GARTMORE MUTUAL FUNDS
                                        &
                        GARTMORE VARIABLE INSURANCE TRUST

                  CODE OF ETHICS FOR SENIOR FINANCIAL OFFICERS
               (AS AMENDED AND RESTATED AS OF SEPTEMBER 18, 2003)

I.     INTRODUCTION

     SECTION  406  OF  THE SARBANES-OXLEY ACT OF 2002.  The Board of Trustees of
each  of  Gartmore  Mutual  Funds  ("GMF") and Gartmore Variable Insurance Trust
("GVIT")  (GMF  and  GVIT hereinafter referred to collectively as the "Company")
has  adopted  this  code  of  ethics (this "Code") to comply with Item 2 of Form
N-CSR,  [1]  which implements Section 406 of the Sarbanes-Oxley Act of 2002 (the
"2002  Act").  Section  406  of  the  2002 Act requires disclosure by management
investment  companies  that  are  registered  with  the  Securities and Exchange
Commission (the "SEC") under the Investment Company Act of 1940, as amended (the
"1940  Act"), concerning a code of ethics for senior financial officers of these
investment  companies.

[1]  Item 2 of Form N-CSR requires a registered management investment company to
     disclose  annually  whether,  as  of  the  end of the period covered by the
     report,  that  company  has  adopted  a  code of ethics that applies to the
     registrant's  principal  executive  officer,  principal  financial officer,
     principal  accounting officer, or controller, or persons performing similar
     functions.  If  the  registrant  has not adopted such a code of ethics, the
     registrant  must  explain why the registrant has not done so. Under Item 2,
     the  registrant  also  must:

COVERED  PERSONS  UNDER THE CODE.  This Code of the Company is applicable to the
Company's chief executive officer (the "CEO") and the Company's senior financial
officers  (e.g., the Company's treasurer and assistant treasurers) (said CEO and
senior  financial  officers hereinafter referred to collectively as the "Covered
Officers").  See  Exhibit  A  to  this  Code.

This  Code  is  intended  to  promote:

     -    honest  and  ethical  conduct,  including  the  ethical  handling  of
          conflicts  of  interest;

     -    full,  fair,  accurate,  timely,  and  understandable  disclosure;

(1)  file  with  the Securities and Exchange Commission a copy of the code as an
     exhibit to the registrant's annual report; (2) post the text of the code on
     the  registrant's Internet website and disclose, in the registrant's annual
     report, the registrant's Internet address, and the fact that the registrant
     has  posted the code on the registrant's Internet website; or (3) undertake
     in the registrant's most recently filed semi-annual report on Form N-CSR to
     provide  to any person without charge, upon request, a copy of the code and
     explain  the  manner  in which this request may be made. Disclosure also is
     required  of amendments to, or waivers (including implicit waivers) from, a
     provision of the code in the registrant's annual report on Form N-CSR or on
     the  registrant's  website.  If  the  registrant  intends  to  satisfy  the
     disclosure  requirement  by  posting  this  information on the registrant's
     website,  the  registrant  will  be  required  to disclose the registrant's
     Internet  address  and  this  intention. Investment companies must make the
     disclosure  discussed in this footnote regardless of whether these officers
     are  employed  by  the  registrant  or  a  third  party.

     -    compliance  with  applicable  laws  and  governmental  rules  and
          regulations;

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

     -    accountability  for  adherence  to  the  Code.

     DESIGNATED  PERSONS  UNDER THE CODE.  As set forth in greater detail below,
the  Covered  Officers  shall  report to either:  (i) one of the officers of the
Company  set  forth  in  Exhibit  B (each hereinafter referred to as a "Gartmore
Designated Person"); and/or (ii) a member of the Audit Committee of the Board of
Trustees  of  the  Company  (each hereinafter referred to as an "Audit Committee
Designated  Person")  (the "Gartmore Designated Person" and the "Audit Committee
Designated  Person"  hereinafter  referred  to  collectively  as the "Designated
Persons," and singly as the "Designated Person," as appropriate).  See Exhibit B
to  this  Code.

