EXHIBIT
ITEM 10 (a)(1)
CODE
OF ETHICS
FOR
PRINCIPAL EXECUTIVE AND PRINCIPAL FINANCIAL OFFICERS
(Pursuant
to Section 406 of the Sarbanes-Oxley Act of 2002)





I.  Covered
Officers/Purpose of the Code 



This  code of
ethics (the “Code”) for each of the registered investment  companies managed by
J. & W. Seligman & Co. Incorporated  (“Seligman”) (collectively, “Funds” and
each a  “Fund”) applies to each Fund’s Principal Executive Officer and
Principal Financial Officer (the “Covered Officers” each of whom is  set forth
in Exhibit A) for the purpose of promoting: 



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







	• 	 	full,
fair, accurate, timely and understandable disclosure in reports and  documents that a
registrant files with, or submits to, the Securities and  Exchange Commission (“SEC”)
and in other public communications made by  a Fund; 







	• 	 	compliance
with applicable laws and governmental rules and regulations; 







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







	• 	 	accountability
for adherence to the Code. 







     Each
Covered Officer should adhere to a high standard of business ethics and should
be sensitive to situations that may give rise to actual as well as apparent
conflicts of interest. 




II.  Covered
Officers Should Handle Ethically Actual and Apparent Conflicts of Interest




	 	Overview. 







	 	     A
“conflict of interest” occurs when a Covered Officer’s private  interest
interferes with the interests of, or his service to, a Fund. For  example, a conflict of
interest would arise if a Covered Officer, or a member of  his family, receives improper
personal benefits as a result of his position with  the Fund. 







	 	     Certain
conflicts of interest arise out of the relationships between Covered Officers  and a Fund
and already are subject to conflict of interest provisions in the 

















	 	Investment
Company Act  of 1940 (“Investment Company Act”) and the  Investment Advisers
Act of 1940 (“Investment  Advisers Act”). For  example, Covered Officers may
not individually engage in  certain transactions  (such as the purchase or sale of
securities or other property) with  a Fund  because of their status as “affiliated
persons” of the Fund. The  Funds’ and  Seligman’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 these
programs 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
from, or as a result of, the contractual relationship between a Fund and  Seligman of
which the Covered Officers are also officers or employees. As a  result, this Code
recognizes that the Covered Officers will, in the normal  course of their duties (whether
formally for a Fund or for Seligman, or for  both), be involved in establishing policies
and implementing decisions that will  have different effects on Seligman and the Fund.
The participation of the  Covered Officers in such activities is inherent in the
contractual relationship  between a Fund and Seligman and is consistent with the
performance by the  Covered Officers of their duties as Officers of the Fund. Thus, if
performed in  conformity with the provisions of the Investment Company Act and the
Investment  Advisers Act, such activities will be deemed to have been handled ethically.
In  addition, it is recognized that the Covered Officers may also be officers or
employees of one or more other investment companies covered by this or other  codes. 







	 	     Other
conflicts of interest are covered by the Code, even if such conflicts of  interest are
not subject to provisions in the Investment Company Act and the  Investment Advisers Act.
The following list provides examples of conflicts of  interest under the Code, but
Covered Officers should keep in mind that these  examples are not exhaustive. The
overarching principle is that the personal  interest of a Covered Officer should not be
placed improperly before the  interest of a Fund. 







*     *     * 



	 	Each
Covered Officer must: 







	• 	 	not
use his personal influence or personal relationships improperly to influence  investment
decisions or financial reporting by a Fund whereby the Covered  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 Covered Officer rather than the benefit of the Fund; 







	• 	 	report
at least annually any business affiliations or other business  relationships (including
those of immediate family members) that have the  potential to raise conflicts of
interests. 

















	 	     These
are some conflicts of interest situations that should not occur unless  specifically
pre-approved by Seligman’s General Counsel, Associate General  Counsel or Director
of Compliance: 







	• 	 	 service
as a director on the board of any public or private company; 







	• 	 	the
receipt of any gifts of significant value or cost from any company with which a  Fund has
current or prospective business dealings; 







	• 	 	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 nor so  extensive as to
raise any question of impropriety; 







	• 	 	any
ownership interest in, or any consulting or employment relationship with, any of  the Fund’s
non-public service providers, other than Seligman, Seligman  Advisors, Inc., Seligman
Services, Inc., Seligman Data Corp. or any affiliated  person thereof; 







	• 	 	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 Covered Officer’s  employment, such as
compensation or equity ownership. 








