<PAGE>
                                 CODE OF ETHICS
                                     OF THE
                                 PIONEER FUNDS,
                        PIONEER FUNDS DISTRIBUTOR, INC.,
                  PIONEER INSTITUTIONAL ASSET MANAGEMENT, INC.
                                      AND
                      PIONEER INVESTMENT MANAGEMENT, INC.

POLICY

     The Pioneer Funds, Pioneer Funds Distributor, Inc. ("PFD"), Pioneer
     Institutional Asset Management, Inc. ("PIAM") and Pioneer Investment
     Management, Inc. ("PIM") (collectively, "Pioneer"), have adopted this Code
     of Ethics ("Code") in compliance with Rule 17j-1 under the Investment
     Company Act of 1940, as amended (the "Investment Company Act of 1940"),
     Rule 204A-1 under the Investment Advisers Act of 1940, as amended
     ("Advisers Act"), or NASD Rule 3050, as applicable.

     This Code establishes standards of conduct expected of all Employees and
     addresses conflicts that may arise from Employees' personal trading and
     other activities. EVERY EMPLOYEE IS EXPECTED TO FULLY UNDERSTAND AND ADHERE
     TO THE POLICIES AND PROCEDURES SET FORTH IN THIS CODE. Pioneer Investments
     operates in a highly regulated industry and is governed by a complex body
     of federal, state and international laws, rules and regulations, which, if
     not observed, can subject Pioneer and/or its Employees to civil and/or
     criminal penalties.

     Although this Code is intended to provide each Employee with guidance as to
     whether certain actions or practices are permissible, it does not cover
     every issue an Employee may face. Pioneer maintains other policies and
     procedures, including a Code of Business Conduct that is applicable to an
     Employee's responsibilities and duties.

     Because no set of guidelines, policies and procedures can anticipate every
     possible situation, it is essential that each Employee follow this Code
     both in letter and in spirit. Technical compliance with the procedures,
     prohibitions and limitations of this Code will not insulate an Employee
     from scrutiny of or, if called for, sanctions for his or her securities
     transactions. Any activity that compromises Pioneer's integrity, even if it
     does not expressly violate guidelines, may result in scrutiny or action by
     the Code of Ethics Oversight Committee or the Compliance Department. You
     are encouraged to contact the Compliance Department with any questions you
     may have about this Code or about your legal and ethical responsibilities.
     Employees should contact the Compliance Department at
     US.Code.of.Ethics@pioneerinvestments.com or at extension 4600.

     PLEASE NOTE THAT STANDARD DEFINED TERMS CAN BE FOUND ON PAGES 3 THROUGH 8
     IN THE "DEFINITIONS" SECTION.

     ONLY CERTAIN PARTS OF THIS CODE APPLY TO THE INDEPENDENT TRUSTEES OF THE
     PIONEER FUNDS, SPECIFICALLY PART I AND PART VI.

LAST REVISED SEPTEMBER 2013


<PAGE>
     ALL PERSONS COVERED BY THIS CODE ARE EXPECTED TO READ THIS CODE CAREFULLY
     AND OBSERVE AND ADHERE TO IT AT ALL TIMES.

     All Employees have an obligation to notify his or her Chief Compliance
     Officer on a timely basis if there is a change to their duties,
     responsibilities or title, which affects their reporting status under this
     Code.

     Pioneer retains the discretion to determine the applicability and
     interpretation of the Code to specific situations.

STATEMENT OF GENERAL PRINCIPLES

     Each Employee must observe the following fiduciary principles with respect
     to his or her personal investment activities:

          .    At all times, each Employee must place the interests of Advisory
               Clients first;

          .    Personal securities transactions of Employees must be conducted
               in a manner designed to avoid actual or potential conflicts of
               interest with the interests of any Advisory Client or any abuse
               of the Employee's position of trust and responsibility; and

          .    Each Employee must avoid actions or activities that would allow
               him or her to inappropriately profit or benefit from his or her
               position at Pioneer, or that otherwise brings into question the
               Employee's independence or judgment.

STANDARDS OF CONDUCT

     All Employees are prohibited from using information concerning the
     investment intentions of Advisory Clients or confidential information
     regarding Advisory clients for personal gain or in a manner detrimental to
     the interests of any Advisory Client. Each Employee also should refer to
     the separate Code of Business Conduct that governs certain activities of
     Employees. In addition to this Code and the separate Code of Business
     Conduct, all Employees must comply with all federal, state and local laws,
     rules and regulations applicable to the business or operations of Pioneer,
     including, but not limited to, the federal securities laws./1/

---------------------------
1    For purposes of this Code, "federal securities laws" means the Securities
     Act of 1933, the Securities Exchange Act of 1934, the Sarbanes-Oxley Act of
     2002, the Investment Company Act of 1940 Act, the Advisers Act, Title V of
     the Gramm-Leach-Bliley Act (privacy), any rules adopted by the Commission
     under any of these statutes, the Bank Secrecy Act as it applies to funds
     and investment advisers, and any rules adopted thereunder by the Commission
     or the Department of the Treasury (anti-money laundering and Office of
     Foreign Assets Control ("OFAC").

LAST REVISED SEPTEMBER 2013                                              PAGE 2


<PAGE>
DEFINITIONS

As used herein:

<TABLE>
<CAPTION>
TERM                          DEFINITION
----                          ----------
<S>                           <C>
ADVISORY CLIENT               Means each Pioneer Fund and each other investment company or other client
                              for which Pioneer acts as an adviser or sub-adviser.

ACCESS PERSON                 Means any person included in the definition of "access person" under
                              Rule 17j-1(a) under the Investment Company Act of 1940 or Rule 204A-1 under
                              the Investment Advisers Act of 1940.

