EX-99.P CODE ETH-3 5 pimcocode.htm PIMCO CODE OF ETHICS pimcocode.htm -- Converted by SEC Publisher, created by BCL Technologies Inc., for SEC Filing
                                                                                                                        PIMCO CODE OF ETHICS
 
                                                                                                                        Effective February 15, 2006
 
                                                                                                                                 INTRODUCTION
 
                                                                                                                               General Principles
 
                   This Code of Ethics (“Code”) is based on the principle that you, as a director, officer or 
other Advisory Employee of Pacific Investment Management Company LLC (“PIMCO”), owe a 
fiduciary duty to, among others, the shareholders of Funds and other clients (together with the 
Funds, the “Advisory Clients”) for which PIMCO serves as an advisor or sub-advisor. 
Accordingly, you must avoid activities, interests and relationships that might interfere or appear 
to interfere with making decisions in the best interests of our Advisory Clients. 
 
                   At all times, you must observe the following general rules: 
 
                   1.  You must place the interests of our Advisory Clients first. In other words, as a 
  fiduciary you must scrupulously avoid serving your own personal interests ahead 
  of the interests of our Advisory Clients. You must adhere to this general 
  fiduciary principle as well as comply with the Code’s specific provisions. 
  Technical compliance with the Code’s procedures will not automatically insulate 
  from scrutiny any trades that indicate an abuse of your fiduciary duties or that 
  create an appearance of such abuse. PIMCO expects that, in your personal 
  trading activities, as in your other activities, you will behave in an ethical manner 
  that is consistent with PIMCO’s dedication to fundamental principals of 
  openness, integrity, honesty and trust. 
 
  Your fiduciary obligation applies not only to your personal trading activities but 
  also to actions taken on behalf of Advisory Clients. In particular, you may not 
  cause an Advisory Client to take action, or not to take action, for your personal 
  benefit rather than the benefit of the Advisory Client. For example, you would 
  violate this Code if you caused an Advisory Client to purchase a Security or 
  Futures Contract you owned for the purpose of increasing the value of that 
  Security or Futures Contract. If you are a portfolio manager or an employee who 
  provides information or advice to a portfolio manager or helps execute a portfolio 
  manager’s decisions, you would also violate this Code if you made a personal 
  investment in a Security or Futures Contract that might be an appropriate 
  investment for an Advisory Client without first considering the Security or 
  Futures Contract as an investment for the Advisory Client. 
 
  Similarly, PIMCO expects you to respect and to protect the confidentiality of 
  material non-public information about our Advisory Clients. PIMCO has adopted 
  Policies and Procedures Applicable to the Disclosure of Information Regarding 
  the Portfolio Holdings of the Funds that PIMCO Advises. You are required to 
  comply with those policies and procedures, which are incorporated into this Code 

 
  and attached hereto as Appendix II. Violations of those policies and procedures 
  may be sanctioned under the provisions of this Code. 
 
                   2.  You must conduct all of your personal Investment Transactions in full 
  compliance with this Code, the Allianz Global Investors of America L.P. 
  (“AGI”) Insider Trading Policy and Procedures (the “AGI Insider Trading 
  Policy”) and applicable federal securities laws, and in such a manner as to 
  avoid any actual or potential conflict of interest or any abuse of your position 
  of trust and responsibility. PIMCO encourages you and your family to develop 
  personal investment programs. However, those investment programs must remain 
  within boundaries reasonably necessary to ensure that appropriate safeguards 
  exist to protect the interests of our Advisory Clients and to avoid even the 
  appearance of unfairness or impropriety. Accordingly, you must comply with 
  the policies and procedures set forth in this Code under the heading PERSONAL 
  INVESTMENT TRANSACTIONS and you must comply with the policies and 
  procedures set forth in the AGI Insider Trading Policy, which is attached to this 
  Code as Appendix III. Doubtful situations should be resolved in favor of our 
  Advisory Clients and against your personal trading. 
 
                   3.  You must not take inappropriate advantage of your position. The receipt of 
  investment opportunities, perquisites, gifts or gratuities from persons seeking 
  business with PIMCO directly or on behalf of an Advisory Client could call into 
  question the independence of your business judgment. Accordingly, you must 
  comply with the policies and procedures set forth in this Code under the heading 
  GIFTS AND SERVICE AS A DIRECTOR. Doubtful situations should be 
  resolved against your personal interest. 
 
                                                            The General Scope Of The Code’s
                                                 Applications To Personal Investment Activities
 
                   The Code reflects the fact that PIMCO specializes in the management of fixed income 
portfolios. The vast majority of assets PIMCO purchases and sells on behalf of its Advisory 
Clients consist of corporate debt Securities, U.S. and foreign government obligations, mortgage- 
backed and asset-backed Securities, money market instruments, foreign currencies, and futures 
contracts and options with respect to those instruments. For its StocksPLUS portfolios, PIMCO 
also purchases futures and options on the S & P 500 index and, on rare occasions, may purchase 
or sell baskets of the stocks represented in the S & P 500 index. For its Convertible portfolios 
and other Advisory Clients, PIMCO purchases convertible securities that may be converted or 
exchanged into underlying shares of common stock. Other PIMCO Funds may also invest in 
convertible securities. The Convertible portfolios and other Advisory Clients may also invest a 
portion of their assets in common stocks. 
 
                   Rule 17j-1 under the Investment Company Act and Rule 204A-1 under the Investment 
Advisers Act require reporting of all personal transactions in Securities (other than certain 
Exempt Securities) by certain persons, whether or not they are Securities that might be 
purchased or sold by PIMCO on behalf of its Advisory Clients. The Code implements those 

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reporting requirements as well as additional reporting requirements that PIMCO has adopted in 
light of regulatory developments regarding trading in mutual fund shares. 
 
  However, since the purpose of the Code is to avoid conflicts of interest arising from 
personal trading activities in Securities and other instruments that are held or might be acquired 
on behalf of our Advisory Clients, this Code only places restrictions on personal trading 
activities in such investments. As a result, this Code does not place restrictions (beyond 
reporting) on personal trading in most individual equity Securities. Although equities are 
Securities, they are not purchased or sold by PIMCO on behalf of the vast majority of PIMCO’s 
Advisory Clients and PIMCO has established special procedures to avoid conflicts of interest 
that might otherwise arise from personal trading in such equity securities. On the other hand, 
this Code does require reporting and restrict trading in certain Futures Contracts that, although 
they are not Securities, are instruments in which PIMCO frequently trades for many of its 
Advisory Clients. 
 
  This Code applies to PIMCO’s officers and directors as well as to all of its Advisory 
Employees. The Code recognizes that portfolio managers and the investment personnel who 
provide them with advice and who execute their decisions occupy more sensitive positions than 
other Advisory Employees and that it is appropriate to subject their personal investment 
activities to greater restrictions. 
 
                                         The Organization Of The Code 
 
  The remainder of this Code is divided into three sections. The first section concerns 
Personal Investment Transactions. The second section describes the restrictions on Gifts And 
Service As A Director. The third section summarizes the methods for ensuring Compliance 
under the Code. In addition, the following Appendices are also a part of this Code: 
 
I.  Definitions of Capitalized Terms 
II.  PIMCO Policies and Procedures Applicable to the Disclosure of Information Regarding 
  the Portfolio Holdings of the Funds that PIMCO Advises 
III.  The AGI Insider Trading Policy 
IV.  Form for Acknowledgment of Receipt of this Code 
V.  Form for Annual Certification of Compliance with this Code 
VI.  Form for Initial Report of Accounts 
VII.  Form for Quarterly Report of Investment Transactions 
VIII.  Form for Annual Holdings Report 
IX.  Preclearance Request Form 
X.  Preclearance Request Form for an Investment Transaction in a PIMCO Closed End Fund 
XI.  Preclearance of AGI Closed End Fund Transaction Form 
XII.  PIMCO Compliance Officers 

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                    Questions

  Questions regarding this Code should be addressed to a Compliance Officer listed on 
Appendix XII. 
 
