CODE OF ETHICS




POLICY
      Each of Pioneer Investment Management, Inc. and Pioneer Institutional
      Asset Management, Inc. (collectively, "Pioneer") is committed to
      maintaining the highest ethical standards in connection with the
      management of its clients' assets. An important element of Pioneer's
      commitment is Pioneer's philosophy of always putting Pioneer clients'
      interests ahead of its own. Accordingly, as a person subject to this Code
      of Ethics for Pioneer (the "Code"), you must conduct yourself in such a
      manner as to avoid any actual or potential conflict of interest with a
      client of Pioneer. The knowledge and/or opportunities you gain as a result
      of your position at Pioneer must be used in a manner that is consistent
      with Pioneer's fiduciary obligations to clients. In addition, Pioneer
      expects you to comply at all times with the federal securities laws of the
      United States applicable to Pioneer's business.

      When making personal investment decisions, you must exercise extreme care
      to ensure that the prohibitions of this Code are not violated.
      Furthermore, you should conduct your personal investing in such a manner
      that will eliminate the possibility that your time and attention are
      devoted to your personal investments at the expense of time and attention
      that should be devoted to your duties at Pioneer.

      It also bears emphasizing that technical compliance with the procedures,
      prohibitions and limitations of the Code will not insulate you
      automatically from scrutiny of, or sanctions for, your securities
      transactions. It is not intended that this policy specifically will
      address every situation regarding personal trading so you must contact the
      Compliance Department if you have any questions about the Code.


APPLICABILITY
      This Code applies to supervised persons of Pioneer. Supervised persons of
      Pioneer are:

        o All associates, officers and directors of Pioneer; and

        o Individuals who provide investment advice on behalf of Pioneer and
are subject to the supervision and control of Pioneer.

      The procedures and restrictions outlined in the Code apply differently
      based on your position within Pioneer. To assist you in determining which
      provisions of the Code apply to you, the Code is divided into three parts:

       o Part I, which  contains  provisions  relating  to  certification  and
the standards of conduct  expected of supervised  persons and is applicable
to all supervised persons;

       o Part II, which relates to personal  investing  and is applicable  only
to access persons; and

       o  Part  III,  which  relates  to  administration  and  enforcement  and
is applicable to all supervised persons.

      It is your responsibility to familiarize yourself with this Code initially
      and again if you change positions in the future.

     Underlined  terms  contained  in the Code have  special  meanings.  You may
     review a definition of a term's meaning by referring to "Important  Terms"
     or by simply clicking on the term.

PURPOSE
      Pioneer has adopted this Code to establish standards of conduct expected
      of its associates and to address conflicts that arise from personal
      trading by associates. This Code has been adopted pursuant to the
      requirements of Rule 204A-1 under the Investment Advisers Act of 1940 and
      Rule 17j-1 under the Investment Company Act of 1940.


I. PROVISIONS APPLICABLE TO ALL SUPERVISED PERSONS


CERTIFICATIONS OF RECEIPT AND COMPLIANCE


      INITIAL CERTIFICATION

      You will be required to certify within 10 calendar days of commencement of
      employment, or the date on which you become an access person or supervised
      person, that you have read and understand the Code and recognize that you
      are subject to the Code. In addition, you may be required to certify that
      you have read and understand the provisions of the Code if your position
      within Pioneer changes and when the Code is amended. Certifications must
      be submitted to the Compliance Department using the form or system
      provided.


      ANNUAL CERTIFICATION

      On an annual basis, you will be expected to certify that:

o        You have received a copy of the then current Code;

o        You have read and understand the Code and recognize that you are
         subject to the Code's requirements;

o You have complied with all applicable requirements of the Code.

      Generally, this certification must be completed by February 15th of each
      year or any other date that is determined by the Chief Compliance Officer.



CODE OF BUSINESS CONDUCT

      All supervised persons of Pioneer are subject to Pioneer's Code of
      Business Conduct. The Code of Business Conduct sets out standards for
      associates dealing with potentially complex ethical decisions. The Code of
      Business Conduct also provides basic information to associates regarding
      Pioneer's procedures for reporting conflicts of interest and raising other
      issues of concern. You should be aware that violations of the Code of
      Business Conduct that result in a violation of the federal securities laws
      of the United States or conflict with Pioneer's fiduciary obligations to
      its clients shall be deemed to be a violation of this Code.

      Associates that are employed by Pioneer Investment Management Limited
      ("PIML") are subject to PIML's Conflict of Interest Policy.



INSIDER TRADING

      In addition to the requirements of this Code, all associates of Pioneer
      are subject to Pioneer's policies and procedures regarding Insider
      Trading. Pioneer's Insider Trading policies and procedures prohibit
      associates from buying or selling any security while in possession of
      material nonpublic information about the issuer of the security. The
      policy also prohibits associates from communicating to third parties any
      material nonpublic information about any security or issuer of securities.
      Any violation of Pioneer's policies and procedures on Insider Trading that
      adversely affect a client shall be deemed to be a violation of this Code.

