14.1

                    TO THE VALUED MEMBERS OF OUR PIONEER TEAM


Dating back to our inception in 1976,  Pioneer has remained focused on providing
the  highest  quality  of  behavioral  health  care  services.   We  continually
demonstrate the compassion,  honesty, and judgment that is expected and required
of a leading health care provider.

To further  our  reputation  as an  industry  leader,  we must  continue to hold
ourselves to the highest professional  standards,  as we respond to the needs of
our  patients  and  their  families,   our  Pioneer   colleagues,   contractors,
third-party payors, and shareholders.

In order to show our  commitment  to ongoing  quality  care, we have updated our
Corporate  Compliance  Plan. As it is  impossible to address every  circumstance
that may arise,  the  Corporate  Compliance  Plan  gives us a general  legal and
ethical  framework  under  which to  operate  on a daily  basis.  The  Corporate
Compliance  Plan covers a range of topics,  including  quality of patient  care,
billing and coding integrity,  protection of property, and health and safety. We
have  attached  a  copy  for  your   reference,   and  ask  that  you  sign  the
acknowledgment  form,  stating that you have read and  understand  the Corporate
Compliance Plan.

If you have any questions  about the Corporate  Compliance  Plan, or if you have
questions regarding any compliance matters,  please use the reporting mechanisms
that are available to you. We all must feel  comfortable  seeking guidance from,
and reporting  issues to, our  supervisors,  managers,  the Facility  Compliance
Liaisons,  and the  Compliance  Officer.  We also have our  toll-free  Corporate
Compliance  Hotline  (800-543-2447  ext. 1250),  which is available 24 hours per
day, 365 days per year. You may call the hotline anonymously and without fear of
retaliation,  to report  potential  violations of patient  rights,  professional
standards   of   conduct,   billing   fraud  and   abuse,   HIPAA  and   patient
confidentiality,  conflicts  of interest,  and other  compliance  concerns.  You
should  provide as many  specific  details as possible,  so that the  Compliance
Officer  will  have  enough   information  to  conduct   appropriate   follow-up
activities.

We thank you for your  continued  commitment to quality care,  and wish you both
professional and personal success as a member of the Pioneer team.




Bruce A. Shear                                 Andy DeMayo, Esq.
Chairman and Chief Executive Officer           Director of Corporate Services /
                                               Compliance Officer



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                               MISSION AND VALUES

The  Mission of Pioneer  is to make a  positive  difference  in the lives of our
patients  and their  families  by  providing  the  highest  quality  health care
services.  To  accomplish  our  Mission,  we  focus on the  five  Values,  which
emphasize  our ongoing  commitment  to quality care,  professional  ethics,  and
industry leadership.

Quality of Patient Care - With a knowledgeable and trained  professional  staff,
we  provide  the  highest  quality  of care to our  patients.  We respond to our
patients'  clinical needs and are  understanding  of their  individual  personal
concerns.

Corporate Responsibility - We conduct all aspects of our business by adhering to
personal  and  professional   ethics,   with  our  cornerstones  being  honesty,
integrity, and trust.

Pioneer Team Members - We recruit, train, and develop talented,  motivated,  and
goal-oriented  individuals.  We communicate with one another in an open, honest,
and respectful  manner,  welcoming the  individuality of our peers and embracing
our common goals.

Industry Leadership - We strive to become a leader in the behavioral health care
industry through strategic expansion, superior clinical care, and recognition in
the communities we serve.

Results-Oriented  - We demonstrate to our  shareholders  and clients that we are
committed  to  positive  outcomes,  by striving  to excel in our  financial  and
operational performance.

All members of the Pioneer team are  committed to observing and  performing  the
Mission and Values.

