HARTFORD SECURITIES DISTRIBUTION COMPANY

                                 CODE OF ETHICS

SECTION 1 - INTRODUCTION

In accordance with Federal securities laws, the Hartford Securities Distribution
Company ("HSD"), as principal underwriter to investment companies registered
under the Investment Company Act of 1940, must adopt and administer a code of
ethics (the "Code"). The adoption and administration of the Code is predicated
upon the following principles: (1) at all times the interests of investment
company shareholders and advisory account clients should be placed first; (2)
all personal securities transactions should be conducted consistent with the
Code and in such a manner as to avoid any actual or potential conflict of
interest or any abuse of an individual's position of trust and responsibility;
and (3) HSD personnel should not take inappropriate advantage of their
positions.

This Code and the procedures set out herein are designed to prevent (a) the use
of any device, scheme or artifice to defraud any Fund for which HSD is the
principal underwriter; (b) the making of any untrue statement of a material fact
to such Fund or the omission of a material fact necessary in order to make the
statements made to such Fund, in light of the circumstances in which they were
made, not misleading; (c) the engagement in any act, practice or course of
business that operates or would operate as a fraud or deceit on such Fund; or
(d) the engagement in any manipulative practice with respect to such Fund.

Requirements set forth under this Code are in addition to the obligations
employees of HSD have to comply with the Code of Ethics and Business Conduct of
The Hartford Financial Services Group, Inc. The Code of Ethics and Business
Conduct of The Hartford Financial Services Group, Inc. is specifically
incorporated herein by this reference.

SECTION 2 - DEFINITIONS

(a)  "Access Person" means any director, officer, or Registered Representative
of HSD who, in the ordinary course of business, makes, participates in, or
obtains information regarding, the purchase or sale of a Covered Security by a
Fund, or whose functions or duties in the ordinary course of business relate to
the making of any recommendation to a Fund with respect to the purchase or sale
of Covered Securities.

(b)  "Automatic Investment Plan" means a program in which regular periodic
purchases (or withdrawals) are made automatically in (or from) investment
accounts in



accordance with a predetermined schedule and allocation. An automatic investment
plan includes a dividend reinvestment plan.

(c)  "Being Considered for Purchase or Sale" as to a Covered Security means when
a recommendation to purchase or sell such Covered Security has been made and
communicated.

(d)  "Beneficial ownership" means that you directly or indirectly, through any
contract, arrangement, understanding, relationship, or otherwise, have or share
in the opportunity, directly or indirectly, to profit or share in any profit
derived from a transaction in a security.

     You are presumed to have beneficial ownership in all of the following, as
applicable:

     1.   securities held by members of your immediate family sharing the same
household with you, although the presumption of beneficial ownership may be
rebutted;

     2.   your interest in securities held by a trust, which may include both
trustees with investment control and, in some instances, trust beneficiaries;

     3.   your right to acquire securities through the exercise or conversion of
any derivative security, whether or not presently exercisable;

     4.   your proportionate interest as a general partner in the portfolio
securities held by any general or limited partnership;

     5.   certain performance-related fees other than an asset-based fee,
received by any broker, dealer, bank, insurance company, investment company,
investment adviser, investment manager, trustee or person or entity performing a
similar function; and

     6.   any right you may have dividends that is separated or separable from
the underlying securities. Otherwise, the right to dividends alone shall not
represent beneficial ownership in the securities.

   You are not deemed to have beneficial ownership in the portfolio securities
held by a corporation or similar entity in which you own securities if you are
not a controlling shareholder of the entity and you do not have or share
investment control over the entity's portfolio.

(e)  "Covered Security" means any interest or instrument commonly known as a
security, except that it shall not include direct obligations of the United
States, bankers' acceptances, certificates of deposit, commercial paper, high
quality short-term debt instruments (including repurchase agreements),
securities issued by The Hartford Financial Services Group, Inc., shares of
open-end mutual funds (unless HSD acts as

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principal underwriter of such fund), variable annuities and variable life
insurance products (unless issued by a control affiliate of HSD and which invest
in Funds distributed by HSD).

(f)  "Fund" means any investment company registered under the Investment Company
Act of 1940 for which HSD serves as principal underwriter and (1) with respect
to which HSD is an affiliated person (or an affiliated person of the Fund's
investment adviser) or (2) an officer, director or general partner of which (or
of the Fund's investment adviser) is also an officer, director or general
partner of HSD.

(g)  "Pre-Clearance Effectiveness Period" means the day on which approval
pursuant to Section 6(e) of this policy is communicated to the Access Person and
the immediately following business day.