III.
Disclosure and Compliance



	• 	 	each
Covered Officer should familiarize himself with the disclosure requirements  generally
applicable to a Fund; 







	• 	 	each
Covered Officer should not knowingly misrepresent, or cause others to  misrepresent,
facts about a Fund to others, whether within or outside the Fund,  including to the Fund’s
directors and auditors, and to governmental  regulators and self-regulatory organizations; 







	• 	 	each
Covered Officer should, to the extent appropriate within his area of  responsibility,
consult with other officers and employees of a Fund and Seligman  with the goal of
promoting full, fair, accurate, timely and understandable  disclosure in the reports and
documents the Fund files with, or submits to, the  SEC and in other public communications
made by the Fund; and 







	• 	 	it
is the responsibility of each Covered Officer to promote compliance with the  standards
and restrictions imposed by applicable laws, rules and regulations. 


















IV.
Reporting and Accountability


         Each Covered Officer must:


	• 	 	upon
adoption of the Code (or thereafter as applicable, upon becoming a Covered  Officer),
affirm in writing to the Board that he has received, read, and  understands the Code; 







	• 	 	 annually
thereafter affirm to the Board that he has complied with the  requirements of the Code; 







	• 	 	not
retaliate against any other Covered Officer or any employee of the Funds or  their
affiliated persons for reports of potential violations that are made in  good faith; and 







	• 	 	 notify
Seligman’s General Counsel, Associate General Counsel or Director of  Compliance
promptly if he knows of any violation of this Code. Failure to do so  is itself a
violation of this Code. 







	 	Seligman’s
General Counsel (or his 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.1 However, any approvals or waivers2 granted
to the Covered Officer  will be promptly reported to the Chairman of the appropriate Fund’s
Board  Operations Committee and reported to the appropriate Fund’s Board at its
next regular meeting. 







     The  following
procedures will be followed in investigating and enforcing this Code: 



	•	 	Seligman’s
General Counsel (or his designee) will take all appropriate  action to investigate any
potential violations reported to him; 







	•	 	if,
after such investigation, Seligman’s General Counsel believes that no  violation has
occurred, he is not required to take any further action;. 







	•	 	any
matter that the General Counsel believes is a violation will be reported to the
appropriate Board; 







	•	 	if
the appropriate Board concurs that a violation has occurred, it will consider
appropriate action, which may include review of, and appropriate 







__________ 


1 The
General Counsel (or his designee) is authorized to consult, as appropriate,  with counsel
to the Funds and the Independent Directors, and is encouraged to do  so.



2 “Waiver” is
defined as “the approval by the  registrant of a material departure from a provision
of the code of ethics” and “implicit waiver,” which must also be
disclosed, is defined as  “the registrant’s failure to take action within a
reasonable period of  time regarding a material departure from a provision of the code of
ethics that  has been made known to an executive officer” of the registrant.














	 	 	modifications
to,  applicable policies and procedures; notification to appropriate personnel of
Seligman or  its board; or a recommendation to dismiss the Covered Officer; and 








	•	 	any
changes to or waivers of this Code will, to the extent required, be disclosed as
provided by SEC rules. 








V.  Other
Policies and Procedures



     This
Code shall be the sole code of ethics adopted by the Funds for purposes of
Section 406 of the Sarbanes-Oxley Act and the rules and forms applicable to
registered investment companies thereunder. Insofar as other policies or
procedures of the Funds, Seligman, Seligman Advisors, Inc., Seligman Services,
Inc., Seligman Data Corp., or other service providers or any of their affiliates
govern or purport to govern the behavior or activities of the Covered Officers
who are subject to this Code, they are superseded by this Code to the extent
that they overlap or conflict with the provisions of this Code. The Funds’,
Seligman’s and Seligman Advisors, Inc.‘s and their affiliates’
codes of ethics under Rule 17j-1 under the Investment Company Act and any other
policies and procedures of such entities are separate requirements applying to
the Covered Officers and others, and are not part of this Code. 




VI.  
Amendments



     Any
amendments to this Code, other than amendments to Exhibit A, must be approved or
ratified by a majority vote of the Board of each Fund, including a majority of
the independent directors. 




VII.  
Confidentiality



     All
reports and records prepared or maintained pursuant to this Code will be
considered confidential and shall be maintained and protected accordingly.
Except as otherwise required by law or this Code, such matters shall not be
disclosed to anyone other than the appropriate Fund’s Board and its
counsel, members of Seligman’s Board of Directors and members of
Seligman’s Law and Regulation Department. 




VIII.  
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. 



September 18,
2003 














Exhibit A




Persons Covered
by this Code of Ethics



Principal
Executive Officer     -     Brian T. Zino

Principal Financial Officer     -     Lawrence P. Vogel