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<PAGE>
                          THE CORPORATE COMPLIANCE PLAN

                          CORPORATE COMPLIANCE PROGRAM

The Corporate  Compliance  Program has been developed to demonstrate our ongoing
commitment to the highest standards of professional and business ethics, as well
as compliance with all laws,  rules,  and regulations  governing the health care
industry.  This  commitment  permeates  all  levels  of  our  organization.  The
Corporate  Compliance  Program  was  established  by  the  Compliance  Oversight
Committee  and  implemented  by  the  Compliance  Officer.   Each  of  Pioneer's
facilities has Facility  Compliance Liaisons to provide the support necessary to
meet our compliance goals.

The Corporate  Compliance  Program is  continually  monitored by the  Compliance
Officer to ensure that we remain in  compliance  with changing and newly enacted
laws and regulations.

For employees who may be covered by a collective  bargaining  agreement,  in the
event there is any conflict between that agreement and this Corporate Compliance
Plan, the agreement will govern.

                       THE COMPLIANCE OVERSIGHT COMMITTEE

The  Compliance  Oversight  Committee  consists  of  the  members  of  Pioneer's
Executive Committee and the Compliance Officer.  The Compliance Officer receives
reports  on the  operational  functions  and  compliance  issues  impacting  our
facilities  via the  Facility  Compliance  Liaisons  and  other  facility  staff
members.  The Compliance  Officer  reports the information on a regular basis to
the Compliance  Oversight  Committee.  The Compliance  Oversight  Committee then
works to design new policies and procedures or initiate activities to remedy any
reported compliance deficiencies.

                             THE COMPLIANCE OFFICER

The Compliance Officer is a member of the Compliance  Oversight  Committee,  and
serves in an advisory role to the Executive  Committee.  The Compliance  Officer
also acts as an intermediary  between the Compliance Oversight Committee and the
Facility Compliance  Liaisons.  If the Compliance Oversight Committee recommends
the implementation of a new policy or procedure,  the Compliance Officer ensures
its implementation by working closely with the Facility Compliance Liaisons. The
Facility Compliance Liaisons  immediately  communicate to the Compliance Officer
any issues  related  to the  Corporate  Compliance  Program,  including  general
compliance questions and potential or actual violations of laws or policies. The
Compliance  Officer  then  determines  how  the  issues  may be  resolved.  When
necessary,  the Compliance Officer works with the Compliance Oversight Committee
or outside legal counsel to determine the most appropriate course of action. The
result may require an amendment to a current  policy,  creation of a new policy,
employee discipline, enhanced training at a facility, or other remediation.


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                   FACILITY COMPLIANCE LIAISONS

One Facility  Compliance  Liaison is appointed by the Compliance Officer at each
facility in order to identify and respond to any issues related to the Corporate
Compliance  Program.  The Facility  Compliance  Liaisons focus on the day-to-day
operations  of  the  facility,  and  ensure  that  the  staff  members  maintain
compliance  with the  Corporate  Compliance  Program.  The  Facility  Compliance
Liaisons  are  easily   accessible  to  all   individuals   who  have  comments,
suggestions,  or wish to  report a  potential  or  actual  violation  of laws or
company  policies.  The Facility  Compliance  Liaisons speak  regularly with the
Compliance Officer,  making  recommendations for new and existing policies,  and
reporting potential or actual violations of laws or company policies.

                             FACILITY HIPAA LIAISONS

One Facility HIPAA Privacy Liaison and one HIPAA Security  Liaison are appointed
by the Compliance  Officer at each facility in order to oversee  compliance with
the privacy and security  regulations of the Health  Insurance  Portability  and
Accountability   Act  of  1996  ("HIPAA").   The  Facility  HIPAA  Liaisons  are
responsible   for   overseeing   and  managing  each   facility's   development,
maintenance,  and  compliance  with all policies and  procedures  related to the
privacy,   confidentiality,   and   security  of  patients'   protected   health
information. The HIPAA Privacy Liaisons monitor compliance with areas, including
patients'   access  to  medical   records,   disclosures  of  protected   health
information,   restrictions  on  the  uses  of  protected  health   information,
amendments  to  medical  records,   contractual   relationships   with  business
associates,  and HIPAA training  sessions.  The HIPAA Security  Liaisons monitor
compliance  with areas,  including  the physical  security of  protected  health
information,  the usage of protected  health  information  by external  parties,
investigation  of  security  breaches,  and  reduction  of the  harm  caused  by
disrupted  access to protected health  information.  The Facility HIPAA Liaisons
are easily accessible to all individuals who have comments, suggestions, or wish
to report a potential or actual violation of confidentiality or security laws or
company policies.

