CODE OF ETHICS
(Revised October 15, 2007)
Westwood Management Corporation
Westwood Trust
Westwood Holdings Group, Inc.
Each Registered Investment Company or series thereof (each of which is considered to be
a Company for this purpose) for which the company listed above presently or hereafter
provides investment advisory services, other than a money market fund or a fund that
does not invest in Securities.
I.	Introduction
The purpose of this Code of Ethics is to promote honest and ethical conduct, focus the
Board of Directors and management of Westwood Holdings Group, Inc. on areas of
ethical risk, provide guidance to directors, officers and employees to help them recognize
and deal with ethical issues, provide mechanisms to report unethical conduct and help to
preserve the culture of honesty and accountability at the Company.
This Code of Ethics establishes rules of conduct for persons who are associated with the
companies named above or with the registered investment companies for which such
companies provide investment advisory or principal underwriter services. The Code
governs their personal investment and other investment-related activities.
The basic rule is very simple: put the client’s interests first. The rest of the rules
elaborate this principle. This Code is intended to assist the companies in fulfilling their
obligations under the law. Article I lays out who the Code applies to, Article II deals
with personal investment activities, Article III deals with other sensitive business
practices, and subsequent parts deal with reporting and administrative procedures.
The Code is very important to the companies and their employees. Violations can not
only cause the companies embarrassment, loss of business, legal restrictions, fines and
other punishments, but for employees can lead to demotion, suspension, firing, ejection
from the securities business, and very large fines.
II.	Applicability
	(A)	The Code applies to each of the following:
		1.	The Companies named or described at the top of page one of the
			Code and all entities that are under common management with

		these Companies or otherwise agree to be subject to the Code
		(“Affiliates”). A listing of the Affiliates, which is periodically
		updated, is attached as Exhibit A.
	2.	Any officer, director or employee of any Company, Affiliate or
		Fund Client (as defined below).
	3.	With respect to all of the Companies, Affiliates and Fund Clients
		except Westwood Management Corporation, any natural person
		who controls any of the Companies, Affiliates or Fund Clients and
		who obtains information regarding the Company’s or the
		Affiliates’ investment recommendations or decisions. However, a
		person whose control arises only as a result of his official position
		with such entity is excluded. Disinterested directors of Fund
		Clients and independent directors of the Companies (excluding
		Westwood Management Corporation) for example, are excluded
		from coverage under this item.
	4.	Any director, officer, general partner or person performing a
		similar function even if he has no knowledge of and is not involved
		in the investment process. Disinterested directors of Fund Clients
		and independent directors of the Companies (excluding Westwood
		Management Corporation) are included in coverage under this
		item.
	5.	As an exception, the Code does not apply to any director, officer or
		employee of any fund Client (such as certain of The Gabelli
		Westwood Funds) with respect to which the Companies’ services
		do not involve the formulation or making of investment
		recommendations or decisions or the execution of portfolio
		transactions if that person is also a director, officer or employee of
		any entity that does perform such services (such as Westwood
		Management Corp.). These individuals are covered by codes of
		ethics adopted by such entities.
(B)	Definitions
	1.	Access Persons. The Companies and the persons described in
		items (A)2 and (A)3 above other than those excluded by item (A)5
		above.
	2.	Access Person Account. Includes all advisory, brokerage, trust or
		other accounts or forms of direct beneficial ownership in which one
		or more Access Person and/or one or more members of an Access
		Person’s immediate family have a substantial proportionate
		economic interest. Immediate family includes an Access Person’s

