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                                CODE OF ETHICS

                                      FOR

                                SENIOR OFFICERS

POLICY

   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, although one person may occupy more than one such office. Each
   Senior Officer is identified by title in Exhibit A to this Code.

   The Chief Compliance Officer ("CCO") of the Pioneer Funds is primarily
   responsible for implementing and monitoring compliance with this Code,
   subject to the overall supervision of the Board of Trustees of the Funds
   (the "Board"). The CCO has the authority to interpret this Code and its
   applicability to particular situations. Any questions about this Code should
   be directed to the CCO or his or her designee.

PURPOSE

   The purposes of this Code are to:

       .  Promote honest and ethical conduct, including the ethical handling of
          actual or apparent conflicts of interest between personal and
          professional relationships;

       .  Promote full, fair, accurate, timely and understandable disclosure in
          reports and documents that the Fund files with, or submits to, the
          Securities and Exchange Commission ("SEC") and in other public
          communications made by the Fund;

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       .  Promote compliance with applicable laws and governmental rules and
          regulations;

       .  Promote the prompt internal reporting of violations of the Code to an
          appropriate person or persons identified in the Code; and

       .  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 the Senior Officer's 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
   Funds because of their status as "affiliated persons" of the Funds. 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 as a result of the contractual relationship between
   the Fund and Pioneer because the Senior Officers are officers or employees
   of both. As a result, this Code recognizes that Senior Officers will, in the
   normal course of their duties (whether formally for a Fund or for Pioneer,
   or for both), be involved in establishing policies and implementing
   decisions that will have different effects on Pioneer and the Fund. The
   participation of Senior Officers in such activities is inherent in the
   contractual relationship between a 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
   investment companies other than the Pioneer Funds.

   Other conflicts of interest are covered by this 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 this Code, Senior
   Officers should keep in mind that such a list cannot ever be exhaustive or
   cover every possible

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   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:

       .  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;

       .  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

       .  Report at least annually any affiliations or other relationships that
          give rise to conflicts of interest.

   Any material conflict of interest situation should be approved by the CCO,
   his or her designee or the Board. Examples of these include:

       .  Service as a director on the board of any public or private company;

       .  The receipt of any gift with a value in excess of an amount
          established from time to time by Pioneer's Business Gift and
          Entertainment Policy 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;

       .  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;

       .  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

       .  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.

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Corporate Opportunities

   Senior Officers may not (a) take for themselves personally opportunities
   that are discovered through the use of a Fund's property, information or
   position; (b) use a Fund's property, information, or position for personal
   gain; or (c) compete with a Fund. 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.

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 or 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 or her particular
   position and by persons under the Senior Officer's supervision. Senior
   Officers should endeavor to comply not only 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 or her 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.

INITIAL AND ANNUAL CERTIFICATIONS

   Upon becoming a Senior Officer the Senior Officer is required to certify
   that he or she has received, read, and understands this Code. On an annual
   basis, each Senior Officer must certify that he or she has complied with all
   of the applicable requirements of this Code.

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ADMINISTRATION AND ENFORCEMENT OF THE CODE

Report of Violations

   Pioneer relies on each Senior Officer to report promptly if he or she knows
   of any conduct by a Senior Officer in violation of this Code. All violations
   or suspected violations of this Code must be reported to the CCO or a member
   of Pioneer's Legal and Compliance Department. Failure to do so is itself a
   violation of this Code.

Investigation of Violations

   Upon notification of a violation or suspected violation, the CCO or other
   members of Pioneer's Compliance Department will take all appropriate action
   to investigate the potential violation reported. If, after such
   investigation, the CCO believes that no violation has occurred, the CCO and
   Compliance Department is not required to take no further action. Any matter
   the CCO 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. The Board
   shall be responsible for determining appropriate action. The Funds, their
   officers and employees, will not retaliate against any Senior Officer for
   reports of potential violations that are made in good faith and without
   malicious intent.

   The CCO or his or her designee 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. The CCO or his
   or her designee shall make inquiries regarding any potential conflict of
   interest.

Violations and Sanctions

   Compliance with this Code is expected and violations of its provisions will
   be taken seriously and could result in disciplinary action. In response to
   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 approval or waiver sought by any
   Senior Officer.

   The Independent Trustees will be responsible for granting waivers, as
   appropriate. Any change to or waiver 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 Ethics under Rule 17j-1 under the
   ICA and Rule 204A-1 of the IAA are separate requirements applying to the
   Senior Officers and others, and are not a part of this Code. To the extent
   any other policies and procedures of the Funds, Pioneer or Pioneer

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   Fund Distributor, Inc. overlap or conflict with the provisions of the this
   Code, they are superseded by 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, a Senior
   Officer is responsible for matters of which the Senior Officer has actual
   knowledge.

AMENDMENTS

   This Code other than Exhibit A may not be amended except in a writing that
   is specifically approved or ratified by a majority vote of the Board,
   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 and their counsel or to Pioneer's
   Legal and Compliance Department.

INTERNAL USE

   This 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.

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EXHIBIT A - SENIOR OFFICERS OF THE PIONEER FUNDS

   President (Principal Executive Officer)

   Treasurer (Principal Financial Officer)

Code of Ethics for Senior Officers
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