UBS Global Asset Management—Americas: Code of Ethics
Table of contents
1.	Introduction			1
2.	Types of Accounts
	2.1	Covered Accounts		3
	2.2	Joint Accounts		3
	2.3	Investment Clubs		3
3.	Establishing Covered Accounts
	3.1	Use of Authorized Brokers		3
	3.2	Discretionary Accounts		4
	3.3	Reporting		5
	3.4	Copying Compliance Department on Statements and Confirms		5
4.	Trading Restrictions
	4.1	Preclearance Requirements		5
	4.2	Frequency		7
	4.3	Holding Period		7
	4.4	Lockout Period		8
	4.5	Prohibited Transactions		8
	4.6	Initial Public Offerings		9
	4.7	Investment in Partnerships and other Private Placements		9
	4.8	Options		9
	4.9	Futures		10
5.	Reporting and Certification Requirements
	5.1.	Initial Holdings Report and Certification		10
	5.2	Quarterly Transactions Report for Covered Persons and Interested Directors		10
	5.3	Quarterly Transactions Report for Independent Directors		11
	5.4	Annual Certification for Covered Persons, Interested Directors
		and Independent Directors		11
6.	Administration and Enforcement
	6.1	Review of Personal Trading Information		11
	6.2	Annual Reports to the Mutual Fund Boards of Directors and
		UBS Global CEOs		11
	6.3	Sanctions and Remedies		12
List of Funds			Appendix A
Trade Request Form			Appendix B
Outside Account Request Form			Appendix C
Private Placement Request Form			Appendix D
Investment Club Pre-Approval Form			Appendix E
Discretionary Account Attestation			Appendix F
Consultants and Temporary Employee Reporting Requirements			Appendix G
Transaction Requirement Matrix			Appendix H
List of Authorized Broker-Dealers			Appendix I
Employee Outside Affiliation / Outside Business Form				Appendix J
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UBS Global Asset Management—Americas: Code of Ethics
UBS GLOBAL ASSET MANAGEMENT-AMERICAS
Code of Ethics
1.	Introduction
	UBS Global Asset Management (“UBS Global AM”)1 has many important assets. Perhaps the
	most valuable is its established and unquestioned reputation for integrity. Preserving this integrity
	demands the continuing alertness of every employee. Each employee must avoid any activity or
	relationship that may reflect unfavorably on UBS Global AM as a result of a possible conflict of
	interest, the appearance of such a conflict, the improper use of confidential information or the
	appearance of any impropriety. Although no written code can take the place of personal integrity,
	the following, in addition to common sense and sound judgment, should serve as a guide to the
	minimum standards of proper conduct. This Code of Ethics (“Code”) is designed to ensure, among
	other things, that all employees conduct their personal securities transactions in a manner where
	clients’ interests are placed first and foremost and are consistent with the law. Any conduct that
	violates this Code is unacceptable and always constitutes an activity beyond the scope of the
	employee's legitimate employment.
	The Code is designed to detect and prevent conflicts of interests between its employees, officers
	and directors and its Advisory Clients2 that may arise due to personal investing activities. UBS
	Global AM also has established separate procedures designed to detect and prevent insider
	trading (“Insider Trading Policy and Procedures”), which should be read together with this Code.
	Personal investing activities of “Covered Persons” (defined below) can create conflicts of interests
	that may compromise our fiduciary duty to Advisory Clients. As a result, Covered Persons must
	avoid any transaction that involves, or even appears to involve, a conflict of interests, diversion of
	an Advisory Client investment opportunity, or other impropriety with respect to dealing with an
	Advisory Client or acting on behalf of an Advisory Client.