     ROLES  AND  RESPONSIBILITIES  OF THE DESIGNATED PERSONS AND THE INDEPENDENT
TRUSTEES.  As  discussed  in  greater  detail  below, given the seniority of the
Covered  Officers:

i.   the  Gartmore  Designated  Person  shall  be  responsible  for  conducting
     investigations  of  prospective  and  past  conduct  or activity by Covered
     Officers  (other  than  the CEO of the Company) brought to the attention of
     the  Gartmore  Designated  Person,  and:

     a.   with  respect  to  such prospective conduct or activity, also shall be
          responsible  for  making  a  final  determination  whether or not such
          conduct  or  activity  will  violate  this  Code;

     b.   with  respect  to  such  past  conduct  or  activity,  also  shall  be
          responsible for making a preliminary determination whether or not such
          conduct  or  activity  has  violated  this  Code;  and

     c.   with  respect  to  such prospective and past conduct or activity, also
          shall be responsible for making a preliminary determination whether or
          not  to  grant a waiver [2] to the Covered Officer for such conduct or
          activity;

          [2]  Item  2  of  Form  N-CSR defines "waiver" as "the approval by the
               registrant  of  a material departure from a provision of the code
               of ethics" and "implicit waiver," which also must be disclosed in
               the  Form  N-CSR,  as  "the  registrant's  failure to take action
               within a reasonable period of time regarding a material departure
               from  a  provision of the code of ethics that has been made known
               to  an  executive  officer" of the registrant. See also Rule 3b-7
               under  the  Securities Exchange At of 1934, as amended (17 C.F.R.
               240.3b-7).

ii.  the Gartmore Designated Person promptly shall report to the Trustees of the
     Company  who  are  not "interested persons" of the Company, as that term is
     defined  in Section 2(a)(19) of the 1940 Act (hereinafter, the "Independent
     Trustees"):

     a.   his  or  her  preliminary  determination  whether or not any such past
          conduct  or  activity  has  violated  this  Code  and  any recommended
          sanction,  as  appropriate;  and

     b.   his  or  her  preliminary  determination  whether  or  not  any  such
          prospective  or  past  conduct  or activity should be the subject of a
          waiver;

iii. the  Audit  Committee Designated Person shall be responsible for conducting
     investigations  of  prospective  and past conduct by the CEO of the Company
     brought  to  the  attention  of the Audit Committee Designated Person, and:

     a.   with  respect  to  such prospective conduct or activity, also shall be
          responsible  for  making  a  final  determination  whether or not such
          conduct  or  activity  will  violate  this  Code;

     b.   with  respect  to  such  past  conduct  or  activity,  also  shall  be
          responsible for making a preliminary determination whether or not such
          conduct  or  activity  has  violated  this  Code;  and

     c.   with  respect  to  such prospective and past conduct or activity, also
          shall be responsible for making a preliminary determination whether or
          not  to  grant  a  waiver  to  the  CEO  for such conduct or activity;

iv.  the  Audit  Committee  Designated  Person  promptly  shall  report  to  the
     Independent  Trustees:

     a.   his  or  her  preliminary  determination  whether or not any such past
          conduct  or  activity  has  violated  this  Code  and  any recommended
          sanction,  as  appropriate;  and

     b.   his  or  her  preliminary  determination  whether  or  not  any  such
          prospective  or  past  conduct  or activity should be the subject of a
          waiver;

v.   the  Independent  Trustees  shall  be  solely  responsible  for  promptly
     determining  whether  or  not: (a) to accept the preliminary determinations
     made  by  the Designated Person with respect to past conduct or activity of
     the  Covered  Officer  (including the CEO of the Company); and (b) to grant
     waivers  under  this  Code  --  and these determinations of the Independent
     Trustees  shall  be  final;

vi.  the  Independent  Trustees  further  shall  be  solely  responsible  for:

     a.   taking  all  necessary  and  appropriate  disciplinary  or  preventive
          action(s)  (necessary  and  appropriate  disciplinary  or  preventive
          action(s)  may include a letter of censure, suspension, dismissal, or,
          in  the  event  of  criminal  or  other  serious  violations  of  law,
          notification  to  the  SEC  and/or  appropriate  law  enforcement
          authorities) in regard to any existing, actual, or potential violation
          of  this  Code  by  any  Covered  Officer  (including  the  CEO of the
          Company);  and

     b.   assuring  that any changes to or waivers (or implicit waivers) of this
          Code,  to  the  extent  required, shall be disclosed on Form N-CSR, as
          provided  by  SEC  rules;  and

vii. all  determinations,  both  preliminary  and  final, made by the Designated
     Persons  and  Independent  Trustees  shall  be  in  writing.

