THE PIONEER COMPLEX OF FUNDS

                  CODE OF ETHICS AND INSIDER TRADING PROCEDURES


The following procedures have 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, by Pioneer
Investments and PFD for purposes of implementing the Code of Ethics (the "Code")
adopted by each entity pursuant to Rule 17j-1 of the Investment Company Act of
1940, as amended (the "Rule"). Pioneer Investment Management, Ltd is a
participating affiliate of Pioneer Investment Management, Inc. Therefore under
the Investment Company Act of 1940, is subject to the Code of Ethics. Unless
indicated otherwise, capitalized terms used herein shall have the meanings
contained in the Code.

Administration of the procedures and reviews of all reports required to be made
pursuant to these procedures will be the responsibility of Dorothy Bourassa,
General Counsel of Pioneer Investment Management USA Inc., Martin J. Wolin,
Director of Compliance, and David Rule, Regulatory Compliance Administrator.

I.       IDENTIFICATION OF AND NOTIFICATION TO ACCESS PERSONS

The Compliance Department within Pioneer Investment Management USA Inc., working
with the Human Resources Department, will identify those employees who meet the
definition of "Access Person" as defined in Rule 17j-1.

Each employee designated as an Access Person and/or Advisory Person will be
notified by the Compliance Department and/or the Human Resources Department at
the time of hire or promotion of his/her designation as an Access Person and/or
Advisory Person and informed of the following policies and procedures. The
failure of the Compliance Department and/or the Human Resources Department to so
notify such employee shall not affect such person's status as an Access Person
and/or Advisory Person under the Code.

II.      REPORTS BY ACCESS PERSONS

INITIAL REPORTS - DISCLOSURE OF PERSONAL HOLDINGS

All Access Persons (other than Independent Trustees) shall submit to the Review
Officer within ten days of becoming an Access Person a report in the form of
EXHIBIT A.

MONTHLY REPORTS - BROKERAGE ACCOUNTS

All Access Person (other than Independent Trustees) are required to direct their
brokers to provide to the Review Officer the following:






o       within ten days of the end of a calendar month, duplicate copies of
        confirmations of all Covered Securities transactions in which the Access
        Person has a Beneficial Ownership interest;

o       within ten days following the end of a calendar quarter, related
        periodic account statements.

In the alternative, if an Access Person is unable to arrange for duplicate
copies of confirmations and periodic account statements to be sent to the Review
Officer, he/she must immediately notify the Review Officer and provide to the
Review Officer within ten days following the end of a month in which a
transaction occurs a report in the form of EXHIBIT B.

All Access Persons (other than Independent Trustees) also shall provide to the
Review Officer within ten days of the end of a calendar month a report on
EXHIBIT B of any Covered Securities transactions which would not be reported on
a brokerage or other account statement.

Any report required to be filed by the Review Officer shall be filed with the
Alternative Review Officer.

Prior to opening a brokerage account, each Access Person (other than Independent
Trustees) must notify the Review Officer to allow the Review Officer an
opportunity to notify the broker that Pioneer requires duplicate confirmations
and period account statements to be sent directly to the Review Officer.

An Independent Trustee shall provide to the Review Officer within ten days of
the end of a calendar month in which a transaction occurs a report in the form
of EXHIBIT B of any Covered Securities transaction in which the Independent
Trustee acquires or disposes of any Beneficial Ownership interest in a Covered
Security if, at the time of the transaction in the Covered Security, the
Independent Trustee knew, or, in the ordinary course of fulfilling his/her
official duties as an Independent Trustee, should have know, that during the
fifteen-day period immediately before or after the date of such transaction,
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.

ANNUAL REPORTS

All Access Persons (other than Independent Trustees) shall provide to the Review
Officer within thirty days following the end of a calendar year a report in the
form of EXHIBIT C, the information on which must be current as of a date no more
than thirty days before the report is submitted.

ANNUAL CERTIFICATIONS

Each Access Person shall certify annually on EXHIBIT D within thirty days
following the end of a calendar year that he/she:

o       has read and understands the Code and recognizes that he/she is subject
        thereto;

o       has complied with the requirements of the Code;

o       has disclosed or reported all Covered Securities transactions and
        accounts required to be disclosed or reported under the Code;


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o       has read and understands Pioneer's Procedures to Prevent Insider Trading
        Violations and recognizes that he/she is subject thereto; and

o       has complied with the requirements of Pioneer's Procedures to Prevent
        Insider Trading Violations.

Failure to comply with the periodic reporting requirements and/or the Annual
Certification procedure will result in the denial of any preclearance requests
as well as any other sanction that may be deemed appropriate.


III.     MONITORING OF PERSONAL TRADING ACTIVITY

PRECLEARANCE PROCEDURES FOR ACCESS PERSONS WHO ARE NOT INDEPENDENT TRUSTEES

All transactions in Covered Securities by Access Persons shall be precleared in
advance by receiving written approval from the Preclearance Officer. The
Preclearance Officer must preclear his/her Covered Securities transactions with
the Alternative Preclearance Officer. Each request for preclearance must be
submitted to the Preclearance Officer on either EXHIBIT E ("Preclearance Form
for Access Persons") or EXHIBIT F ("Preclearance Form for Portfolio Managers and
Investment Analysts") prior to 2:00 pm. in order to receive a response on the
following day.. Verbal approvals of Covered Securities transactions are not
permitted.

Any approval by the Preclearance Officer is valid for three business days,
including the day on which the approval is granted. If an Access Person is
unable to effect the Covered Securities transaction during such period, he/she
must resubmit a completed EXHIBIT E or F and reobtain approval from the
Preclearance Officer prior to effecting the Covered Securities transaction.