	As fiduciaries, Covered Persons must at all times comply with the following principles:
	a.	Client Interests Come First. Covered Persons must scrupulously avoid serving their own
		personal interests ahead of the interests of Advisory Clients. If a Covered Person puts his/her
		own personal interests ahead of an Advisory Client’s, or violates the law in any way, he/she
		will be subject to disciplinary action, even if he/she is in technical compliance with the Code.
	b.	Avoid Taking Advantage. Covered Persons may not make personal investment decisions
		based on their knowledge of Advisory Client holdings or transactions. The most common
		example of this is "front running," or knowingly engaging in a personal transaction ahead of an
		Advisory Client with the expectation that the Advisory Client's transaction will cause a
		favorable move in the market. This prohibition applies whether a Covered Person's transaction
		is in the same direction as the transaction placed on behalf of an Advisory Client (for example,
		two purchases) or the opposite direction (a purchase and sale).
		If you are uncertain whether a real or apparent conflict exists in any particular situation or if you
		become aware of a violation, you should consult with the Compliance Department immediately.
		This Code applies to each of the UBS Global Advisors and the registered investment
		companies for which a UBS Global Advisor serves as investment manager, investment advisor
1 When used in this Code “UBS Global Asset Management” and “UBS Global AM” includes UBS Global Asset
Management (US) Inc. and UBS Global Asset Management (Americas) Inc. We refer to these entities collectively as UBS
Global Advisors.
2 Advisory Client means any client (including but not limited to mutual funds, closed-end funds and separate accounts) for
which UBS Global serves as an investment adviser or sub-adviser, to whom it renders investment advice, or for whom it
makes investment decisions.
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UBS Global Asset Management—Americas: Code of Ethics
	and/or principal underwriter (“Funds”) that are listed on Appendix A (which may be amended
	from time to time). The Code sets forth detailed policies and procedures that Covered Persons
	of UBS Global Advisors must follow in regard to their personal investing activities. All Covered
	Persons are required to comply with the Code as a condition of continued employment.
	Who is subject to the Code?
	Covered Persons. For purposes of this Code, Covered Person is defined as:
	•	Each employee, officer and director of a UBS Global Advisor, their spouses and members
		of their immediate families;3
	•	An employee, officer or director of any UBS AG affiliate who is domiciled on the premises
		of UBS Global AM for a period of 30 days or more; and
	•	Consultants and other temporary employees hired for a period of 30 days or more whose
		duties include access to UBS Global AM's technology and systems, and/or trading
		information in any form, unless they obtain a written exemption from the Compliance
		Department. Consultants and other temporary employees who are employed for less than
		a 30-day period, but who have access to UBS Global AM's trading information, will be
		subject to the reporting requirements described in Appendix G.
	Interested Directors of a Fund. Directors of any Fund that is an Advisory Client (current
	Funds are listed on Appendix A) who are not Covered Persons but who are affiliated with
	another subsidiary of UBS AG (“Interested Directors”) are subject to the following sections of
	the Code, except if covered by “Independent Directors of a Fund” below:
	Section 5.1		Initial Holdings Report and Certification
	Section 5.2		Quarterly Transactions Report for Covered Persons and Interested Directors
	Section 5.4		Annual Certification for Covered Persons, Interested Directors and Independent
			Directors
	Independent Directors of a Fund. Directors of a Fund who are not affiliated with a UBS
	Global Advisor (“Independent Directors”)as well as Interested Directors who do not have
	access to non-public information regarding the Portfolio Holdings of any fund advised by a
	UBS Global AM Advisor or who are not involved in making securities recommendations or
	have access to such recommendations that are not public are subject only to the following
	sections of the Code:
	Section 5.3		Quarterly Transactions Report for Independent Directors
	Section 5.4		Annual Certification for Covered Persons, Interested Directors and Independent
			Directors
2.	Types of Accounts
	2.1 Covered Accounts
	"Covered Account" includes any securities account (held at a broker-dealer, transfer agent,
	investment advisory firm, bank, or other financial services firm) in which a Covered Person has a
	beneficial interest or over which a Covered Person has investment discretion or other control or
	influence.4 Restrictions placed on transactions executed within a Covered Account also pertain to
3 Immediate family includes your spouse, children and/or stepchildren and other relatives who live with you if you
contribute to their financial support.