     NOT  A  1940  ACT RULE 17J-1 CODE OF ETHICS.       This Code is not adopted
under,  nor intended to serve as a basis for complying with the requirements of,
Rule  17j-1  under  the  1940  Act.

II.     COVERED  OFFICERS  SHOULD  ACT  HONESTLY  AND  CANDIDLY

     Each  Covered  Officer  owes  a  duty to the Company to act with integrity.
Integrity  requires,  among  other  things, being honest and candid.  Deceit and
subordination  of  principle  are  inconsistent  with  integrity.

     Each  Covered  Officer  must:

     -    act  with  integrity,  including  being  honest and candid while still
          maintaining  the  confidentiality of information where required by law
          or  the  Company's  policies;

     -    observe the letter of the laws and governmental rules and regulations,
          accounting  standards,  and  Company  policies;

     -    adhere  to  a  high  standard  of  business  ethics;  and

     -    place  the  interests  of the Company before the Covered Officer's own
          personal  interests.

     All  activities of Covered Officers should be guided by and adhere to these
standards.

III.     COVERED  OFFICERS SHOULD HANDLE ETHICALLY ACTUAL AND APPARENT CONFLICTS
         OF  INTEREST

     GENERAL  PRINCIPLE.  The 1940 Act is designed, in part, to address inherent
conflicts  of  interest  that exist in the management of an investment company's
assets  by  a  third  party (i.e., the investment company's investment adviser).
Similarly, the Investment Advisers Act of 1940, as amended (the "Advisers Act"),
addresses conflicts of interest faced by an investment adviser in the management
of  client  assets.  The  principles  set  forth  in  this  section  relating to
conflicts  of interest reflect the fact that investment companies and investment
advisers  thereof  already  are  subject  to prohibitions on certain activities,
including  self-dealing,  and  substantial  limitations  regarding  conflicts of
interest  by  the  1940  Act  and the Advisers Act and the SEC rules promulgated
thereunder.  In  light  of  the  existing  structural, statutory, and regulatory
environment  for  registered investment companies, a code of ethics broader than
necessary  to  meet  the  new  2002  Act  code  of  ethics  requirement  may  be
unnecessary.  This Code, however, is intended to require the Covered Officers to
adhere  to  the  general  principle of the Company's advisers that those persons
responsible  for  managing  other  people's  money should be held to the highest
standards  of  integrity.

     GUIDING  PRINCIPLES.     A  "conflict  of  interest"  occurs  when  an
individual's  private  interest interferes with the interests of the Company and
the  shareholders  of  the  Company.  A  conflict  of  interest can arise when a
Covered Officer has interests that may make it difficult to perform that Covered
Officer's  Company  work objectively.  For example, a conflict of interest would
arise  if  a  Covered  Officer,  or  a  member  of the Covered Officer's family,
receives  improper  personal  benefits  as  a  result  of  the Covered Officer's
position  in  the  Company.  In  addition,  investment  companies also should be
sensitive to situations that create apparent, not actual, conflicts of interest.
Service  to  the  Company  should  never  be  subordinated  to personal gain and
advantage.

     Certain  conflicts  of  interest  covered  by  this  Code  arise out of the
relationships  between Covered Officers and the Company that already are subject
to  conflict  of  interest  provisions in the 1940 Act and the Advisers Act. For
example,  Covered  Officers  may not individually engage in certain transactions
(such  as the purchase or sale of securities or other property) with the Company
because  of  the  status  of  Covered  Officers  as  "affiliated persons" of the
Company,  as  that  term  is  defined  at  Section  2(a)(3)  of  the  1940  Act.
Accordingly,  as  to  the  existing  statutory  and  regulatory  prohibitions on
individual  behavior,  these  prohibitions shall be deemed to be incorporated in
this  Code  and,  therefore,  any  violation of these prohibitions also shall be
deemed  to  be  a  violation  of  the Code. Covered Officers, in all cases, must
comply  with  applicable  statutes  and  regulations.