The Preclearance Officer will base his/her decision whether to approve a Covered
Securities transaction for an Access Person after considering the specific
restrictions and limitations set forth in, and the spirit of, the Code,
including whether the Covered Security at issue is being considered for purchase
or sale by an Investment Company or Institutional Account. The Preclearance
Officer is not required to give any explanation for refusing to approve a
requested Covered Securities transaction.

PRECLEARANCE PROCEDURES FOR ACCESS PERSONS WHO ARE INDEPENDENT TRUSTEES

Independent Trustees are encouraged to preclear Covered Securities transactions
only when there is a question as to the then current trading activities of an
Investment Company; otherwise preclearance by an Independent Trustee is neither
encouraged nor required.

DE MINIMUS EXCEPTIONS

The Preclearance Officer has discretion to approve transactions by Access
Persons (other than Advisory Persons) of trades of 500 shares or fewer in
companies with market capitalizations of $20 billion or greater.

The Preclearance Officer has discretion to determine the DE MINIMUS value of
gifts and other personal benefits under the Code. Currently, the following may
be accepted:


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o       gifts with reasonable values of no more than $100 annually from any
        single person or entity;

o       customary business lunches, dinners and entertainment at which both the
        Advisory Person and the giver are present; and

o       promotional items of DE MINIMUS value.

REVIEW OF REPORTS

The Review Officer shall compare the reported personal Covered Securities
transactions of each Access Person with completed and contemplated portfolio
transactions of the Investment Companies and Institutional Accounts to determine
whether a violation of the Code may have occurred. The Review Officer shall also
compare reported personal securities transactions during the year with the
annual report submitted by the person. In the case of reports of personal
Covered Securities transactions of the Review Officer, the Alternative Review
Officer shall perform such comparison. Before making any determination that a
violation has been committed by an Access Person, the Review Officer or
Alternative Review Officer, as the case may be, shall provide such person with
an opportunity to supply additional explanatory information or material.

If the Review Officer or Alternative Review Officer, as the case may be,
determines that a violation of the Code has or may have occurred, he/she shall
submit a written determination, together with the related information or
material provided by the Access Person, to the President of Pioneer Investments
who shall make an independent determination of whether a violation has occurred.

On a monthly basis, the Review Officer shall prepare a summary of his/her review
of all preclearance forms submitted during the month with the monthly
confirmations and/or periodic account statements of such Access Persons and
provide such report to the President of Pioneer Investments and such other
persons as the President shall deem appropriate, including, but not limited to,
the Chief Investment Officer of Pioneer, the General Counsel of Pioneer and
counsel to the Pioneer Funds.

On an annual basis, the Review Officer shall prepare and submit to the Board of
Trustees of the Investment Companies, as well as other relevant parties, a
summary of the level of compliance by all Access Persons of the Code during the
previous year, including, without limitation, the number and nature of all
material violations and the sanctions imposed. The report shall certify that the
Investment Companies, Pioneer Investments and PFD have adopted procedures
reasonably necessary to prevent Access Persons from violating the Code. The
report may also include any recommended changes to existing Code restrictions or
procedures based upon Pioneer's experience with the Code, evolving industry
practices and developments in applicable laws or regulations. The Alternative
Review Officer shall prepare reports with respect to compliance by the Review
Officer.

IV.      SANCTIONS

VIOLATIONS BY ACCESS PERSONS

Any violation of the Code by an Access Person who is not an Independent Trustee
shall result in the imposition of such sanctions as Pioneer may deem appropriate
under the circumstances, which may include, but are not limited to, removal or
suspension from office, termination of


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employment, a letter of censure and/or restitution to the affected
Investment Company or Institutional Account of an amount equal to the advantage
the offending person shall have gained by reason of such violation. In addition,
as part of any sanction, Pioneer may require the Access Person to reverse the
trade(s) at issue and forfeit any profit or absorb any loss from the trade.
Violations of the Code by an Access Person also may result in criminal
prosecution or civil action. The Board of Trustees of any Investment Company
shall have the power to modify or increase any sanction as it deems appropriate.

VIOLATIONS BY INDEPENDENT TRUSTEES

Any violation of the Code by an Independent Trustee shall result in the
imposition of such sanctions as the other members of the Board of Trustees may
deem appropriate under the circumstances, which may include, but are not limited
to, removal from office.

V.       RECORDKEEPING REQUIREMENTS

Pioneer shall maintain and preserve in an easily accessible place:

o    a copy of the Code (and any prior code of ethics that was in effect at any
     time during the past five years) for a period of not less than five years;

o    a record of any violation of the Code and of any action taken as a result
     of such violation for a period of not less than five years following the
     end of the fiscal year in which the violation occurs;

o    a copy of each preclearance request and any report submitted under the Code
     by an Access Person for a period of not less than five years following the
     end of the fiscal year in which the preclearance request or report is made,
     the first two years in an easily accessible place;

o    a record of all persons who are, or within the past five years were,
     required to make reports pursuant to the Code and who are or were
     responsible for reviewing such reports;

o    a copy of each report submitted to the Boards of Trustees of the Investment
     Companies under the Code for a period of not less than five years following
     the end of the fiscal year in which such report is made, the first two
     years in an easily accessible place; and

o    a record of any decision, and the reasons supporting such decision, to
     approve the acquisition by Investment Personnel of Initial Public Offerings
     or Limited Offerings for at least five years after the end of the fiscal
     year in which such approvals are granted.

VI.      PIONEER'S POLICIES AND PROCEDURES TO PREVENT INSIDER TRADING

Every employee of Pioneer is subject to Pioneer's Policies and Procedures to
Prevent Insider Trading. Pioneer's Policy Statement on Insider Trading is
attached as EXHIBIT G. Each employee is required to acknowledge annually that
he/she has read and complied with the Policies. The Review Officer oversees
administration of the annual certification.


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