4 Beneficial interest in an account includes any direct or indirect financial interest in an account.
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UBS Global Asset Management—Americas: Code of Ethics
	investments held outside of an account over which a Covered Person has physical control, such
	as a stock certificate.5
	2.2 Joint Accounts
	Covered Persons are prohibited from entering into a joint account with any Advisory Client.
	2.3 Investment Clubs
	A Covered Person may participate in an investment club only if he/she obtains the prior written
	approval of the Compliance Department. Requests for approval must be submitted on the
	Investment Club Pre-Approval Form (See Appendix E). Approval will only be granted if the
	Covered Person can ensure that the investment club will comply with all of the provisions of this
	Code.
	If the Covered Person can demonstrate that he/she does not participate in investment decision-
	making, then a waiver of the preclearance requirement may be granted. An exemption from the
	preclearance requirement will not be granted if the Covered Person has influence or control over
	the club's investment decisions or if Covered Persons make up 50% or more of the club's
	membership.
	The Compliance Department will periodically review investment club trading for abuses and
	conflicts and reserves the right to cancel approval of participation or to subject all of the club's
	trades to preclearance and other requirements.6 Investment club accounts may not be used to
	undermine these procedures.
3.	Establishing Covered Accounts
	3.1 Use of Authorized Brokers
	Generally, Covered Persons may maintain a Covered Account only with authorized broker-dealers.
	The current list of Authorized Brokers, which is subject to change from time to time, is included in
	Appendix I. Any exceptions to this rule must be approved in writing by the Compliance
	Department (See Appendix C for the appropriate form). However, Covered Persons hired on or
	before December 31, 2001 and who maintain a Covered Account at an unauthorized broker-dealer
	that was opened on or before June 30, 2002 may continue to maintain the account with the
	unauthorized broker. Covered Persons must obtain prior written approval from the Compliance
	Department to open a futures account.
	Exceptions. The following Covered Accounts may be maintained away from an Authorized Broker
	without obtaining prior approval. Note: Covered Persons are required to report all Covered
	Accounts pursuant to the Reporting and Certification Requirements of Section 5 below.
	•	Mutual Fund Only Accounts. Any account that permits a Covered Person only to buy and sell
		shares of open-end mutual funds for which UBS Global AM does not serve as investment
		adviser or subadviser and cannot be used to trade any other types of securities like stocks or
		closed-end funds.
	•	401(k) Plans. Any account with a 401(k) retirement plan that a Covered Person established
		with a previous employer, provided that the investments in the plan are limited to pooled
		investment options (e.g., open-end mutual funds). A 401(k) plan account that permits you to
		trade individual securities or invest in pools consisting of securities of a single issuer must be
5 Covered Accounts also include accounts for which a Covered Person has power of attorney, serves as executor, trustee
or custodian, and corporate or investment club accounts.
6 Transactions effected through an investment club are subject to the reporting requirements outlined in Section 5.
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UBS Global Asset Management—Americas: Code of Ethics
	approved by the Compliance Department. The UBS SIP plan or any successor UBS 401(k)
	plan is not an excepted account within this definition.
•	Investments in the Physical Control of a Covered Person. Covered Persons may maintain
	physical possession of an investment (for example, a stock certificate).
•	You must obtain approval to maintain the following Covered Accounts:
•	Investments Directly with Issuers (or their Transfer Agents). Covered Persons may participate
	in direct investment plans that allow the purchase of an issuer's securities without the
	intermediation of a broker-dealer provided that timing of such purchases is determined by the
	plan (e.g., dividend reinvestment plans ("DRIPS”)). Such investments must be approved prior
	to the initial purchase of the issuer’s securities. Once approved, you are not required to
	preclear purchases or sales of shares in the plan, although transactions and holdings must be
	reported. However, if you withdraw the securities and hold a certificate or transfer them to a
	brokerage account, subsequent sales are subject to preclearance as well as the 30-day
	holding period.