     As  to  conflicts  arising  from,  or  as  a  result  of  the  contractual
relationship  between,  the  Company  and the investment adviser(s) of which the
Covered  Officers  also are officers or employees, it is recognized by the Board
of  Trustees of the Company that, subject to each investment adviser's fiduciary
duties  to  the  Company,  the  Covered  Officers, in the normal course of their
duties (whether formally for the Company or for the adviser, or for both), shall
be  involved in establishing policies and implementing decisions which will have
different  effects  on  the  investment  adviser  and  the Company. The Board of
Trustees  of  the  Company  recognizes  that  the  participation  of the Covered
Officers in these activities is inherent in the contractual relationship between
the Company and the investment adviser and is consistent with the expectation of
the  Board of Trustees of the Company of the performance by the Covered Officers
of their duties as officers of the Company. In addition, it is recognized by the
Board  of Trustees of the Company that the Covered Officers also may be officers
or  employees  of  other  investment  companies advised by the same adviser and,
accordingly, the principles of this paragraph shall further apply to the Covered
Officers  acting  in  these  capacities  as  well.

     RESPONSIBILITIES OF COVERED OFFICERS:  In accordance with these principles,
each  Covered  Officer  must:

     -    avoid  conflicts  of  interest  wherever  possible;

     -    handle  any  actual  or  apparent  conflict  of  interest  ethically;

     -    not  use  the  Covered  Officer's  personal  influence  or  personal
          relationships to influence investment decisions or financial reporting
          by  an  investment  company  whereby the Covered Officer would benefit
          personally  to  the  detriment  of  the  investment  company;

     -    not  cause  an  investment  company  to  take  action, or fail to take
          action,  for  the  personal benefit of the Covered Officer rather than
          for  the  benefit  of  said  company;

     -    not  use  knowledge of portfolio transactions made or contemplated for
          an  investment  company  to  profit  or cause others to profit, by the
          market  effect  of  these  transactions;

     -    as  described in more detail below, discuss with a Gartmore Designated
          Person  any material transaction or relationship that could reasonably
          be expected to give rise to a conflict of interest; provided, however,
          that  the  CEO  of  the  Company  must discuss with an Audit Committee
          Designated  Person any material transaction or relationship that could
          reasonably  be  expected  to  give rise to a conflict of interest; and

     -    report  at  least annually to the Company on the Company's "Trustees &
          Officers  Questionnaire"  any  and  all  material  transactions,
          affiliations,  or  relationships  that could reasonably be expected to
          give  rise  to,  or  be  related  to,  a  conflict  of  interest.

     CONFLICT  OF  INTEREST SITUATIONS:  Certain conflict of interest situations
that  always  should  be  discussed  by  a  Covered Officer with the appropriate
Designated  Person  include  the  following:

     -    any  outside  business  activity  that  detracts  from an individual's
          ability  to  devote  appropriate  time  and  attention  to  his or her
          responsibilities  with  the  Company;

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

     -    the receipt of any non-nominal or non de minimis gifts (i.e., gifts in
          excess of $500.00) from any company with which the Company has current
          or  prospective  business  dealings;

     -    the  receipt  of  any  entertainment  from  any company with which the
          Company  has  current  or  prospective  business dealings, unless said
          entertainment  is business related, reasonable in cost, appropriate as
          to  time  and  place,  and not so frequent as to raise any question of
          impropriety;

     -    being  in  the  position  of  supervising,  reviewing,  or  having any
          influence  on  the  job  evaluation,  pay, or benefit of any immediate
          family  member;

     -    any  ownership  interest  in,  or  any  consulting  or  employment
          relationship  with, any of the Company's service providers, other than
          the  Company's  investment  adviser  or  any  of  the  Company's other
          affiliates;  and

     -    a  direct  or  indirect financial interest in commissions, transaction
          charges,  or  spreads  paid  by  the  Company  for effecting portfolio
          transactions or for selling or redeeming shares other than an interest
          arising from the Covered Officer's employment, such as compensation or
          equity  ownership.