                              The definition of Access Persons includes:

                                (i)   each officer, director, trustee, general partner of a Pioneer Fund, PIM,
                                      PIAM or PFD, except that an Independent Trustee shall not be an Access
                                      Person under this Code solely by reason of being a trustee of a Pioneer Fund;

                                (ii)  any natural person in a control (as defined in the Investment Company  Act
                                      of 1940) relationship to Pioneer who obtains information concerning recommendations
                                      made to Advisory Clients with regard to the purchase or sale of securities by
                                      an Advisory Client; and

                                (iii) an Employee if:

                                      (A)  in connection with his or her regular functions or duties, the Employee makes,
                                           participates in or obtains information regarding the purchase or sale of a
                                           Reportable Security  by an Advisory Client, or whose functions relate to the
                                           making of any recommendations with respect to such purchases or sales.

                                      (B)  the Employee has access to timely (i.e., nonpublic) information relating to
                                           investment management activities, research and/or client portfolio holdings and
                                           those who in the course of their employment regularly receive access to trading
                                           activity of Advisory Clients; or

                                      (C)  the Employee has been notified in writing by the Compliance Department that the
                                           Employee has been designated as an Access Person by the Compliance Department by
                                           virtue of the nature of the Employee's duties and functions.

                              Examples of "access to information" include access to trading systems (such as CRD or PMA),
                              portfolio accounting systems (such as MFact), research databases or settlement information.
                              All Employees in the Fund Accounting, Investment Operations, Enterprise Technology Services,
                              Legal and Compliance and Risk groups are deemed to be Access Persons, unless the Compliance
                              Department specifically determines that any such Employee is not an Access Person.
</TABLE>

LAST REVISED SEPTEMBER 2013                                              PAGE 3


<PAGE>
DEFINITIONS

As used herein:

<TABLE>
<CAPTION>
TERM                          DEFINITION
----                          ----------
<S>                           <C>
AUTOMATIC INVESTMENT PLAN     Means a program in which regular periodic purchases (or withdrawals) are made automatically
                              in (or from) investment accounts in accordance with a predetermined schedule and allocation.
                              An automatic investment plan includes a dividend reinvestment plan.

BENEFICIAL INTEREST           Means any economic interest, such as the right to share in gains or losses, in a Reportable
                              Security. This would also include any interest by which a person subject to this Code or any
                              Family Member living in the same household as such person, can directly or indirectly derive
                              a monetary benefit from the purchase, sale or ownership of a Reportable Security.

                              The ultimate determination of whether you have Beneficial Interest depends on the facts of each
                              particular case.  If you have any questions, contact the Compliance Department for assistance
                              with determining if you have a Beneficial Interest in a Reportable Security.

CCO                           Means with respect to an Employee of PIM, PIAM or PFD, the Chief Compliance Officer of PIM, PIAM
                              or PFD, respectively.

                              CCO means the CCO of the Pioneer Funds when the context so requires.

CODE OF BUSINESS CONDUCT      Means the separate set of guidelines that defines the standards to which all Employees are
                              expected to adhere during the course of their employment with, and when conducting business
                              on behalf of, Pioneer.

CODE OF ETHICS OVERSIGHT
COMMITTEE                     Means the Code of Ethics Oversight Committee, which is comprised of senior management
                              representatives from Pioneer's Sales, Legal, Compliance, Investment Management and Research
                              Departments.  The Code of Ethics Oversight Committee has oversight responsibility for
                              administrating this Code.

EMPLOYEE                      Means any person included in the definition of "supervised person" as defined in Section 202(a)(25)
                              of the Advisers Act.

                              The definition of Employee includes each officer, director, trustee, partner (or other person
                              occupying a similar status or performing similar functions) or employee (including temporary
                              employees and independent contractors) of a Pioneer Fund, PIM, PIAM or PFD, and any other person
                              who provides investment advice on behalf of PIM or PIAM and is subject to the supervision and
                              control of PIM or PIAM, except that the definition of Employee does not include an Independent
                              Trustee of a Pioneer Fund.
</TABLE>

LAST REVISED SEPTEMBER 2013                                              PAGE 4


<PAGE>
DEFINITIONS

As used herein:

<TABLE>
<CAPTION>
TERM                          DEFINITION
----                          ----------
<S>                           <C>
FAMILY MEMBER                 Means grandparent, parent, mother-in-law or father-in-law; husband, wife or domestic partner
                              (whether registered or unregistered under applicable law); brother, sister, brother-in-law,
                              sister-in-law, son-in-law or daughter-in-law; children (including step and adoptive relationships);
                              and grandchildren.

INDEPENDENT TRUSTEE           Means any trustee or director of a Pioneer Fund who is not an "interested person" (as that term is
                              defined by Section 2(a)(19) of the Investment Company Act of 1940) of the Fund.

INITIAL PUBLIC OFFERING       Means any offering of securities registered under the Securities Act of 1933 the issuer of which
                              immediately before the offering was not subject to the reporting requirements of Section 13 or 15(d)
                              of the Securities Act of 1934.

INVESTMENT PERSON             Means an Access Person who is (1) a Portfolio Manager, (2) a securities analyst or trader who
                              provides information and advice to a Portfolio Manager or who helps execute a Portfolio Manager's
                              decisions, (3) any Employee who works directly with a Portfolio Manager or in the same department as
                              a Portfolio Manager, (4) any other person who, in connection with his or her regular functions or
                              duties, makes or participates in making recommendations regarding an Advisory Client's purchase or
                              sale of securities, or (5) any natural person in a control relationship to a Pioneer Fund or Pioneer
                              who obtains information concerning recommendations made to the Pioneer Fund with regard to the
                              purchase or sale of securities by the Pioneer Fund.

                              In addition to the above definitions, an Employee is an "Investment Person" if the Employee has been
                              notified in writing by the Compliance Department that the Employee has been designated as an
                              "Investment Person" by the Compliance Department by virtue of the nature of the Employee's duties
                              and functions.

MANAGED ACCOUNTS              Means Personal Accounts over which a person subject to this Code has no direct or indirect influence
                              or control, which includes an account managed on a discretionary basis by someone else.