3.2 Discretionary Accounts.
Covered Persons must obtain Compliance Department approval in order to open discretionary
securities accounts. A discretionary account is one where all investment decisions are made by a
third-party who is unrelated to the Covered Person or is not otherwise a Covered Person
("Discretionary Account"). Although Discretionary Accounts are exempt from the provisions of
Section 4 (Trading Restrictions) of this Code, they are still Covered Accounts and must comply
with all other provisions of this Code, including this Section and Section 5 (Reporting and
Certification Requirements). In order to obtain necessary approval to open a Discretionary
Account, Covered Persons must provide the following to the Compliance Department:
•	A copy of the signed Investment Advisory Agreement and/or any other relevant documents
	creating the Account that demonstrate that the fiduciary has full investment discretion; and
•	A signed attestation (See Appendix F) that, if the Covered Person discusses any specific
	strategies, industries or securities with the independent fiduciary, the Covered Person will pre-
	clear any related trades that result from the discussion. (Note that if no such discussions take
	place in advance of transactions, preclearance is not required).
The Compliance Department will review Discretionary Account trading for abuses and conflicts and
reserves the right to cancel approval of a Discretionary Account and to subject all of the account’s
trades to preclearance and other requirements of this Code. Discretionary Accounts may not be
used to undermine these procedures.
3.3 Reporting
Covered Persons must disclose all reportable accounts and investments within 10 calendar days
after commencing employment or association with UBS Global Asset Management. Covered
Persons will be required to review and update their holdings, securities account transactions and
confirm they have read and understand the Code of Ethics quarterly and annually thereafter.
Initial holdings information must be current as of a date not more than 45 days prior to your hire
date. Please note that you cannot conduct personal trades until you have received a log in and
password from the iTrade System.
Covered Persons are responsible for notifying the Compliance Department at the time any
Covered Account is opened and immediately upon making or being notified of a change in
ownership or account number. The notification should be submitted in writing to the Compliance
Department and include the broker name, name of the account, the date the account was opened,
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UBS Global Asset Management—Americas: Code of Ethics
	account number (if new account) or, if the account number changed, the old number and the new
	number and the effective date of the change.
	3.4 Copying the Compliance Department on Statements and Confirms
	The Compliance Department receives automatic feeds of trade confirmations and account
	statements from Authorized Brokers. However, for accounts maintained away from Authorized
	Brokers, Covered Persons must arrange for the Compliance Department to receive directly from
	the executing broker-dealer, bank, or other third-party institution duplicate copies of trade
	confirmations for each transaction and periodic account statements for each Covered Account.
	Covered Persons are not required to provide duplicate confirms and statements for Mutual Fund
	Only Accounts.
	If You Cannot Arrange for Duplicate Confirmations or Statements. You may wish to engage in a
	transaction for which no confirmation can be delivered to the Compliance Department (e.g., a
	transaction in a privately placed security or a transaction in individual stocks held in a 401(k) plan).
	These types of transactions require the prior written approval of the Compliance Department and
	will involve additional reporting requirements.
4.	Trading Restrictions
	Security means any interest or instrument commonly known as a security, whether in the nature of
	debt or equity, including but not limited to any option, futures contract, shares of registered open-
	end investment companies (mutual funds) advised or subadvised by UBS Global AM, warrant,
	note, stock, treasury stock, bond, debenture, evidence of indebtedness, certificate of interest or
	any participation in or right to subscribe to or purchase any such interest or instrument. For
	purposes of these trading restrictions and the reporting requirements described in Section 5, the
	term security does not include direct obligations of the U.S. government , bankers' acceptances,
	bank certificates of deposit, commercial paper, high-quality short-term debt instruments (including
	repurchase agreements), or shares of registered open-end investment companies (mutual funds)
	for which UBS Global AM does not serve as investment adviser or subadviser. (See Appendix (A)
	for a list of funds advised or subadvised by UBS Global AM).
	4.1 Preclearance Requirements
	Covered Persons must obtain prior written approval before purchasing, selling or transferring any
	security, or exercising any option (except as noted below).