      Associates that are employed by Pioneer Investment Management Limited
      ("PIML") are subject to PIML's Insider Dealing Policy.


II. PERSONAL INVESTING PROVISIONS APPLICABLE TO ACCESS PERSONS


REPORTING REQUIREMENTS

      You must report the information set forth below to the Compliance
      Department. Any report provided under this section may contain a statement
      that the report shall not be construed as an admission by the person
      making the report that he or she has any direct or indirect beneficial
      ownership in the security to which it relates. The Code applies to any
      reportable security in which an access person has any direct or indirect
      beneficial ownership.


      HOLDINGS REPORTS


      Initial holdings report
      Within 10 calendar days of becoming an access person, you must disclose to
      the Compliance Department all of your employee-related accounts and all
      reportable securities holdings, including the holdings of any investment
      company that is registered under the Investment Company Act of 1940 that
      is advised or sub advised by Pioneer (reportable funds), that are
      beneficially owned by you whether or not they are held in an
      employee-related account. If the 10th day falls on a weekend or a holiday,
      the report is due on the business day immediately preceding this deadline.

      Initial holdings reports must be submitted to the Compliance Department
      using the form or system provided and must contain information that is
      current as of a date no more than 45 calendar days prior to becoming an
      access person.

      If you become the beneficial owner of another person's securities (e.g.,
      by marriage to the owner of the securities), then transactions in those
      securities also become subject to the reporting and pre-clearance
      requirements of the Code. You must report your beneficial ownership of
      these securities within 10 calendar days of your knowledge of their
      existence. Additionally, any changes to the registration of a security
      (i.e., transfers from one account into another) must be reported to the
      Compliance Department within 10 calendar days of your knowledge of the
      change.


      Annual holdings report
      On an annual basis, you are required to report to the Compliance
      Department all of your employee-related accounts and all reportable
      securities including reportable funds beneficially owned by you other than
      through a Pioneer Account, whether or not they are held in an
      employee-related account, using the form or system provided. The annual
      holdings report must be submitted to the Compliance Department by February
      15 of each year and must contain information that is current as of
      December 31 of the prior year.


      TRANSACTION REPORTS


      U.S. access persons
      U.S. access persons employed by Pioneer must direct their brokers to
      provide duplicate copies of confirmations of transactions in reportable
      securities including reportable funds other than those held through
      Pioneer Accounts, and duplicate copies of all periodic statements related
      to their employee-related account(s) to the following address:

                       Pioneer Investment Management, Inc.
                              Compliance Department
                                 60 State Street
                           Boston, Massachusetts 02109

      Such instructions must be made promptly upon becoming an access person and
      as new accounts are established, but no later than 10 calendar days after
      the end of a calendar quarter in which such account was established. You
      may arrange for a request to be sent directly to your brokerage firm from
      the Compliance Department.

      If you are unable to arrange for duplicate copies of confirmations and
      periodic account statements to be sent to Pioneer in a timely manner, you
      must immediately notify Compliance.


      Non-U.S. access persons
      Access persons employed by a non-U.S. based affiliate of Pioneer must
      report their personal securities transactions to Pioneer's Compliance
      Department within 30 calendar days after the close of each calendar
      quarter using the form or system provided by the Compliance Department.
      Quarterly transaction reports must list all brokerage accounts opened or
      closed and all reportable securities transactions executed during the
      quarter. Quarterly transaction reports must be submitted even if you did
      not enter into any transactions or open any accounts during the quarter.


      EXCEPTIONS TO REPORTING REQUIREMENTS

      You do not need to report:

     o  Transactions  and holdings in  securities  or  instruments  that are not
reportable securities;

     o Purchase  transactions effected pursuant to an automatic investment plan.
Holdings in automatic investment plans are reportable;

     o Securities  held in accounts  over which the access  person or investment
person has no direct or indirect influence or control, which includes securities
held in an  account  managed  for an  access  person or  investment  person on a
discretionary  basis by someone else.  All such accounts must be approved by the
Compliance  Department.  In addition, to rely on this exception you must arrange
for your  broker or adviser to submit a  discretionary  authorization  letter or
equivalent to the Compliance Department;

     o Transactions and holdings in a 529 Plan (accounts in 529 Plan accounts
are required to be reported);

     o Interests in variable annuity or life insurance products.

     o UCITS and other equivalent non-U.S.  funds which are similar in structure
to open-end U.S. mutual funds that are not advised by Pioneer
or its affiliates. Please contact the Compliance department if you need guidance
on which non-U.S. funds this exception applies to;

     o Futures on direct obligations of the government of the United States;

     o Transactions and holdings in currency;

     o Transactions and holdings in commodities.