                                            PERSONAL INVESTMENT TRANSACTIONS
 
                                                                       In General
 
  Subject to the limited exceptions described below, you are required to report all 
Investment Transactions in Securities and Futures Contracts made by you, a member of your 
Immediate Family or a trust in which you have an interest, or on behalf of any account in which 
you have an interest or which you direct. In addition, you must preclear certain Investment 
Transactions in Securities and Futures Contracts that PIMCO holds or may acquire on 
behalf of an Advisory Client, including certain Investment Transactions in Related 
Securities. 
 
  The details of these reporting and preclearance requirements are described below. This 
Code uses a number of acronyms and capitalized terms, e.g. AGI, AGI Closed End Fund,1 
AGID, Advisory Client, Advisory Employee, Beneficial Ownership, Closed End Fund, Code, 
Compliance Officer, Designated Security, Duplicate Broker Reports, ETF, Exempt Security, 
Fixed Income Security, Fund, Futures Contract, Immediate Family, Initial Public Offering, 
Insider Trading Policy, Investment Company Act, Investment Transaction, Money Market Fund, 
Mutual Fund, Mutual Fund Security, Personal Account, PIMCO, PIMCO Closed End Fund, 
Portfolio Employee, Private Placement, Qualified Foreign Government, Related Account, 
Related Security, Relevant Debt Security, Reportable Fund, and Security. The definitions of 
these acronyms and capitalized terms are set forth in Appendix I. To understand your 
responsibilities under the Code, it is important that you review and understand the 
definitions in Appendix I. 
 
                                                          Reporting Obligations
 
  Notification Of Reporting Obligations 
 
  As an Advisory Employee, you are required to report accounts and Investment 
Transactions in accordance with the requirements of this Code. 
 
  Use Of Broker-Dealers And Futures Commission Merchants 
 
  Unless you are an independent director, you must use a registered broker-dealer or 
registered futures commission merchant to engage in any purchase or sale of a publicly-traded 
Security or Publicly-Traded Futures Contract. This requirement also applies to any purchase or 
sale of a publicly-traded Security or of a Publicly-Traded Futures Contract in which you have, or 
 
1  Note that many AGI Closed End Funds are subadvised by PIMCO. Investment Transactions in such 
Closed End Funds are subject to the AGI preclearance procedures described on pages 9 and 10. 

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by reason of an Investment Transaction will acquire, a Beneficial Ownership interest. Thus, as a 
general matter, any Investment Transaction in publicly-traded Securities or Publicly-Traded 
Futures Contracts by members of your Immediate Family will need to be made through a 
registered broker-dealer or futures commission merchant. For transactions involving a Mutual 
Fund Security that may be sold directly by a Mutual Fund, you may transact purchases or sales 
of these shares with the Mutual Fund’s transfer agent or other designated entity. 
 
                   Initial Report 
 
                   Within 10 days after commencing employment or within 10 days of any event that causes 
you to become subject to this Code (e.g. promotion to a position that makes you an Advisory 
Employee), you shall supply to a Compliance Officer copies of the most recent statements for 
each and every Personal Account and Related Account that holds or is likely to hold a Security 
or a Futures Contract in which you have a Beneficial Ownership interest, as well as copies of 
confirmations for any and all Investment Transactions subsequent to the effective date of those 
statements. These documents shall be supplied to the Compliance Officer by attaching them to 
the form appended hereto as Appendix VI. 
 
                   On that same form you shall supply the name of any broker, dealer, transfer agent, bank 
or futures commission merchant and the number for any Personal Account and Related Account 
that holds or is likely to hold a Security or a Futures Contract in which you have a Beneficial 
Ownership interest for which you cannot supply the most recent account statement. You shall 
also certify, where indicated on the form, that the contents of the form and the documents 
attached thereto disclose all such Personal Accounts and Related Accounts. 
 
                   In addition, you shall also supply, where indicated on the form, the following information 
for each Security or Futures Contract in which you have a Beneficial Ownership interest, to the 
extent that this information is not available from the statements attached to the form: 
 
                   1.  A description of the Security or Futures Contract, including, as applicable, its 
  name, title, interest rate, maturity date, exchange ticker symbol or CUSIP number; 
 
                   2.  The quantity (e.g., in terms of numbers of shares, units or contracts) and principal 
  amount (in dollars) of the Security or Futures Contract; and 
 
                   3.  The name of any broker, dealer, transfer agent, bank or futures commission 
  merchant with which you maintain an account in which the Security or Futures 
  Contract is held. 
 
                   The information contained in your Initial Report (Appendix VI) and in the statements and 
other documents attached to that form must be current as of a date not more than 45 days prior to 
the date upon which you become an Advisory Employee. You must sign and date your Initial 
Report.   
 
 
 
                   New Accounts 

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                   Immediately upon the opening of a new Personal Account or a Related Account that 
holds or is likely to hold a Security or a Futures Contract, you shall supply a Compliance Officer 
with the name of the broker, dealer, transfer agent, bank or futures commission merchant for that 
account, the identifying number for that Personal Account or Related Account, and the date the 
account was established. 
 
                   Timely Reporting Of Investment Transactions 
 
                   You must cause each broker, dealer, transfer agent, bank or futures commission merchant 
that maintains a Personal Account or a Related Account that holds a Security or a Futures 
Contract in which you have a Beneficial Ownership interest to provide to a Compliance Officer, 
on a timely basis, duplicate copies of trade confirmations of all Investment Transactions in that 
account and of periodic statements for that account (“Duplicate Broker Reports”). 
 
                   In addition, you must report to a Compliance Officer, on a timely basis, any Investment 
Transaction in a Security or a Futures Contract in which you have or acquired a Beneficial 
Ownership interest that was established without the use of a broker, dealer, transfer agent, bank 
or futures commission merchant. 
 
                   Quarterly Certifications And Reporting 
 
                   At the end of the first, second and third calendar quarters, a Compliance Officer will 
provide you with a list of all accounts that you have previously identified to PIMCO as a 
Personal Account or a Related Account that holds or is likely to hold a Security or a Futures 
Contract. Within 30 days after the end of that calendar quarter, you shall make any necessary 
additions, corrections or deletions to that list and return it to a Compliance Officer with a 
certification that: (a) the list, as modified (if necessary), represents a complete list of the 
Personal Accounts and Related Accounts that hold Securities or Futures Contracts in which you 
have or had a Beneficial Ownership interest and for which PIMCO should have received or will 
receive timely Duplicate Broker Reports for the calendar quarter just ended, and (b) the broker, 
dealer, transfer agent, bank or futures commission merchant for each account on the list has been 
instructed to send a Compliance Officer timely Duplicate Broker Reports for that account no 
later than 30 days after the end of that calendar quarter. 
 
                   You shall provide, on a copy of the form attached hereto as Appendix VII, the following 
information for each Investment Transaction during the calendar quarter just ended, to the extent 
that the Duplicate Broker Reports for that calendar quarter did not supply or will not supply this 
information to PIMCO within 30 days after the close of the calendar quarter: 
 
                   1.  The date of the Investment Transaction; 
 
                   2.  A description of the Security or Futures Contract, including, as applicable, its 
  name, title, interest rate, maturity date, exchange ticker symbol or CUSIP number; 
 
                   3.  The quantity (e.g., in terms of numbers of shares, units or contracts) and principal 
                                     amount (in dollars) of each Security or Futures Contract involved;

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                   4.  The nature of the Investment Transaction (i.e., purchase, sale or any other type of 
  acquisition or disposition); 
 
                   5.  The price of the Security or Futures Contract at which the transaction was 
  effected; and 
 
                   6.  The name of the broker, dealer, transfer agent, bank, or futures commission 
  merchant with or through which the Investment Transaction was effected. 
 
                   You shall provide similar information for the fourth calendar quarter on a copy of the 
form attached hereto as Appendix VIII, which form shall also be used for the Annual Holdings 
Report described below. You must sign and date each of your Quarterly Reports. 
 
                   Annual Holdings Reports 
 
                   At the end of each calendar year, a Compliance Officer will promptly provide to you a 
list of all accounts that you have previously identified to PIMCO as a Personal Account or a 
Related Account that held or was likely to hold a Security or a Futures Contract during that 
calendar year. Within 30 days after the end of that calendar year, you shall make any necessary 
additions, corrections or deletions to that list and return it to a Compliance Officer with a 
certification that: (a) the list, as modified (if necessary), represents a complete list of the 
Personal Accounts and Related Accounts that held Securities or Futures Contracts in which you 
had a Beneficial Ownership interest as of the end of that calendar year and for which PIMCO 
should have received or will receive an account statement of holdings as of the end of that 
calendar year, and (b) the broker, dealer, transfer agent, bank or futures commission merchant 
for each account on the list has been instructed to send a Compliance Officer such an account 
statement.   
 
