Code of Ethics November 2004 Following is the Code of Ethics for The Capital
Group Companies Inc. (Capital), which includes Capital Research and Management
Company, the investment adviser to the American Funds and those involved in the
distribution of the funds, client support and services; and Capital Group
International Inc. (CGII), which includes Capital Guardian Trust Company and
Capital International Inc. The Code of Ethics applies to all associates.



                           The Capital Group Companies
                                 CODE OF ETHICS


All of us within the Capital organization are responsible for maintaining the
very highest ethical standards when conducting business. In keeping with these
standards, we must always place the interests of clients and fund shareholders
ahead of our own. Moreover, we should adhere to the spirit as well as the letter
of the law and be vigilant in guarding against anything that could color our
judgment.

Over the years we have earned a reputation for the highest integrity. Regardless
of lesser standards that may be followed through business or community custom,
we must observe exemplary standards of openness, integrity, honesty and trust.
Accordingly, we have adopted certain standards as described below for the
purpose of deterring wrongdoing and promoting: 1) honest and ethical conduct; 2)
full, fair, accurate, timely and understandable disclosure in reports and
documents; 3) compliance with applicable laws (including federal securities
laws), rules, and regulations; 4) the prompt internal reporting of violations of
our Code of Ethics; and 5) accountability for adherence to our Code of Ethics.

General Guidelines

Although specific policies are discussed in more detail below, these are general
guidelines that all Capital associates should be aware of:

o                 It is a crime in the U.S. and many other countries to transact
                  in a company's securities while in possession of material
                  nonpublic information about the company. If there is any
                  question as to whether you've received material information
                  (typically from a company "insider") you should contact any
                  member of the legal staff to discuss.

o                 You should not knowingly misrepresent, or cause others to
                  misrepresent, facts about Capital to clients, fund
                  shareholders, regulators, or any other member of the public.
                  Disclosure in reports and documents should be fair and
                  accurate.

o                 You should not accept extravagant gifts or entertainment from
                  persons or companies who are trying to solicit business from
                  any of the Capital companies. Capital's Gifts and
                  Entertainment Policy is summarized below.

o                 Safeguarding nonpublic information - - All associates are
                  responsible for safeguarding nonpublic information about
                  securities recommendations and fund and client holdings (for
                  example, analyst research reports, investment meeting
                  discussions or notes, current fund/client transaction
                  information). If you have regular access to such information,
                  you will likely be subject to additional personal investing
                  limitations under Capital's Personal Investing Policy. Even if
                  you are not a "covered person" under the Personal Investing
                  Policy, certain general principles apply to you, and you
                  should not trade based on any Capital company's confidential,
                  proprietary investment information where fund or client trades
                  are likely to be pending or imminent.

o                 Other types of information (for example, marketing plans,
                  employment issues, shareholder identities, etc.) may also be
                  confidential and should not be shared with individuals outside
                  the company (except those retained to provide services for the
                  Capital companies).

Excessive trading of Capital-managed Funds - - You should not engage in
excessive trading of the American Funds or any other Capital-managed investment
vehicles worldwide to take advantage of short-term market movements. Excessive
activity, such as a frequent pattern of exchanges, could involve actual or
potential harm to shareholders or clients. Note that this applies to your spouse
and any other immediate family members.

Ban on Participation in IPOs - - Capital associates and their immediate family
members residing in their household may not participate in Initial Public
Offerings (IPOs). Although exceptions are rarely granted, they will be
considered on a case-by-case basis, for example, where a family member is
employed by the IPO Company and IPO shares are considered part of that family
member's compensation.

Limitation on Service on Boards - - Associates are discouraged from serving on
the board of directors or advisory board of any public or private company (this
does not apply to boards of Capital companies or funds). You must receive
approval prior to serving on a board, except for boards of charitable
organizations or other nonprofit organizations. In addition, certain associates
will be sent a form annually and asked to disclose their board positions.

Failure to adhere to our Code of Ethics may result in disciplinary action being
taken, including termination.


Annual Certification of Code of Ethics

Each associate will receive a copy of the Code of Ethics annually and is
responsible for certifying in writing that they have read and understood the
Code.


Reporting Violations

You have a responsibility to report any violations of our Code of Ethics,
including: (i) fraud or illegal acts involving any aspect of our business; (ii)
noncompliance with applicable laws, rules and regulations; (iii) intentional or
material misstatements in our regulatory filings, internal books and records or
client records or reports; or (iv) activity that is harmful to our clients or
fund shareholders. Deviations from controls or procedures that safeguard the
company, including the assets of shareholders and clients, should also be
reported. Reported violations of the Code of Ethics will be investigated and
appropriate actions will be taken.