                              All such accounts must be approved by the Compliance Department.  For the purpose of this section,
                              the person claiming to have no direct or indirect influence or control over such a Personal Account
                              must first provide a written explanation to the Compliance Department describing the circumstances
                              of the Personal Account and reasons why such person believes he or she does not have direct or
                              indirect influence or control (i.e., no investment discretion) over that Personal
</TABLE>

LAST REVISED SEPTEMBER 2013                                              PAGE 5


<PAGE>
DEFINITIONS

As used herein:

<TABLE>
<CAPTION>
TERM                          DEFINITION
----                          ----------
<S>                           <C>
                              Account and that he or she does not provide any investment advice or suggestions with respect to the
                              Personal Account. In addition, the Access Person may be required to arrange for his or her broker or
                              adviser to provide to the Compliance Department documentation to evidence such Personal Account
                              arrangement.

PERSONAL ACCOUNT              Means any account in which a Beneficial Interest is held by a person subject to this Code, or any
                              account in which a person subject to this Code has any direct or indirect Beneficial Interest,
                              including accounts of Family Members living in the same household.

PFD EMPLOYEES                 Means registered persons of PFD and employees of PFD who are not registered persons, including PFD
                              officers and directors.

PIONEER FUND                  Means any investment company registered under the Investment Company Act of 1940 for which PIM
                              serves as the investment adviser (but not as a sub-adviser) or for which PFD serves as the principal
                              underwriter.

PIONEER ACCOUNT               Means Pioneer's savings, retirement and deferred compensation accounts which include each of Pioneer
                              Savings and Investment Plan, Pioneer Retirement Benefit Plan, Pioneer Investment Management Bonus
                              Deferral Plan, Pioneer Deferred Compensation Plan for Certain Employees, Pioneer Performance and
                              Retention Incentive Compensation Award Plan and the Pioneer Intermediate Deferred Compensation Award
                              Plan.  The definition of Pioneer Account includes any other account held directly through Pioneer.

PORTFOLIO MANAGER             Means an individual who has direct responsibility and authority to make investment decisions
                              affecting an Advisory Client.

PRIVATE PLACEMENT             Means an offering that is exempt from registration pursuant to Section 4(2) or Section 4(6) or
                              pursuant to Rules 504, 505 or 506 under the Securities Act of 1933 and other similar non-U.S.
                              securities.  Private placements include, but are not limited to, private equity partnerships, hedge
                              funds, limited partnerships and venture capital funds.

REPORTABLE FUND               Means each Pioneer Fund plus each investment company registered under the Investment Company Act of
                              1940 sub-advised by PIM or for which PFD serves as the principal underwriter.

                              A list of Reportable Funds is available on Navigator US under Business Units - Legal & Compliance -
                              [Policies and Procedures].

Reportable Security           Means a security as defined by Section 2(a)(36) of the Investment Company Act of 1940, except for
                              the securities and instruments excepted below.  The term "Reportable Security" is very broad and
</TABLE>

LAST REVISED SEPTEMBER 2013                                              PAGE 6


<PAGE>
DEFINITIONS

As used herein:

<TABLE>
<CAPTION>
TERM                          DEFINITION
----                          ----------
<S>                           <C>
                              includes stocks, bonds, including convertible and preferred securities, ADRs and GDRs, warrants and
                              rights, such as:

                                      .  Limited partnership interests;

                                      .  Limited liability company interests;

                                      .  Interests in private investment funds, hedge funds and investment clubs;

                                      .  Futures on securities;

                                      .  Options on securities;

                                      .  Shares in closed-end funds;

                                      .  Shares of Reportable Funds;

                                      .  Shares of exchange-traded funds;

                                      .  Securities issued by agencies or instrumentalities of the U.S. government
                                         (e.g., GNMA obligations), municipal obligations; and

                                      .  Securities issued by foreign governments.

                              Reportable Securities do not include:

                                      .  Direct obligations of the government of the United States;

                                      .  Bankers' acceptances;

                                      .  Bank certificates of deposit;

                                      .  Commercial paper;

                                      .  Money market funds, including money market funds where PIM serves as the investment
                                         adviser or sub-adviser that comply with Rule 2a-7 under the Investment Company
                                         Act  of 1940;

                                      .  High quality short-term debt instruments, including repurchase agreements; and

                                      .  Shares of open-end investment companies registered under the Investment Company
                                         Act of 1940,   other than Reportable Funds.

SECONDARY PUBLIC OFFERING     Means a registered offering of a Reportable Security, which previously had been issued to the public.
</TABLE>

LAST REVISED SEPTEMBER 2013                                              PAGE 7


<PAGE>
APPLICABILITY

     The procedures and restrictions outlined in the Code apply differently
     based on your position, role and responsibilities within Pioneer. The
     Compliance Department will confirm which category applies to you. To assist
     you in determining which provisions of this Code apply to you, this Code is
     divided into the following parts:

<TABLE>
<CAPTION>
PARTS      DESCRIPTION                       APPLIES TO                             KEY PROVISIONS
-----      -----------                       ----------                             --------------
<S>        <C>                               <C>                                    <C>
PART I     Transactions in Open-End and      All Employees                          Transactions In Closed-End Pioneer Funds
           Closed-End Pioneer Funds
                                             Independent Trustees                   Transactions In Open-End Pioneer Funds

PART II    Personal Account Provisions       U.S. Access Persons                    Permitted Brokerage Firms
           Applicable to PFD Employees and
           U.S. Access Persons               PFD Employees

PART III   Personal Trading                  Access Persons including               Pre-clearance Of Transactions
           Provisions                        Investment Persons
           Applicable to Access Persons
                                                                                    Pre-clearance Procedures

                                                                                    Trading Restrictions

                                                                                    Access Persons-Prohibited Transactions

                                                                                    Investment Persons-Special Provisions

PART IV    Personal Trading Provisions       PFD Employees and members of Pioneer   Initial Public Offerings and Secondary Offerings
           Applicable to PFD Employees       Investment Management
           and Management Committee Members  USA Inc. Management Committee          Private Placements

PART V     Reporting and Certifications Requirements                                Holdings Reports

PART VI    Independent Trustees

PART VII  Administration and Enforcement of the Code
</TABLE>

     Engagement by PFD, PIAM, PIM, or any other US affiliate, of any person as a
     consultant, temporary employee, intern or independent contractor shall be
     communicated to the respective Compliance Department. The Compliance
     Department will review the person's role, responsibilities and other
     relevant information, and make a determination as to whether this Code
     applies to that person.