                             QUALITY OF PATIENT CARE

We  are  committed  to  providing   high-quality  patient  care,  by  exhibiting
compassion,  integrity,  and  innovation.  We will treat all of our patients and
their  families  with the highest  level of  consideration  and  respect,  while
continually respecting their dignity and right to privacy.

o    We will provide all of our patients  with  high-quality  behavioral  health
     care services.

o    We will not discriminate based on race, color, religion,  sex, age, marital
     status, national origin, veterans status, or disability.

o    Our  patients  and their  families  have the right to request  and  receive
     information  regarding the identity and professional  qualifications of all
     personnel involved in the patients' care.

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<PAGE>
o    We will honor the patients' right to participate in all decisions regarding
     their  health  care,  including  the  refusal  of  treatment  to the extent
     permitted  by  law,  and  we  will  keep  the  patients   informed  of  the
     consequences  of any action taken.  We will provide  patients with adequate
     and accurate information  concerning clinical decisions and treatments,  so
     they will be fully informed.

o    Patients have the right to voice their opinions about the care and services
     we provide.

o    We will promptly and  courteously  answer all  questions  from patients and
     their families,  or, when  necessary,  refer the question to another source
     better suited to respond.

o    We will  develop and  maintain  complete,  accurate,  and  legible  patient
     medical records, which shall be stored in a confidential setting.

o    We will only employ those  personnel with proper  credentials,  experience,
     and expertise to meet the needs of our patients.

o    Only  individuals  with valid licenses or credentials  shall perform direct
     clinical care.

o    We  will  participate  in  continuing  education  programs  to  ensure  our
     understanding of evolving  industry  standards,  as well as compliance with
     newly enacted laws, rules, and regulations.

o    We will  routinely  assess and evaluate  our  clinical  protocols to ensure
     compliance  with  current  standards  of  practice  and  relevant  laws and
     regulations.

o    We will  provide  only  those  health  care  services  that  are  medically
     necessary,  appropriate,  safe,  and in  compliance  with all  standards of
     practice and relevant laws, rules, and regulations.

                  COMPLIANCE WITH LAWS, RULES, AND REGULATIONS

We will act in accordance with all applicable  laws,  rules,  and regulations in
order to provide the highest  quality of care and maintain the  integrity of our
organization.

o    We will not pursue any business opportunity that would require us to engage
     in illegal or unethical behavior.

o    We  understand  that if we violate the law or the  company's  policies  and
     procedures,  or  knowingly  fail to  report  such a  violation,  we will be
     subject  to  disciplinary  action.  Depending  on the  specific  violation,
     Pioneer may take disciplinary  action up to and including  termination,  as
     well as referral to law enforcement,  government agencies,  or professional
     licensing boards, as applicable.


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<PAGE>
o    We will abide by all of the legal and ethical guidelines  pertaining to the
     confidentiality  of patient  medical  records  and other  protected  health
     information. Absent either a valid authorization signed by the patient or a
     court  order  signed  by a judge or  magistrate,  all  information  about a
     patient's condition, care, treatment,  personal affairs, or medical records
     will only be discussed with the patient, the patient's legal representative
     (when  appropriate  custodial  paperwork is received),  the clinical  staff
     involved  in the  patient's  direct  care,  or whose  job  responsibilities
     specifically require knowledge of such confidential information.