PRE-CLEARANCE REQUIREMENTS

      One of the most important objectives of this Code is to prevent you from
      making personal trades on the basis of information about securities
      transactions made for Pioneer's clients. Trading on such information for
      personal benefit constitutes a violation of this Code. To reduce the
      possibility of a conflict with a client transaction, except as otherwise
      permitted by this Code, access persons must pre-clear all personal
      transactions in reportable securities (excluding reportable funds).

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

     o Do  not  possess  any  material  nonpublic  information  relating  to the
security;

     o Are not using  knowledge  of any  proposed  trade or  investment  program
relating to Pioneer's clients for personal benefit;

     o Believe the proposed trade is available to any market  participant on the
same terms; and

     o Will provide any other relevant  information  requested by the Compliance
Department.

      As part of the pre-clearance process, you will be deemed to be certifying
      that all accounts opened and all transactions executed during the calendar
      quarter have been reported and you are required to review your account(s)
      holdings information in the Personal Trading Assistant (PTA) system prior
      to submitting any pre-clearance request. You must notify the Compliance
      Department immediately if the information recorded therein is in any way
      inaccurate.

      Pre-clearance approvals may be considered invalid if it is discovered that
      the information provided at the time the transaction was approved is no
      longer accurate. You may not seek to pre-clear any transaction which, if
      approved and executed, would violate this Code.


      DE MINIMIS EXCEPTION

      Transactions by U.S access persons in reportable securities with a value
      of US$10,000 or less (or its non-U.S. equivalent) of an issuer with a
      market capitalization of US$3 billion or greater will be approved ("De
      Minimis Exception") provided the access person is deemed to have no prior
      knowledge of activity in such security by any client. For non-U.S. access
      persons the De Minimis Exception transaction limit is (euro)8,000 (this
      amount may be adjusted periodically due to exchange rate changes) or less
      provided the security is listed on a regulated exchange.

      Multiple transactions in a single day of a single security will be
      aggregated for purposes of this exemption.

      De Minimis transactions in reportable securities must be entered as a
      pre-clearance request on trade date for monitoring and record keeping
      purposes. Failure to submit a pre-clearance request for De Minimis
      Exception transactions for reporting purposes is a violation of the Code.


      EXCEPTIONS TO PRE-CLEARANCE REQUIREMENTS

      The following transactions do not require pre-clearance:

o    Transactions  in reportable  funds held in Pioneer  Savings and  Investment
     Plan, Pioneer Retirement Benefit Plan, Pioneer Investment  Management Bonus
     Deferral Plan, Pioneer Voluntary Bonus Deferral Plan,  Pioneer  Performance
     and  Retention  Incentive  Compensation  Plan and the Pioneer  Intermediate
     Deferred Compensation Award Plan;

o    Transactions in sovereign debt of foreign governments;

o    Transactions  in  non-U.S.  funds  or UCITS or  equivalent  funds  that are
     similar in structure to open-end U.S. mutual funds;

o    Transactions in pre-approved non-discretionary accounts;

o    Involuntary  purchases or sales of securities (e.g., stock splits and other
     similar  corporate  actions,  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;  or a security that is
     sold by a broker, without your consultation,  to meet a margin call not met
     by you);

o    Transactions effected pursuant to an automatic investment plan;


o    Rights offerings (i.e.,  purchases of securities effected upon the exercise
     of rights issued by an issuer  proportionately to all holders of a class of
     its securities,  to the extent such rights were acquired by associates from
     the issuer, and sales of such rights so acquired);

o    Tender offers that are involuntary (i.e., tenders of securities pursuant to
     tender  offers  that are  expressly  conditioned  on the  tender  offeror's
     acquisition  of all of the  securities of the same class).  This  exemption
     does not apply to tenders of securities pursuant to any other tender offer;

o    Transactions in securities that are not reportable securities;


o    Transactions in a 529 Plan;

o    Futures on broad based indices;

o    Acquisition of securities through inheritance; and

o    The giving or receipt of a security as a gift.




      HOW DO I PRE-CLEAR TRANSACTIONS?


      Procedures for obtaining pre-clearance for all securities transactions
      other than private placements

      Requests for pre-clearance of securities transactions other than private
      placements and initial and secondary public offerings must be made using
      PTA pre-clearance system, which is available on Navigator US. Private
      placements and initial and secondary public offerings must be pre-cleared
      manually by the Compliance Department.

