THE PIONEER COMPLEX OF FUNDS
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                                 CODE OF ETHICS
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                                  INTRODUCTION


This Code of Ethics (the "Code") has been adopted by each registered investment
company (individually an "Investment Company" and collectively the "Investment
Companies") for which Pioneer Investment Management, Inc. ("Pioneer
Investments") serves as an investment adviser or for which Pioneer Funds
Distributor, Inc. ("PFD") serves as principal underwriter, Pioneer Investments
and PFD. The Code is applicable to Access Persons, including Independent
Trustees, of the Investment Companies, as well as Access Persons of Pioneer
Investments and PFD. Pioneer Investments, PFD and the Investment Companies are
sometimes together referred to herein as "Pioneer."

Pioneer and its affiliated entities are committed to maintaining the highest
ethical standards in connection with the management of investment companies and
institutional accounts. Dishonesty, self-dealing, conflicts of interest and
trading on material non-public information will not be tolerated.

The Code reflects Pioneer's views on dishonesty, self-dealing and conflicts of
interest. Every person who has been designated by Pioneer as an "Access Person"
is required to read the Code annually and to certify that he/she has complied
with its provisions and with the reporting requirements. In addition, every
employee of Pioneer is subject to Pioneer's Policies and Procedures to Prevent
Insider Trading.

Any person who has any question regarding the applicability of the Code or
Pioneer's Policies and Procedures to Prevent Insider Trading or the related
prohibitions, restrictions and procedures or the propriety of any action, is
urged to contact the Office of the General Counsel.


                                    SECTION 1

                               STATEMENT OF POLICY

Section 17(j) of the Investment Company Act of 1940 (the "1940 Act") provides,
among other things, that it is unlawful for any Access Person of Pioneer to
engage in any act, practice or course of business in connection with the
purchase or sale, directly or indirectly, by such Access Person of any Covered
Security held or to be acquired by an Investment Company in contravention of
such rules and regulations as the Securities and Exchange Commission (the
"Commission") may adopt to define and prescribe means reasonably necessary to
prevent such acts, practices or courses of business as are fraudulent, deceptive
or manipulative.

It is the policy of Pioneer that no Access Person shall engage in any act,
practice or course of conduct that would violate the provisions of Section 17(j)
and the rules thereunder. The fundamental position of Pioneer is, and has been,
that each Access Person shall place at all times the interests of the Investment
Companies and their shareholders and the Institutional Accounts ahead of his/her
private Covered Securities transactions. Accordingly, private Covered Securities
transactions by Access Persons must be conducted in a manner consistent with
this Code so as to avoid any actual or potential conflict of interest or any
abuse of an Access Person's position of trust and responsibility. Further,
Access Persons should not take inappropriate advantage of their positions with
or relationships to any Investment Company, any Institutional Account or
Pioneer.


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Without limiting in any manner the fiduciary duty owed by Access Persons or the
provisions of this Code, it should be noted that Pioneer considers it proper
that purchases and sales be made by its Access Persons in the marketplace of
Covered Securities owned by the Investment Companies or Institutional Accounts;
PROVIDED, HOWEVER, that such personal Covered Securities transactions comply
with the spirit of, and the specific restrictions and limitations set forth in,
this Code. Such personal Covered Securities transactions also should be made in
amounts consistent with the normal investment practice of the Access Person
involved and with an investment, rather than a trading, outlook. Not only does
this policy encourage investment freedom and result in establishing investment
experience, but it also fosters a continuing personal interest in such
investments by those responsible for the continuous supervision of the
portfolios of the Investment Companies and Institutional Accounts. In making
personal investment decisions with respect to any Covered Security, extreme care
must be exercised by Access Persons to ensure that the prohibitions of this Code
are not violated. Further, personal investing by Access Persons should be
conducted in such a manner so as to eliminate the possibility that the Access
Person's time and attention is being devoted to his/her personal investments at
the expense of time and attention that should be devoted to management of an
Investment Company's or Institutional Account's portfolio. It should be
emphasized that technical compliance with the procedures, prohibitions and
limitations of this Code will not automatically insulate from scrutiny personal
Covered Securities transactions by an Access Person which show a pattern of
abuse of his/her fiduciary duty to any Investment Company or Institutional
Account.