LAST REVISED SEPTEMBER 2013                                              PAGE 8


<PAGE>
     It is your responsibility to familiarize yourself with this Code initially
     and periodically thereafter, including each time you change positions
     within Pioneer.

I.   TRANSACTIONS IN CLOSED-END AND OPEN-END PIONEER FUNDS

     TRANSACTIONS IN CLOSED-END PIONEER FUNDS

     Each Employee and Independent Trustee must obtain pre-clearance of all
     purchases and sales of shares of closed-end Pioneer Funds. Shares of a
     closed-end Pioneer Fund may be sold or purchased only in the 10
     calendar-day period following the announcement of the Pioneer Fund's
     dividend (generally during the first week of each month). Dividend
     announcements are available on the Pioneer Funds' website. Transactions in
     a closed-end Pioneer Fund cannot be executed without receiving approval in
     advance.

     TRANSACTIONS IN OPEN-END PIONEER FUNDS

     Pioneer's policy is to endeavor to prevent disruptive short-term trading in
     open-end Pioneer Funds. Accordingly, when purchasing, exchanging or
     redeeming shares of open-end Pioneer Funds, all Employees and Independent
     Trustees must comply in all respects with the policies and standards set
     forth in the Funds' prospectuses, including specifically the restrictions
     on market timing activities, exchanges and redemption policies, as
     monitored by each Fund's transfer agent.

II.  PERSONAL ACCOUNT PROVISIONS APPLICABLE TO PFD EMPLOYEES AND U.S. ACCESS
     PERSONS

     PREFERRED BROKERS

     All PFD Employees and Access Persons who began their employment or
     otherwise became a PFD Employee or an Access Person with Pioneer after
     March 1, 2005, may only open Personal Accounts with one of the following
     brokerage firms:

          .    Bank of America Merrill Lynch

          .    Charles Schwab

          .    Credit Suisse

          .    Edward Jones

          .    E*Trade Financial

          .    Fidelity Brokerage Services

          .    Morgan Stanley Wealth Management

          .    Raymond James

          .    TD Ameritrade

          .    Scottrade

          .    UBS Financial

LAST REVISED SEPTEMBER 2013                                              PAGE 9


<PAGE>
          .    Vanguard

          .    Wells Fargo

     Each new Access Person and PFD Employee (whether or not an Access Person)
     must submit all Personal Account and Reportable Securities holdings
     information to the Compliance Department (such information to be current as
     of a date no more than 45 calendar days before the report is submitted)
     within 10 calendar days of hire or the date on which an individual becomes
     an Access Person or PFD Employee.

     If a PFD Employee or an Access Person or family member, living in the same
     household, of such persons opens a new personal account or becomes
     associated with a pre-existing account, details of the account and
     reportable securities must be sent to the Compliance Department
     immediately. The account should be reported on PTA. The PFD Employee or
     Access Person must agree to allow the brokerage firm to provide the
     Compliance Department with reports of transactions executed in the new
     account.

     New PFD Employees and Access Persons must transfer all Personal Accounts to
     one of the preferred firms listed above within 90 days of becoming a PFD
     Employee or Access Person.

     The preferred broker restriction on employee related brokerage accounts
     described above does not apply to Managed Accounts or accounts that are not
     capable of holding Reportable Securities or accounts reported by temporary
     employees of Pioneer such as consultants, temps or interns.

     Additional exemptions from the foregoing requirements may be granted only
     by the Code of Ethics Oversight Committee and the Compliance Department,
     acting together. Requests for exemptions may be denied. Exemptions that are
     granted may be revoked if transactions in the accounts are not reported in
     accordance with the above requirements.

III. PERSONAL TRADING PROVISIONS APPLICABLE TO ACCESS PERSONS

     PRE-CLEARANCE OF TRANSACTIONS

     One of key objectives of this Code is to prevent personal trades being made
     on the basis of information about securities transactions made for Advisory
     Clients. EACH ACCESS PERSON MUST OBTAIN PRE-CLEARANCE OF ALL REPORTABLE
     SECURITIES TRANSACTIONS IN HIS OR HER PERSONAL ACCOUNTS, EXCEPT:

     .    Purchases or sales of Reportable Funds (including any such
          transactions in a Pioneer Account);

     .    Purchases or sales of securities in a Managed Account;

     .    Involuntary purchases or sales of Reportable Securities made in a
          Personal Account, such as Reportable Securities received pursuant to
          an Automatic Investment Plan (including systematic investment plans
          and dividend reinvestment plans), a stock split or other similar
          corporate action, an in-the-money option that is exercised
          automatically by a broker or the issuer of the shares; a security that
          is called away as a result of an exercise of an option; a security
          that is sold by a broker without prior consultation to meet a margin
          call, or through a gift or bequest;

     .    Purchases of Reportable Securities made in a Personal Account that
          result from the exercise of rights acquired from an issuer as part of
          a pro rata distribution to all holders of a class of securities of
          such issuer, and the sale of such rights;

     .    Involuntary tender offers of Reportable Securities;

LAST REVISED SEPTEMBER 2013                                              PAGE 10

<PAGE>
     .    Purchases or sales of non-U.S. funds similar in structure to U.S.
          open-end mutual funds;

     .    Transactions in futures in broad based indices;

     .    Purchases or sales in securities that are not Reportable Securities;

     .    Purchases or sales of sovereign debt of foreign governments;

     .    Purchases or sales of securities in certain 529 Plan accounts are
          exempt.

     .    Other exceptions that may be approved by the Compliance Department
          based on a review of the facts and circumstances. Such exceptions will
          be documented.

     PRE-CLEARANCE PROCEDURES

     Requests for pre-clearance of securities transactions other than Private
     Placements and Initial Public Offerings and Secondary Public Offerings must
     be made using the Personal Trading Assistant ("PTA") personal trading
     monitoring application. If the PTA system is not available, pre-clearance
     requests may be made by electronic mail. All pre-clearance requests must
     include the name of the security, a definitive security identifier (e.g.,
     CUSIP, ticker, or SEDOL or ISIN), the number of shares or amount of bonds
     involved, the nature of the transaction, (whether the transaction is a
     purchase or sale), the Personal Account details, security price, estimated
     total value and trade currency. Responses to all requests will be made
     through the PTA system or by written confirmation by the Compliance
     Department. The Compliance Department maintains a record of all approvals
     and denials.