(h)  "Purchase or Sale of a Covered Security" includes, among other things, the
writing of an option to purchase or sell a Covered Security.

(i)  "Security Held or to be Acquired by a Fund" means any Covered Security
that, within the most recent fifteen days is or has been held by the Fund, or
considered by the Fund or an Adviser for purchase by the Fund. The term also
includes any option to purchase or sell, and any security convertible into or
exchangeable for a Covered Security during the fifteen day period.

SECTION 3 - LEGAL REQUIREMENTS

It is unlawful for any director, officer, employee or other affiliated person of
HSD, in connection with the purchase or sale, directly or indirectly, of a
Security Held or to be Acquired by a Fund:

(a)  to use any device, scheme or artifice to defraud the Fund;

(b)  to make any untrue statement of a material fact to the Fund, or to omit to
state a material fact necessary in order to make the statements made to the
Fund, in light of the circumstances in which they were made, not misleading;

(c)  to engage in any act, practice or course of business that operates or would
operate as a fraud or deceit on the Fund; or

(d)  to engage in any manipulative practice with respect to such Fund.

SECTION 4 - PROHIBITION ON CERTAIN PURCHASES AND SALES OF SECURITIES AND RELATED
REQUIREMENTS

(a)  Trading Restriction on Access Persons - An Access Person shall not purchase
or sell, directly or indirectly, any Covered Security in which he or she has, or
by reason of

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such transaction acquires, any direct or indirect beneficial ownership and which
to his or her actual knowledge at the time of such purchase or sale is being
considered for purchase or sale by any Fund or is the subject of a pending order
or trade by any Fund. Additionally, if pre-clearance is required in accordance
with Section 6(e), an Access Person may not purchase or sell, directly or
indirectly, any Covered Security unless pre-clearance approval to make the
purchase or sale has been granted in accordance with Section 6(e). If
pre-clearance is required in accordance with Section 6(e), an Access Person may
place an order for purchase or sale only during the Pre-Clearance Effectiveness
Period, which order may not be revoked or withdrawn by such Access Person
outside of the Pre-Clearance Effectiveness Period.

(b)  Prohibition on Market Timing and Late Trading in Hartford Advised or
Underwritten Funds - Access Persons may not engage, directly or indirectly, in
any transaction in shares of any mutual fund where HSD or a control affiliate
acts as adviser or principal underwriter of such fund which is (i) in violation
of Rule 22c-1 under the Investment Company Act of 1940 or (ii) in violation of
or more frequent than is permitted by the prospectus for such fund (or by the
prospectus for a variable product investing in such fund) or by The Hartford
Investment and Savings Plan. Access Persons investing in shares of mutual funds
outside of the Funds also are expected to comply with applicable federal
securities laws and fund policies with respect to their investments in shares of
such mutual funds, including laws and policies relating to late trading and
market timing.

(c)  Gifts - Access Persons may not accept gifts beyond those courtesies deemed
to be customary, reasonable and proper under the particular business
circumstances from any person or entity that does business with or on behalf of
any Fund. Acceptance of all gifts must be in accordance with the Code of Ethics
and Business Conduct of The Hartford Financial Services Group, Inc. Access
Persons who are registered representatives or principals are reminded that they
also must comply with applicable provisions of the NASD Conduct Rules with
respect to gifts.

(d)  Service on Boards of Directors - Access Persons may not serve on the board
of directors of a company unless such service is approved in accordance with the
Code of Ethics and Business Conduct of The Hartford Financial Services Group,
Inc. Additionally, Access Persons must provide notice of any approved service on
a board of directors to the compliance officer of HSD.

SECTION 5 - EXEMPTED TRANSACTIONS

The trading restrictions of Section 4 of this Code shall not apply to:

(a)  Purchases or sales effected in any personal investment account over which
the Access Person has no direct influence or control. (An Access Person is
presumed to have direct influence or control over the account of a spouse, minor
child or other dependent relatives.);

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(b)  Purchases or sales which are non-volitional on the part of the Access
Person:

(c)  Purchases which are part of any Automatic Investment Plan;

(d)  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; and

(e)  Purchases and sales of exchange traded securities designed to replicate
specific indices, or sub-components of an index, such as SPDRS, Diamonds, Midcap
SPDRS and WEBS.

SECTION 6 - COMPLIANCE PROCEDURES

(a)  Initial and Annual Holdings Report - Within ten days of becoming an Access
Person and not later than February 14th of each year thereafter, each Access
Person must submit a report to the compliance officer of HSD with the
information listed below.

     (1)  The title, number of shares, and principal amount of all Covered
     Securities directly or indirectly beneficially owned by the Access Person.