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	spouse and minor children and any family member living in the
	same household as the Access Person. A substantial proportionate
	economic interest will generally be 10% of the equity in the
	account in the case of an Access Person and 25% of the equity in
	the account in the case of all Access Persons in the aggregate
	whichever is first applicable. Investment partnerships and similar
	indirect means of ownership other than registered open-end
	investment companies are also treated as accounts.
	As an exception, accounts in which one or more Access Persons
	and/or their immediate family have a substantial proportionate
	interest which are maintained with persons who have no affiliation
	with the companies and with respect to which no Access Person
	has, in the judgment of the Compliance Officer after reviewing the
	terms and circumstances, any direct or indirect influence or control
	over the investment or portfolio execution process are not Access
	Person Accounts.
	As a further exception, subject to the provisions of Article III(I)6,
	bona fide market making accounts of Gabelli & Company are not
	Access Person Accounts.
	As a further exception, subject to the provisions of Article III(I)6,
	bona fide error accounts of the Companies and the Affiliates are
	not Access Person Accounts.
3.	Clients. Investment advisory accounts maintained with any of the
	Companies or Affiliates by any person, other than Access Person
	Accounts. However, Fund Clients covered by item (A)5 above are
	considered Client accounts only with respect to employees
	specifically identified by the Compliance Officer as having regular
	information regarding investment recommendations or decisions or
	portfolio transactions for such Fund Clients.
4.	Companies. The companies named or described at the top of page
	one of the Code.
5.	Compliance Officer. The person designated as Westwood’s Chief
	Compliance Officer.
6.	Covered Persons. The Companies, the Access Persons and the
	persons described in item (A)4 above.
7.	Executive Manager. The CEO or President of Westwood
	Management Corp.

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		8.	Fund Clients. Clients that are registered investment companies or
			series thereof.
		9.	Portfolio Managers. Access Persons who are principally
			responsible for investment decisions with respect to any Client
			accounts.
		10.	Security. Any financial instruments treated as a security for
			investment purposes and any related instruments such as futures,
			forward or swap contracts entered into with respect to one or more
			securities. However, the term security does not include securities
			issued by the Government of the United States, bankers’
			acceptances, bank certificates of deposit, commercial paper and
			high quality short-term debt instruments, including repurchase
			agreements, or units of bank regulated commingled funds.
III.	Restrictions on Personal Investing Activities
	(A)	Basic Restriction on Investing Activities
		If a Security is owned in any Client account, such Security or any related
		Security (such as an option, warrant or convertible security) may not be
		purchased or sold for any Access Person Account subject to the previously
		owned related Security exception set forth in paragraph (B) below. If an
		Access Person owns a Security that is subsequently purchased in any
		Client account, the Access Person may not sell such Security until it is
		sold out of all Client accounts. If a purchase or sale order is pending for
		any Client account by any Company or Affiliate, any request to purchase
		or sell such Security or any related Security (such as an option, warrant or
		convertible security) for an Access Person Account will be denied. If a
		Security is under active consideration for purchase in any Client account
		by any Company or Affiliate, any request to purchase or sell such Security
		or any related Security (such as an option, warrant or convertible security)
		for an Access Person Account may be denied at the discretion of the
		Compliance Officer and the Executive Manager.
	(B)	Investments owned prior to employment.
		If a Security is owned by an Access Person when such person becomes a
		new employee, such Access Person will not be asked to sell their position
		in the Security, but all future transactions in such Security will be subject
		to paragraph A.
		In the case of a related Security (such as an option, warrant or convertible
		security) that is owned by an Access Person when such person becomes a
		new employee, the Access Person may not exercise/convert such related

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	Security if a purchase or sale order is pending for any Client account by
	any Company or Affiliate. If the Security is under active consideration for
	purchase or sale in any Client account, any request to exercise/convert a
	related Security may be denied at the discretion of the Compliance Officer
	and the Executive Manager.
(C)	Initial Public Offerings
	No Security or related Security may be acquired in an initial public
	offering for any Access Person Account.
(D)	Blackout Period
	No Security or related Security may be bought, sold or exercised for any
	Access Person Account during the period commencing seven (7) calendar
	days prior to and ending seven (7) calendar days after the purchase or sale
	(or entry of an order for the purchase or sale) of that Security or any
	related Security for the account of any Client.
(E)	Short-term Trading
	No Security or related Security may, within a 60-day period, be bought
	and sold or sold and bought at a profit for any Access Person Account.
(F)	Exempt Transactions. The following transactions are exempt from the
	restrictions set forth in paragraphs (A), (B) and (D) above and do not
	require pre-clearance under paragraph (H) below:
	1.	Participation in an ongoing basis in an automatic investment plan
		including 401K plans or an issuer’s dividend reinvestment or stock
		purchase plan,
	2.	Participation in any transaction over which no Access Person had
		any direct or indirect influence or control, involuntary transactions
		(such as mergers, inheritances, gifts, etc.),
	3.	Shares of registered open-end investment companies other than
		shares of investment companies advised by the firm or its affiliates
		or subadvised by the firm,
	4.	Securities transactions processed for an Access Person Account
		that has been formed for the sole purpose of product development.
	5.	Non-convertible fixed income Securities rated at least “A”, and
	6.	Municipal Securities.
(G)	Permitted Exceptions