You can report confidentially to:
o        Your manager or department head
o        Capital's Audit Committee
o        any lawyer employed by the Capital organization



Capital's Gifts and Entertainment Policy - Conflicts of Interest

       A conflict of interest occurs when the private interests of associates
       interfere or could potentially interfere with their responsibilities at
       work. Associates must not place themselves or the company in a position
       of actual or potential conflict. Associates may not accept gifts worth
       more than $100, excessive business entertainment, loans, or anything else
       involving personal gain from those who conduct business with the company.
       In addition, a business entertainment event exceeding $200 in value
       should not be accepted unless the associate receives permission from the
       Gifts and Entertainment Policy Committee.

       Gifts or entertainment that are reimbursed by Capital do not need to be
       reported (or pre-cleared). The expenses, however, are subject to the
       approval of the associate's manager. When giving a gift or extending
       entertainment on behalf of Capital, it is important to keep in mind that
       giving an extravagant gift or entertaining excessively or lavishly may
       create the appearance of conflict. Associates should also be aware that
       certain laws or rules may prohibit or limit gifts or entertainment
       extended to public officials -- especially those responsible for
       investing public funds.

Political and Charitable Contributions

       In soliciting political or charitable donations from various people in
       the business community, associates must never allow the present or
       anticipated business relationships of Capital or any of its affiliates to
       be a factor in soliciting such contributions. In addition, certain
       associates are subject to additional restrictions due to their
       involvement with "College America(R)," the American Funds 529 College
       Savings Plan.

Reporting

       Although the limitations on accepting gifts applies to all associates as
       described above, some associates will be asked to fill out quarterly
       reports. If you receive a reporting form, you must report any gift
       exceeding $50 in value (although it is recommended that you report all
       gifts received) and business entertainment in which an event exceeds $75.

Gifts and Entertainment Policy Committee

       The Gifts and Entertainment Policy Committee oversees administration of
and compliance with the Policy.


Insider Trading

       Antifraud provisions of U.S. securities laws as well as the laws of other
       countries generally prohibit persons in possession of material nonpublic
       information from trading on or communicating the information to others.
       Sanctions for violations can include civil injunctions, permanent bars
       from the securities industry, civil penalties up to three times the
       profits made or losses avoided, criminal fines and jail sentences.

       While investment research analysts are most likely to come in contact
       with material nonpublic information, the rules (and sanctions) in this
       area apply to all Capital associates and extend to activities both within
       and outside each associate's duties. Any associate who believes that he
       or she may have material non-public information should contact a Capital
       lawyer.


Personal Investing Policy

       As an associate of The Capital Group Companies, you may have access to
       confidential information. This places you in a position of special trust.

       You are associated with a group of companies that is responsible for the
       management of many billions of dollars belonging to mutual fund
       shareholders and other clients. The law, ethics and our own policy place
       a heavy burden on all of us to ensure that the highest standards of
       honesty and integrity are maintained at all times.

       There are several rules that must be followed to avoid possible conflicts
       of interest in personal investments. Keep in mind, however, that placing
       the interests of clients and fund shareholders first is the core
       principle of our policies and applies even if the matter is not covered
       by a specific provision. The following is only a summary of Capital's
       Personal Investing Policy.


The following provisions apply only to associates covered under the Personal
Investing Policy.

Covered Persons

       You are a "covered person" if you have access to non-public investment
       information relating to current or imminent fund/client transactions. If
       you receive a quarterly personal investing disclosure form, you are
       considered a covered person.

       Covered persons must conduct their personal securities transactions in
       such a way that they do not conflict with the interests of the funds and
       client accounts. This policy also includes securities transactions of
       family members living in the covered person's household and any trust or
       custodianship for which the associate is trustee or custodian. A conflict
       may occur if you, or a family member in the same household, or a trust or
       custodianship for which you are trustee or custodian, have a transaction
       in a security when the funds or client accounts are considering or
       concluding a transaction in the same security. For purposes of this
       Policy, "covered persons" include immediate family members living in the
       same household.

       Additional rules apply to "investment associates" including portfolio
       counselors/managers, investment analysts and research associates, trading
       associates including trading assistants, and investment administration,
       portfolio control and fixed income control associates including
       assistants (see below).

Prohibited Transactions for Covered Persons

       o   IPO investments
       o Writing puts and calls on securities that are subject to pre-clearance
       o Short sales of securities that are subject to pre-clearance

Initial and Annual Holdings Reports

Any associate that becomes a covered person must submit a list of portfolio
holdings and securities accounts within 10 calendar days of becoming covered. In
addition, all covered associates will be required to review and update their
holdings and securities account information annually.