     (2)  The name of any broker, dealer or bank with which the Access Person
     maintains a securities account.

     (3)  The date the report is submitted. The report should contain
     information that is no more than 45 days old. With respect to securities
     held in The Hartford Investment and Savings Plan, in lieu of the report
     described above, Access Persons may confirm in writing a composite record
     retained by HSD of the information required in the report. When reporting
     with respect to variable products which invest in Covered Securities, the
     report should include the above information with respect to the underlying
     Covered Securities.

(b)  Quarterly Reporting - Every Access Person shall, within 30 days after the
end of each calendar quarter, submit a report to the compliance officer of HSD,
with respect to transactions in any Covered Security in which such Access Person
has, or by reason of such transaction acquires, any direct or indirect
beneficial ownership in the Covered Security, the information listed below.

     (1)  The date of the transaction, the title, interest rate and maturity
     date (if applicable), the number of shares, and the principal amount of
     each Covered Security involved.

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

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     (3)  The price at which the transaction was effected.

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

     (5)  If the Access Person has established a brokerage account during the
     quarterly period, the name of the broker, dealer or bank and the date the
     account was established.

     (6)  The date the report is submitted.

(c)  Review of Reports - The compliance officer of HSD or a designee shall be
responsible for reviewing all reports referenced above.

(d)  Confirmations - Access Persons must direct their brokers to send duplicate
copies of confirmations for all Covered Security transactions to the compliance
officer of HSD. Access Persons need not make the reports required by Section
6(b) with respect to investments in The Hartford Investment and Savings Plan, so
long as all of the information required thereby has otherwise been provided to
the compliance officer in the time period required by Section 6(b).

(e)  Pre-Clearance - All Access Persons must preclear with the compliance
officer of HSD trades in all fixed income Covered Securities. The compliance
officer will consider, but not be limited to considering the following: is the
Access person aware that a Covered Security is being considered for purchase or
sale by any Fund; does the Access Person have any material non-public
information concerning the issuer of the Covered Security; are any order or
trades of a Fund pending for the Covered Security. The compliance officer may
contact credit analysts or portfolio managers to affirm that a Covered Security
is not under consideration.

(f)  Training - All new Access Persons shall be trained, as appropriate,
regarding the requirements of this Code. In addition, Access Persons will
receive periodic updates, as appropriate, regarding compliance with this Code.
Training typically takes place through organized seminars or meetings, though
computer-based training may also be used. Other training methods may be used if
found suitable by the compliance officer of HSD.

(g)  Annual Certification - Access Persons must certify annually that they have
read and understand the Code and have complied with its requirements.

(h)  Report to Board - On an annual basis management of the HSD must submit to
the Boards of Directors of the Funds a written report which:

     (1)  Describes any issues arising under the Code or procedures since the
     last report to the Board of Directors, including, but not limited to,
     information about

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     material violations of the Code or procedures and sanctions imposed in
     response to the material violations; and

     (2)  Certifies that HSD has adopted procedures reasonably necessary to
     prevent Access Persons from violating the Code.

(i)  Determination of Access Persons - The compliance officer of HSD shall
determine, from time to time, the identity of the persons meeting the definition
of "Access Persons". The determination of the compliance officer of HSD shall be
final.

(j)  Exemptions - The reporting requirements of Sections 6(a), (b) and (d) of
this Code shall not apply to transactions described in Sections 5(a) or (c) of
this Code. The pre-clearance requirement of Section 6 of this Code shall not
apply to transactions described in Section 5 of this Code.

SECTION 7 - SANCTIONS

Upon discovering a violation of this Code, HSD's Board of Directors may impose
such sanctions as it deems appropriate, including, among other things, a letter
of sanction, suspension or termination of the employment of the violator. All
material violations of this Code and any sanctions imposed with respect thereto
shall be reported periodically to the appropriate entity's President and the
Director of Compliance for The Hartford Financial Services Group, Inc.

SECTION 8 - EXEMPTIVE PROCEDURE

The compliance officer of HSD may, after consultation with the Director of
Compliance of The Hartford Financial Services Group, Inc. and the Hartford Life
General Counsel, grant exemptions from the requirements in this Code in
appropriate circumstances. In addition, violations of the provisions regarding
personal trading will presumptively be subject to being reversed in the case of
a violative purchase, and to disgorgement of any profit realized from the
position by payment of the profit to any client disadvantaged by the
transaction, or to a charitable organization, as determined by HSD, unless the
violator establishes to the satisfaction of HSD that under the particular
circumstances disgorgement would be an unreasonable remedy for the violation.

Approved by the Funds: November2, 2004

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