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	Purchases and sales of the following Securities for Access Person
	Accounts are exempt from the restrictions set forth in paragraphs A, C and
	D above if such purchases and sales comply with the preclearance
	requirements of paragraph (H) below:
	1.	Shares of registered open-end investment companies advised by the
		firm or its affiliates or subadvised by the firm, and
	2.	Exchange traded funds.
	In addition, the exercise of rights that were received pro rata with other
	security holders is exempt if the preclearance procedures are satisfied.
(H)	Pre-Clearance of Personal Securities Transactions
	No Security or related Security (such as an option, warrant or convertible
	security) may be bought, sold or exercised for an Access Person Account
	unless (i) the Access Person obtains prior approval from an Executive
	Manager and the Compliance Officer, or in the absence of the Compliance
	Officer, from a designee of the Compliance Officer; (ii) the approved
	transaction is completed on the same day approval is received; and (iii) the
	Compliance Officer or an Executive Manager does not rescind such
	approval prior to execution of the transaction. (See paragraph J below for
	details of the Pre-Clearance Process.)
(I)	Private Placements
	The purchases or sale of Securities that are not publicly traded will not be
	approved unless the Access Person provides full details of the proposed
	transaction (including written certification that the investment opportunity
	did not arise by virtue of such person’s activities on behalf of any Client)
	and the Compliance Officer and an Executive Manager conclude, after
	consultation with one or more of the relevant Portfolio Managers, that the
	Companies would have no foreseeable interest in investing in such
	Security or any related Security for the account of any Client.

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(J)	Pre-Clearance Process
	1.	No Security may be purchased or sold for any Access Person
		Account unless the particular transaction has been approved in
		writing by an Executive Manager and the Compliance Officer, or in
		the absence of the Compliance Officer, a designee of the
		Compliance Officer. The Compliance Officer shall review, not less
		frequently than weekly, confirmations from brokers to assure that
		all transactions effected for Access Person Accounts are effected in
		compliance with this Code.
	2.	Access Persons must direct brokerage and other firms with which
		they have Access Person Accounts to furnish to the Compliance
		Officer on a timely basis duplicate copies of confirmations of, and
		account statements concerning, all personal Securities transactions.
	3.	A Trading Approval Form, attached as Exhibit B, must be
		completed and submitted to the Compliance Officer for approval
		by the Compliance Officer and an Executive Manager prior to
		entry of an order.
	4.	After reviewing the proposed trade and the level of potential
		investment interest on behalf of Clients in the Security in question,
		the Compliance Officer and an Executive Manager shall approve
		(or disapprove) a trading order on behalf of an Access Person as
		expeditiously as possible. Transactions described in paragraph (G)
		above will generally be approved unless it is believed for any
		reason that the Access Person Account should not trade in such
		Security at such time.
	5.	Once an Access Person’s Trading Approval Form is approved, the
		transaction must be executed on the same day. If the Access
		Person’s trading order request is not approved, or is not executed
		on the same day it is approved, the clearance lapses although such
		trading order request may be resubmitted at a later date.
	6.	Trading approval for the Compliance Officer must be obtained
		from the CEO or President of Westwood Management Corp., and
		trading approval for the CEO and the President must be obtained
		from the Compliance Officer.
	7.	The Compliance Officer shall review all Trading Approval Forms,
		all initial, quarterly and annual disclosure certifications and the
		trading activities on behalf of all Client accounts with a view to
		ensuring that all Covered Persons are complying with the spirit as
		well as the detailed requirements of this Code.