     Requests normally will be processed on the same day they are made, but in
     some cases additional time may be required to pre-clear a particular
     transaction.

     By seeking pre-clearance, you will be deemed to be certifying to Pioneer
     that:

          .    Except in connection with transactions involving securities of
               entities that are not publically traded, you do not possess any
               material nonpublic information relating to the Reportable
               Security or issuer of the Reportable Security;

          .    You are not using knowledge of any proposed trade,
               recommendation or investment program relating to an Advisory
               Client for personal benefit;

          .    You believe the proposed trade is available to any relevant
               market participant on the same terms;

          .    You will provide any other relevant information requested by the
               Compliance Department; and

          .    All Personal Accounts opened and all transactions executed
               during the calendar quarter have been reported and are properly
               reflected in the PTA system.

     Generally, in reviewing a pre-clearance request, the Compliance Department
     will consider, among other factors, whether the proposed trade might
     present a conflict or the appearance of a conflict with an Advisory
     Client's transaction(s), whether the transaction might influence the market
     in a material respect and whether the transaction has the potential to take
     advantage or hinder trading for an Advisory Client. Factors to be
     considered in determining whether a proposed transaction is in conflict
     with an Advisory Client transaction(s) shall be determined, reviewed and
     monitored by the Compliance Department and the Code of Ethics Oversight
     Committee.

LAST REVISED SEPTEMBER 2013                                              PAGE 11


<PAGE>
          Pre-clearance requests must be submitted within the designated
     pre-clearance timeframe established by Pioneer's Compliance Department. A
     pre-cleared transaction must be submitted and executed between the hours of
     8:30 a.m and 4:00 p.m. Eastern Time on the day the approval is granted
     unless approval is granted for a longer period by the Compliance
     Department. If some or all of a pre-cleared transaction is not executed
     during the period, pre-clearance must be requested again in order to
     complete or execute the trade.

     EXCESSIVE TRADING

     Access Persons are discouraged from trading excessively. Pioneer strongly
     discourages high levels of personal trading activity and monitors such
     activity. Excessive or inappropriate trading that interferes with job
     performance will not be permitted. If it is determined that an Access
     Person has engaged in an unusually high level of personal trading or a
     pattern of excessive trading, Pioneer may place restrictions on such
     person's personal trading or take other disciplinary action.

     INITIAL PUBLIC OFFERINGS, SECONDARY PUBLIC OFFERINGS, PRIVATE PLACEMENTS
     AND OTHER PRIVATE OFFERINGS

     Access Persons may not purchase any security in an Initial Public Offering,
     Secondary Public Offering, or Private Placement except with the prior
     written approval of the Compliance Department and the Head of Portfolio
     Management US (or his or her designee). Sales of such securities by Access
     Persons also must be approved in advance.

     Registered Persons of PFD, PFD Employees, and members of the Management
     Committee of Pioneer Investment Management USA Inc. are not permitted to
     purchase any security in an Initial Public Offering of an equity security
     except as permitted by FINRA Rule 5130.

     If an Access Person seeks pre-approval for the acquisition of a Reportable
     Security in a Private Placement or an Initial Public Offering or a
     Secondary Public Offering, the Access Person shall set forth in detail the
     rationale for the transaction using the form provided by the Compliance
     Department. Any approval will be granted only after consideration is given
     to whether the investment opportunity should be reserved for an Advisory
     Client and whether the opportunity is being offered to the Access Person by
     virtue of his or her position with or relationship to an Advisory Client.

     Access Persons may not purchase or sell any interest in a collective
     investment vehicle that is exempt from registration under the 1933 Act,
     including, but not limited to, hedge funds, private funds or similar
     investment limited partnerships, without pre-approval from the Compliance
     Department.

     BLACK-OUT PERIOD

     Access Persons may not buy or sell a Reportable Security on the same day an
     Advisory Client trades in that security except in a pre-cleared transaction
     or a transaction exempt from the pre-clearance requirements.

     ACCESS PERSONS-PROHIBITED TRANSACTIONS

     Access Persons may not:

          .    Engage in a Reportable Securities transaction in a Personal
               Account unless the transaction has been pre-cleared or is
               excluded from the pre-clearance requirements of this Code.

LAST REVISED SEPTEMBER 2013                                              PAGE 12


<PAGE>
          .    Participate in investment clubs.

          .    Engage in intraday trading.

          .    Sell a security short.

          .    Use derivatives, such as futures, options on futures, or options
               or warrants on a Reportable Security, to evade the restrictions
               set forth in this Code. A convertible bond is not a derivative
               for the purposes of this Code.

          .    Purchase or sell in a Personal Account options (including naked
               options), other than options on broad-based indices.

          .    Engage in speculative strategies such as spreads and straddles.

          .    Purchase and sell, or conversely sell and purchase, in Personal
               Accounts any Reportable Security within any period of sixty (60)
               calendar days, except:

               (i)  Reportable Securities purchased or sold in transactions
                    excluded from the pre-clearance requirements of this Code;
                    or

               (ii) Exchange traded funds; or

               (iii) A Reportable Security sold at a loss, if the trade has been
                     approved by the Compliance Department.

          .    Place any "good until canceled" or "limit" or equivalent order
               with any broker other than a limit order that is good for that
               day only.

     INVESTMENT PERSONS-SPECIAL PROVISIONS

     (Note: Every Investment Person also is an Access Person and remains subject
     to the provisions in the previous sections.)

     Investment Persons are subject to the following additional provisions:

     BLACK-OUT PERIOD: No Investment Person may purchase or sell any Reportable
     Security for a Personal Account within seven (7) calendar days before or
     seven (7) calendar days after the same Reportable Security is purchased or
     sold by an Advisory Client. An Investment Person will not be deemed to have
     violated this restriction if his or her trade occurs in the seven (7)
     calendar day period prior to the trade by an Advisory Client if the
     Investment Person did not know and had no reason to know that a trade for
     an Advisory Client was being considered, the trade was pre-cleared or it is
     a transaction exempt from the pre-clearance requirements.