                   You shall provide, on a copy of the form attached hereto as Appendix VIII, the following 
information for each Security or Futures Contract in which you had a Beneficial Ownership 
interest, as of the end of the previous calendar year, to the extent that the previously referenced 
account statements have not supplied or will not supply this information to PIMCO: 
 
                   1.  A description of the Security or Futures Contract, including, as applicable, its 
  name, title, interest rate, maturity date, exchange ticker symbol or CUSIP number; 
 
                   2.  The quantity (e.g., in terms of numbers of shares, units or contracts) and principal 
  amount (in dollars) of each Security or Futures Contract in which you had any 
  Beneficial Ownership interest; and 
 
                   3.  The name of any broker, dealer, transfer agent, bank or futures commission 
  merchant with which you maintain an account in which any such Security or 
  Futures Contract has been held or is held for your benefit. 
 
                   The information contained in your Annual Holdings Report (Appendix VIII) and in the 
statements and other documents attached to or referenced in that form must be current as of a 

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date not more than 45 days prior to the date that report is submitted to PIMCO. You must sign 
and date your Annual Holdings Report. 
 
                   In addition, you shall also provide on your Annual Holdings Report (Appendix VIII) 
your Investment Transaction information for the fourth quarter of the calendar year just ended. 
This information shall be of the type and in the form required for the quarterly reports described 
above. 
 
                   All of the Reporting Obligations described above shall apply to Mutual Fund Securities 
(other than Money Market Funds) and Exchange-Traded Funds (“ETFs”) in which you 
have a Beneficial Ownership interest. 
 
                   Related Accounts 
 
                   The reporting and certification obligations described above also apply to any Related 
Account (as defined in Appendix I) and to any Investment Transaction in a Related Account. 
 
                   It is important for you to recognize that the definitions of “Related Account” and 
“Beneficial Ownership” in Appendix I may require you to provide, or to arrange for the broker, 
dealer, transfer agent, bank or futures commission merchant to furnish, copies of reports for any 
account used by or for a member of your Immediate Family or a trust in which you or a member 
of your Immediate Family has any vested interest, as well as for any other accounts in which you 
may have the opportunity, directly or indirectly, to profit or share in the profit derived from any 
Investment Transaction in that account. 
 
                   Exemptions From Reporting 
 
                   You need not report Investment Transactions in any account over which neither you nor 
an Immediate Family Member has or had any direct or indirect influence or control. 
 
                   You also need not report Investment Transactions in Exempt Securities (as defined in 
Appendix I) nor need you furnish, or require a broker, dealer, transfer agent, bank or futures 
commission merchant to furnish, copies of confirmations or periodic statements for accounts that 
hold only Exempt Securities. This exemption from reporting shall end immediately, however, at 
such time as there is an Investment Transaction in that account in a Futures Contract or in a 
Security that is not an Exempt Security. 
 
                                                    Prohibited Investment Transactions
 
                   Initial Public Offerings of Equity Securities 
 
                   No Advisory Employee may acquire Beneficial Ownership of any equity Security in an 
Initial Public Offering. 
 
 
 
                   Private Placements and Initial Public Offering of Debt Securities 

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                   You may not acquire a Beneficial Ownership interest in any Security through a Private 
Placement (or subsequently sell it), or acquire a Beneficial Ownership interest in any Fixed 
Income Security in an Initial Public Offering unless you have received the prior written approval 
of a Compliance Officer listed on Appendix XII. Approval will not be given unless a 
determination is made that the investment opportunity should not be reserved for one or more 
Advisory Clients, and that the investment opportunity has not been offered to you by virtue of 
your position with PIMCO. 
 
                   If, after receiving the necessary approval, you have acquired a Beneficial Ownership 
interest in a Fixed Income Security through an Initial Public Offering or in a Security through a 
Private Placement, you must disclose that investment when you play a part in any consideration 
of any investment by an Advisory Client in the issuer of that Security, and any decision to make 
such an investment must be independently reviewed by a portfolio manager who does not have 
a Beneficial Ownership interest in any Security of that issuer. 
 
                   Allianz AG 
 
                   You may not engage in any Investment Transaction in Securities of Allianz AG, except 
during the trading windows applicable to such transactions, as set forth below under “Blackout 
Periods.” 
 
                                                                                 Preclearance
 
                   All Investment Transactions in Securities and Futures Contracts in a Personal Account or 
Related Account, or in which you otherwise have or will acquire a Beneficial Ownership 
interest, must be precleared by a Compliance Officer unless an Investment Transaction, Security 
or Futures Contract falls into one of the following categories that are identified as “exempt from 
preclearance.” 
 
                   Preclearance Procedure 
 
                   Preclearance shall be requested by completing and submitting a copy of the applicable 
preclearance request form attached hereto as Appendix IX (or, in the case of an Investment 
Transaction in a PIMCO Closed End Fund, Appendix X, or, in the case of an Investment 
Transaction in an AGI Closed End Fund, Appendix XI) to a Compliance Officer. No Investment 
Transaction subject to preclearance may be effected prior to receipt of written authorization of 
the transaction by a Compliance Officer. The authorization and the date of authorization will be 
reflected on the preclearance request form. Unless otherwise specified, that authorization shall 
be effective, unless revoked, until the earlier of: (a) the close of business on the day the 
authorization is given, or (b) until you discover that the information on the preclearance request 
form is no longer accurate. In the case of a request for preclearance of a limit order, a new 
request for preclearance must be submitted if your order is not filled by the close of business on 
the day the authorization is given. 
 
                   The Compliance Officer from whom authorization is sought may undertake such 
investigation as he or she considers necessary to determine that the Investment Transaction for 

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which preclearance has been sought complies with the terms of this Code and is consistent with 
the general principles described at the beginning of the Code. 
 
                   Before deciding whether to authorize an Investment Transaction in a particular Security 
or Futures Contract, the Compliance Officer shall determine and consider, based upon the 
information reported or known to that Compliance Officer, whether within the most recent 15 
days the Security, the Futures Contract or any Related Security: (a) is or has been held by an 
Advisory Client, or (b) is being or has been considered for purchase by an Advisory Client. The 
Compliance Officer shall also determine whether there is a pending buy or sell order in the same 
Security or Futures Contract, or in a Related Security, on behalf of an Advisory Client. If such 
an order exists, authorization of the personal Investment Transaction shall not be given until the 
Advisory Client’s order is executed or withdrawn. This prohibition may be waived by a 
Compliance Officer if he or she is convinced that: (a) your personal Investment Transaction is 
necessary, (b) your personal Investment Transaction will not adversely affect the pending order 
of the Advisory Client, and (c) provision can be made for the Advisory Client trade to take 
precedence (in terms of price) over your personal Investment Transaction. 
 
                   For an Investment Transaction in an AGI Closed End Fund, you must complete and 
submit the preclearance request form attached hereto as Appendix XI and comply with the AGI 
Policy for Transactions in Closed End Funds that may be found on the Legal and Compliance 
page of the PIMCO intranet site. In determining whether to preclear such an Investment 
Transaction, the Compliance Officer shall coordinate with the AGI Fund Administration Group. 
A list of AGI Closed End Funds (many of which are subadvised by PIMCO) may be found in 
Appendix I (as part of the definition of “AGI Closed End Fund”) or on the Legal and 
Compliance page of the PIMCO intranet site. 
 
                   Exemptions From Preclearance 
 
                   Preclearance shall not be required for the following Investment Transactions, Securities 
and Futures Contracts. They are exempt only from the Code’s preclearance requirement, and, 
unless otherwise indicated, remain subject to the Code’s other requirements, including its 
reporting requirements. 
 