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IV.	Other Investment-Related Restrictions
	(A)	Conflicts of Interest
		Access Persons are prohibited from engaging in any activity, practice, or
		act which conflicts with, or appears to conflict with, the interests of the
		companies, its customers, or vendors. Covered Persons are required to
		fully disclose any potential conflict of interest to your supervisor/manager.
		A conflict of interest exists when you, knowingly or unknowingly, engage
		in any activity that may compromise you, another employee, or the
		company in its relationship with a customer, vendor, or competitor.
		1.	Gifts & Entertainment. Potential conflicts of interest with a
			customer, vendor, or competitor may include soliciting business for
			personal gain, accepting gifts other than those of nominal value
			(not more than $100), or requesting favors, discounts, or services.
			a.	No Access Person shall accept any gift or other item of
				more than $100 in value from any client, competitor, or any
				person or entity that does business with or on behalf of any
				client. If you are offered, receive, or anticipate receiving
				something of value from any of the named entities, you
				must disclose the matter to your supervisor/manager.
			b.	Access Persons shall report offers of entertainment (dinners,
				sports/concert events from any person or entity that does
				business with or on behalf of any Client.
		2.	Service as a Director. No Access Person shall commence service
			on the Board of Directors of a publicly traded company or any
			company in which any Client account has an interest without prior
			authorization from the Chief Compliance Officer based upon a
			determination that the Board service would not be inconsistent with
			the interests of the Clients.
	(B)	Disclosure of Conflicts
		Full disclosure to your supervisor/manager of any potential conflict of
		interest is required as soon as such potential conflict is discovered. If you
		believe that unusual circumstances justify your engaging in an activity that
		may result in a conflict of interest, you may request in writing that your
		supervisor/manager or Compliance Department review the situation and
		grant an exception.
V.	Reports and Additional Compliance Procedures

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(A)	Quarterly Transaction Reports
	Every Covered Person, except independent directors of Affiliates of the
	Companies, must submit a Transaction Report (Exhibit C) containing the
	information set forth in paragraph (C) below with respect to transactions
	in any Security in which such Covered Person has or by reason of such
	transactions acquires, any direct or indirect beneficial ownership (as
	defined in Exhibit D) in the Security; and with respect to any account
	established by the Covered Person in which any Securities were held for
	the direct or indirect benefit of the Covered Person subject to the
	exceptions listed below in paragraph (B).
	1.	The Transaction Report must be submitted to the Compliance
		Officer no later than 10 days after the end of the calendar quarter in
		which the transaction or account to which the report relates was
		effected or established, and the report must contain the date that the
		report is submitted.
	2.	A Transaction report must contain the following information:
		a.	The date of the transaction, the title and number of shares and
			the principal amount of each Security involved;
		b.	The nature of the transaction (i.e., purchase, sale or any other
			type of acquisition or disposition);
		c.	The price at which the transaction was effected; and
		d.	The name of the broker, dealer or bank with or through whom
			the transaction was effected.
	3.	This report must contain the following information with respect to
		accounts established:
		a.	The name of the broker, dealer or bank with whom the
			account was established; and
		b.	The date the account was established.
(B)	Transaction Report Exceptions
	A Covered Person is not required to submit a report in the following
	instances:
	1.	A Covered Person who is required to make reports only because he
		is a director of one of the Fund Clients and who is a “disinterested”
		director thereof need not make a report with respect to any

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		transactions other than those where he knew or should have known
		in the course of his duties as a director that any Fund Client of
		which he is a director has made or makes a purchase or sale of the
		same or a related Security within 15 days before or after the
		purchase or sale of such Security or related Security by such
		director.
	2.	A Covered Person need not make a report with respect to any
		transactions effected for, and Securities held in, any account over
		which such person does not have any direct or indirect influence or
		control; and
	3.	A Covered Person need not make a report with respect to any
		transactions effected pursuant to an automatic investment plan (this
		includes dividend reinvestment plans),
(C)	Ownership Admission
	Any report submitted to comply with the requirements of this Article V
	may contain a statement that the report shall not be construed as an
	admission by the person making such report that he has any direct or
	indirect benefit ownership in the Security to which the report relates. A
	person need not make any report under this Article V with respect to
	transaction effected for, and Securities held in, any account over which the
	person has no direct or indirect influence or control.
(D)	Initial Holdings Report
	No later than 10 days after beginning employment with any of the
	Companies or Affiliates or otherwise becoming a Covered Person, each
	Covered Person (except for a “disinterested” director of the Fund Client or
	an “independent” director of the Companies (other than Westwood
	Management Corporation) who is required to submit reports solely by
	reason of being such a director) must submit an Initial Holdings Report
	(Exhibit E) containing the following information:
	1.	The title, number of shares and principal amount of each Security in
		which the Covered Person had any direct or indirect beneficial
ownership when the person became a Covered Person;
	2.	The name of any broker, dealer or bank with whom the Covered
		Person maintained an account in which any Securities were held for
		the direct or indirect benefit of the Covered Person as of the date the
		person became a Covered Person; and
	3.	The date that the report is submitted.