	•	The Process. The preclearance process is done electronically through iTrade or in the event
		the system is down, involves the following three steps:
	•	Complete the Form. Covered Persons must complete a Trade Request Form (See Appendix
		B) and submit it to the Compliance Department before making a purchase, sale or transfer of a
		security, or exercising an option.
	•	Wait for Approval. The Compliance Department will review the form and, as soon as
		practicable, determine whether to authorize the transaction.
	•	Execute Before the Approval Expires. A preclearance approval for a transaction is only
		effective on the day you receive approval (regardless of time).
	•	If your trade is not fully executed by the end of the day, you must obtain a new preclearance
		approval before your order (or the unfilled portion of your order) can be executed. Accordingly,
		limit orders and “good ‘til cancelled” instructions must be withdrawn by the end of the day,
		unless a new approval is obtained.
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UBS Global Asset Management—Americas: Code of Ethics
Exceptions. Covered Persons do not need to preclear the following types of transactions.
Please see the “Transaction Requirement Matrix” in Appendix H for a summary of the
preclearance requirements.
-	Open-End Investment Company Shares (Mutual Funds), including funds offered within a
	529 College Savings Plan. Purchases and sales of mutual funds do not require
	preclearance and are not subject to the reporting requirements of Section 5. However,
	certain holding period requirements apply to open-end registered investment companies
	advised or subadvised by UBS Global (see Section 4.3 herein).
-	Unit Investment Trusts (UITs). Purchases and sales of unit investment trusts do not
	require preclearance.
-	Exchange Traded Funds (ETFs). Purchases and sales of Exchange Traded Funds that
	are based on a broad-based securities index do not require preclearance. Transactions in
	all other ETFs, including industry or sector-based funds, must be precleared.
-	Certain Corporate Actions. Acquisitions of securities through stock dividends, dividend
	reinvestments, stock splits, reverse stock splits, mergers, consolidations, spin-offs, or other
	similar corporate reorganizations or distributions generally applicable to all holders of the
	same class of securities do not require preclearance.
-	Rights. Acquisition of securities through the exercise of rights issued by an issuer pro rata
	to all holders of a class of its securities, to the extent the rights were acquired through the
	rights offering and not through the secondary market.
-	UBS Savings and Investment Plan and Third Party 401(k) Plans. Any transaction in these
	plans is generally exempt from the preclearance requirements, unless the plan permits a
	Covered Person to trade individual securities (e.g., shares of stock), in which case such
	transactions are subject to preclearance.
-	UBS AG Securities. Transactions by Covered Persons in UBS securities7 generally are
	exempt from the preclearance requirements. Covered Persons who are deemed company
	insiders are not eligible for this exception and must preclear all purchases and sales of
	UBS securities. In addition, any Covered Person who possesses material non-public
	information regarding UBS AG is prohibited from engaging in transactions in UBS
	securities.
-	Futures and Options on Currencies, Commodities and Broad Based Indices. A Covered
	Person is not required to preclear futures and options on currencies or on a broad-based
	securities index.8
-	Transactions in Discretionary Accounts. Except under certain circumstances, a Covered
	Person is not required to preclear transactions in a Discretionary Account.
-	NOTE: All transactions, including those exempt from the preclearance requirement (other
	than mutual funds), are subject to the reporting requirements (See Section 5).
7 Note that Independent Directors of a mutual fund managed or advised by a UBS Global Advisor are prohibited from
purchasing or otherwise acquiring or holding any security issued by UBS.
8 The term “Broad-based Securities Index” is not easily defined. Generally, a Broad-based Securities Index covers a wide
range of companies and industries. Only futures and options on a Broad-based Securities Index are exempt from the pre-
clearance requirement. The Compliance Department will maintain a list of approved Broad-based Securities Indices and,
if you are unsure as to whether a particular index qualifies under the Code, you should consult the Compliance
Department.
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UBS Global Asset Management—Americas: Code of Ethics
4.2 Frequency
In order to ensure that Covered Persons are not distracted from servicing Advisory Clients,
Covered Persons should not engage in more than 20 transactions per month. (Note: This does
not include repetitive transactions such as rolling futures contracts.)