      If PTA is not available, pre-clearance requests may be made in writing, or
      by electronic mail. All pre-clearance requests must include the name of
      the security, a definitive security identifier (e.g., CUSIP, ticker, or
      SEDOL), the number of shares or amount of bonds involved, and the nature
      of the transaction, i.e., whether the transaction is a purchase or sale.
      Responses to all requests will be made either through PTA or the
      Compliance Department will document the request and confirm whether or not
      pre-clearance has been granted. The Compliance Department maintains a
      record of all approval and denials.

      Requests normally will be processed on the same day however, additional
      time may be required to pre-clear certain securities transactions.

      Pre-clearance requests can only be submitted through PTA and/or to the
      Compliance Department within the designated pre-clearance timeframe. For
      U.S. access persons all approved transactions must be
      executed by 4:00 p.m. Eastern time on the day the approval is granted.
      Non-U.S. access persons must execute all approved transactions by either
      the end of the business day in which the approval was granted, or no later
      than the end of the next business day after approval is granted in their
      time zone. If you decide not to execute the transaction during the
      pre-clearance period, or the entire trade is not executed, you must
      request pre-clearance again at such time as you decide to execute or
      complete the trade.

      You may not 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.

      For pre-clearance purposes, derivative transactions are treated as
      transactions in the underlying security.


      Procedures for obtaining pre-clearance for private placements

      You must obtain prior written approval from the Compliance Department and
      the Head of Portfolio Management US before purchasing or selling, directly
      or indirectly, a security in a private placement. In considering whether
      to approve a transaction in a private placement, the Compliance Department
      and the Head of Portfolio Management US, or his or her designee, will take
      into account whether the investment opportunity should be reserved for a
      client and whether the opportunity is being offered to you by virtue of
      your position with or relationship to a client. If you are an investment
      person and have been authorized to acquire securities in a private
      placement, you should be aware that this information will be disclosed to
      the Head of Portfolio Management US. In such circumstances, a client's
      decision to purchase securities of the issuer will be subject to an
      independent review by appropriate personnel with no personal interest in
      the issuer.


      Procedures for obtaining pre-clearance for initial and secondary
      public offerings

      You may not purchase any security in an initial public offering or in a
      secondary public offering or without first obtaining written approval from
      the Compliance Department and the Head of Portfolio Management US. Any
      approval will take into account whether the investment opportunity should
      be reserved for a client and whether the opportunity is being offered to
      you by virtue of your position with or relationship to a client. If you
      are an investment person and have been authorized to acquire securities in
      an initial public offering or a secondary public offering you should be
      aware that this information will be disclosed to the Head of Portfolio
      Management US or his or her designee.



PERMITTED BROKERAGE ACCOUNTS

      U.S. access persons who begin their employment or
      otherwise became an access person with Pioneer after March 1, 2005, will
      be required to hold their reportable securities in an account with one of
      the following brokerage firms:

o        Charles Schwab

o        A.G. Edwards /Wachovia Securities

o        Merrill Lynch

o        Fidelity Brokerage

o        TD Ameritrade

o        E*Trade Financial

o        Smith Barney Citigroup

o        UBS Financial

o        Morgan Stanley

o        Scottrade

      Access persons who began their employment or otherwise became access
      persons before March 1, 2005 will be required to open new brokerage
      accounts with one of the above listed brokerage firms.

      New access persons will have 90 days from their date of hire or date they
      become an access person to transfer the existing accounts to a broker at
      one of the above brokerage firms. If your employment with Pioneer began
      before March 1, 2005, or you otherwise became an access person before
      March 1, 2005, you will be allowed to continue to hold your accounts with
      brokerage firms other than one of those named above. However, if you hold
      an account with a firm other than the above firm, and seek to move your
      account(s) to another firm, then you must use one of the above firms.

      The restriction on brokerage accounts does not apply to non-discretionary
      accounts or accounts that are not capable of holding reportable
      securities.

      Upon opening an account, you are required to disclose the account to the
      Compliance Department immediately after the account is opened. You must
      also agree to allow the broker-dealer to provide the Compliance Department
      with reports of employee-related accounts and transactions executed
      therein and to allow the Compliance Department to access all account
      information.

      You are required to receive approval from the Compliance Department to
      maintain an employee-related account with broker-dealers other than those
      on the list. Permission to open or maintain employee-related accounts with
      a broker-dealer other than those on the list of approved brokers may not
      be granted or may be revoked if transactions are not reported as described
      above.



RESTRICTIONS ON PERSONAL INVESTMENTS

      The restrictions in the Code apply equally to the covered transactions and
      to instruments related to the covered transaction. A related instrument is
      any security or instrument issued by the same entity as the issuer of the
      covered transaction, including options, rights, warrants, preferred stock,
      bonds and other obligations of that issuer or instruments otherwise
      convertible into securities of that issuer.