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(E)	Annual Certification
	Annually each Covered Person must certify that he has read and
	understood the Code and recognizes that he is subject to such Code. In
	addition, annually each Covered Person must certify that he has disclosed
	or reported all personal Securities transactions required to be disclosed or
	reported under the Code and that he is not subject to any regulatory
	disability described in the annual certification form. Furthermore, each
	Covered Person (except for a “disinterested” director of the Fund Client or
	an “independent” director of any of the companies (other than Westwood
	Management Corporation) who is required to submit reports solely by
	reason of being such a director) annually must submit a report containing
	the following information (which information must be current as of a date
	no more than 30 days before the report is submitted):
	1.	The title, number of shares and principal amount of each Security
		in which the Covered Person had any direct or indirect beneficial
		ownership;
	2.	The name of any broker, dealer or bank with whom the Covered
		Person maintains an account in which any Securities are held for
		the direct or indirect benefit of the Covered Person; and
	3.	The date that the report is submitted.
	The form of such certification and report is attached as Exhibits F and G.
(F)	Duplicate Brokerage Statements in lieu of Reports
	A Covered Person will be deemed to have complied with the quarterly
	transaction report requirements of this Article V insofar as the Compliance
	Officer receives in a timely fashion duplicate monthly or quarterly
	brokerage statements on which all transactions required to be reported
	hereunder are described.
(G)	Reporting of Violations
	1.	Violations of the Code of Ethics must be promptly reported to the
		Chief Compliance Officer.
		a.	Anonymous reporting is acceptable.
		b.	All violations will be reviewed by the Trade Monitoring and
			Compliance Committee.
(H)	Board Report

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		At least annually (or quarterly in the case of Items 4 and 5 below), each of
		the Companies that has a Fund Client or that provides principal
		underwriting services for a Fund Client shall, together with each Fund
		Client, furnish a written report to the Board of Directors of the Fund Client
		that:
		1.	Describes any issues arising under the Code since the last report.
		2.	Certifies that Companies have developed procedures concerning
			Covered Persons’ personal trading activities and reporting
			requirements relevant to such Fund Clients that are reasonably
necessary to prevent violations of the Code;
		3.	Recommends changes, if any, to the Fund Clients’ or the
			Companies’ Codes of Ethics or procedures;
		4.	Provided a summary of any material or substantive violations of
			this Code by Covered Persons with respect to such Fund Clients
			which occurred during the past quarter and the nature of any
			remedial action taken; and
		5.	Describes any material or significant exceptions to any provisions
			of this code of Ethics as determined under Article VI below.
The Compliance Officer shall notify each employee of any of the Companies or Affiliates
as to whether such person is considered to be an Access Person or Covered Person and
shall notify each other that is considered to be an Access Person or Covered Person.
VI.	Sanctions
	Upon discovering that a Covered Person has not complied with the requirements
	of this Code, the Board of Directors of the relevant Company or of the relevant
	Fund Client, whichever is most appropriate under the circumstances, may impose
	on that person whatever sanctions the Board deems appropriate, including, among
	other things, disgorgement of profit, censure, suspension or termination of
	employment. Material violations of requirements of this Code by employees of
	Covered Persons and any sanctions imposed in connection therewith shall be
	reported not less frequently than quarterly to the Board of Directors of any
	relevant Company or Fund Client, as applicable.
VII.	Exceptions
	(A)	The Trade Monitoring Compliance Committee (the “TMCC”) of the
		Companies reserves the right to decide, on a case-by-case basis,
		exceptions to any provisions under this Code. Any exceptions made
		hereunder will be maintained in writing by the TMCC.

