probably consider the
information important in deciding whether to buy, hold or sell securities of the
company to which the information relates.

Officers are subject to certain restrictions under New York Insurance Law
governing ownership of Phoenix stock. Officers and their family members are
prohibited from purchasing shares of Phoenix stock for a period of two years
from the date of demutualization.

All employees with a title of Vice President or higher, plus certain other
employees whose positions place them in regular contact with non-public
information, are subject to a further restriction as well. These employees may
only buy or sell Phoenix securities during "window" periods.

No employee, officer or director may buy or sell securities of another company
with the knowledge that those securities are being considered for purchase or
sale by Phoenix, any of its subsidiaries or any advisory accounts. In the case
of any company in which Phoenix owns 10 percent or more of the outstanding
equity, no employee (or family member) may make any personal investment without
prior approval from the Law Department.

Certain employees who are involved with the Company's investment adviser and
broker-dealer operations may be required to secure preclearance of and/or report
all personal securities transactions. In addition, Phoenix reserves the right to
require duplicate confirmations, quarterly transaction reports and prior
clearance for any personal securities transactions. If you have any question
whether your position requires preclearance or reporting, you should contact the
compliance officer for your business area (investment adviser or broker-dealer)
or the Corporate Compliance Department.

Confidentiality

Employees are required to maintain the confidentiality of information entrusted
to them by the Company or its customers. Disclosure of confidential information
is restricted to authorized persons or in situations in which disclosure is
legally mandated. Confidential information includes all non-public information
that may or may not be of use to competitors, or harmful to



the Company or its customers if disclosed, including, but not limited to:
internal operating procedures; investment strategies; sales data and customer
lists; financial plans; projections; and reports. An employee's obligation to
protect confidential information continues even after termination of his or her
employment.

Protection and Use of Company Property and Assets

Employees are given access to Company property to assist them in effectively
carrying out their duties to the Company. Company property should only be used
for legitimate purposes. All employees should protect the Company's property and
ensure its efficient use. Theft, fraud, carelessness and waste have a direct
impact on the Company's profitability.

Examples of Company property include proprietary and non-public information,
equipment, facilities, vehicles, funds and other assets. Improper use or abuse
of Company property is prohibited. Expenses to be paid for by the Company, via
reimbursement or direct payment, are limited to those expenses that are
authorized and related to legitimate business activities.

Corporate Disclosures

As a public company, Phoenix is required to publicly disclose certain
information on a regular basis. This includes financial information and other
material information about The Phoenix Companies, Inc. It is imperative that
such information is disseminated in a consistent manner and in accordance with
SEC disclosure requirements and Company policy. In order to ensure that
information released is accurate and properly disseminated, only certain
individuals are authorized to speak on behalf of the Company. Employees are
prohibited from speaking with rating agencies, analysts, investors or the press
without obtaining prior authorization from the President and Chief Executive
Officer. Employees receiving any such inquiries should refer such individuals to
the appropriate area for response:

..    Press and News Media - All inquiries must be referred to the Senior Vice
     President, Corporate Communications.



..    Rating Agencies - All inquiries must be referred to the Chief Financial
     Officer.

..    Securities Analysts and Investors - All inquiries must be referred to the
     Vice President, Investor Relations or the Chief Financial Officer.

Employees are prohibited from disclosing any non-public information about the
Company's financial performance or commenting on the Company's stock
performance.

Accuracy and Retention of Company Records

The integrity of Phoenix's records is vital to the Company's continued success.
The altering, falsification or misuse of Company documents is strictly
prohibited.

Phoenix's business transactions must be accurately recorded on the Company's
books and records in accordance with generally accepted accounting principles,
any other required accounting basis and established Company policy. Financial
information must fairly represent all relevant information.

The retention and destruction of Company records shall be in accordance with
established Company policies and applicable legal and regulatory requirements.

Commitment to Clients

Phoenix upholds its commitment to our clients by conducting our business fairly
and honestly, and maintaining the highest ethical standards in all dealings with
customers.

Safeguarding Customer Assets



Employees have an obligation to safeguard the assets of our customers at all
times, and to protect them from all forms of misuse. Misappropriation of funds
can include theft, fraud, embezzlement or unauthorized borrowing. Employees must
not, under any circumstances, misappropriate funds, property or other assets, or
assist another individual in doing so.

Ethical Market Conduct

The Company expects all who are involved in the sales and marketing of its
products and services to abide by the following principles:

..    Conduct business according to high standards of honesty and fairness;

..    Provide competent and customer-focused sales and service;

..    Engage in active and fair competition;

..    Provide clear, honest and fair advertising and sales materials;

..    Handle customer complaints and disputes in an appropriate and timely
     manner; and

..    Monitor sales and service procedures to help ensure compliance with ethical
     market conduct.

Privacy and Confidential Personal Information



It is the responsibility of every employee to maintain the privacy of
confidential personal information. Confidential personal information includes
non-public financial and health information obtained from consumers and
customers in connection with providing a financial product or service. Specific
examples of confidential personal information include information concerning
assets, income, businesses, estates, financial plans and health.