Code of Ethics


To the Trustees, Officers and employees of the Progressive Capital Accumulation
Trust


I. BACKGROUND

        The Board of Trustees of the Progressive Capital Accumulation Trust (the
"Trust") reviews periodically the matter of purchases and sales of securities by
the Progressive Capital Accumulation Trust and the Trusts' officers and
employees. The Board has considered that because of the judgmental nature of the
questions involved and the confidence of the board in the persons concerned, the
matter is not a subject for rigid, detailed rules and regulations, but rather
for a statement of policy as a guide to persons of good faith.

        This code of ethics is intended as a statement of policy to guide
persons of good faith in handling their own investments.


II. DEFINITIONS

        a) "Trust" means the Progressive Capital Accumulation Trust.

        b) "Access person" means any trustee, officer, general partner, or
        advisory person of the Trust.

        c) "Advisory person" means (i) any employee of the Trust or of any
        company in a control relationship with the Trust, who, in connection
        with his regular functions or duties, makes, participates in, or obtains
        information regarding the purchase or sale of a security by the Trust,
        or whose functions relate to the making of any recommendations with
        respect to purchases or sales; and (ii) any natural person in a control
        relationship to the Trust who obtains information concerning
        recommendations made to the Trust with regard to the purchase or sale of
        a security.

        d) a security is "being considered for purchase or sale" when a
        recommendation to purchase or sell a security has been made and
        communicated and, with respect to the person making the recommendation,
        when such person seriously considers making such a recommendation.

        e) "Beneficial ownership" shall be interpreted in the same manner in
        which it would be in determining whether a person is subject to the
        provisions of Section 16 of the Securities Act of 1934 and the rules and
        regulations thereunder, except that the determination of direct or
        indirect beneficial ownership shall apply to all securities which an
        access person has or acquires.

        f) "Control" shall have the same meaning as that set forth in Section
        2(a) (9) of the Investment Company Act.

        g) "Disinterested trustee" means a trustee of the Trust who is not an
        "interested person" of the Trust within the meaning of Section 2(a) (9)
        of the Investment Company Act.

        h) "Purchase or sale of a security" includes, inter alia, the writing of
        an option to purchase or sell a security.




        i) "Security" shall have the meaning set forth in Section 2(a) (36) of
        the Investment Company Act, except that it shall not include shares of
        registered open-end investment companies, securities issued by the
        Government of the United States, short-term debt securities which are
        "government securities" within the meaning of Section 2(a) (16) of the
        Investment Company Act, banker's acceptances, bank certificates of
        deposit, commercial paper, and other such money market instruments as
        designated by the Board of Trustees.


III. EXEMPTED TRANSACTIONS

        The prohibitions of Section IV of this Code shall not apply to:

        a) Purchases or sales effected in any account over which the access
        person has no direct or indirect influence or control.

        b) Purchase or sales of securities which are not eligible for purchase
        or sale by the Trust.

        c) Purchases or sales which are non-volitional on the part of either the
        access person or the Trust.

        d) Purchases which are part of an automatic dividend reinvestment plan.

        e) Purchases effected upon the exercise of rights issued by an issuer
        pro rata to all holders of a class of its securities, to the extent such
        rights were acquired from such issuer, and sales of such rights so
        acquired.

        f) Purchases or sales which, in the opinion of the Board of Trustees,
        are only remotely potentially harmful to the Trust because they would be
        very unlikely to affect a highly institutional market, or because they
        clearly are not related economically to the securities to be purchased,
        sold, or held by the Trust. No such purchases or sales by access persons
        shall be effected prior to the completion of the related transactions by
        the Trust. In addition, such purchases or sales shall be reviewed by the
        board on a semi-annual basis to ensure compliance with the intent of
        this Code.


IV. PROHIBITED PURCHASES AND SALES

        No access person shall purchase or sell, directly or indirectly, any
security in which he has, or by reason of such transaction acquires, any direct
or indirect beneficial ownership and which to his actual knowledge at the time
of such purchase or sale:

        a) is being considered for purchase or sale by the Trust; or

        b) is being purchased or sold by the Trust.



V. REPORTING

        a) Every access person shall report to the Trust the information
        described in Section V(c) of this Code with respect to transactions in
        any security in which such access person has, or by reason of such
        transaction acquires, any direct or indirect beneficial ownership in the
        security; provided, however, that an access person shall not be required
        to make a report with respect to transaction effected for any account
        over which such person does not have direct or indirect influence.

        b) a disinterested trustee of the Trust need only report a transaction
        in a security if such trustee, at the time of that transaction, knew or,
        in the ordinary course of fulfilling his official duties as a trustee of
        the Trust, should have known that, during the 15 day period immediately
        preceding the date of the transaction by the trustee, such security was
        purchased or sold by the Trust or was being considered for purchase or
        sale by the Trust.

        c) Every report shall be made not later than 10 days after the end of
        the calendar quarter in which the transaction to which the report
        relates was effected, and shall contain the following information:

           i) the date of the transaction, the title and the number of shares,
           and the principal amount of each security involved;

           ii) the nature of the transaction (i.e. purchase, sale, or any other
           type of acquisition or disposition);

           iii) the price at which the transaction was effected; and,

           iv) the name of the broker, dealer or bank with or through whom the
           transaction was effected.

        d) Any such report may contain a statement that the report shall not be
        construed as an admission by the person making such report that he has
        any direct or indirect beneficial ownership in the security to which the
        report relates.

VI. SANCTIONS

        Upon discovering a violation of this Code, the Board of Trustees of the
Trust may impose such sanctions, as it deems appropriate, including, inter alia,
a letter of censure or suspension or termination of the employment of the
violator.


VII. CONCLUSION

        The Board of Trustees urges that all concerned should keep the above
matters constantly in mind and comply with the above reporting requirements.