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	(B)	Personal Trading. Requests for exceptions to the personal investing
		restrictions set forth in Article III of this Code must be submitted in
		writing to the Chief Compliance Officer along with any Trading Approval
		Form required for the transaction. Following are guidelines that the
		TMCC will consider when reviewing requests for personal trading
		restriction exceptions:
		1.	Access to research/analyst information: an employee requesting an
			exception should have little or no access to research/analyst
			information;
		2.	De minimus trade: if an employee requests an exception for a
			transaction in a security that is held in a Client Account, the
			transaction must, in the opinion of the Chief Compliance Officer,
			be a de minimus trade, i.e. a small number of shares in a security
			with a large market cap and a high average trading volume that is
			not likely to adversely affect the price of the security; or
		3.	Expiration of stock options: the exercise of stock options granted
by a previous employer that are about to expire.
VIII.	Preservation of Documents
	This Code, a copy of each report by a Covered Person, any written report made
	hereunder by the Companies or the Compliance Officer, lists of all persons
	required to make reports, a list of any exceptions, and the reasons therefore, with
	respect to Article II.C, and any records under Article II.H with respect to
	purchases pursuant to Article II.I above, shall be preserved with the records of the
	relevant Company and any relevant Fund Client for the period required by Rule
	17j-l.
IX.	Other Laws, Rules and Statements of Policy
	Nothing contained in this Code shall be interpreted as relieving any Covered
	Person from acting in accordance with the provision of any applicable law, rule or
	regulation or any other statement of policy or procedure governing the conduct of
	such person adopted by the Companies, the Affiliates or the Fund Clients.
	All activities of the company must be conducted in full compliance with all
	applicable laws and regulations. Senior management should be informed
	regarding all matters pertinent to the company’s position regarding such laws and
	regulations. The company expects all employees to follow the spirit as well as the
	letter of the law. In addition, Covered Persons are expected to fully comply with
	the company’s Amended and Restated Insider Trading Policy that prohibits illegal
	insider trading and the use of material non-public information. All employees are
	expected to cooperate fully with the company’s internal and outside auditors,
	attorneys, and regulatory examiners
X.	Future Information

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If any person has any question with regard to the applicability of the provisions of this Code generally or with regard to any Securities transaction or transactions, he should consult the Chief Compliance Officer.

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	Exhibit A
LIST OF AFFILIATES OF THE COMPANIES
Westwood Holdings Group, Inc.
Westwood Trust
Affiliated mutual funds:
WHG LargeCap Value Fund
WHG SMidCap Fund
WHG Income Opportunity Fund
WHG Balanced Fund
WHG SmallCap Value Fund
Gabelli Westwood Equity Fund
Gabelli Westwood Balanced Fund
Gabelli Westwood Intermediate Bond Fund
UBS PACE Large Company Value Equity Investments
The Timothy Plan Large/Mid-Cap Value Fund
The Timothy Plan Small-Cap Value Fund

	Exhibit B
PRE-CLEARANCE TRADING APPROVAL FORM
I, __________________________________________________(name), am an Access
Person or authorized officer thereof and seek pre-clearance to engage in the
transaction described below; for the benefit of myself or another access person:
Acquisition or Disposition (circle one)
Name of Account:
Account Number:
Date of Request:
Security:
Amount or # of Shares:
Broker:
If the transaction involves a Security that is not publicly traded, a description of proposed
transaction, source of investment opportunity and any potential conflicts of interest:
I hereby certify that, to the best of my knowledge, the transaction described herein is not
prohibited by the Code of Ethics and that the opportunity to engage in the transaction did
not arise by virtue of my activities on behalf of any Client.
Signature:________________________	Print Name:________________________
Approved or Disapproved (circle one)
Date of Approval _____________________________
Signature:_________________________	Print Name:_________________________
Compliance Officer Approval:______________________________

                                                                                                                                                          Exhibit C 

                                                                       TRANSACTION REPORT 

Report Submitted by:  _________________________________________________

                                                                         Print Your Name 

This transaction report (the “Report”) is submitted pursuant to Section IV(B) of the Code 

of Ethics of the Companies and supplies information with respect to transactions in any 

Security in which you may be deemed to have, or by reason of such transaction acquire, 

any direct or indirect beneficial ownership interest, and with respect to accounts 

established by you in which any Securities were held for your direct or indirect benefit, 

for the period specified below. If you were not employed by or affiliated with us during 

this entire period, amend the dates specified below to cover your period of employment. 

Unless the context otherwise requires, all terms used in the Report shall have the same 

meaning as set forth in the Code of Ethics. 

If you have no reportable transactions or new accounts, sign and return this page only. If 

you have reportable transactions or new accounts, complete, sign and return page 2 and 

any attachments. 

I HAD NO REPORTABLE SECURITIES TRANSACTIONS DURING THE PERIOD 

____________________ THROUGH _____ ____________. I CERTIFY THAT I 

AM FULLY FAMILIAR WITH THE CODE OF ETHICS AND THAT TO THE BEST 

OF MY KNOWLEDGE THE INFORMATION FURNISHED IN THIS REPORT IS 

TRUE AND CORRECT. 