                                    SECTION 2

                                   DEFINITIONS

2.1      ACCESS PERSON.  The term "Access Person" shall mean the following:

o             The term "Access Person" with respect to an Investment Company
              shall mean any Trustee, officer or Advisory Person of such
              Investment Company.

o             The term "Access Person" with respect to Pioneer Investments shall
              mean any general partner, director, officer or Advisory Person of
              Pioneer Investments.

o             The term "Access Person" with respect to PFD shall mean any
              director or officer of PFD who in the ordinary course of business
              makes, participates in or obtains information regarding the
              purchase or sale of Covered Securities for an Investment Company
              for which PFD acts, or whose functions or duties, in the ordinary
              course of business, relate to the making of any recommendation to
              an Investment Company or Institutional Account regarding the
              purchase or sale of Covered Securities.

2.2      ADVISORY PERSON. The term "Advisory Person" shall mean (i) every
         employee of an Investment Company, Pioneer Investments, PFD or The
         Pioneer Group, Inc. ("PGI") (or any other company in a Control
         relationship with Pioneer Investments) who, in connection with his or
         her regular functions or duties, makes, participates in, or obtains
         information regarding, the purchase or sale of a Covered Security by an
         Investment Company or Institutional Account, or whose functions relate
         to the making of any recommendations with respect to such purchases or
         sales, (ii) every natural person in a Control relationship to an
         Investment Company, Pioneer Investments, PFD or


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         PGI who obtains
         information concerning recommendations made to an Investment Company or
         Institutional Account with regard to the purchase or sale of a Covered
         Security and (iii) any other employee or independent contractor of any
         Investment Company, Pioneer Investments, PFD or PGI designated as an
         Advisory Person by the Review Officer. Advisory Person shall not
         include directors of PGI who are not also officers or employees of
         Pioneer Investments, PFD, PGI or an Investment Company.

2.3      BENEFICIAL OWNERSHIP "Beneficial Ownership" of a security shall mean
         having or sharing an opportunity, either directly or indirectly,
         through any contract, arrangement, understanding, relationship or
         otherwise, to profit or share in any profit derived from a transaction
         in a security. Indirect opportunities to profit or share in any profit
         would be deemed to exist as a result of, but not limited to, the
         following:

o             securities held by members of an Access Person's immediate family
              sharing the same household (I.E., any child, stepchild,
              grandchild, parent, stepparent, grandparent, spouse, sibling,
              mother-in-law, father-in-law, son-in-law, daughter-in-law,
              brother-in-law, sister-in-law, including adoptive relationships)
              or any other individual(s) sharing the same household;

o             a general partner's proportionate interest in securities held by
              a general or limited partnership;

o             a performance-related fee, other than an asset-based fee, received
              by any broker, dealer, bank, insurance company, investment
              company, investment adviser, investment manager, trustee or person
              or entity performing a similar function;

o             the right to dividends which is separate or separable from the
              underlying security;

o             an Access Person's interest in securities held by a trust; or

o             an Access Person's right to acquire securities through the
              exercise or conversion of any derivative security.

2.4      CONSIDERED FOR PURCHASE OR SALE. A Covered Security is being
         "Considered for Purchase or Sale" by an Investment Company or
         Institutional Account during any period in which Pioneer Investments
         is: (i) actively trading or attempting to trade in the Covered Security
         for an Investment Company or Institutional Account; (ii) passively
         interested in trading in the Covered Security for an Investment Company
         or Institutional Account, I.E., would buy or sell the Security within a
         price range communicated to Pioneer Investments' trading department; or
         (iii) considering, within an Investment Committee of Pioneer
         Investments, the implementation of a trading program for the Covered
         Security (including any period during which the Investment Committee is
         in receipt of a recommendation with respect to which it has not yet
         made a decision). With respect to a Pioneer Investments analyst, the
         foregoing period shall commence on the day that he/she decides to
         recommend the purchase or sale of the Covered Security to the
         Investment Committee of Pioneer Investments and shall continue for a
         period of three months after such date.