     In  addition, any activity or relationship that would present a conflict of
interest  for  a  Covered  Officer  also likely would present a conflict for the
Covered  Officer  if a member of the Covered Officer's family engages in such an
activity  or  has  such  a  relationship.

IV.     DISCLOSURE

     Each  Covered  Officer  is required to be familiar, and to comply, with the
Company's  disclosure controls and procedures in connection with the 2002 Act so
that  the  Company's  subject reports and documents filed with the SEC comply in
all material respects with the applicable federal securities laws and SEC rules.
In  addition,  each  Covered  Officer  that  has direct or supervisory authority
regarding  these  SEC filings or the Company's other public communications, also
should  consult,  to the extent appropriate within the Covered Officer's area of
responsibility,  with  other  Company  officers  and  employees  and  take other
appropriate  steps  regarding  these  disclosures  with the goal of making full,
fair,  accurate,  timely,  and  understandable  disclosure.

     Accordingly,  each  Covered  Officer  must:

     -    familiarize  himself  or  herself  with  the  disclosure  requirements
          applicable  to  the Company as well as with the business and financial
          operations  of  the  Company;  and

     -    not  knowingly  misrepresent,  or  cause others to misrepresent, facts
          about  the  Company  to others, whether within or outside the Company,
          including,  among others, the Company's internal auditors, independent
          directors,  independent  auditors,  and  governmental  regulators  and
          self-regulatory  organizations.

V.     COMPLIANCE

     It  is  the  Company's  policy  to  comply  with  all  applicable  laws and
governmental  rules  and regulations.  It is the personal responsibility of each
Covered  Officer  to  adhere  to the standards and restrictions imposed by these
laws,  rules,  and  regulations, including, among others, those laws, rules, and
regulations  relating  to  affiliated  transactions,  accounting,  and  auditing
matters.

VI.     ACCOUNTABILITY,  REPORTING,  AND  ENFORCEMENT RESPONSIBILITIES UNDER THE
        CODE

     RESPONSIBILITIES  OF  THE  COVERED  OFFICERS:   Each  Covered Officer must:

     -    upon  receipt  of  the  Code,  sign  and  submit  to  the  appropriate
          Designated  Person  an acknowledgment stating that the Covered Officer
          has  received,  has  read,  and understands the Code (see Exhibit C to
          this  Code);

     -    annually  thereafter,  submit  a  form  to  the appropriate Designated
          Person confirming that the Covered Officer has received, has read, and
          understands  the  Code  and  has complied with the requirements of the
          Code  (see  Exhibit  D  to  this  Code);

     -    not  retaliate  against  any  employee,  Designated Person, or Covered
          Officer  for  reports  of  potential  violations that are made in good
          faith;  and

     -    notify  the  appropriate  Designated  Person  promptly  if the Covered
          Officer  becomes  aware of any existing or potential violation of this
          Code  (failure to notify the appropriate Designated Person under these
          circumstances  is  itself  a  violation  of  this  Code).

     GENERAL  RESPONSIBILITIES  OF  THE DESIGNATED PERSONS:  Except as otherwise
described  herein, the Designated Person:  (i) shall be responsible for applying
this  Code  to  specific  situations  in  which  questions  are presented to the
Designated  Person;  and  (ii)  has  the authority to interpret this Code in any
particular  situation.  The  Designated  Person  shall take all actions that the
Designated  Person  considers  necessary  and  appropriate  to  investigate  any
existing,  actual,  or  potential  violations reported to the Designated Person.

     SPECIFIC  ACCOUNTABILITY  &  REPORTING  RESPONSIBILITIES:  The  Gartmore
Designated  Person  and  the  Audit Committee Designated Person shall report, in
writing,  quarterly  to  the  Independent  Trustees  all  determinations,  both
preliminary  and  final,  if  any,  made  during  the  previous  quarter.