      The restrictions and blackout periods listed below are designed to avoid
      conflict with our clients' interests. However, patterns of trading that
      meet the letter of the Code but are intended to circumvent the
      restrictions are prohibited. It is expected that you will comply with the
      restrictions below in good faith and conduct your personal securities
      transactions in keeping with the intended purpose of this Code.


      ENGAGE IN ACTIVITIES FOR PERSONAL BENEFIT

      You may not induce or cause a client to take action, or to fail to take
      action, when you intend for such action to benefit you personally rather
      than primarily the client. For example, you would violate this Code by
      causing a client to purchase or refrain from selling a security you owned
      for the purpose of supporting or increasing the price of that security.


      PROFIT FROM KNOWLEDGE OF CLIENT TRANSACTIONS

      You may not use your knowledge of client transactions to profit by the
      market effect of such transactions. This means that you may not purchase
      or sell a security when you knew, or should have known, that the security
      was being considered for any client. For example:

o    You may not front-run  any trade of a client  (i.e.,  you may not knowingly
     trade before a contemplated  transaction for a client). You could be deemed
     to be front-running if you:

o    Purchase a security  while  knowing that Pioneer  intended to purchase that
     security for a client; or

o    Sell a security  while knowing that Pioneer  intended to sell that security
     for a client.

o    You cannot  purchase  a  security  (or its  economic  equivalent)  with the
     intention of recommending  that the security be purchased for a client,  or
     sell short a security (or its economic  equivalent)  with the  intention of
     recommending that the security be sold for a client.

o        You cannot:

o    Buy a  security  if you know that  Pioneer  is buying the same or a related
     security for a client at the same time;

o    Sell a security  if you know that  Pioneer is selling the same or a related
     security for a client at the same time; or

o    Transact  in  securities  of any  issuer  for  which you  possess  material
     nonpublic information for yourself or any Pioneer client.

      INTENTIONALLY EVADE THE PROSPECTUS REQUIREMENTS OF PIONEER FUNDS

      All transactions in shares of a Pioneer fund must be consistent with the
prospectus requirements applicable to the fund.


      TRADING RESTRICTIONS

      Access persons may not:


o    Transact in reportable securities without pre-clearance, with the exception
     of reportable funds.

o    Perform  intraday  trading,  that is buying and selling  the same  security
     (even for a different quantity) in the same day.

o    Fail to disclose personal interests in recommended securities.  You may not
     recommend any securities  transaction  for a client  without  disclosing in
     advance any interest that you or any member of your immediate family has in
     such security or the issuer thereof to the Head of Portfolio  Management US
     or  the  person  expected  to act  on  such  recommendation.  You  may  not
     participate in the decision to purchase and sell  securities of such issuer
     for a client. Factors that should be disclosed include, but are not limited
     to:

o    Your beneficial ownership of any securities of such issuer;

o    Any contemplated transaction by you in such securities;

o    Any position with such issuer or its  affiliates  held by you or any member
     of your immediate family; and

o    Any  present  or  proposed  business  relationship  (including  employment)
     between  such  issuer  or its  affiliates  and  you or any  member  of your
     immediate  family or any party in which you or any member of your immediate
     family have a significant interest.

o    Participate in investment clubs.



      ACCOUNTS OF OTHER PEOPLE

      Investment persons may not manage discretionary accounts of persons
      outside of your immediate family. You may not exercise investment
      discretion over accounts in which you have no beneficial interest. If you
      wish to apply for a waiver, you must contact the Compliance Department.


      BLACKOUT DATES FOR TRADING

      Investment persons may not buy or sell a security within seven calendar
      days before or after a client trades in the same security. You will not be
      deemed to have violated this restriction if your trade occurs within the
      seven-day period prior to the client trade, you did not know and had no
      reason to believe that a trade for a client in such security was being
      considered, and your transaction was pre-cleared.


      Access persons may not buy or sell a security on the same day a client
      trades in that security except for pre-cleared transactions.


      DERIVATIVES

      Access persons cannot use derivatives including futures, options on
      futures, or options or warrants on a reportable security to evade the
      restrictions of the Code. Trading in listed and unlisted options
      (including naked options), other than listed option transactions in broad
      based indices, and speculative strategies such as spreads and straddles in
      reportable securities are not permitted.


      EXCESSIVE TRADING

      You are discouraged from trading excessively. Pioneer strongly discourages
      high levels of personal trading activity and monitors such activity. If it
      is determined that you have engaged in a pattern of excessive trading,
      Pioneer may place restrictions on your personal trading or take other
      disciplinary action.


      SHORT SALES

      No access person may sell a reportable security short.


      HOLDING PERIOD

      No access person may profit from the purchase and sale, or sale and
      purchase, of the same (or equivalent) reportable security excluding
      reportable funds, within 60 calendar days from the date of the purchase or
      sale. Transactions in reportable fund transactions must be consistent with
      the prospectus requirements applicable to each fund and monitored by each
      fund's transfer agent.