  Investment Transactions Exempt From Preclearance 
 
                   Preclearance shall not be required for any of the following Investment Transactions: 
 
                   1.  Any transaction in a Security or Futures Contract in an account that is managed or 
  held by a broker, dealer, bank, futures commission merchant, investment advisor, 
  commodity trading advisor or trustee and over which you do not exercise 
  investment discretion, have notice of transactions prior to execution, or otherwise 
  have any direct or indirect influence or control. There is a presumption that you 
  can influence or control accounts held by members of your Immediate Family 
  sharing the same household. This presumption may be rebutted only by 
  convincing evidence. 
 
                   2.  Purchases of Securities under dividend reinvestment plans. 

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       3.         Purchases of Securities by exercise of rights issued to the holders of a class of 
         Securities pro rata, to the extent they are issued with respect to Securities in 
         which you have a Beneficial Ownership interest. 
 
       4.         Acquisitions or dispositions of Securities as the result of a stock dividend, stock 
         split, reverse stock split, merger, consolidation, spin-off or other similar corporate 
         distribution or reorganization applicable to all holders of a class of Securities in 
         which you have a Beneficial Ownership interest. 
 
         Securities Exempt From Preclearance Regardless Of Transaction Size 
 
                 Preclearance shall not be required for an Investment Transaction in the following 
       Securities or Related Securities, regardless of the size of that transaction: 
 
       1.         All Exempt Securities as defined in Appendix I, i.e., U.S. Government Securities, 
         shares in Money Market Funds, and high quality short-term debt instruments. 
 
       2.         All Mutual Fund Securities as defined in Appendix I. 
 
       3.         All Closed End Funds and rights distributed to shareholders in Closed End Funds 
         other than any AGI Closed End Fund, PIMCO Closed End Fund or Closed End 
         Fund that is a Designated Security. 
 
       4.         All options on any index of equity Securities. 
 
       5.         All Fixed Income Securities issued by agencies or instrumentalities of, or 
                                                         unconditionally guaranteed by, the Government of the United States.
 
       6.         All options on foreign currencies or baskets of foreign currencies (whether or not 
         traded on an exchange or board of trade). 
 
       7.         Except for Designated Securities (as defined in Appendix I and discussed 
         below), all equity Securities and ETFs or options, warrants or other rights to 
         equity Securities or ETFs. 
 
         Securities Exempt from Preclearance Depending On Transaction Size 
 
                 Preclearance shall not be required for an Investment Transaction in the following 
       Securities or Related Securities if they do not exceed the specified transaction size thresholds 
       (which thresholds may be increased or decreased by PIMCO upon written notification to 
       employees in the future depending on the depth and liquidity of the markets for these Fixed 
       Income Securities): 
 
       1.         Purchases or sales of up to $1,000,000 (in market value or face amount, 
         whichever is lesser) per calendar month per issuer of Fixed Income Securities 
         issued by a Qualified Foreign Government. 

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                   2.  Purchases or sales of the following dollar values (measured in market value or 
  face amount, whichever is lesser) of corporate debt Securities, mortgage-backed 
  and other asset-backed Securities, taxable or tax-exempt state, local and 
  municipal Fixed Income Securities, structured notes and loan participations, 
  foreign government debt Securities issued by non-qualified foreign governments, 
  or debt Securities issued by an international agency or a supranational agency 
                                     (hereinafter collectively referred to as “Relevant Debt Securities”):
 
  a.  Purchases or sales of up to $100,000 per calendar month per issuer if the 
    original issue size of any Relevant Debt Security being purchased or sold 
    was less than $50 million; 
 
  b.  Purchases or sales of up to $500,000 per calendar month per issuer if the 
    original issue size of any Relevant Debt Security being purchased or sold 
                                                          was at least $50 million but less than $100 million; or
 
  c.  Purchases or sales of up to $1,000,000 per calendar month per issuer if the 
    original issue size of any Relevant Debt Security being purchased or sold 
    was at least $100 million. 
 
  Preclearance of Designated Securities 
 
                   If a Compliance Officer receives notification, from a Portfolio Employee or otherwise, 
that an equity Security or a Closed End Fund or an option, warrant or other right to such an 
equity Security or Closed End Fund is held by an Advisory Client or is being considered for 
purchase or sale by PIMCO on behalf of one or more of its Advisory Clients, the Compliance 
Officer will send you an e-mail message or similar transmission notifying you that this equity 
Security, Closed End Fund or option, warrant or other right to that equity Security or Closed End 
Fund is now a “Designated Security.” A current list of Designated Securities (if any) will also 
be available on the Legal and Compliance page of the PIMCO intranet site. You must preclear 
any Investment Transaction in a Designated Security or a Related Security during the period 
when that designation is in effect. 
 
 
 
  Futures Contracts Exempt From Preclearance Regardless Of Transaction Size 
 
                   Preclearance shall not be required for an Investment Transaction in the following Futures 
Contracts, regardless of the size of that transaction (as indicated in Appendix I, for these 
purposes a “Futures Contract” includes a futures option): 
 
                   1.  Currency Futures Contracts. 
 
                   2.  U.S. Treasury Futures Contracts. 
 
                   3.  Eurodollar Futures Contracts. 

- 12 -

 
                   4.  Futures Contracts on any index of equity Securities. 
 
                   5.  Futures Contracts on physical commodities or indices thereof (e.g., contracts for 
  future delivery of grain, livestock, fiber or metals, whether for physical delivery 
  or cash). 
 
                   6.  Privately-Traded Contracts. 
 
  Futures Contracts Exempt From Preclearance Depending On Transaction Size 
 
                   Preclearance shall not be required for an Investment Transaction in the following Futures 
Contracts if the total number of contracts purchased or sold during a calendar month does not 
exceed the specified limitations: 
 
                   1.  Purchases or sales of up to 50 Publicly-Traded Futures Contracts to acquire 
  Fixed Income Securities issued by a particular Qualified Foreign Government. 
 
                   2.  Purchases or sales of up to 10 of each other individual Publicly-Traded 
  Futures Contract if the open market interest for such Futures Contract as 
  reported in The Wall Street Journal on the date of your Investment Transaction 
  (for the previous trading day) is at least 1,000 contracts. Examples of Futures 
  Contracts for which this exemption would be available include a Futures Contract 
  on a foreign government debt Security issued by a non-qualified foreign 
  government as well as a 30-day Federal Funds Futures Contract. 
 
                   For purposes of these limitations, a Futures Contract is defined by its expiration month. 
For example, you need not obtain preclearance to purchase 50 December Futures Contracts on 
German Government Bonds and 50 March Futures Contracts on German Government Bonds. 
Similarly, you may roll over 10 September Fed Funds Futures Contracts by selling those 10 
contracts and purchasing 10 October Fed Funds Futures Contracts since the contracts being sold 
and those being purchased have different expiration months. On the other hand, you could not 
purchase 10 January Fed Funds Future Contracts if the open interest for those contracts was less 
than 1,000 contracts, even if the total open interest for all Fed Funds Futures Contracts was 
greater than 1,000 contracts. 
 
  Additional Exemptions From Preclearance 
 
                   PIMCO’s Chief Compliance Officer, in consultation with PIMCO’s Chief Legal Officer, 
may exempt other classes of Investment Transactions, Securities or Futures Contracts from the 
Code’s preclearance requirement upon a determination that they do not involve a realistic 
possibility of violating the general principles described at the beginning of the Code. 
 
  Preclearance Required 
 
                   Given the exemptions described above, preclearance shall be required for Investment 
Transactions in: 

- 13 -

       1.         Designated Securities. 
 
       2.         Relevant Debt Securities in excess of the per calendar month per issuer thresholds 
         specified for purchases or sales of those Securities in paragraph 2 under 
         “Securities Exempt from Preclearance Depending on Transaction Size.” 
 
       3.         More than $1,000,000 per calendar month in debt Securities of a Qualified 
         Foreign Government. 
 
       4.         Related Securities that are exchangeable for or convertible into one of the 
         Securities requiring preclearance under (1), (2), or (3) above. 
 
       5.         More than 50 Publicly-Traded Futures Contracts per calendar month to acquire 
         Fixed Income Securities issued by a particular Qualified Foreign Government. 
 
       6.         More than 10 of any other individual Publicly-Traded Futures Contract or any 
         Publicly-Traded Futures Contract for which the open market interest as reported 
         in The Wall Street Journal on the date of your Investment Transaction (for the 
         previous trading day) is less than 1,000 contracts, unless the Futures Contract is 
         exempt from preclearance regardless of transaction size. 
 