o    We will not offer, pay, solicit,  or receive any remuneration to or from an
     individual or entity,  whether that  remuneration is in cash or in kind, in
     order to induce  patient  referrals  or arrange for the  provision of other
     healthcare  items  and  services.  Such  prohibited  remuneration  includes
     kickbacks, bribes, rebates, or other compensation,  which are paid in order
     to obtain or provide patient referrals.

o    All contractual arrangements with non-full-time clinical staff and referral
     sources  must be reviewed  and  approved  by the  Compliance  Officer,  and
     executed  by a member of the  Executive  Committee.  Such  agreements  must
     provide fair market value rates for actual services rendered. Every payment
     made pursuant to the agreements must be supported by proper  documentation,
     indicating  that the  contracted  services were performed in an acceptable,
     legal manner.

o    For those facilities that obtain payment from government payors,  including
     Medicare and Medicaid,  we will not  knowingly  employ or contract with any
     individual or entity who is listed by any state or federal  agency as being
     sanctioned,  disbarred,  or otherwise ineligible to participate in state or
     federally  funded health care programs.  All employees and contractors will
     be  informed  that  sanction  checks  will  be  performed  at the  time  of
     engagement  and, when  warranted,  any time  thereafter.  All employees and
     contractors  also shall be informed that their employment or engagement may
     be suspended or terminated, pending the results of the sanction checks.

o    All  employees and  contractors  will be required to report to the Facility
     Compliance Liaison or Compliance Officer any felony or misdemeanor  arrests
     and  convictions  during  the term of their  employment  or  contract.  All
     employees and contractors will be informed that criminal  background checks
     will be performed at the time of engagement and, when  warranted,  any time
     thereafter. All employees and contractors also shall be informed that their
     employment  or  engagement  may be  suspended  or  terminated,  pending the
     results of the criminal background checks.

o    As employees of an organization  whose securities are traded  publicly,  we
     will not  release  insider,  non-public  information  that could  affect an
     investor's  decision to buy or sell our stock.  We will  neither  trade our
     stock,  nor provide tips to others to trade our stock,  based on non-public
     information we acquired during our employment. We also will not divulge any
     non-public  information  pertaining to our vendors,  contractors,  or other
     organizations  with  whom  we deal  during  the  course  of  business.  All
     employees and contractors shall consult  Pioneer's  policies and procedures
     or contact  the  Executive  Committee  if they have  questions  about these
     restrictions, or to report a potential or actual violation.



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<PAGE>
o    We  will  preserve  Pioneer's   intellectual  property  rights,   including
     copyrights,   trademarks,  and  service  marks.  We  also  will  honor  the
     intellectual property rights of others by obtaining  authorization from the
     copyright  holder prior to copying any  newsletters,  magazines,  journals,
     articles, computer software, or other copyrighted materials.

o    We will not make false, misleading,  or inaccurate statements to government
     agencies  or  payors,  nor  shall  we bribe  or  offer  inducements  to any
     governmental or political official or representative of a payor.

o    We will ensure that all data,  reports,  and records,  including  financial
     records,  accounting  entries,  materials  submitted  to  payors  and other
     documentation  pertaining to our  business,  are  complete,  accurate,  and
     truthful.  If we discover an error or omission,  we immediately will notify
     our supervisor, the Facility Compliance Liaison, or the Compliance Officer.

o    We will retain all  business-related  records in accordance with applicable
     laws, rules, regulations, and policies.

                          BILLING AND CODING INTEGRITY

We will maintain honesty,  accuracy,  and integrity in all activities  involving
billing, coding, and support documentation.

o    We will only  submit for  payment  or  reimbursement  claims  for  services
     actually  rendered  and  evidenced  by an accurate  and  legible  note in a
     patient's medical record. Under no circumstances will we submit a claim for
     payment  or  reimbursement  that  is  false,  fraudulent,   incomplete,  or
     otherwise inaccurate.

o    We will  only  submit  claims  for  services  based on  documentation  that
     complies  with the  applicable  community  standards of  practice,  such as
     medical necessity.

o    We will train and monitor all applicable staff in the proper usage of codes
     and appropriate rates.

o    We will enter and issue claims in a timely manner,  including  bills issued
     to patients for co-payments and  deductibles.  In addition,  we will ensure
     that  claims  are filed in  accordance  with all  applicable  laws,  rules,
     regulations and company policies.