     The  Independent  Trustees  shall report, in writing, quarterly to the full
Board of Trustees all actions taken under this Code with respect to the previous
quarter:

     a.   by  the Gartmore Designated Person with respect to prospective conduct
          or activity of the Covered Officer (other than the CEO of the Company)
          and  by  the  Audit  Committee  Designated  Person  with  respect  to
          prospective  conduct  or  activity  of  the  CEO;  and

     b.   by  the  Independent  Trustees with respect to all other matters under
          this  Code.

     AUTHORIZED  CONSULTING  PERSONS:  In  addition,  the  Designated Person, as
appropriate,  also  is  authorized  to  consult with the following other persons
(hereinafter  referred to collectively, with the Audit Committee of the Board of
Trustees  of  the  Company,  as  the  "Authorized  Consulting  Persons"), and is
encouraged  to  do  so:  (i)  any  Audit  Committee  Designated Person; (ii) the
chairperson  of  the  Nominating  and Board Governance Committee of the Board of
Trustees of the Company; (iii) the Independent Trustees of the Company; (iv) the
"Lead"  Independent  Trustee  of  the  Company; (v) the Board of Trustees of the
Company;  (vi)  counsel  to the Company; and/or (vii) counsel to the Independent
Trustees.

VII.     OTHER  POLICIES  AND  PROCEDURES

     As  noted above, this Code is not adopted under, nor intended to serve as a
basis  for complying with the requirements of, Rule 17j-1 under the 1940 Act (in
regard  to  the  reporting,  disclosure, and preclearance of personal securities
transactions  and  personal  securities  holdings,  and to other related matters
covered  by  Rule  17j-1  under  the  1940  Act).

     The  code  of ethics of the Company and the code of ethics of the Company's
investment advisers, each pursuant to Rule 17j-1 under the 1940 Act, and each as
amended and reapproved from time to time, each sets forth more detailed policies
and  procedures  that  are  separate  requirements  which  apply  to the Covered
Officers  and  other  persons,  and  are  not  part  of  this  Code.

VIII.     AMENDMENTS

     This  Code may not be amended except in written form, which amendments must
be  specifically approved by a majority vote of the Company's Board of Trustees,
including  a  majority  of  the  Independent  Trustees of the Company's Board of
Trustees.

IX.     CONFIDENTIALITY

     All  reports and records prepared or maintained pursuant to this Code shall
be  considered  confidential  and shall be maintained and protected accordingly.
Except  as  otherwise  required  by law or this Code, these matters shall not be
disclosed  to  anyone  other  than  Designated Persons and Authorized Consulting
Persons.

X.     INTERNAL  USE

     This  Code  is intended solely for the internal use by the Company and does
not  constitute  an  admission,  by or on behalf of the Company, as to any fact,
circumstance,  or  legal  conclusion.

XI.     APPROVAL  HISTORY

     This Code implements Section 406 of the Sarbanes-Oxley Act of 2002, and has
been:

NOMINATING  AND  BOARD  GOVERNANCE  COMMITTEES:

     Initially  approved  and  adopted  by  the  Nominating and Board Governance
     Committees  of  the  Boards  of  Trustees  of the Gartmore Mutual Funds and
     Gartmore  Variable  Insurance  Trust:

     June  4,  2003

     Subsequently  amended  and  restated by the Nominating and Board Governance
     Committees  of  the  Boards  of  Trustees  of the Gartmore Mutual Funds and
     Gartmore  Variable  Insurance  Trust:

     August  19,  2003

AUDIT  COMMITTEES:

     Initially  approved,  ratified,  and adopted by the Audit Committees of the
     Boards  of  Trustees  of  the  Gartmore  Mutual Funds and Gartmore Variable
     Insurance  Trust:

     September  17,  2003

BOARDS  OF  TRUSTEES:

     Initially  approved  and  adopted by the Boards of Trustees of the Gartmore
     Mutual  Funds  and  Gartmore  Variable  Insurance  Trust:

     June  5,  2003

     Subsequently amended and restated by the Boards of Trustees of the Gartmore
     Mutual  Funds  and  Gartmore  Variable  Insurance  Trust:

     September  18,  2003

<PAGE>
                                   EXHIBIT  A:

                  "COVERED OFFICERS" UNDER THIS CODE OF ETHICS
                              (as  of June 5, 2003)

Paul J. Hondros    President & Chief Executive Officer, GMF and GVIT
Gerald J. Holland  Treasurer & Chief Financial Officer, GMF and GVIT
William Baltrus    Assistant Treasurer, GMF and GVIT
Joseph Finelli     Assistant Treasurer, GMF and GVIT
Bryan C. Haft      Assistant Treasurer, GMF and GVIT
Michael Leonard    Assistant Treasurer, GMF and GVIT
Brian J. O'Neill   Assistant Treasurer, GMF and GVIT
Mary Lou Vitale    Assistant Treasurer, GMF and GVIT


<PAGE>
                                   EXHIBIT  B:

               "DESIGNATED PERSONS" UNDER THIS CODE OF ETHICS [1]
                              (as  of June 5, 2003)



                          "GARTMORE DESIGNATED PERSON"

                                    Each of:

Eric  E.  Miller                    Secretary,  GMF  and  GVIT

     (Mr.  Miller currently also serves as a Senior Vice President and the Chief
Counsel  for  Gartmore  Global  Investments)


Michael  Krulikowski               Assistant  Secretary,  GMF  and  GVIT

     (Mr.  Krulikowski  currently  also serves as a Vice President and the Chief
Compliance  Officer  for  Gartmore  Global  Investments)



                       "AUDIT COMMITTEE DESIGNATED PERSON"

                       Each member of the Audit Committee
                    of the Board of Trustees of GMF and GVIT
                            shall be deemed to be an
                      "Audit Committee Designated Person."





[1]  The  Securities  and  Exchange Commission has indicated that any Designated
     Person  of the Company "should have sufficient status within the company to
     engender respect for the code and the authority to adequately deal with the
     persons  subject  to  the code regardless of their stature in the company."



<PAGE>
                                   EXHIBIT  C:

                              INITIAL CERTIFICATION

                            GARTMORE MUTUAL FUNDS AND
                        GARTMORE VARIABLE INSURANCE TRUST
                  CODE OF ETHICS FOR SENIOR FINANCIAL OFFICERS


To:     Eric  E.  Miller,  Secretary,  GMF  and  GVIT
        Michael  Krulikowski,  Assistant  Secretary,  GMF  and  GVIT


1.   I  hereby  acknowledge  receipt  of  the  Gartmore Mutual Fund and Gartmore
     Variable  Insurance Trust Code of Ethics for Senior Financial Officers (the
     "Code").

2.   I  have  read  and  understand  the Code, and I recognize that I am subject
     thereto  in  the  capacity  of  a  "Covered  Officer."

3.   I shall comply with the requirements of the Code, and shall disclose/report
     all  violations or potential violations of the Code as required thereunder.

4.   As  of  the  date  indicated  below,  I  am  not aware of any violations or
     potential  violations  of  the  Code.


Signature:                   _________________
Name:                        _________________
Title:                       _________________
Date  Report  Submitted:     _________________

<PAGE>
                                   EXHIBIT  D:

                              ANNUAL CERTIFICATION

                            GARTMORE MUTUAL FUNDS AND
                        GARTMORE VARIABLE INSURANCE TRUST
                  CODE OF ETHICS FOR SENIOR FINANCIAL OFFICERS


To:     Eric  E.  Miller,  Secretary,  GMF  and  GVIT
        Michael  Krulikowski,  Assistant  Secretary,  GMF  and  GVIT


1.   I  have  read and understand the Gartmore Mutual Fund and Gartmore Variable
     Insurance  Trust Code of Ethics for Senior Financial Officers (the "Code"),
     and  I  recognize  that  I am subject thereto in the capacity of a "Covered
     Officer".

2.   I  hereby  certify  that,  during  the year ended December 31, 200_, I have
     complied with the requirements of the Code and have reported all violations
     or  potential  violations  required  to  be  reported pursuant to the Code.


Signature:                   _________________
Name:                        _________________
Title:                       _________________
Date  Report  Submitted:     _________________