2.5      CONTROL. The term "Control" shall mean the power to exercise a
         controlling influence over the management or policies of Pioneer
         Investments, PFD or PGI, unless such power is solely the result of an
         official position with Pioneer Investments, PFD or PGI, all as
         determined in accordance with Section 2(a)(9) of the 1940 Act.

2.6      COVERED SECURITY. The term "Covered Security" shall have the meaning
         set forth in Section 2(a)(36) of the 1940 Act and also shall include
         other derivative financial instruments


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         (including, but not limited to, options, futures contracts and options
         on futures contracts) except that it shall not include:

o        Direct obligations of the government of the United States;

o        Bankers' acceptances;

o        Bank certificates of deposit;

o        Commercial paper;

o        High quality short-term debt instruments, including repurchase
         agreements (I.E., any instrument that has a maturity at issuance
         of fewer than 366 days and that is rated in one of the two highest
         rating categories by a Nationally Recognized Statistical Rating
         Organization); or

o        Shares of registered open-end investment companies, including the
         Investment Companies.

         (For reporting purposes, transactions in shares of Pioneer Interest
         Shares must be reported.)

2.7      FIDUCIARY ACCOUNT. "Fiduciary Account" is an account with respect to
         which an Access Person is an investment adviser, trustee or other
         fiduciary and in which the Access Person does not otherwise have any
         Beneficial Ownership interest.

2.8      INDEPENDENT TRUSTEE.  "Independent Trustee" shall mean any Trustee of
         an Investment Company who is not an "interested person" (within the
         meaning of Section 2(a)(19) of the 1940 Act) of the Investment
         Company, Pioneer Investments or PFD.

2.9      INITIAL PUBLIC OFFERING. "Initial Public Offering" shall mean an
         offering of securities registered under the Securities Act of 1933, the
         issuer of which, immediately before registration, was not subject to
         the reporting requirements of Section 13 or 15(d) of the Securities
         Exchange Act of 1934.

2.10     INSTITUTIONAL ACCOUNT.  "Institutional Account" refers to any account,
         other than an Investment Company, to which Pioneer Investments provides
         investment advice.

2.11     INVESTMENT COMPANY.  "Investment Company" refers to any U.S. registered
         investment company for which Pioneer Investments serves as an
         investment adviser or subadviser or for which PFD serves as principal
         underwriter.  "Investment Companies" refers to all such companies.

2.12     LIMITED OFFERING. "Limited Offering" shall mean an offering of
         securities that is exempt from registration under the Securities Act of
         1933 pursuant to Section 4(2) or Section 4(6) or pursuant to Rules 504,
         505 or 506 under the Securities Act of 1933.

2.13     MATERIAL NON-PUBLIC INFORMATION. "Material Non-Public Information" with
         respect to an issuer is information, not yet released to the public,
         that would have a substantial likelihood of affecting a reasonable
         investor's decision to buy or sell any Covered Securities of such
         issuer.


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2.14     PORTFOLIO MANAGER. "Portfolio Manager" shall mean every person who is
         responsible for the day-to-day management of an Investment Company or
         an Institutional Account, or every person who shares such
         responsibility with another Portfolio Manager.

2.15.    PRECLEARANCE OFFICER. "Preclearance Officer" shall mean the officer of
         Pioneer Investments designated from time to time by the Chairman of
         Pioneer Investments to provide written prior approval of purchases and
         sales by Access Persons. The term "Alternative Preclearance Officer"
         shall mean the officer designated from time to time by the Chairman of
         Pioneer Investments to provide written prior approval of purchases and
         sales by the Preclearance Officer, as well as Access Persons when the
         Preclearance Officer is not available, and who shall act in all
         respects in the manner prescribed herein for the Preclearance Officer.

2.16     REVIEW OFFICER. "Review Officer" shall mean the officer of Pioneer
         Investments designated from time to time by the Chairman of Pioneer
         Investments to receive and review reports of purchases and sales by
         Access Persons. The term "Alternative Review Officer" shall mean the
         officer designated from time to time by the Chairman of Pioneer
         Investments to receive and review the reports of purchases and sales by
         the Review Officer, as well as Access Persons when the Review Officer
         is not available, and who shall act in all respects in the manner
         prescribed herein for the Review Officer.