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<PAGE>
o    We will timely review all  Explanation of Benefits  forms,  and verify that
     all payments  received relate to services actually  rendered.  All rejected
     invoices  will  be  promptly  investigated  and  reissued  only  after  the
     necessary corrections are made.

o    We will take immediate steps to alert the appropriate  entity or individual
     if we  discover  inaccuracies  in  claims  that  have  been  submitted  for
     reimbursement.  If we  receive  any  money  that was not due to us, we will
     promptly issue a refund.

                         AVOIDING CONFLICTS OF INTEREST

We will take all steps to avoid  conflicts and the  appearance of conflicts that
may arise between our personal interests and our duties and  responsibilities as
members of the Pioneer team.

o    We will seek advanced  written  approval from Pioneer's  management  before
     engaging in any situation that may create an actual  conflict of loyalty or
     interest,  or the  appearance of such a conflict.  For those  situations in
     which we are unsure if a conflict  exists,  we first will seek the guidance
     of our  supervisor,  the Facility  Compliance  Liaison,  or the  Compliance
     Officer.

o    Pioneer allows employees to hold jobs outside of the organization,  as long
     as those employees can effectively  continue meeting Pioneer's  performance
     standards.  We may  not  hold  other  jobs if such  activity  is  expressly
     prohibited by contract,  or if an actual or potential  conflict of interest
     is created by such other employment.  It is our  responsibility to take the
     necessary steps to confirm the propriety of our actions in advance.

o    We  will  not  establish  an  association  or  other  connection  with  any
     individual or organization, whose operation conflicts with Pioneer's stated
     Mission and Values, and policies and procedures.

o    We will not solicit or accept gifts, favors, or hospitality of considerable
     value  from  patients,   visitors,  vendors,  referral  sources,  or  other
     organizations with which we conduct business.  "Considerable  value" refers
     to a gift,  favor,  or hospitality,  including  entertainment,  meals,  and
     tickets, with a high fair market value. We will track and monitor the gifts
     we  receive,  to ensure  that they are  provided  in the  normal  course of
     Pioneer's legitimate business activities.

o    We will not solicit or accept  money or cash  equivalents,  including  gift
     certificates, in any amount from any source. Any employee who receives such
     a monetary gift immediately  should contact their supervisor,  the Facility
     Compliance Liaison, or the Compliance Officer.


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<PAGE>
o    We will not solicit or accept gifts,  favors,  or hospitality of any value,
     whether or not of  considerable  value,  if it appears or might appear that
     the donor is seeking to influence our decisions.

o    We will not offer or provide gifts, favors, or hospitality to organizations
     with which we conduct  business,  except for  infrequent,  modest  business
     courtesies.  Such  business  courtesies  shall be tracked and  monitored to
     ensure that they are  infrequent,  of nominal  value,  and  provided in the
     normal course of Pioneer's legitimate business activities.

o    We  will  not  offer  or  provide  gifts,  favors,  or  hospitality  to any
     individual or entity,  regardless of the frequency or value,  if it appears
     or might appear that we are seeking to influence the recipient's decisions.

o    We  will  not  solicit,   accept,  offer,  or  provide  gifts,  favors,  or
     hospitality  from  or to a  government  agency,  government  official,  law
     enforcement  officer,  or member of a judiciary,  regardless of the amount,
     frequency, and type of such gift.

o    While we are allowed and encouraged to take part in the political  process,
     we  will  not  contribute   money  or  resources  to  candidates,   elected
     representatives, political parties, or political organizations on behalf of
     the  company,  nor  will we use  company  funds  to  support  a  particular
     candidate or issue.

o    We will  work  productively  to  promote  Pioneer's  business  while on the
     company's time.

o    We will transact  business in furtherance of Pioneer's best  interests,  by
     working  with  those  individuals  and  companies  that  operate  with  the
     integrity and ethical standards shared by Pioneer.

o    We immediately will report any potential  conflicts of interest  concerning
     ourselves,  our family members,  and our colleagues to our supervisor,  the
     Facility Compliance Liaison, or the Compliance Officer.