Pre-clearance of Securities Transactions

Covered  persons  must  receive  approval  before  buying or selling  securities
including (but not limited to):

o        stocks of companies (public or private, including purchases through
         private placements)

o        bonds (except U.S. government bonds or other sovereign government
         bonds rated AAA or Aaa or equivalent)

o        venture capital partnerships

o        options on securities subject to pre-clearance (the exercise of
         options must also be pre-cleared)

o        closed-end funds including investment trust companies

o        index funds or exchange-traded funds that are not on the pre-approved
         list of index funds/ETFs

o        transactions in the above securities in PEP and ISA accounts (available
         in the U.K. only) over which you have discretion

       Before buying or selling securities, covered persons must check with the
staff of the Personal Investing Committee.

       Pre-clear requests will be handled during the hours the New York Stock
       Exchange ("NYSE") is open (generally 6:30am to 1:00pm Pacific Time).

       You will generally receive a response within one business day. Unless a
       different period is specified, clearance is good until the close of the
       New York Stock Exchange ("NYSE") on the day that you check. Associates
       from offices outside the U.S. and/or associates trading on non-U.S.
       exchanges are usually granted enough time to complete their transaction
       during the next available trading day. If you have not executed your
       transaction within this period, you must again pre-clear your
       transaction. Note that investments in private placements and venture
       capital partnerships must be pre-cleared and reported and are subject to
       special review. In addition, opportunities to acquire a stock that is
       "limited" (i.e., a broker-dealer is only given a certain number of shares
       to sell and is offering the opportunity to buy) may be subject to the
       Gifts and Entertainment Policy.

Exception for De Minimis Transactions

       The de minimis exception is NOT available to associates based in Tokyo or
       associates considered investment associates: portfolio
       counselors/managers, investment analysts and research associates, trading
       associates including trading assistants, and investment administration,
       portfolio control and fixed income control associates including
       assistants.

       All other covered associates may execute one transaction (either a buy or
       a sell) of 100 shares or less per issuer per calendar month without
       pre-clearance. You must, however, still report these trades on your
       quarterly form. Larger or more frequent share transactions must be
       pre-cleared. If an associate pre-clears a transaction and is denied
       permission, s/he may not execute a de minimis transaction in that issuer
       without pre-clearance for a period of seven calendar days.

Reporting Transactions

       Covered persons must submit quarterly disclosure of certain transactions.
       You will receive reporting forms each quarter that are due no later than
       15 calendar days after the end of the quarter. Reports will be reviewed
       by the staff of the Personal Investing Committee. Transactions of
       securities (including fixed-income securities) or options must be
       pre-cleared as described above and reported except as outlined below:

       Report Only (no need to pre-clear):

o          purchases or sales of any fund advised or sub-advised by a Capital
           company (for example, American Funds, Endowments, Capital
           International Funds, etc). Note that transactions in American Funds
           in Capital's 401(k) or MRP accounts or in accounts held with American
           Funds Service Company (where the account number has been disclosed)
           need not be reported on the quarterly form
o          purchases or sales of any other fund (except funds that are advised
           or sub-advised by a Capital company) that is not a U.S. registered
           open-end investment company (including closed end funds and funds
           registered outside the U.S. such as OEICs and Luxembourg or French
           SICAVs or FCPs)
o          purchases or sales of index funds or exchange traded funds that are
           on the pre-approved list of funds
o          participation in any CGII private equity fund/partnership
o          de minimis transactions (see above)
o          distributions of stock from venture capital partnerships
o          gifts or bequests (either receiving or giving) of securities (note
           that sales of securities received as a gift must be both pre-cleared
           and reported)
o          sales pursuant to tender offers
o          options or futures of index funds or exchange traded funds that are
           on the pre-approved list of funds

       Do Not Pre-clear or Report:

       o U.S. registered open-end investment companies (mutual funds) except
       funds advised or sub-advised by any Capital company o money market
       instruments or other short-term debt instruments with maturities (at
       issuance) of one year or less that are
           rated in one of the highest two rating categories by a Nationally
           Recognized Statistical Rating Organization or unrated but of
           equivalent quality
       o   direct obligations of the U.S. Government or bonds issued by
           sovereign governments outside the U.S. that are rated AAA or
           Aaa or equivalent
       o bankers' acceptances, CDs or other commercial paper o currencies
       (including options and futures) o commodities
       o   transactions in accounts for which you have completely turned over
           investment decision-making authority to a professional money manager
           (see "Professionally Managed Accounts" below)

       Personal investing should be viewed as a privilege, not a right. As such,
       the Personal Investing Committee may place limitations on the number of
       pre-clearances and/or transactions.


Securities Accounts

1.     Disclosure of Securities Accounts

       You must disclose the following types of accounts:
        o  accounts currently holding securities that are subject to
           pre-clearance or reporting (including any accounts that hold funds
           advised or sub-advised by a Capital company)
        o accounts that have the ability to hold securities that are subject to
        pre-clearance or reporting o PEP and ISA accounts that hold securities
        subject to pre-clearance or reporting o accounts where you (or immediate
        family members residing with you) have completely turned over investment
        decision-making
           authority to a professional money manager

       You do not need to disclose accounts that can only hold cash or cash
equivalents.