                                    SECTION 3

                              PROHIBITED ACTIVITIES

While the scope of actions which may violate the Statement of Policy set forth
above cannot be exactly defined, such actions would always include at least the
following prohibited activities:

3.1      Except on behalf of Fiduciary Accounts with respect to such Access
         Person, no ACCESS PERSON who is not an Independent Trustee shall enter
         an order for the purchase or sale of a Covered Security which an
         Investment Company or Institutional Account is purchasing or selling or
         considering for purchase or sale until the later of (i) the day after
         the Investment Company's or Institutional Account's transaction in that
         Covered Security is completed or (ii) after the Investment Company or
         Institutional Account is no longer considering the Covered Security for
         purchase or sale, unless the Review Officer determines, after
         disclosure and review of all material information, that it is clear
         that, in view of the nature of the Covered Security and the market for
         such Covered Security, the order of the Access Person will not
         adversely affect the price paid or received by the Investment Company
         or Institutional Account and that the order of the Access Person will
         not be advantaged by the transaction by the Investment Company or
         Institutional Account. Any Covered Securities transactions by an Access
         Person in violation of this Subsection 3.1 shall, at the discretion of
         the Chairman of Pioneer Investments, be reversed, any profits disgorged
         to the affected Investment Company or Institutional Account or to
         charity or other appropriate sanctions imposed.

         Except on behalf of Fiduciary Accounts as to which the Independent
         Trustee is a fiduciary, no Independent Trustee shall enter an order for
         the purchase or sale of a Covered Security if he/ she knew or, in the
         ordinary course of fulfilling his/ her official duties as an
         Independent Trustee, should have known, that during the 15-day period
         immediately before or after the entry of such order, such Covered
         Security was purchased or sold by an Investment Company, or such
         Covered Security was considered by Pioneer Investments for purchase or
         sale by an Investment Company.


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3.2      No ACCESS PERSON shall, directly or indirectly, purchase or sell any
         Covered Security in which he/she has, or by reason of such purchase
         acquires, any Beneficial Ownership interest within a period of seven
         calendar days before and after any Investment Company or Institutional
         Account advised by Pioneer Investments has purchased or sold such
         Covered Security or within seven calendar days of the Covered Security
         being recommended for purchase or sale by Pioneer Investments. Any
         Covered Security transaction by an Access Person in violation of this
         Subsection 3.2 shall, at the discretion of the Chairman of Pioneer
         Investments, be reversed, any profits disgorged to the affected
         Investment Company or Institutional Account or to charity or other
         appropriate sanctions imposed. The provisions of this Subsection 3.2
         are subject to a DE MINIMUS exception for Access Persons other than
         Advisory Persons at the discretion of the Preclearance Officer.

3.3      No ACCESS PERSON shall purchase or sell, or cause to be purchased or
         sold, any Covered Security for a Fiduciary Account as to which he/she
         is a fiduciary if any such purchase or sale may, to the reasonable
         knowledge of such Access Person, adversely affect the interest of an
         Investment Company or Institutional Account in purchasing or selling
         such Covered Security or use the transaction by an Investment Company
         or Institutional Account to advantage such Fiduciary Account. Covered
         Securities transactions for a Fiduciary Account which may adversely
         affect an Investment Company or Institutional Account include (i)
         purchases that put upward pressure on the price of a Covered Security
         being purchased or considered for purchase or (ii) sales that put
         downward pressure on the price of a Covered Security being sold or
         considered for sale by an Investment Company or Institutional Account.

         No Access Person shall be in violation of this Subsection 3.3 with
         respect to:

o             a transaction in a Covered Security for Fiduciary Accounts if the
              aggregate number of shares included in all such transactions on
              any trading day does not exceed the lesser of (x) 1% of the
              outstanding shares of the Covered Security or (y) the average
              weekly trading volume of shares of such Covered Security during
              the four previous calendar weeks; or

o             the sale of a Covered Security on behalf of a Fiduciary Account by
              an Access Person acting in good faith in fulfillment of his/her
              fiduciary duty to sell the Covered Security.