4.3 Holding Period
If a Covered Person is required to preclear a transaction in a security, he/she also must hold the
security for at least 30 days.
As a result, Covered Persons may not:
•	buy a security or Related Investment within 30 days after selling that security or Related
	Investment; or
•	sell a security or Related Investment within 30 days after purchasing that security or Related
	Investment.
•	Please refer to the Transaction Requirement Matrix in Appendix H.
Related Investments are investments whose value is based on or derived from the value of
another security, including convertible securities and derivative securities such as options, futures
and warrants.
Exceptions.
a.	UITs and ETFs, although not subject to preclearance, must be held for at least 30 days.
b.	Shares of registered open-end investment companies advised or sub-advised by UBS Global
	must be held for at least 30 days.
c.	If a security has experienced a loss equal to at least 10% of the purchase price, the Covered
	Person may sell the security in less than 30 days, with prior approval from the Compliance
	Department.
d.	If you receive restricted stock as part of your compensation, you are not required to hold it for
	30 days after it vests.
4.4 Lockout Period
Investment Personnel9 are prohibited from buying, selling or transferring any security if they know
that the security, or Related Investment, was purchased or sold on behalf of an Advisory Client five
days or less prior thereto or will be purchased or sold on behalf of an Advisory Client within five
days therefrom. Personal trades in securities that are effected in close proximity to the addition or
deletion of such security to or from a model will be closely scrutinized. Pre-clearance through i-
trade should not be equated with pre-clearance of conflicts.
(i)	Covered Persons are prohibited from executing a securities transaction on a day during which
	any client or fund has a pending or executed “buy” or “sell” in the same security.
(ii)	Trade Reversals. Even if a personal transaction is pre-cleared, such personal transaction is
	subject to being reversed after-the-fact. Furthermore, as indicated below, the Compliance
	Department may require any violator to disgorge any profits or absorb any losses associated
9 “Investment Personnel” include Covered Persons who are portfolio managers, research analysts, traders and any other
person who, in connection with his or her regular functions or duties, makes or participates in making recommendations to
clients regarding the purchase or sale of securities or has functions or duties relating to the making of recommendations
regarding purchases and/or sales.
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UBS Global Asset Management—Americas: Code of Ethics
	with the relevant security. In short, Covered Persons assume the risk (financial or otherwise)
	associated with any trade reversal.
(iii) Broad-based Securities Indices. A Covered Person’s knowledge that a security will be
	purchased or sold by an account managed with a quantitative model that tracks the
	performance of a Broad-Based Securities Index, such as the S&P 500 or the Russell 1000,
	does not trigger the lockout period. Futures and options transactions on Broad-based
	Securities Indices or currencies also are exempt from the lockout period.
(iv) The Chief Compliance Officer may grant individual exceptions at his/her discretion.
4.5 Prohibited Transactions
UBS Global views the following transactions as especially likely to create conflicts with Advisory
Client interests. Covered Persons are therefore prohibited from engaging in the following
transactions:
a.	Short Sales. Covered Persons are prohibited from entering into a net short position with
	respect to any security.
b.	Futures. Purchase or sale of futures that are not traded on an exchange, as well as options on
	any type of futures (exchange-traded or not) are prohibited. This prohibition does not apply to
	currency forwards (futures or otherwise).
c.	Securities Issued by Suppliers & Vendors. Covered Persons who have information about or
	are directly involved in negotiating a contract with a supplier or vendor of UBS Global AM may
	not purchase securities issued by that supplier or vendor.
4.6 Initial Public Offerings
Covered Persons are prohibited from acquiring securities in an initial public offering (other than a
new offering of a registered open-end investment company).
In the event that a Covered Person holds securities in a company that has announced that it will
engage in an IPO, he or she must immediately notify the Compliance Department.