       7.         Any other Security or Publicly-Traded Futures Contract that is not within the 
         “exempt” categories listed above. 
 
       8.         Any PIMCO Closed End Fund. 
 
       9.         Any AGI Closed End Fund. 
 
                                                        Holding Periods for Certain Investments
 
                            An Advisory Employee may not, within 60 calendar days, purchase and sell, or sell and 
       purchase, the same Fixed Income Security or Related Security in any account(s) in which the 
       Advisory Employee has a Beneficial Ownership interest. 
 
                           An Advisory Employee may not, within 6 months, purchase and sell, or sell and 
       purchase, shares of an AGI Closed End Fund subadvised by PIMCO or shares of a PIMCO 
       Closed End Fund in any account(s) in which the Advisory Employee has a Beneficial 
       Ownership interest. Pursuant to the AGI Policy for Transactions in AGI Closed End Funds (a 
       copy of which may be found on the Legal and Compliance page of the PIMCO intranet site), the 
       minimum holding period for an AGI Closed End Fund not subadvised by PIMCO is 60 calendar 
       days.   
 
                           As described below, different minimum holding periods apply to Investment 
       Transactions in Mutual Fund Securities (which do not include Closed End Funds). 

- 14 -

 
                   A Portfolio Employee may not, within 60 calendar days, purchase and sell, or sell and 
purchase, the same Designated Security or Related Security in any account(s) in which the 
Portfolio Employee has a Beneficial Ownership interest. 
 
                   These minimum holding periods do not apply to Investment Transactions in U.S. 
Government Securities, most equity Securities, shares of Money Market Funds, index options or 
Futures Contracts nor do they apply to a purchase or sale in connection with one of the four 
categories of Investment Transactions Exempt From Preclearance described above, including 
purchases of Securities under a dividend reinvestment plan. 
 
                                                                         Blackout Periods
 
                   You may not purchase or sell a Security, a Related Security or a Futures Contract at a 
time when you intend or know of another’s intention to purchase or sell that Security or Futures 
Contract on behalf of any Advisory Client. 
 
                   As noted previously in the description of the Preclearance Process, a Compliance Officer 
may not preclear an Investment Transaction in a Security or a Futures Contract at a time when 
there is a pending buy or sell order in the same Security or Futures Contract, or a Related 
Security, until that order is executed or withdrawn. 
 
                   These prohibitions do not apply to Investment Transactions in any Futures Contracts that 
are exempt from preclearance regardless of transaction size. 
 
                   Special Blackout Periods apply to Investment Transactions in AGI Closed End Funds 
(see the AGI Policy for Transactions in AGI Closed End Funds, a copy of which may be found 
on the Legal and Compliance page of the PIMCO intranet site). 
 
                   You are not permitted to purchase or sell shares of Allianz AG during any designated 
blackout period. A blackout period starts six weeks prior to the release of Allianz AG annual 
financial statements and two weeks prior to the release of Allianz AG quarterly results. These 
blackout periods also apply to the exercise of cash settled options or any kind of rights granted 
under compensation or incentive programs that completely or in part refer to Allianz AG. 

- 15 -

                                                      Transactions In Mutual Fund Securities

                   Reporting of Mutual Fund Security Transactions 
 
                   All of the Reporting Obligations described in the Code shall apply to Mutual Fund 
Securities (other than Money Market Funds) in which you have a Beneficial Ownership interest. 
For purposes of the Code, shares of Closed End Funds and ETFs are not considered Mutual Fund 
Securities. Investment Transactions in Closed End Funds and ETFs are covered by other 
sections of the Code. 
 
                   Holding Periods for Mutual Fund Security Transactions 
 
                   An Advisory Employee may not, within 30 calendar days, purchase and sell, or sell and 
purchase, the same Mutual Fund Security in any account(s) in which the Advisory Employee 
has a Beneficial Ownership interest. This 30-day minimum holding period applies to purchases 
and sales of the same Mutual Fund Security regardless of whether those transactions occurred in 
a single account (e.g., a brokerage account, a 401(k) account, a deferred compensation account, 
etc.) or across multiple accounts in which the Advisory Employee has a Beneficial Ownership 
interest. With respect to a Mutual Fund that invests exclusively or primarily in Funds or other 
collective investment vehicles or pools (often referred to as a “fund of funds”), this minimum 
holding period applies only to the investment in the top-tier Mutual Fund. Thus, for purposes of 
determining compliance with this minimum holding period, an Advisory Employee is not 
required to “look through” a fund of funds in which he or she invests. 
 
                   This minimum holding period shall not apply with respect to purchases or sales made 
pursuant to (1) automatic reinvestment of dividends, capital gains, income or interest received 
from a Mutual Fund, or (2) a periodic investment, redemption, or reallocation plan in a deferred 
compensation, 401(k), retirement or other account (e.g., purchases of Mutual Fund Securities 
every pay period in an employee’s 401(k) account). In order to rely on this exception, the 
investment options in the plan may not be changed more frequently than every 30 calendar days. 
This minimum holding period also does not apply to a purchase or sale in connection with one of 
the four categories of Investment Transactions Exempt From Preclearance described above. 

- 16 -

  GIFTS AND SERVICE AS A DIRECTOR

  Gifts

                   You may not accept any investment opportunity, gift, gratuity or other thing of more 
than nominal value from any person or entity that does business, or desires to do business, with 
PIMCO directly or on behalf of an Advisory Client (a “Giver”). You may, however, accept 
gifts from a single Giver so long as the value of each gift is modest and their aggregate value 
does not exceed $1,000 per quarter. This includes business meals, sporting events and other 
entertainment events at the expense of a Giver, so long as the expense is reasonable, infrequent 
and both you and the Giver are present. You are expected to comply with the PIMCO Vendor, 
Broker and Issuer Conduct Policy and to notify a Compliance Officer if you are the recipient of a 
gift, business meal, sporting event or other entertainment event whose value may exceed a 
guideline set forth in that Policy. If the value of a gift, meal or event exceeds such a guideline, 
you may be asked to pay a charity the amount of that excess. 
 
                  If you are a registered representative of Allianz Global Investors Distributors LLC 
(“AGID”), the aggregate annual gift value from a single Giver shall not exceed $100.00. As an 
AGID representative, you are required to maintain a record of each gift, gratuity, investment 
opportunity or similar item, and make such record available to a Compliance Officer upon 
request. 
 
 
                                                                    Service As A Director
 
                   If you are an Advisory Employee, you may not serve on the board of directors or other 
governing board of a publicly traded entity, other than of a Fund for which PIMCO is an advisor 
or sub-advisor, unless you have received the prior written approval of the Chief Executive 
Officer and the Chief Legal Officer of PIMCO. Approval will not be given unless a 
determination is made that your service on the board would be consistent with the interests of 
our Advisory Clients. If you are permitted to serve on the board of a publicly traded entity, you 
will be isolated from those Advisory Employees who make investment decisions with respect to 
the Securities of that entity, through a “Chinese Wall” or other procedures. 

- 17 -

                                                 COMPLIANCE

                                                Delivery of The Code to All Advisory Employees

                   On or before the effective date of this Code, the Compliance Officers shall provide a 
copy of the Code to each Advisory Employee. If the Code is amended, the Compliance Officers 
shall provide a copy of that amendment to each Advisory Employee on or before the effective 
date of that amendment. On or before the commencement of each new Advisory Employee’s 
employment, a Compliance Officer or his/her designee shall provide a copy of the Code and of 
any amendments to the Code to that new Advisory Employee. 
 
                                                                                 Certifications
 
                   Upon Receipt Of This Code 
 
                   Upon commencement of your employment or the effective date of this Code, whichever 
occurs later, you shall be required to acknowledge receipt of your copy of this Code by 
completing and returning a copy of the form attached hereto as Appendix IV. By that 
acknowledgment, you will also agree: 
 
                   1.  To read the Code, to make a reasonable effort to understand its provisions, and to 
  ask questions about those provisions you find confusing or difficult to understand. 
 