                             PROTECTION OF PROPERTY

We are committed to protecting our organization's and patients' assets and
property from theft, loss, waste, or misuse.

o    We will be held  responsible and accountable for the proper  expenditure of
     Pioneer's  funds and the  appropriate  use of Pioneer's  property.  We will
     recognize and abide by our duty to protect and preserve  Pioneer's  assets,
     property, and facilities.

o    We will obtain  prior  approval  from the  appropriate  level of  Pioneer's
     management prior to the commitment or expenditure of any Pioneer funds.

o    We will follow all  policies  and  procedures  related to the  handling and
     recording  of  funds  and  property  that are  received  in the  course  of
     conducting our business.


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o    We accept our duty to safeguard the property of our patients and visitors.

o    We  will  dispose  of  surplus,  obsolete,  or  unusable  property  only in
     accordance  with  Pioneer's  policies  and  procedures.   Pioneer  strictly
     prohibits any unauthorized removal or disposal of property.

o    As  all of  Pioneer's  internal  information  and  publications,  including
     policies and procedures, facility listings,  organizational charts, patient
     and provider  information,  and customer lists are the property of Pioneer,
     we will  not  copy or  communicate  this  information  to any  unauthorized
     person, whether within or outside the organization.

o    We will use Pioneer's computer networks,  e-mail systems, and software only
     for authorized  purposes,  which are directly related to our job functions.
     We understand  that the company may monitor our e-mail and any  information
     stored or retrieved on our work computers at any time.

                                HEALTH AND SAFETY

We are committed to providing a safe  environment  for our patients,  employees,
and visitors.

o    We will promote sound  environmental and safety  practices,  which prevent,
     detect, and monitor damage to our facilities.

o    We will handle  hazardous  materials  and other medical waste in accordance
     with all applicable laws, rules, and regulations.

o    We will take all necessary precautions to ensure our safety, as well as the
     safety of our patients, visitors, peers, and other personnel.

o       We will maintain a workplace free from violence. Weapons of any kind are
        prohibited on company property, as is all conduct that may be deemed
        threatening, violent, intimidating, or harassing.

o    To ensure the safety and well being of our patients and colleagues,  we are
     committed to maintaining an alcohol-free work environment. We will not use,
     possess,  or be under the influence of alcohol while on company property or
     on company time.

o    We  will  not  manufacture,  distribute,  use,  possess,  or be  under  the
     influence of any controlled  substances,  including  illegal  narcotics and
     prescription medications for which we do not have a valid prescription.  We
     understand  that this  requirement  applies  both  while we are on  company
     property and company  time,  as well as during our personal  time away from
     the  work  environment,  since  such  behavior  may  adversely  affect  our
     company's  reputation  within the  communities we serve.  We are subject to
     drug  testing at the time of our  employment,  and anytime  thereafter,  in
     accordance with Pioneer's policies and procedures.

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o    We will  immediately  report to our  supervisor or the Facility  Compliance
     Liaison all accidents involving a patient,  visitor,  or employee.  We will
     complete  and  submit  a  detailed  incident  report,  in  accordance  with
     Pioneer's policies and procedures.

o    We will be familiar with emergency plans and risk  management  policies and
     procedures.  We  will  have  access  to  information  pertaining  to  fire,
     disaster, and other emergency plans.

o    We will  ensure  that all  pharmaceutical  products  are  properly  stored,
     secured,  and inventoried.  We will promptly report missing  pharmaceutical
     supplies  or  substances  to  our  supervisor  or the  Facility  Compliance
     Liaison.