3.4      No ACCESS PERSON shall, directly or indirectly, without first obtaining
         approval of the President of Pioneer Investments, communicate to any
         person any Material Non-Public Information relating to any issuer of
         any Covered Security owned by an Investment Company or Institutional
         Account. No Access Person shall, directly or indirectly, without first
         obtaining approval of the President of Pioneer Investments, communicate
         to any person who is not an Access Person any Material Non-Public
         Information relating to an Investment Company or Institutional Account,
         including, without limitation, the purchase or sale or the considered
         purchase or sale of a Covered Security on behalf of such Investment
         Company or Institutional Account, except to the extent necessary to
         effect Covered Securities transactions on behalf of such Investment
         Company or Institutional Account. No Access Person shall trade on or
         otherwise use any Material Non-Public Information for his /her personal
         benefit or for the benefit of any other person or entity or otherwise
         act in a manner detrimental to the Covered Securities transactions of
         an Investment Company or Institutional Account.

3.5      No ACCESS PERSON shall engage in, or permit anyone within his /her
         Control to engage in, any act, practice or course of conduct which
         would operate as a fraud or deceit upon, or constitute a manipulative
         practice with respect to, an Investment Company or Institutional
         Account or any


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         issuer of any Covered Security owned by an Investment
         Company or Institutional Account or which would violate Pioneer's
         Policies and Procedures to Prevent Insider Trading Violations.

3.6      No ADVISORY PERSON shall, directly or indirectly, purchase any security
         pursuant to an Initial Public Offering. Access Persons (other than
         Advisory Persons) shall not directly or indirectly purchase any
         security pursuant to an Initial Public Offering without obtaining prior
         written approval from the Preclearance Officer, after disclosure to and
         review by the Preclearance Officer of all material information. Any
         approval will take into account whether the investment opportunity
         should be reserved for an Investment Company or Institutional Account
         and whether the opportunity is being offered to Access Person by virtue
         of his /her position with or relationship to an Investment Company or
         Institutional Account.

3.7      No ADVISORY PERSON shall, directly or indirectly, purchase any security
         sold in a Limited Offering without obtaining prior written approval
         from the Preclearance Officer, after disclosure to and review by the
         Preclearance Officer of all material information. Any approval will
         take into account whether the investment opportunity should be reserved
         for an Investment Company or Institutional Account and whether the
         opportunity is being offered to such Advisory Person by virtue of his
         /her position with or relationship to an Investment Company or
         Institutional Account.

3.8      No ADVISORY PERSON shall accept any gift or personal benefit valued in
         excess of a DE MINIMUS value (as established from time to time by the
         Preclearance Officer). Any solicitation of gifts or gratuities is
         unprofessional and is strictly prohibited.

3.9      No ADVISORY PERSON shall serve on the board of directors of any
         publicly traded company, absent prior written authorization by the
         President of Pioneer Investments and determination by the President of
         Pioneer Investments that the board service would be consistent with the
         interests of the Investment Companies and the Institutional Accounts.
         An Advisory Person who serves on the board of directors of a publicly
         traded company may not participate in the decision to purchase or sell
         any Covered Securities of such company by or on behalf of any
         Investment Company or Institutional Account.

3.10     No ADVISORY PERSON shall recommend any Covered Securities transaction
         for any Investment Company or Institutional Account without having
         previously disclosed any interest in such Covered Securities or the
         issuer thereof to the President of Pioneer Investments, including
         without limitation:

o             his/her Beneficial Ownership of any Covered Securities of such
              issuer;

o             any contemplated transaction by such person in such Covered
              Securities;

o             any position with such issuer or its affiliates; and

o             any present or proposed business relationship between such issuer
              or its affiliates and such person or any party in which such
              person has a significant interest.

         Such interested Advisory Person may not participate in the decision by
         Pioneer Investments on behalf of any Investment Company or
         Institutional Account to purchase and sell Covered Securities of such
         issuer.


