JOHN HANCOCK VARIABLE SERIES TRUST I
                  CODE OF ETHICS FOR SENIOR FINANCIAL OFFICERS

General Principles

The Trustees of the John Hancock Variable Series Trust I (the "Trust") have
adopted this code of ethics (this "Code") setting forth standard of ethics for
the Chief Executive Officer, Chief Financial Officer and Treasurer ("Senior
Financial Officers") of the Trust. All Senior Financial Officers are charged
with the duty to maintain the standards set forth below.

No Code can address every situation that a Senior Financial Officer may face. As
a guiding principle, Senior Financial Officers should strive to implement the
spirit as well as the letter of applicable laws, rules and regulations, and to
provide the type of clear and complete disclosure and information that Trust
shareholders have a right to expect.

     Honest and Ethical Conduct

          Each Senior Financial Officer owes a duty to the Trust to act with
     integrity and honesty in the conduct of his or her duties and
     responsibilities. Each Senior Financial Officer shall comply with all
     applicable governmental laws, rules and regulations, and accounting
     standards, while adhering to a high standard of business ethics.

     Avoidance of Conflicts of Interest

          Senior Financial Officers shall ethically handle any actual or
     apparent conflict of interest, direct or indirect, between personal and
     professional relationships. A Senior Financial Officer should not engage in
     personal, business or professional relationships or dealings which would
     impair his or her independence of judgment or adversely affect the
     performance of his or her duties in the best interests of the Trust and its
     shareholders. Any relationship or dealing that would present a conflict for
     a Senior Financial Officer could also present a conflict if it is related
     to a member of his or her immediate family.

     Disclosure

          Senior Financial Officers have a supervisory role with respect to the
     financial information included in reports filed with regulatory agencies
     and public disclosures by the Trust, and therefore have particular
     responsibilities in connection with those communications.

          . Each Senior Financial Officer shall familiarize himself or herself
          with the disclosure requirements applicable to the Trust, as well as
          the business and financial operations of the Trust.

          . Each Senior Financial Officer shall ensure that reasonable steps are
          taken within his or her areas of



          responsibility to promote full, fair, accurate, timely and
          understandable disclosure in all regulatory filings, as well as when
          communicating with the Trust's shareholders or the general public, in
          accordance with applicable law.

          . No Senior Financial Officer shall violate his or her responsibility
          to the Trust by knowingly and willfully misrepresenting, or causing
          others to misrepresent, facts about the Trust to others, including the
          Trust's independent auditors, governmental regulators or
          self-regulatory organizations.

     Compliance with Applicable Law

          It is the Trust's policy to comply with all applicable laws and
     governmental rules and regulations. It is the personal responsibility of
     each Senior Financial Officer to take reasonable steps to adhere to the
     standards and restrictions imposed by those laws, rules and regulations,
     including those relating to accounting and auditing matters.

Compliance Procedures

All Senior Financial Officers are responsible for ensuring that their own
conduct complies with this Code. If a Senior Financial Officer is aware of any
material transaction or relationship that could reasonably be expected to give
rise to a conflict of interest or which might be viewed as potentially affecting
his or her performance of Trust responsibilities, the Senior Financial Officer
shall notify the Trust's Chief Legal Officer of this transaction or
relationship. In addition, any Senior Financial Officer who becomes aware of any
existing or potential violation of this Code shall notify the Chief Legal
Officer promptly, who shall conduct an appropriate investigation. The Chief
Legal Officer shall report any violation of this Code to the Audit Committee of
the Trust.

Anyone who violates the provisions of this Code, fails to report a known
violation or refuses to cooperate in the investigation of any potential
violation will be subject to disciplinary action, up to and including
termination of service with the Trust. Subject to applicable law, the Audit
Committee may waive provisions of this Code.

Other Policies and Procedures

This Code does not supplant or supersede any other Trust policy or procedure
relating to conflicts of interest or business practices. Those policies and
procedures are separate requirements applying to those working on Trust matters
generally, including Senior Financial Officers among others, and are not part of
this Code.

December 10, 2003