EXHIBIT 14.01


                                                                   February 2003


              CITIGROUP CODE OF ETHICS FOR FINANCIAL PROFESSIONALS


This Citigroup Code of Ethics for Financial Professionals applies to the
principal executive officer of Citigroup and its reporting subsidiaries and all
professionals worldwide serving in a finance, accounting, treasury, tax or
investor relations role. Citigroup expects all of its employees to act in
accordance with the highest standards of personal and professional integrity in
all aspects of their activities, to comply with all applicable laws, rules and
regulations, to deter wrongdoing and abide by the Citigroup Code of Conduct and
other policies and procedures adopted by Citigroup that govern the conduct of
its employees. This Code of Ethics is intended to supplement the Citigroup Code
of Conduct.

You agree to:

   (a)  Engage in and promote honest and ethical conduct, including the ethical
        handling of actual or apparent conflicts of interest between personal
        and professional relationships;

   (b)  Avoid conflicts of interest and to disclose to the Director of Citigroup
        Global Compliance any material transaction or relationship that
        reasonably could be expected to give rise to such a conflict;

   (c)  Take all reasonable measures to protect the confidentiality of
        non-public information about Citigroup or its subsidiaries and their
        customers obtained or created in connection with your activities and to
        prevent the unauthorized disclosure of such information unless required
        by applicable law or regulation or legal or regulatory process;

   (d)  Produce full, fair, accurate, timely, and understandable disclosure in
        reports and documents that Citigroup or its subsidiaries files with, or
        submits to, the Securities and Exchange Commission and other regulators
        and in other public communications made by Citigroup or its
        subsidiaries;

   (e)  Comply with applicable governmental laws, rules and regulations, as well
        as the rules and regulations of self-regulatory organizations of which
        Citigroup or its subsidiaries is a member; and

   (f)  Promptly report any possible violation of this Code of Ethics to the
        Director of Citigroup Global Compliance or any of the parties or
        channels listed in the Citigroup Code of Conduct.

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You are prohibited from directly or indirectly taking any action to fraudulently
influence, coerce, manipulate or mislead Citigroup or its subsidiaries'
independent public auditors for the purpose of rendering the financial
statements of Citigroup or its subsidiaries misleading.

You understand that you will be held accountable for your adherence to this Code
of Ethics. Your failure to observe the terms of this Code of Ethics may result
in disciplinary action, up to and including termination of employment.
Violations of this Code of Ethics may also constitute violations of law and may
result in civil and criminal penalties for you, your supervisors and/or
Citigroup.

If you have any questions regarding the best course of action in a particular
situation, you should promptly contact the Director of Citigroup Global
Compliance. You may choose to remain anonymous in reporting any possible
violation of this Code of Ethics.

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YOUR PERSONAL COMMITMENT TO THE CITIGROUP CODE OF ETHICS FOR FINANCIAL
PROFESSIONALS

I acknowledge that I have received and read the Citigroup Code of Ethics for
Financial Professionals, dated February 2003, and understand my obligations as
an employee to comply with the Code of Ethics.

I understand that my agreement to comply with the Code of Ethics does not
constitute a contract of employment.

Please sign here:                                    Date:
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Please print your name:
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GEID Number:
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This signed and completed form must be returned to your manager or designated
human resources professional.