                                EMPLOYEE SERVICES

We are committed to treating all employees in a fair and equitable manner, while
helping them to achieve their full potential.

o    We will  receive the highest  levels of respect  and  consideration  in the
     workplace.  Pioneer  does not accept  inequitable  or unfair  treatment  or
     harassment of any type. Unfair treatment  includes,  but is not limited to,
     unlawful  discriminatory  practices or harassment  based on sex, age, race,
     national  origin,  religion,   disability,   or  any  other  characteristic
     protected  by law.  Unlawful  harassment  includes,  but is not limited to,
     slurs, epithets,  threats,  derogatory comments, and unwelcome or offensive
     jokes. In addition, unlawful harassment may result from verbal and physical
     conduct of a sexual nature by any employee, supervisor, manager, physician,
     or other  individual.  Such  unlawful  conduct  includes  sexual  advances,
     requests for sexual favors,  uninvited  touching,  or sexual  comments that
     tend to create an intimidating, hostile, or offensive work environment. Any
     employee,  supervisor,  or  manager  who  becomes  aware  of  any  unlawful
     harassment,  whether  or not  that  employee  is  directly  affected,  must
     immediately act in accordance with Pioneer's  harassment policy by advising
     a supervisor, the facility's Human Resources Representative, the facility's
     Chief  Executive  Officer,  Pioneer's  Director  of  Human  Resources,  the
     Compliance  Officer,   Pioneer's  Executive  Committee,  or  the  Corporate
     Compliance Hotline.

o    We are required to abide by the standards of our  profession,  and exercise
     reasonable judgment and objectivity in the performance of our duties.

o    We will  ensure  that each  individual  is provided  equal  employment  and
     advancement  opportunities  regardless of sex, age, race,  national origin,
     religion,  and disability.  This equal opportunity  practice relates to all
     personnel matters,  including, but not limited to, compensation,  benefits,
     training, promotions, transfers, layoffs, and recalls from layoffs.

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<PAGE>
o    We will not sign or witness any legal  documents  on behalf of Pioneer.  If
     requested  to do so, we will refer the matter to our  supervisor,  Facility
     Compliance Liaison, or the Compliance Officer.

o    We will demonstrate respect, consideration,  and courteousness when working
     with  one  another,  regardless  of  our  position  or  status  within  the
     organization.

o    We understand that our work areas and computer  systems are the property of
     Pioneer,  and may be  subject  to search  upon a  reasonable  suspicion  of
     wrongdoing.

o    We will properly  maintain and remain  current on the  requirements  of our
     licenses, certifications, and other credentials. We immediately must report
     any  limitations  or revocations  of such  credentials  to our  supervisor,
     Facility Compliance Liaison, or Compliance Officer.

                               OPEN COMMUNICATION

We will foster an environment that encourages open and honest communication.

o    We will share ideas,  resolve problems or concerns,  and treat all opinions
     with respect and consideration.

o    We will raise legitimate  questions or concerns in an appropriate,  timely,
     and efficient manner, without fear of retaliation.

o    We will strive to understand the duties,  responsibilities,  and challenges
     that face our colleagues on a daily basis.

o    Supervisors and managers will respond in a timely and appropriate manner to
     all questions and concerns brought to their attention.

o    We will be truthful and accurate in our  advertising  and public  relations
     activities.  Prior to  distribution,  we will  share  with  the  Compliance
     Officer any advertising or public relations information.


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                                 ACKNOWLEDGMENT

I acknowledge that I have received,  read, and understand  Pioneer's Mission and
Values and the Corporate  Compliance Plan. I further acknowledge that I will, at
all times, act in accordance with these  materials,  and that I am not presently
aware  of any  activity,  relationship,  or  conduct  that may be  considered  a
violation of the Mission and Values or the Corporate Compliance Plan.


_______________________________________                 ____________________
Signature                                               Date


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Print Name




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