      This provision does not apply to transactions in reportable securities
      that are exempt from pre-clearance described above.



EXCEPTIONS PERTAINING TO NON-U.S. PERSONS

      The following exceptions have been approved for non-U.S. access persons
      that are employed by Pioneer Investment Management Limited ("PIML"):

o    Requests for  pre-clearance  of  securities  transactions  are  pre-cleared
     manually  by the  Compliance  Department  using the  forms  and  procedures
     provided by PIML's Compliance Department.

o    Initial  Certifications are completed using the forms or system provided by
     PIML's Compliance Department;

o    The De Minimis Exception transaction limit is (euro)8,000 (this amount may
     be adjusted periodically due to exchange rate changes) or less, provided
     the security is listed on a regulated exchange.

o    All  approved  transactions  must  be  executed  by  either  the end of the
     business day in which the approval was granted, or no later than the end of
     the next business day after approval is granted in the access person's time
     zone.

o    The Code's trading prohibitions relating to blackout and derivative trading
     will not apply to the PIML  access  persons  provided it is  determined  by
     PIML's Compliance Department during the pre-clearance approval process that
     there is no conflict or potential conflict with the U.S. clients'
     interests.  This  analysis  will  include a review  and a written
     determination  that  there  is  no  conflict  with  U.S. clients'
     transactions  and  holdings  in  covered   transactions  and  to
     instruments related to the covered transaction.

III. ADMINISTRATION AND ENFORCEMENT
      The Compliance Department is charged with oversight and interpretation of
      the Code in a manner considered fair and equitable, in all cases placing
      Pioneer's clients' interests first.

      The Compliance Department will inform you if you are considered an access
      person under the Code. Pioneer shall use reasonable diligence and
      institute procedures reasonably necessary to prevent violations of the
      Code.

      A copy of the Code is available on Navigator US. Likewise, any amendments
      to the Code will be posted on Navigator US promptly after they become
      available. Associates will be given notice of all changes to, or
      restatements of, the Code.

      Acknowledgement of, and compliance with, the Code is a condition of
      employment with Pioneer. The Code does not create any obligations to any
      person or entity other than Pioneer. The Code is not a promise or
      contract, and it may be modified at any time. Pioneer retains the
      discretion to decide whether the Code applies to a specific situation, and
      how it should be interpreted.


      REVIEW

      The Compliance Department will review on a regular basis the reports filed
      pursuant to the Code. In this regard, special attention will be given to
      evidence, if any, of potential violations of the antifraud provisions of
      the federal securities laws or the procedural requirements or ethical
      standards set forth in the Code.


      REPORTING VIOLATIONS OF THE CODE

      Pioneer relies upon you to report promptly any conduct you believe to be a
      violation of the Code. You must report violations or suspected violations
      of the Code to the Compliance Department or a Pioneer lawyer. All such
      reports or inquiries will be subject to investigation.

      Pioneer will not tolerate any form of retaliation against an associate 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 an associate if, upon
      investigation, it determines that the associate was dishonest or malicious
      in making the report or providing information to investigators.

      In conducting an investigation, Pioneer will attempt to keep the
      identities of the associate 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 or to other authorities.


      VIOLATIONS AND SANCTIONS

      Compliance with the Code is expected and violations of its provisions are
      taken seriously. You must recognize that the Code is a condition of
      employment with Pioneer, and a serious violation of the Code or related
      policies may result in termination of your employment. Since many
      provisions of the Code also reflect provisions of the U.S. Securities
      laws, you should be aware that violations could also lead to regulatory
      enforcement action resulting in suspension or expulsion from the
      securities business, fines and penalties, and imprisonment.

      Federal law requires that the Code must not only be adopted, but must be
      enforced with reasonable diligence. The Compliance Department will keep
      records of any violation of the Code and of the actions taken as a result
      of such violations.


      Sanctions
      Violations of this Code may result in the imposition of the sanctions as
      published by the Compliance Department from time to time. These sanctions
      may include, but are not limited to: terminating or suspending your
      employment; suspending your personal trading privileges; issuing a letter
      of censure or warning; requiring you to pay a fine; requiring you to
      compensate the affected client for an amount equal to the advantage you
      gained by reason of such violation; and requiring you to reverse the
      trade(s) at issue and forfeit any profit or absorb 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, your 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 your personnel record after a period of five years from
      the date of the violation.


      HARDSHIP EXEMPTIONS

      In cases of hardship, the CCO or their designee can grant exemptions from
      the restrictions in the Code. The decision will be based on a
      determination that a hardship exists and that the transaction for which an
      exemption is requested would not result in a conflict with Pioneer's
      clients' interests or violate any other policy embodied in this Code.
      Other factors that may be considered include: the size and holding period
      of your 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.