                   2.  To comply with the Code, including its general principles, its reporting 
  requirements, its preclearance requirements, and its provisions regarding gifts and 
  service as a director. 
 
                   3.  To advise the members of your Immediate Family about the existence of the 
  Code, its applicability to their personal trading activity, and your responsibility to 
                                     assure that their personal trading activity complies with the Code.
 
                   4.  To cooperate fully with any investigation or inquiry by or on behalf of a 
  Compliance Officer to determine your compliance with the provisions of the 
  Code. 
 
                   In addition, your acknowledgment will recognize that any failure to comply with the 
Code and to honor the commitments made by your acknowledgment may result in disciplinary 
action, including dismissal. 
 
                   Annual Certificate Of Compliance 
 
                   You are required to certify on an annual basis, on a copy of the form attached hereto as 
Appendix V, that you have complied with each provision of your initial acknowledgment (see 
above). In particular, your annual certification will require that you certify that you have read 
and that you understand the Code, that you recognize you are subject to its provisions, that you 
complied with the requirements of the Code during the year just ended and that you have 
disclosed, reported, or caused to be reported all Investment Transactions required to be disclosed 
or reported pursuant to the requirements of the Code. 

  - 18 -

 

                                                                       Post-Trade Monitoring

                   The Compliance Officers shall review the Initial Reports, Annual Holding Reports, 
Quarterly Transaction Reports, Duplicate Broker Reports and other information supplied to them 
concerning your personal Investment Transactions so that they can detect and prevent potential 
violations of the Code. The Compliance Officers may also review and rely upon reports and 
information provided to them by third parties, including AGI. PIMCO’s Compliance Officers 
will perform such investigations and make such inquiries as they consider necessary to perform 
their post-trade monitoring function. You agree to cooperate with any such investigation and to 
respond to any such inquiry. You should expect that, as a matter of course, the Compliance 
Officers will make inquiries regarding any personal Investment Transaction in a Security or 
Futures Contract that occurs on the same day as a transaction in the same Security or Futures 
Contract on behalf of an Advisory Client. 
 
                                                        Duty to Report Violations of the Code 
 
                   Each Advisory Employee is required to report any suspected violation of the Code 
promptly to the Chief Compliance Officer. 
 
                                                                                   Waivers
 
                   PIMCO’s Chief Compliance Officer, in consultation with PIMCO’s Chief Legal Officer, 
may grant an individual waiver to an Advisory Employee from any requirement of this Code 
(other than any requirement specified by Rule 17j-1 under the Investment Company Act or under 
Rule 204A-1 under the Investment Advisers Act) if together they determine that compliance with 
the requirement would impose an undue burden or hardship on the Advisory Employee. The 
Chief Compliance Officer shall maintain a log of each waiver granted that includes, among other 
things, the name of the Advisory Employee, the particular requirement of the Code to which the 
waiver applies, the effective date of the waiver, and a summary of the reasons why the waiver 
was granted. 
 
                                                                      Remedial Actions
 
                   If you violate this Code, you are subject to remedial actions, which may include, but are 
not limited to, full or partial disgorgement of profits, imposition of a fine, censure, demotion, 
suspension or dismissal, or any other sanction or remedial action required by law, rule or 
regulation. As part of any sanction, you may be required to reverse an Investment Transaction 
and to forfeit any profit or to absorb any loss from the transaction. 
 
                   PIMCO’s Chief Legal Officer and Chief Compliance Officer shall have the ultimate 
authority to determine whether you have violated the Code and, if so, the remedial actions they 
consider appropriate or required by law, rule or regulation. In making their determination, the 
Chief Legal Officer and the Chief Compliance Officer shall consider, among other factors, the 
gravity of your violation, the frequency of your violations, whether any violation caused harm or 
the potential of harm to any Advisory Client, your efforts to cooperate with their investigation, 
and your efforts to correct any conduct that led to a violation. 

                                                                               - 19 -

                                                     Reports To Directors And Trustees

                   Reports Of Material Violations 
 
                   The General Counsel of AGI and the directors or trustees of any affected Fund that is an 
Advisory Client will be informed on a timely basis of any material violation of this Code. 
 
                   Reports of Material Changes To The Code 
 
                   PIMCO will promptly advise the directors or trustees of any Fund that is an Advisory 
Client if PIMCO makes any material change to this Code. 
 
                   Annual Reports 
 
                   PIMCO’s management will furnish a written report annually to the General Counsel of 
AGI and to the directors or trustees of each Fund that is an Advisory Client. Each report, at a 
minimum, will:   
 
                   1.  Describe any issues arising under the Code, or under procedures implemented by 
  PIMCO to prevent violations of the Code, since management’s last report, 
  including, but not limited to, information about material violations of the Code, 
  procedures and sanctions imposed in response to such material violations, and 
  individual waivers from any requirement of the Code; and 
 
                   2.  Certify that PIMCO has adopted procedures reasonably necessary to prevent 
  Advisory Employees from violating the Code. 
 
                                                                                                   Recordkeeping
 
                   Beginning on the effective date of this Code, PIMCO will maintain the following records, 
which shall be available to the Securities and Exchange Commission or any representative of the 
Commission at any time and from time to time for reasonable periodic, special or other 
examination:     
 
                   1.  PIMCO’s Chief Compliance Officer shall maintain, in any easily accessible place 
  at PIMCO’s principal office: 
 
  (a)  a copy of PIMCO’s current Code and of each predecessor of that Code 
    that was in effect at any time within the previous five (5) years; 
 
  (b)  a record of any violation of the Code, and of any action taken as a result of 
    the violation, for at least five (5) years after the end of the fiscal year in 
    which the violation occurred; 
 
  (c)  copies of all written acknowledgements of receipt of the Code for each 
    Advisory Employee who is currently, or within the past five years was, an 
    Advisory Employee; 

                                                                                                          - 20 -

 
         (d)         a copy of each report made by an Advisory Employee pursuant to this 
           Code, including any Duplicate Broker Report submitted on behalf of that 
           Advisory Employee, for at least two (2) years after the end of the fiscal 
           year in which that report was made or that information was provided; 
 
         (e)         a list of the names of all persons who are currently, or within the past five 
           (5) years were, Advisory Employees and/or otherwise required to make 
           reports pursuant to this Code and the names of all persons who are or were 
           responsible for reviewing the reports of those Advisory Employees; 
 
         (f)         a copy of each report to the General Counsel of AGI or to the directors or 
           trustees of a Fund that is an Advisory Client for at least two (2) years after 
           the end of the fiscal year in which that report was made; 
 
         (g)         the log required under “Waivers” for at least five (5) years after the end of 
           the fiscal year in which the relevant waivers were granted; and 
 
         (h)         a record of any decision, and the reasons supporting the decision, to 
           approve the acquisition by an Advisory Employee of a Beneficial 
           Ownership interest in any Security in an Initial Public Offering or in a 
           Private Placement for at least five (5) years after the end of the fiscal year 
           in which such approval was granted. 
 
       2.         PIMCO shall also maintain the following additional records in an easily 
         accessible place: 
 
         (a)         a copy of each report made by an Advisory Employee pursuant to this 
           Code, including any Duplicate Broker Report submitted on behalf of that 
           Advisory Employee, for at least five (5) years after the end of the fiscal 
           year in which that report was made or that information was provided; and 
 
         (b)         a copy of each report to the General Counsel of AGI or to the directors or 
           trustees of a Fund that is an Advisory Client for at least five (5) years after 
           the end of the fiscal year in which that report was made. 

                                                                                                       - 21 -

  APPENDIX I

  Definitions Of Capitalized Terms

                   The following definitions apply to the capitalized terms used in the Code: 
 
AGI   
 
                   The acronym “AGI” means Allianz Global Investors of America L.P. 
 
AGI Closed End Fund   
 
                   The term “AGI Closed End Fund” means any Closed End Fund identified below or on 
the Legal and Compliance page of the PIMCO intranet site. Advisory Employees are 
encouraged to check the PIMCO intranet site for changes to the list below. 
 