     INITIAL PUBLIC OFFERINGS, SECONDARY PUBLIC OFFERINGS, PRIVATE PLACEMENTS
     AND OTHER PRIVATE OFFERINGS: No Investment Person may purchase any security
     in an Initial Public Offering, Secondary Public Offering, Private Placement
     or other private offering, except with the prior written approval of the
     Compliance Department and the Head of Portfolio Management US (or his or
     her designee). Sales of such securities also must be approved in advance.
     If an Investment Person seeks pre-approval for the purchase of a Private
     Placement, an Initial Public Offering, a Secondary Public Offering or any
     other private offering, the Investment Person shall set forth in detail the
     rationale for the transaction using the form provided by the Compliance
     Department.

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     DUTY TO MAKE UNBIASED RECOMMENDATIONS: Investment Persons have an
     affirmative duty to make unbiased and timely recommendations to Advisory
     Clients. Investment Persons may not recommend any Reportable Security to an
     Advisory Client in which the Investment Person has an interest without
     first reporting that interest to the Compliance Department.

     CLIENT OPPORTUNITIES: Investment Persons may not use his or her knowledge
     of Advisory Client transactions to purchase or sell a Reportable Security,
     when he or she knew or should have known that the security was being
     considered as an appropriate investment for any Advisory Client unless the
     transaction is approved in accordance with Pioneer's standard procedures.
     Investment Persons may not delay making a timely recommendation of
     securities in order to trade personally.

     ACCOUNTS OF OTHERS: An Investment Person may not manage accounts of persons
     other than those of Advisory Clients or of his or her Family Members unless
     a waiver has been granted by the Compliance Department to permit an
     Investment Person to manage such accounts.

IV.  PERSONAL TRADING PROVISIONS APPLICABLE TO PFD EMPLOYEES AND MANAGEMENT
     COMMITTEE MEMBERS

     PUBLIC OFFERINGS: Registered Persons of PFD, PFD Employees, and members of
     the Management Committee of Pioneer Investment Management USA Inc. may not
     purchase equity securities in an Initial Public Offering except as
     permitted by FINRA Rule 5130.

     PRIVATE PLACEMENTS AND OTHER PRIVATE OFFERINGS: No PFD Employee may
     purchase any security in a Private Placement or any other private offering,
     except with the prior written approval of the Compliance Department and the
     Head of Portfolio Management US (or his or her designee). If a PFD Employee
     seeks pre-approval for the purchase of a Private Placement, the Employee
     shall set forth in detail the rationale for the transaction using the form
     provided by the Compliance Department. Any approval will be granted only
     after consideration is given to whether the investment opportunity should
     be reserved for an Advisory Client and whether the opportunity is being
     offered to the Employee by virtue of his or her position with or
     relationship to an Advisory Client.

     PRECLEARANCE REQUIREMENTS: PFD Employees who are Access Persons are subject
     to the pre-clearance requirements described in Part III above. PFD
     Employees who are not Access Persons are not subject to any of the above
     pre-clearance requirements.

     REPORTING: PFD Employees must complete initial and annual holdings Personal
     Account reports and transaction reports and must attempt to arrange for
     duplicate copies of confirmations of all transactions and/or periodic
     account statements of all Personal Accounts to be sent to the Compliance
     Department in accordance with Part V below.

V.   REPORTING  AND  CERTIFICATION  REQUIREMENTS

     REPORTING REQUIREMENTS(refer to page 10 for additional details)

     INITIAL AND ANNUAL HOLDINGS REPORTS: Each Access Person and each PFD
     Employee (whether or not an Access Person) initially and on an annual basis
     thereafter shall report to the Compliance Department all holdings in
     Reportable Securities (including holdings in any Reportable Fund) occurring
     in his or her Personal Accounts (such information to be current as of a
     date no more than 45 calendar days before the report is submitted). Initial
     reports must be filed within 10 calendar days of the date on which an
     individual becomes an Access Person or PFD Employee. The Compliance
     Department will determine the form or system on which the required
     information is to be reported.

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<PAGE>
     DUPLICATE STATEMENTS: Each Access Person and PFD Employee must attempt to
     arrange for duplicate copies of confirmations of all transactions and/or
     periodic account statements of all Personal Accounts, other than those
     transactions and holdings held in the Pioneer Accounts, to be sent to:

                     Pioneer Investment Management USA Inc.
                             Compliance Department
                          13th Floor, 60 State Street
                          Boston, Massachusetts 02109

     Such instructions must be made promptly upon becoming an Access Person or
     PFD Employee and as new accounts are established but no later than 30 days
     after the end of a calendar quarter.

     If duplicate copies of confirmations and periodic account statements cannot
     be arranged to be sent to Pioneer in a timely manner, the Compliance
     Department must be notified immediately.

     Access Persons and PFD Employees are responsible for following up with the
     broker to ensure that such instructions are being followed.

     QUARTERLY REPORTS:

     PREFERRED BROKER ACCOUNTS - ELECTRONIC REPORTING

     A quarterly transaction report is not required for U.S. Access Persons and
     PFD Employees who hold Personal Accounts with preferred brokers that
     provide transaction information via electronic form to the Compliance
     Department for the time period that would be covered by the quarterly
     report.

     PREFERRED BROKER ACCOUNTS - NON-ELECTRONIC REPORTING

     Each U.S. Access Person and each PFD Employee must report, within 30
     calendar days after the end of each calendar quarter, all transactions in
     Reportable Securities occurring in the quarter in a Personal Account held
     with a preferred broker that does not provide electronic reporting on the
     Personal Account to the Compliance Department. Quarterly transaction
     reports must be submitted even if there was no transaction during the
     quarter.

     NON-PREFERRED BROKER ACCOUNTS

     Each U.S. Access Person and each PFD Employee must report, within 30
     calendar days after the end of each calendar quarter, all transactions in
     Reportable Securities occurring in the quarter in a Personal Account held
     with a non-preferred broker. Quarterly transaction reports must be
     submitted even if there was no transaction during the quarter.