Signature:  ___________________________________

Position:  ____________________________________

Date:  _______________________________________

					Page 2
		TRANSACTION REPORT
Report Submitted by:		___________________________________________________________________
			Print Your Name
The following tables supply the information required by Section IV(B) of the
Code of Ethics for the period specified below. Transactions reported on brokerage
statements or duplicate confirmations actually received by the Compliance Officer do not
have to be listed although it is your responsibility to make sure that such statements or
confirmations are complete and have been received in a timely fashion.
		TRANSACTIONS
		Whether			Name of the
		Purchase, Sale,			Broker/Dealer
		Short Sale, or			with or through
Securities		Other Type of		Price Per	whom the	Nature of
(Name and	Date of	Disposition or	Quantity of	Share or	Transaction	Ownership of
Symbol)	Transaction	Acquisition	Securities	Other Unit	was Effected	Securities
		NEW ACCOUNTS ESTABLISHED
Name of Broker, Dealer or Bank			Account Number		Date Account Established
I CERTIFY THAT I AM FULLY FAMILIAR WITH THE CODE OF ETHICS AND
THAT TO THE BEST OF MY KNOWLEDGE THE INFORMATION FURNISHED IN
THIS REPORT IS TRUE AND CORRECT FOR THE PERIOD OF
__________________________ THROUGH __________________________.
Signature:			Date:
Position:

                                                                                                                                                                     Exhibit D

BENEFICIAL OWNERSHIP

For purposes of the attached Code of Ethics, “beneficial ownership” shall be interpreted in the same manner as it would be in determining whether a person is subject to the provisions of Section 16 of the Securities Exchange Act of 1934 and the rules and regulations thereunder, except the determination of direct or indirect beneficial ownership shall apply to all securities that a Covered Person has or acquires. The term “beneficial ownership” of securities would include not only ownership of securities held by a Covered Person for his own benefit, whether in bearer form or registered in his name or otherwise, but also ownership of securities held for his benefit by other (regardless of whether or how they are registered) such as custodians, brokers, executors, administrators, or trustees (including trusts in which he has only a remainder interest), and securities held for his account by pledges, securities owned by a partnership in which he is a member if he may exercise a controlling influence over the purchase, sale or voting of such securities, and securities owned by any corporation or similar entity in which he owns securities if the shareholder is a controlling shareholder of the entity and has or shares investment control over the entity’s portfolio.

Ordinarily, this term would not include securities held by executors or administrators of estates in which a Covered Person is a legatee or beneficiary unless there is a specified legacy to such person of such securities or such person is the sole legatee or beneficiary and there are other assets in the estate sufficient to pay debts ranking ahead of such legacy, or the securities are held in the estate more than a year after the decedent’s death.

Securities held in the name of another should be considered as “beneficially” owned by a Covered Person where such person enjoys “financial benefits substantially equivalent to ownership.” The Securities and Exchange Commission has said that although the final determination of beneficial ownership is a question to be determined in the light of the facts of the particular case, generally a person is regarded as the beneficial owner of securities held in the name of his or her spouse and their minor children. Absent special circumstances such relationship ordinarily results in such person obtaining financial benefits substantially equivalent to ownership, e.q., application of the income derived from such securities to maintain a common home, or to meet expenses that such person otherwise would meet from other sources, or the ability to exercises a controlling influence over the purchase, sale or voting of such securities.

A Covered Person also may be regarded as the beneficial owner of securities held in the name of another person, if by reason of any contract, understanding, relationship, agreement, or other agreement, he obtains therefrom financial benefits substantially equivalent to those of ownership.

A Covered Person also may be regarded as the beneficial owner of securities held in the name of a spouse, minor children or other person, even though he does not obtain therefrom the aforementioned benefits of ownership, if he can vest or revest title in himself at once or at some future time.

                                                                                                                                                                 Exhibit E 

INITIAL HOLDINGS REPORT

Report submitted by:_______________________________________________________ 

Print Name

This initial holdings report (the “Report”) is submitted pursuant to Section IV (D) of the 

Code of Ethics of the Companies and supplies information with respect to any Security in 

which you may be deemed to have any direct or indirect beneficial ownership interest and 

any accounts established by you in which any Securities were held for your direct or 

indirect benefit, as of the date you became subject to the Code of Ethics. 