 
AGI Closed End Funds Subadvised by PIMCO  Other AGI Closed End Funds 
 
PIMCO California Municipal Income Fund (PCQ)  Municipal Advantage Fund (MAF) 
PIMCO California Municipal Income Fund II  NFJ Dividend, Interest & Premium Strategy Fund 
(PCK)  (NFJ) 
PIMCO California Municipal Income Fund III  Nicholas-Applegate Convertible & Income Fund 
(PZC)  (NCV) 
PIMCO Corporate Income Fund (PCN)  Nicholas-Applegate Convertible & Income Fund II 
  (NCZ) 
PIMCO Corporate Opportunity Fund (PTY)  Nicholas-Applegate International & Premium 
  Strategy Fund (NAI) 
PIMCO Floating Rate Income Fund (PFL)   
PIMCO Floating Rate Strategy Fund (PFN)   
PIMCO Global StocksPLUS & Income Fund   
(PGP)   
PIMCO High Income Fund (PHK)   
PIMCO Municipal Income Fund (PMF)   
PIMCO Municipal Income Fund II (PML)   
PIMCO Municipal Income Fund III (PMX)   
PIMCO New York Municipal Income Fund (PNF)   
PIMCO New York Municipal Income Fund II   
(PNI)   
PIMCO New York Municipal Income Fund III   
(PYN)   

                                                                                                                                                      I-1

 
AGID 
 
                   The acronym “AGID” means Allianz Global Investors Distributors LLC. 
 
Advisory Client 
 
                   The term “Advisory Client” shall have the meaning provided in the first paragraph of the 
Code. 
 
Advisory Employee 
 
                   The term “Advisory Employee” means: (1) a director, officer or general partner of 
PIMCO or an employee of PIMCO (or of any company in a control relationship to PIMCO): (a) 
who, in connection with his or her regular functions or duties, makes, participates in, or obtains 
information regarding the purchase or sale of a Security or Futures Contract by PIMCO on 
behalf of an Advisory Client; (b) who has access to non-public information regarding any 
Advisory Client’s purchase or sale of Securities, or non-public information regarding the 
portfolio holdings of any Reportable Fund; (c) whose functions relate to the making of any 
recommendations with respect to the purchase or sale of a Security or Futures Contract by 
PIMCO on behalf of an Advisory Client; or (d) who is involved in making securities 
recommendations to Advisory Clients, or who has access to such recommendations that are non- 
public; or (2) any natural person in a control relationship to PIMCO who obtains information 
concerning recommendations made to a Fund with regard to the purchase or sale of a Security by 
the Fund. 
 
Beneficial Ownership 
 
                   As a general matter, you are considered to have a “Beneficial Ownership” interest in a 
Security or a Futures Contract if you have the opportunity, directly or indirectly, to profit or 
share in any profit derived from an Investment Transaction in that Security or Futures Contract. 
You are presumed to have a Beneficial Ownership interest in any Security or Futures 
Contract held, individually or jointly, by you or a member of your Immediate Family (as 
defined below). In addition, unless specifically excepted by a Compliance Officer based on a 
showing that your interest in a Security or a Futures Contract is sufficiently attenuated to avoid 
the possibility of conflict, you will be considered to have a Beneficial Ownership interest in a 
Security or a Futures Contract held by: (1) a joint account to which you are a party, (2) a 
partnership in which you are a general partner, (3) a partnership in which you or your 
Immediate Family holds a controlling interest and with respect to which Security or Futures 
Contract you or your Immediate Family has investment discretion, (4) a limited liability 
company in which you are a manager-member, (5) a limited liability company in which you or 
your Immediate Family holds a controlling interest and with respect to which Security or Futures 
Contract you or your Immediate Family has investment discretion, (6) a trust in which you or a 
member of your Immediate Family has a vested interest or serves as a trustee with investment 
discretion, (7) a closely-held corporation in which you or your Immediate Family holds a 
controlling interest and with respect to which Security or Futures Contract you or your 
Immediate Family has investment discretion, or (8) any account (including retirement, pension, 

                                                                                    I-2

 
deferred compensation or similar account) in which you or your Immediate Family has a 
substantial economic interest. 
 
                   For purposes of this Code, “Beneficial Ownership” shall also be interpreted in a manner 
consistent with SEC Rule 16a-1(a)(2) (17 C.F.R. §240.16a-1(a)(2)). 
 
Closed End Fund 
 
                   The term "Closed End Fund" means (1) a collective investment vehicle or pool that is a 
"Closed-End Company" as defined in Section 5(a)(2) of the Investment Company Act and 
registered as an investment company under the Investment Company Act, (2) a collective 
investment vehicle or pool that is organized or established outside of the United States which 
issues a fixed number of Securities which generally does not provide the right to purchase or 
redeem such Securities or (3) a collective investment vehicle or pool organized or established in 
the United States that is either excluded from the definition of “investment company” under the 
Investment Company Act, or relies on an applicable exemption from registration under the 
Investment Company Act and which issues a fixed number of Securities no class of which is 
publicly traded in the U.S., and which generally does not provide the right to purchase or redeem 
such Securities. 
 
Code 
 
                   The term “Code” shall have the same meaning provided in the first paragraph of the 
Code. 
 
Compliance Officer 
 
                    The term “Compliance Officer” means a PIMCO Compliance Officer listed on 
Appendix XII to the Code. 
 
Designated Security 
 
                   The term “Designated Security” shall mean any equity Security or Closed End Fund or 
an option, warrant or other right to such an equity Security or Closed End Fund designated as 
such by a Compliance Officer, after receiving notification, from a Portfolio Employee or 
otherwise, that said equity Security or Closed End Fund is held by an Advisory Client or is being 
considered for purchase or sale by PIMCO on behalf of one or more of its Advisory Clients. A 
current list of Designated Securities may be found on the Legal and Compliance page of the 
PIMCO intranet site. 
 
Duplicate Broker Reports 
 
                   The term “Duplicate Broker Reports” means duplicate copies of trade confirmations of 
relevant Investment Transactions and of periodic statements for a relevant Personal Account or 
Related Account. 

                                                                                           I-3

 
ETF   
 
                   The acronym “ETF” means an Exchange-Traded Fund. 
 
Exempt Security 
 
                   The term “Exempt Security” refers to: 
 
                   1.  Direct obligations of the Government of the United States; 
 
                   2.  Shares issued by open-end Funds that are Money Market Funds; and 
 
                   3.  Bankers’ acceptances, bank certificates of deposit, commercial paper and high 
  quality short-term debt instruments, including repurchase agreements. For these 
  purposes, a “high quality short-term debt instrument” means any instrument 
  having a maturity at issuance of less than 366 days and that is rated in one of the 
  two highest rating categories by a Nationally Recognized Statistical Rating 
  Organization. 
 
Fixed Income Security 
 
The term “Fixed Income Security” shall mean a fixed income Security issued by an agency or 
instrumentality of, or unconditionally guaranteed by, the Government of the United States, a 
corporate debt Security, a mortgage-backed or other asset-backed Security, a taxable or tax- 
exempt fixed income Security issued by a state or local government or a political subdivision 
thereof, a structured note or loan participation, a foreign government debt Security, or a debt 
Security of an international agency or a supranational agency. For purposes of this Code, the 
term “Fixed Income Security” shall not be interpreted to include a U.S. Government Security or 
any other Exempt Security (as defined above). 
 
Fund   
 
                   The term “Fund” means an investment company registered under the Investment 
Company Act.   
 
Futures Contract 
 
                   The term “Futures Contract” includes (a) a futures contract and an option on a futures 
contract traded on a United States or foreign board of trade, such as the Chicago Board of Trade, 
the Chicago Mercantile Exchange, the London International Financial Futures Exchange or the 
New York Mercantile Exchange (a “Publicly-Traded Futures Contract”), as well as (b) a forward 
contract, a swap, a cap, a collar, a floor and an over-the-counter option (other than an option on a 
foreign currency, an option on a basket of currencies, an option on a Security or an option on an 
index of Securities) (a “Privately-Traded Contract”). Consult with a Compliance Officer prior to 
entering into a transaction in case of any doubt. For purposes of this definition, a Publicly- 
Traded Futures Contract is defined by its expiration month, i.e., a Publicly-Traded Futures 
Contract on a U.S. Treasury Bond that expires in June is treated as a separate Publicly-Traded 
Futures Contract from a Publicly-Traded Futures Contract on a U.S. Treasury Bond that expires 

                                                                                 I-4

 
in July. For purposes of this Code, “Futures Contract” shall not include a “security future” as 
defined in Section 3(a)(55) of the Securities Exchange Act of 1934 (15 U.S.C. § 78c(a)(55)). 
 