      If you are seeking an exemption you should submit a written request to the
      CCO, setting forth the nature of the hardship along with any pertinent
      facts and reasons why you believe the exemption should be granted. You are
      cautioned that 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.


      APPEALS

      If you believe you have been treated unfairly by any action rendered with
      respect to a violation of the Code or a waiver request, you may appeal the
      determination by providing the Compliance Department with a written
      explanation within 30 calendar days of being informed of such
      determination. If appropriate, the Compliance Department will arrange for
      a review by senior management of Pioneer will advise you whether the
      action will be imposed, modified or withdrawn.


      REPORTING TO THE MANAGEMENT COMMITTEE

      Once a year, the CCO will prepare a report for the Management Committee of
      Pioneer Investment Management USA Inc. that will:

o    Summarize current procedures under the Code and changes to those procedures
     since the prior report;

o    Describe  any issues  arising  under the Code since the last  report to the
     Board  or  the  Management  Committee,   including,  but  not  limited  to,
     information about material  violations of the Code and sanctions imposed in
     response to the material violations; and

o    Discuss any recommended changes to the Code.

CONFIDENTIALITY
      Normally, Pioneer will keep all information obtained under this Code in
      strict confidence. However, violations will be reported to senior
      management and Pioneer may report information to third parties under
      certain circumstances. For example, Pioneer may make reports of securities
      transactions and violations of this Code available to clients or former
      clients, the Securities and Exchange Commission or any other regulatory or
      self-regulatory organization to the extent required by law or regulation,
      or to other civil or criminal authorities if Pioneer considers it to be
      necessary or advisable.


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


QUESTIONS AND EDUCATIONAL MATERIALS
      You are encouraged to bring to the Compliance Department any questions you
      may have about interpreting or complying with this Code about securities,
      accounts or personal trading activities of associates or your family or
      household members, about your legal or ethical responsibilities, or about
      similar matters that may involve this Code. U.S associates of Pioneer
      should contact Geraldine Leahy or Leah Rumbaua with any questions.
      Associates of Pioneer Investment Management Limited should contact
      Veronica Brennan and associates of Pioneer Global Asset Management S.p.A.
      should contact Cristina Costigliolo.

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





<PAGE>




IMPORTANT TERMS


       Term                    Definition

       Access person           Access person is defined as 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. Generally, you are an
                               "access person" if you are a "supervised person"
                               of Pioneer and:

                               o Are an officer, or director or employee of
                                 Pioneer;

                               o Have access to information regarding the
                                 purchase or sale of a security by
                                 Pioneer for its clients;

                               o Have access to information regarding
                                 recommendations of securities to
                                 client or whose function relates to the making
                                 of such recommendations;

                               o Have access to nonpublic information regarding
                                 any clients' purchase or
                                 sale of securities or regarding the holdings
                                 of any fund advised or sub-advised by Pioneer;
                                 or

                               o Are an investment person.


                               Generally, examples of "access to information"
                               would include having access to trading systems
                               (e.g., CRD or PMA), portfolio accounting systems
                               (e.g., MFact), research databases, or settlement
                               information. Access persons typically include
                               associates in the following departments:

                               o        Fund accounting;

                               o        Investment operations;

                               o        Information services & technology;

                               o        Product management;

                               o        Legal and compliance; and

                               o        Risk.

                               The Compliance Department will determine who is
                               an access person under the Code of Ethics.

       Associate               Associate means an employee, including a
                               temporary employee, and an independent
                               contractor.

       Automatic investment    Automatic investment plan means a program in
       plan                    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 ownership    Beneficial ownership is interpreted in
                               the same manner as it would be under Rule
                               16a-1(a)(2) of The Securities Exchange Act of
                               1934 (the "Exchange Act") determining whether a
                               person is the beneficial owner of a security for
                               purposes of section 16 of the Exchange Act and
                               the rules and regulations thereunder.

                               Generally, you have beneficial ownership in a
                               security if you have the opportunity directly or
                               indirectly to receive or share in any profit
                               derived from a transaction in the security,
                               whether or not the security or the relevant
                               account is in your name or is held in an ordinary
                               brokerage or retirement plan account. The
                               ultimate determination of whether you have
                               beneficial ownership in a security or an account
                               depends on the facts of your particular case. Key
                               factors you should consider are your ability to
                               benefit from the proceeds of the security, and
                               the degree to which you exercise control over the
                               security.