2.     Duplicate Account Statements and Trade Confirmations

       You must submit duplicate statements and trade confirmations (or other
       equivalent documentation) for accounts currently holding securities that
       are subject to pre-clearance and/or reporting (other than American Funds
       accounts where records are held at American Funds Service Company).
       Covered persons should inform their investment broker-dealers that they
       are employed by an investment organization.

       In addition, covered persons must direct their broker-dealers to send
       duplicate trade confirmations and account statements (or other equivalent
       documentation) for all new or existing accounts on a timely basis. If
       they are not able to send duplicates directly, you must submit copies of
       all trade confirmations and account statements as soon as they become
       available.

       All documents received are kept strictly confidential and are maintained
       by LAO Legal in accordance with applicable Federal Securities laws.1

       If your broker requires a letter requesting duplicate trade confirmations
       and monthly statements, please contact the Staff of the Personal
       Investing Committee.

       If your broker will be sending confirmation statements for an immediate
       family member with a different last name than you, you should inform the
       staff of the Personal Investing Committee with the name of the family
       member and that person's relationship to you.

3.       Professionally Managed Accounts

       If you have an account where you have completely turned over
       decision-making authority to a professional money manager (who is not
       covered by our policy), you should have a signed "Professionally Managed
       Account Exception Memo" on file with the staff of the Personal Investing
       Committee. (This memo is not required for PIM accounts.) You must
       disclose the existence of these accounts and provide the account numbers
       on your personal investing disclosure forms. You do not need to pre-clear
       or report securities transactions in these accounts.



Additional Policies for "Investment Associates"

       1.  Investment Associates

           Unless otherwise specified, the term "investment associates"
           includes: portfolio counselors/managers, investment analysts and
           research associates, trading associates including trading assistants,
           and investment administration, portfolio control and fixed income
           control including assistants.

       2.  Disclosure of Personal Ownership of Recommended Securities

           Portfolio counselors/managers and analysts will be asked on a regular
           basis to disclose securities that they own both personally and
           professionally and, for analysts, securities that they hold
           personally that are within their research coverage. This disclosure
           will be reviewed on a periodic basis by the staff of the Personal
           Investing Committee or other appropriate Capital Committees. In
           addition, to the extent that disclosure has not already been made to
           the Personal Investing Committee (by including information on the
           quarterly form), any associate who is in a position to recommend the
           purchase or sale of securities by the fund or client accounts that
           s/he personally owns should first disclose such ownership either in
           writing (in a company write-up) or verbally (when discussing the
           company at investment meetings) prior to making a recommendation.2 If
           you have any questions, you should contact the staff of the Personal
           Investing Committee.

       3.  Blackout Periods

           Investment associates may not buy or sell a security during a period
           beginning seven calendar days before and ending seven calendar days
           after a fund or client account transacts in that issuer. The blackout
           period applies to trades in the same management company with which
           the associate is affiliated. If a fund or client account transaction
           takes place in the seven calendar days following a pre-cleared
           transaction by an investment associate, the personal transaction may
           be reviewed by the Personal Investing Committee to determine the
           appropriate action, if any. For example, the Committee may recommend
           that the associate be subject to a price adjustment to ensure that he
           or she has not received a better price than the fund or client
           account.

       4. Ban on short-term trading profits

           Investment associates are generally prohibited from profiting from
           the purchase and sale or sale and purchase of the same (or
           equivalent) securities within 60 days. This restriction applies to
           the purchase of an option and the exercise of the option within 60
           days.

Other Considerations

       Associates may not accept negotiated commission rates or any other terms
       that they believe may be more favorable than the broker-dealer grants to
       accounts with similar characteristics. U.S. broker-dealers are subject to
       certain rules designed to prevent favoritism toward such accounts.

       In addition, material outside business interests may give rise to
       potential conflicts of interest. Associates are asked to report if they
       are a senior officer of or own more than 5% of any private or public
       company that is or potentially may be doing business with any Capital
       company or with the American Funds. This reporting requirement also
       applies to any immediate family member residing within the associate's
       household.


Personal Investing Committee

       Any questions or hardships that result from these policies or requests
       for exceptions should be referred to Capital's Personal Investing
       Committee.

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1 Information about particular transactions may be provided to an associate's
supervisor or appropriate Human Resources manager by Personal Investing
Committee staff where the transactions are in violation of the Policy, may
impact the associate's job performance, or raise conflict of interest-related
issues.

2 Note that this disclosure requirement is consistent with both AIMR standards
as well as the ICI Advisory Group Guidelines.