Immediate Family 
 
                   The term “Immediate Family” means any of the following persons who reside in your 
household, depend on you for basic living support, or for whom you have investment 
discretion: your spouse, any child, stepchild, grandchild, parent, stepparent, grandparent, 
sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in- 
law, including any adoptive relationships. 
 
Initial Public Offering 
 
                   The term “Initial Public Offering” means an offering of securities registered under the 
Securities Act of 1933 (15 U.S.C. § 77a), the issuer of which, immediately before the 
registration, was not subject to the reporting requirements of Sections 13 or 15(d) of the 
Securities Exchange Act of 1934 (15 U.S.C. § 78m or § 78o(d)). 
 
Insider Trading Policy 
 
                   The term “Insider Trading Policy” shall mean the AGI Insider Trading Policy and 
Procedures attached as Appendix III to this Code. 
 
Investment Company Act 
 
                   The term “Investment Company Act” means the Investment Company Act of 1940, as 
amended. 
 
Investment Transaction 
 
                   The term “Investment Transaction” means any transaction in a Security or a Futures 
Contract in which you have, or by reason of the transaction will acquire, a Beneficial Ownership 
interest, and includes, among other things, the writing of an option to purchase or sell a Security. 
 
Money Market Fund 
 
                   The term “Money Market Fund” means any taxable or tax-exempt money market Fund or 
any similar open-end Fund. 
 
Mutual Fund 
 
                   The term “Mutual Fund” means (1) a collective investment vehicle or pool that is an 
open-end management investment company as defined in Section 5(a)(1) of the Investment 
Company Act and registered as an investment company under the Investment Company Act 
(other than Money Market Funds that are “Exempt Securities,” as defined above), (2) a 
collective investment vehicle or pool that is organized or established outside of the United States 
that generally provides the right to purchase or redeem Securities issued by such fund on a daily 
basis, or (3) a collective investment vehicle or pool organized or established in the United States 

                                                                                  I-5

that is either excluded from the definition of “investment company” under the Investment 
Company Act, or relies on an applicable exemption from registration under the Investment 
Company, and which generally provides the right to purchase or redeem Securities issued by 
such fund on a daily basis. 
 
Mutual Fund Security 
 
                   The term “Mutual Fund Security” means an equity Security issued by a Mutual Fund. 
 
Personal Account 
 
                   The term “Personal Account” means the following accounts that hold or are likely to hold 
a Security (as defined below) or a Futures Contract (as defined above) in which you have a 
Beneficial Ownership interest: any account in your individual name; any joint or tenant-in- 
common account in which you have an interest or are a participant; any account for which you 
act as trustee, executor, or custodian; any account over which you have investment discretion or 
otherwise can exercise control (other than non-related clients’ accounts over which you have 
investment discretion), including the accounts of entities controlled directly or indirectly by you; 
and any other account in which you have a Beneficial Ownership interest (other than such 
accounts over which you have no investment discretion and cannot otherwise exercise control). 
 
PIMCO 
 
                   The acronym “PIMCO” shall mean Pacific Investment Management Company LLC. 
 
PIMCO Closed End Fund 
 
          The term “PIMCO Closed End Fund” means any Closed End Fund for which PIMCO acts 
as investment advisor, including, but not necessarily limited to, PIMCO Commercial Mortgage 
Securities Trust, Inc., and PIMCO Strategic Global Government Fund, Inc. A current list of 
PIMCO Closed End Funds may be found on the Legal and Compliance page of the PIMCO 
intranet site. 
 
Portfolio Employee 
 
                   The term “Portfolio Employee” means: (1) a portfolio manager or any employee of 
PIMCO (or of any company in a control relationship with PIMCO) who, in connection with his 
or her regular functions or duties, makes or participates in making recommendations regarding 
the purchase or sale of securities by a Fund, or (2) any natural person who controls PIMCO and 
who obtains information concerning recommendations made to a Fund that is an Advisory Client 
regarding the purchase or sale of Securities by the Fund. For these purposes, “control” has the 
same meaning as in Section 2(a)(9) of the Investment Company Act (15 U.S.C. § 80a-2(a)(9)). 
 
Private Placement 

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                   The term “Private Placement” means an offering that is exempt from registration under 
the Securities Act of 1933 pursuant to Section 4(2) or Section 4(6) (15 U.S.C. § 77d(2) or 
§ 77d(6)) or pursuant to SEC Rules 504, 505 or 506 (17 C.F.R. §§ 230.504, 230.505, or 230.506) 
under the Securities Act of 1933. 
 
Qualified Foreign Government 
 
                   The term “Qualified Foreign Government” means a national government of a developed 
foreign country with outstanding Fixed Income Securities in excess of fifty billion dollars. A list 
of Qualified Foreign Governments will be prepared as of the last business day of each calendar 
quarter, will be available from the Chief Compliance Officer, and will be effective for the 
following calendar quarter. 
 
Related Account 
 
                   The term “Related Account” means any account, other than a Personal Account, that 
holds a Security or a Futures Contract in which you have a Beneficial Ownership interest. 
 
Related Security 
 
                   The term “Related Security” shall mean any option to purchase or sell, and any Security 
convertible into or exchangeable for, a Security that is or has been held by PIMCO on behalf of 
one of its Advisory Clients or any Security that is being or has been considered for purchase by 
PIMCO on behalf of one of its Advisory Clients. 
 
Relevant Debt Security 
 
                   The term “Relevant Debt Security” shall mean corporate debt Securities, mortgage- 
backed and other asset-backed Securities, taxable and tax-exempt state, local and municipal 
Fixed Income Securities, structured notes and loan participations, foreign government debt 
Securities issued by non-qualified foreign governments, or debt securities issued by an 
international agency or a supranational agency. 
 
Reportable Fund 
 
                   The term “Reportable Fund” shall mean any Fund for which PIMCO serves as an 
investment advisor (as defined in Section 2(a)(2) of the Investment Company Act) or any Fund 
whose investment advisor or principal underwriter controls PIMCO, is controlled by PIMCO, or 
is under common control with PIMCO. 
 
Security 
 
                   As a general matter, the term “Security” shall mean any stock, note, bond, debenture or 
other evidence of indebtedness (including any loan participation or assignment), ETF, Closed 
End Fund, limited partnership interest or investment contract other than an Exempt Security 
(as defined above). The term “Security” includes a Mutual Fund Security or an option on a 
Security, on an index of Securities, on a currency or on a basket of currencies, including such an 

                                                                                 I-7

option traded on the Chicago Board of Options Exchange or on the New York, American, Pacific 
or Philadelphia Stock Exchanges, as well as such an option traded in the over-the-counter 
market. For purposes of this Code, the term “Security” shall include a “security future” as 
defined in Section 3(a)(55) of the Securities Exchange Act of 1934, but otherwise shall not 
include a Futures Contract or a physical commodity (such as foreign exchange or a precious 
metal). 
 
                   As a technical matter, the term “Security” shall, except as otherwise provided above, 
have the meaning set forth in Section 2(a)(36) of the Investment Company Act (15 U.S.C. § 80a- 
2(a)(36)), which defines a Security to mean: 
 
                   Any note, stock, treasury stock, security future, bond debenture, evidence of 
indebtedness, certificate of interest or participation in any profit-sharing agreement, collateral- 
trust certificate, preorganization certificate of subscription, transferable share, investment 
contract, voting-trust certificate, certificate of deposit for a security, fractional undivided interest 
in oil, gas, or other mineral rights, any put, call, straddle, option, or privilege on any security 
(including a certificate of deposit) or on any group or index of securities (including any interest 
therein or based on the value thereof), or any put, call, straddle, option, or privilege entered into 
on a national securities exchange relating to foreign currency, or, in general, any interest or 
instrument commonly known as a “security”, or any certificate of interest or instrument 
commonly known as a “security”, or any certificate of interest or participation in, temporary or 
interim certificate for, receipt for, guarantee of, warrant or right to subscribe to or purchase, any 
of the foregoing. 

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