                               You are generally presumed to be the beneficial
                               owner of:

                                        o Securities held by you, your
                                          spouse/domestic partner or members of
                                          your immediate family sharing your
                                          household;

                                        o Securities held by a trust, in which
                                          you have a direct or
                                          indirect pecuniary interest;

                                        o Your proportionate interest in
                                          securities held by a partnership,
                                          corporation or similar entity under
                                          your control;

                                        o Securities held by an unmarried
                                          person with whom you share your
                                          household and combine your
                                          financial resources in a manner
                                          similar to that of married persons;
                                          and

                                        o Securities you have a right to
                                          acquire through the exercise or
                                          conversion of a "derivative
                                          security."

       CCO                     Chief Compliance Officer of Pioneer Investment
                               Management, Inc ("PIM") and /or the Chief
                               Compliance Officer of Pioneer Institutional Asset
                               Management, Inc ("PIAM").

       Derivative              A financial security, such as an option or
                               future, whose characteristics and value depend on
                               the characteristics and value of an underlying
                               security. A convertible bond is not a derivative
                               for the purposes of this Code of Ethics.

       Employee-related        An employee-related account is an account in
       account                 which securities are held account for your
                               benefit. It includes, but is not limited to:

                                o Your own accounts and accounts "beneficially
                                  owned" by you;

                                o Your spouse's/domestic partner's accounts and
                                  the accounts of any members of your immediate
                                  family sharing your household; and

                                o Accounts in which you, your
                                  spouse/domestic partner, or members
                                  of your immediate family sharing
                                  your household have a beneficial
                                  interest.

       Immediate family        Any child, stepchild, grandchild, parent,
                               stepparent, grandparent, spouse, sibling,
                               mother-in-law, father-in-law, son-in-law,
                               daughter-in-law, brother-in-law, or
                               sister-in-law, including adoptive relationships.

       Initial public          This means any offering of securities registered
       offerings               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              This encompasses any influence
       discretion              (whether it is sole or shared, direct or
                               indirect) that you exercise over an account or
                               reportable security. It includes the power to
                               manage, trade or give instructions concerning the
                               investment disposition of assets in an account or
                               to approve or disapprove transactions in an
                               account.

       Investment persons      You are an "investment person" if you:


                               o Are involved in making securities
                                 recommendations to clients; or

                               o Are a portfolio management, research or trading
                                 associate.

       Pioneer Account         Each of Pioneer Savings and Investment
                               Plan, Pioneer Retirement Benefit Plan, Pioneer
                               Investment Management Bonus Deferral Plan,
                               Pioneer Voluntary Bonus Deferral Plan, Pioneer
                               Performance and Retention Incentive Compensation
                               Plan and the Pioneer Intermediate Deferred
                               Compensation Award Plan or any other account held
                               directly through Pioneer.

       Private placement       An offering of securities 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         A reportable fund is any open-end
                               US mutual fund advised or
                               sub-advised by PIM or distributed by Pioneer
                               Funds Distributor ("PFD") (e.g., the Pioneer
                               Funds). Such funds generally include the Pioneer
                               Funds, Pioneer's VCT Portfolios, and any funds
                               for which Pioneer serves as subadviser. A
                               complete list of reportable funds is available on
                               Navigator US under Business Units / Legal &
                               Compliance / [name]/ [name].

     Reportable security       Reportable security means a security as
                               defined by section 2(a)(36) of the Investment
                               Company Act of 1940. The term "reportable
                               security" is very broad and includes stocks,
                               bonds, including convertible and preferred
                               securities, ADRs and GDRs, warrants and rights
                               and other instruments you might not ordinarily
                               think of as securities, such as:

                               o All kinds of limited partnerships;

                               o Limited Liability Company Interests;

                               o Private investment funds, hedge funds and
                                 investment clubs;

                               o Futures on securities;

                               o Options on securities;

                               o Closed-end funds;

                               o Exchange-traded funds; and

                               o 529 plans (legally known as
                                 "qualified tuition plans" sponsored
                                 by states, state agencies or
                                 educational institutions and
                                 authorized by Section 529 of the
                                 Internal Revenue Code).

                               Reportable securities do not include:
                               o Direct obligations of the government of the
                                 United States (note that securities issued
                                 by agencies or instrumentalities of the
                                 U.S. government (e.g., GNMA obligations),
                                 municipal obligations and obligations of
                                 other governments are reportable securities);

                               o Bankers' acceptances;

                               o Bank certificates of deposit;

                               o Commercial paper;

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

                               o Shares of open-end investment
                                 companies registered under the
                                 Investment Company Act of 1940, as
                                 amended that is not advised or
                                 subadvised by PIM.

       Secondary Public        Is a registered offering of a block of a
       Offering                reportable security which had been previously
                               issued to the public.

       Supervised Person       "Supervised person" means any partner,
                               officer, director (or any other person occupying
                               a similar status or performing similar
                               functions), or employee of Pioneer, or other
                               person who provides investment advice on behalf
                               of the investment adviser and is subject to the
                               supervision and control of the investment
                               adviser.