     PIONEER ACCOUNTS: Transactions and holdings of securities held in Pioneer
     Accounts, as defined, are NOT required to be included in quarterly or
     annual reports. Transactions and holdings of securities held by the
     Transfer Agent, Pioneer Investment Management Shareholder Services, Inc.
     ("PIMSS") are required to be included in quarterly or annual reports.

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<PAGE>
     ANNUAL AND QUARTERLY REPORTING EXCEPTIONS: The following types of
     Reportable Securities transactions do not have to be included in the
     quarterly reports to the Compliance Department. (Please note, however, that
     holdings of such Reportable Securities are required to be included in the
     annual holdings report):

        .    Purchases of Reportable Securities made pursuant to an Automatic
             Investment Plan;

     The following transactions and holdings are not required to be reported on
     a quarterly or annual basis:

        .    Transactions and holdings in securities or instruments that are not
             Reportable Securities;

        .    Transactions and holdings in non-U.S. funds similar in structure to
             U.S. open-end mutual funds, such as UCITs, that are not advised by
             Pioneer or its affiliates;

        .    Transactions and holdings in securities in Managed Accounts; and

     Transactions and holdings in certain 529 Plan Accounts are exempt.

     CERTIFICATIONS

     (Note: The Compliance Department will determine the form or system on which
     the required information is to be reported).

     INITIAL CERTIFICATION AND UPDATES: Upon request all Employees shall
     acknowledge that they have received, read and understand this Code, and any
     material amendment, and recognize that they are subject to its
     requirements.

     ANNUAL CERTIFICATIONS: All Employees shall certify at least annually that
     they have read and understand this Code, recognize that they are subject to
     its requirements and have complied with the requirements of this Code. All
     Employees shall also certify annually that they have reported all holdings
     of Reportable Securities in Personal Accounts required to be reported
     pursuant to this Code.

VI.  INDEPENDENT TRUSTEES

     QUARTERLY REPORTING: An Independent Trustee is required to make a quarterly
     report with respect to any transaction during the applicable quarter in a
     Reportable Security in which the Independent Trustee had any direct or
     indirect Beneficial Interest (excluding, for purposes of this subparagraph,
     transactions in open-end Pioneer Funds) if such Independent Trustee knew
     or, in the ordinary course of fulfilling his or her duties as an
     Independent Trustee should have known, that during the 15-day period
     immediately before or after the transaction in such Reportable Security, an
     Advisory Client purchased or sold such Reportable Security, or an Advisory
     Client or PIM considered purchasing or selling such Reportable Security.
     Each such report shall be made within 30 calendar days after the end of the
     applicable calendar quarter in the form provided by the Compliance
     Department. The quarterly reporting exceptions set forth in Part V above
     shall apply to any quarterly reports required to be made by an Independent
     Trustee under this Part VI.

     No report will be required for any quarter in which an Independent Trustee
     only has exempt transactions to report. Sanctions for any violation of this
     Code of Ethics by an Independent Trustee of a Pioneer Fund will be
     determined by a majority vote of other Independent Trustees of such Fund.

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<PAGE>
VII.  ADMINISTRATION  AND  ENFORCEMENT

     Acknowledgement of, and compliance with, this Code is a condition of
     employment with Pioneer. This Code does not create any obligations to any
     person or entity other than Pioneer. This Code is not a promise or a
     contract, and it may be modified at any time.

     REPORTING VIOLATIONS OF THE CODE

     DUTY OF EACH EMPLOYEE TO REPORT: Pioneer relies on each Employee to report
     promptly any conduct you believe to be a violation of this Code. You must
     report violations or suspected violations of this Code to the Compliance
     Department or a Pioneer lawyer. All such reports will be investigated.

     RETALIATION PROHIBITED: Pioneer will not tolerate any form of retaliation
     against any person who lodges a good faith report of a violation or
     suspected violation or cooperates in an investigation. Where retaliation is
     found to have occurred, the offending party will be subject to disciplinary
     action, up to and including termination of employment. Pioneer also
     reserves the right to take corrective action against a person if, upon
     investigation, it determines that the person was dishonest or malicious in
     making a report or providing information to investigators.

     CONFIDENTIALITY: In conducting an investigation, Pioneer will attempt to
     keep the identities of the person reporting the suspected violation and of
     witnesses confidential. Where this is not possible, information will be
     disclosed only as necessary to conduct the investigation and to permit
     members of management to ensure the efficiency and security of Pioneer's
     business activities. Where a report involves a violation of a law or
     regulation, Pioneer may also be obligated to make certain information
     available to clients or former clients, the Securities and Exchange
     Commission, FINRA or other authorities.

     PENALTIES AND SANCTIONS

     SANCTIONS: Any violation of this Code (other than by an Independent
     Trustee) shall be subject to the imposition of such sanctions by the
     Compliance Department as the Compliance Department deems appropriate under
     the circumstances to achieve the purposes of this Code. Please refer to the
     Code of Ethics Violation and Sanctions Guidelines for further details.

     These sanctions may include, but are not limited to: terminating or
     suspending employment; suspending personal trading privileges; issuing a
     letter of censure or warning; requiring a fine to be paid; requiring the
     compensation of an affected Advisory Client for an amount equal to the
     advantage gained by reason of such violation; or requiring the reversal of
     the trade(s) at issue and forfeit of any profit or absorption of any loss
     from the trade.

     In deciding whether to impose sanctions, Pioneer may take into account any
     factors that it determines to be appropriate in imposing sanctions, which
     may include, but are not limited to, an Employee's history of compliance,
     the nature of the violation, whether the violation was intentional or
     inadvertent and any harm suffered by a client. Violations of this Code also
     may result in criminal prosecution or civil action. Violations will be
     removed from an Employee's personnel record after a period of five years
     from the date of the violation.

     Pioneer reserves the right to take any legal action it deems appropriate
     against any Employee who violates any provision of this Code and to hold
     Employees liable for any and all damages (including, but not limited to,
     all costs and attorney fees) that Pioneer may incur as a direct or indirect
     result of any such Employee's violation of this Code or related law or
     regulation.