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                                    SECTION 4

                         EXEMPT TRANSACTIONS AND CONDUCT

The prohibitions of Section 3 of this Code (other than Subsections 3.4 and 3.5)
shall not be deemed to be violated by any of the following transactions:

4.1      Purchases or sales of Covered Securities for an account over which the
         Access Person has no direct or indirect influence or Control;

4.2      Purchases or sales of Covered Securities which are non-volitional on
         the part of the Access Person;

4.3      Purchases or sales of Covered Securities pursuant to an automatic
         dividend reinvestment, cash purchase or withdrawal plan provided that
         no adjustment is made by the Access Person to the rate at which Covered
         Securities are purchased or sold, as the case may be, under such a plan
         during any period in which the Covered Security is being considered for
         purchase or sale by any Investment Company or Institutional Account;

4.4      Purchases of Covered Securities effected upon the exercise of rights
         issued by an issuer pro rata to all holders of a class of its Covered
         Securities, to the extent such rights were acquired by the Access
         Person from the issuer, and sales of such rights so acquired;

4.5      Purchases or sales of Covered Securities which receive the prior
         approval of the Review Officer, after disclosure to and review by the
         Review Officer of all material information and provided that such prior
         approval is based on the reasonable conclusion that the proposed
         purchase or sale would not be in violation of the spirit of this Code
         or would not cause any injury to any Investment Company or
         Institutional Account;

4.6      Purchases or sales of Covered Securities made in good faith on behalf
         of another Investment Company or Institutional Account, it being
         understood by, and disclosed to, the Investment Companies and
         Institutional Accounts that Pioneer may make contemporaneous investment
         decisions and cause to be effected contemporaneous executions on behalf
         of one or more Investment Companies and Institutional Accounts and that
         such executions may increase or decrease the price at which Covered
         Securities are purchased or sold for the Investment Companies and
         Institutional Accounts;

4.7      Tenders of Covered Securities pursuant to tender offers which are
         expressly conditioned on the tender offer's acquisition of all of the
         Covered Securities of the same class; and

4.8      Except as otherwise provided in Section 3.3, purchases or sales of
         Covered Securities for a Fiduciary Account as to which the Access
         Person is a fiduciary.


                                    SECTION 5

          POLICIES AND PROCEDURES TO PREVENT INSIDER TRADING VIOLATIONS

All employees of Pioneer or any affiliate, including Access Persons other than
Independent Trustees, are subject to Pioneer's Policies and Procedures to
Prevent Insider Trading Violations, in addition to the


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requirements of this Code. Any violation of the Insider Trading Policy
which adversely affects any Investment Company or Institutional Account shall be
deemed to be a violation of this Code.

                                    SECTION 6

                                 CONFIDENTIALITY

All information obtained from any Access Person hereunder shall be kept in
strict confidence by Pioneer, except that reports of Covered Securities
transactions hereunder will be made available to the Investment Companies and
Institutional Accounts and to the Commission or any other regulatory or
self-regulatory organization to the extent required by law or regulation or to
the extent Pioneer considers necessary or advisable in cooperating with an
investigation or inquiry by the Commission or any other regulatory or
self-regulatory organization.

                                    SECTION 7

                                 INTERPRETATION

The Board of Trustees, on behalf of an Investment Company, as well as Pioneer,
may from time to time adopt such interpretations of this Code as it deems
appropriate.

                                    SECTION 8

                             EXCEPTIONS TO THE CODE

Although exceptions to the Code will rarely, if ever, be granted, Pioneer
Investments' Chairman, after consultation with the Review Officer, may make
exceptions on a case by case basis, to any of the provisions of this Code upon a
determination that the conduct at issue involves a negligible opportunity for
abuse or otherwise merits an exemption from the Code. All such exceptions must
be received in writing by the Access Person before becoming effective. The
Review Officer shall report the exception to the Board of Trustees of the
Investment Companies at the next regularly scheduled Board meeting.

                                    SECTION 9

                  ADOPTION OF PROCEDURES TO ADMINISTER THE CODE

Pioneer has adopted procedures to administer the Code of Ethics and Pioneer's
Policies and Procedures to Prevent Insider Trading. Pioneer shall administer
such procedures in accordance with applicable rules and regulations adopted by
the Commission, and all Access Persons are required to comply with such
procedures.




                                              Approved:  March 7, 2000
                                              Effective:    March 7, 2000








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