Unless the context otherwise requires, all terms used in the Report shall have the same 

meaning as set forth in the Code of Ethics. 

If you have no reportable Securities or accounts, sign and return this page only. If you 

have reportable Securities or accounts, complete, sign and return Page 2 and any 

attachments. 

I HAVE NO REPORTABLE SECURITIES OR ACCOUNTS AS OF 

____________________. I CERTIFY THAT I AM FULLY FAMILIAR WITH THE 

CODE OF ETHICS AND THAT, TO THE BEST OF MY KNOWLEDGE, THE 

INFORMATION FURNISHED IN THIS REPORT IS TRUE AND CORRECT. 

Signature:______________________________ 

Position:_______________________________ 

Date:__________________________________ 

			Page 2
	INITIAL HOLDINGS REPORT
Report submitted by:_______________________________________________________
	Print Name
The Following tables supply the information required by Section IV (D) of the Code of
Ethics as of the date you became subject to the Code.
	SECURITIES HOLDINGS
		Name of Broker/Dealer	Nature of Ownership of
Securities (Name and Symbol)	Quantity of Securities	Where Securities Are Held	Securities
ACCOUNTS
Name of Broker, Dealer or Bank		Account Number
I CERTIFY THAT I AM FULLY FAMILIAR WITH THE CODE OF ETHICS AND
THAT, TO THE BEST OF MY KNOWLEDGE, THE INFORMATION FURNISHED
IN THIS REPORT IS TRUE AND CORRECT AS OF _________________________. .
Signature:______________________________
Position:_______________________________
Date:__________________________________

	Exhibit F
ANNUAL CERTIFICATION OF CODE OF ETHICS
A.	I (a Covered Person) hereby certify that I have read and understand the firm’s
	Code of Ethics, and recognize that I am subject to its provisions. In addition, I
	hereby certify that I have disclosed or reported all personal Securities transactions
	required to be disclosed or reported under the Code of Ethics;
B.	Within the last ten years there have been no complaints or disciplinary actions
	filed against me by any regulated securities or commodities exchange, any self-
	regulatory securities or commodities organization, any attorney general, or any
	governmental office or agency regulating insurance securities, commodities or
	financial transactions in the United States, in any state of the United States, or in
	any other country;
C.	I have not within the last ten years been convicted of or acknowledged
	commission of any felony or misdemeanor arising out of my conduct as an
	employee, salesperson, officer, director, insurance agent, broker, dealer,
	underwriter, investment manager or investment advisor; and
D.	I have not been denied permission or otherwise enjoined by order, judgment or
	decree of any court of competent jurisdiction, regulated securities or commodities
	exchange, self-regulatory securities or commodities organization or other federal
	or state regulatory authority from acting as an investment advisor, securities or
	commodities broker or dealer, commodity pool operator or trading advisor, or as
	an affiliated person or employee of any investment company, bank, insurance
	company or commodity broker, dealer, pool operator or trading advisor, or from
	engaging in or continuing any conduct or practice in connection with any such
	activity or the purchase or sale of any security.
E.	Unless I am exempt from filing an Annual Holdings Report (as a “disinterested”
	director of a Fund Client or an independent director of an Affiliate), I have
	attached a completed Annual Holdings Report which is accurate as of a date no
	more than 30 days ago.
	Signature:  __________________________________________
	Print Name:  _________________________________________
	Date:  ______________________________________________

			EXHIBIT G
	ANNUAL HOLDINGS REPORT
Report submitted by:_______________________________________________________
	Print Name
The Following tables supply the information required by Section IV (E) of the Code of
Ethics as of the date you became subject to the Code.
	SECURITIES HOLDINGS
		Name of Broker/Dealer	Nature of Ownership of
Securities (Name and Symbol)	Quantity of Securities	Where Securities Are Held	Securities
		ACCOUNTS
Name of Broker, Dealer or Bank		Account Number
I CERTIFY THAT I AM FULLY FAMILIAR WITH THE CODE OF ETHICS AND
THAT, TO THE BEST OF MY KNOWLEDGE, THE INFORMATION FURNISHED
IN THIS REPORT IS TRUE AND CORRECT AS OF DECEMBER 31, ________.
Signature:______________________________
Position:_______________________________
Date:__________________________________