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<PAGE>
     Sanctions for any violation of this Code of Ethics by an Independent
     Trustee of a Pioneer Fund will be determined by a majority vote of other
     Independent Trustees of such Fund.

     HARDSHIP AND OTHER EXEMPTIONS: The CCO or his or her designee may from time
     to time grant hardship or other exemptions from the trading restrictions,
     pre-clearance requirements or other provisions of this Code. The decision
     will be based on a review of the relevant facts and circumstance and a
     determination will be made depending on the facts whether a hardship or
     other valid reason exists that would permit an exemption to be granted. The
     transaction for which an exemption is requested should not result in a
     conflict with Pioneer's Advisory Clients' interests or violate any other
     policy embodied in this Code. Other factors that may be considered include:
     the size and holding period of a position in the security, the market
     capitalization of the issuer, the liquidity of the security, the amount and
     timing of client trading in the same or a related security, and other
     relevant factors. The CCO or his or her designee may seek additional
     approval from the Head of US Portfolio Management or his or her designee.

     Exemption requests should be submitted in writing to the Compliance
     Department setting forth the reason for the request along with any
     pertinent facts and reasons why the exemption should be granted. Exemptions
     are intended to be exceptions, and repetitive requests for exemptions are
     not likely to be granted. Records of the approval of exemptions and the
     reasons for granting exemptions will be maintained by the Compliance
     Department.

     REVIEW PROCESS: An Employee may request review by the Compliance Department
     of a decision or determination made by the Compliance Department pursuant
     to this Code. The request must be submitted within 30 days of the
     Compliance Department's decision or determination. The Compliance
     Department, in its sole discretion, may elect to consider or reject the
     request for review. If appropriate in reaching a decision, the Compliance
     Department will arrange for a review of the matter by senior management of
     Pioneer and/or the Code of Ethics Oversight Committee.

     DUTIES OF THE COMPLIANCE DEPARTMENT

     The Compliance Department is responsible for the oversight, interpretation
     and administration of this Code, and the preparation for review and
     approval of any amendments to the Code.

     The Compliance Department will inform you if you are subject to this Code.

     A copy of this Code is available on Navigator US and the PTA Home Page.
     Likewise, amendments to the Code will be posted on Navigator US and PTA
     promptly after they become effective. Employees will be given notice of all
     changes to, or restatements of, the Code.

     DUTIES OF THE CCO

     The CCO (or his or her designee) shall have the following responsibilities:

          .    Furnishing all Employees with copies of this Code and initially
               and periodically informing them of their duties and obligations
               hereunder;

          .    Designating, as desired, appropriate personnel to review
               transaction and holdings reports submitted pursuant to the Code;

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<PAGE>
          .    Reviewing and approving pre-clearance requests;

          .    Maintaining or supervising the maintenance of all records
               required by this Code;

          .    Issuing any interpretation of this Code that, in the CCO's
               judgment, is consistent with the objectives of this Code;

          .    Conducting such investigations as shall reasonably be required
               to detect and report any apparent violations of this Code to the
               Compliance Department and to the Trustees of the affected Pioneer
               Funds;

          .    Submitting a quarterly report to the Boards of Trustees of the
               Pioneer Funds of any violations of this Code and the sanctions
               imposed as a result; and

          .    Submitting a written report at least annually to the Board of
               Trustees of each Pioneer Fund, Board of Directors of PFD and the
               Management Committee of PIM and its affiliates that:

               .    Describes any issues arising under this Code since the last
                    report, including, but not limited to, information about
                    material violations of this Code or procedures and sanctions
                    imposed in response to the material violations;

               .    Summarizes existing procedures concerning personal
                    investing and any changes in the procedures made during the
                    previous year;

               .    Identifies any recommended changes in existing restrictions
                    or procedures based upon experience under this Code,
                    evolving industry practices or developments in applicable
                    laws or regulations.

     RECORDKEEPING

     The Compliance Department shall maintain or cause to be maintained in an
     easily accessible place, the following records:

          .    A copy of any Code adopted pursuant to Rule 17j-1 under the
               Investment Company Act of 1940 or Rule 204A-1 under the Advisers
               Act, which has been in effect during the most recent five (5)
               year period.

          .    A record of any violation of any such Code, and of any action
               taken as a result of such violation, within three (3) years from
               the end of the calendar year in which such violation occurred.

          .    A copy of all written acknowledgements by Access Persons during
               the most recent five (5) year period.

          .    A copy of each report made by an Access Person or an Independent
               Trustee, as well as trade confirmations and/or account statements
               that contain information not duplicated in such reports, within
               five (5) years from the end of the fiscal year of Pioneer in
               which such report is made or information is provided, the first
               two (2) years in an easily accessible place.

          .    A copy of each report made by the CCO (or his or her designee)
               within five (5) years from the end of the fiscal year of Pioneer
               in which such report is made or issued, the first two (2) years
               in an easily accessible place.

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<PAGE>
          .    A list, in an easily accessible place, of all persons who are,
               or within the most recent five (5) year period have been, Access
               Persons or were required to make reports pursuant to Rules 17j-1
               and 204A-1 and this Code or who are or were responsible for
               reviewing these reports.

          .    A record of any decision, and the reasons supporting the
               decision, to permit an Access Person or Investment Person to
               acquire a Private Placement or Initial Public Offering security,
               for at least five (5) years after the end of the fiscal year in
               which permission was granted.

     AMENDMENTS

     Pioneer may amend this Code as necessary or appropriate to achieve the
     purposes of Rules 17j-1 and 204A-1. Any material changes to this Code must
     be approved by the Board of Trustees of each Pioneer Fund, including a
     majority of the Independent Trustees, within six months after the change
     has been adopted by Pioneer.

     INTERPRETATION

     Pioneer may, from time to time, adopt such interpretations of this Code, as
     Pioneer deems appropriate.

     EDUCATIONAL MATERIALS

     The Compliance Department may from time to time circulate educational
     materials or bulletins designed to assist you in understanding and carrying
     out your duties under this Code.

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