4.7 Investment in Partnerships and Other Private Placements
Covered Persons are permitted to acquire interests in general partnerships and limited
partnerships, and to purchase privately placed securities, provided they obtain prior approval from
the Compliance Department. Once approved, additional capital investments (other than capital
calls related to the initial approved investment) require a new approval. Covered Persons
requesting permission must complete the Private Placement Request Form (See Appendix D).
4.8 Options
a.	Call Options: A Covered Person may purchase a call option on an individual security or ETF
	only if the call option has a period to expiration of at least 30 days from the date of purchase
	and the Covered Person either (1) holds the option for at least 30 days prior to sale or (2)
	holds the option and, if exercised, the underlying security, for a total period of 30 days.
	(Similarly, if you choose to exercise the option, you may count the period during which you
	held the call option toward the 30-day holding period for the underlying security or ETF.)
	A Covered Person may sell ("write") a call option on an individual security or ETF only if he/she
	has held the underlying security (in the corresponding quantity) for at least 30 days (Covered
	Call).
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UBS Global Asset Management—Americas: Code of Ethics
b.	Put Options: A Covered Person may purchase a put option on an individual security or ETF
	only if the put option has a period to expiration of at least 30 days from the date of purchase
	and the Covered Person holds the put option for at least 30 days. If a Covered Person
	purchases a put on a security he/she already owns (Put Hedge), he/she may include the time
	he/she held the underlying security towards the 30-day holding period for the put.
	A Covered Person may not sell ("write") a put on an individual security or ETF.
c.	Options on Broad-Based Indices: Covered Persons may purchase or sell an option on a
	Broad-based Securities Index ("Index Option") only if the option has a period to expiration of at
	least 30 days from the date of purchase or sale. A Covered Person may buy or sell an Index
	Option with a period to expiration of less than 30 days from the date of purchase or sale to
	close out an open position only if he/she has held the position being closed out for at least 30
	days or another exception under Section 4.3 (Holding Period) applies.
Note: Covered Persons must obtain preclearance approval to exercise an option on an individual
	security or ETF as well as to purchase or sell such an option.
4.9 Futures
A Covered Person may purchase and sell exchange-traded futures and currency forwards.
Purchases and sales of futures contracts on an individual security are subject to the lockout period
(See Section 4.4 above). Purchases and sales of all futures contracts are subject to the holding
period requirement (See Section 4.3 above).
Note: Covered Persons must obtain preclearance approval to purchase or sell futures contracts on
an individual security.
5. Reporting and Certification Requirements
5.1 Initial Holdings Report and Certification
Within 10 days after a Covered Person commences employment, he/she must certify that he/she
has read and understands the Code, that he/she will comply with its requirements, and that he/she
has disclosed or reported all personal investments and accounts required to be disclosed or
reported. Interested Directors other than Covered Persons are also required to make this report
within 10 days of becoming an Interested Director of a Fund.
Exceptions: Covered Persons are not required to report holdings in:
•	U.S. Registered Open-End Mutual Funds that are not advised or sub-advised by UBS Global
	(see Appendix A for a list of funds advised or subadvised by UBS Global).
•	U.S. Government Securities10
•	Money Market Instruments11
•	Accounts over which a Covered Person has no direct or indirect influence or control
10 Covered Persons are required to report transactions in Fannie Maes and Freddie Macs.
11 Money Market Instruments include bankers’ acceptances, bank certificates of deposit, commercial paper, and high-
quality short-term debt instruments, including repurchase agreements.
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UBS Global Asset Management—Americas: Code of Ethics
	However, Covered Persons are required to include in initial and annual holdings reports the name
	of any broker-dealer or bank with which the Covered Person has an account in which any
	securities are held for his/her direct or indirect benefit.
	5.2 Quarterly Transactions Report for Covered Persons and Interested Directors
	Within 30 days of the end of each calendar quarter, Covered Persons must file a report of all
	securities and U.S.-registered open-end mutual fund transactions for which UBS Global serves as
	adviser or subadviser on a Quarterly Transactions Report unless a duplicate confirmation or
	similar document was sent to the Compliance Department contemporaneously with the
	transaction. In addition, Covered Persons are required to report any account opened during the
	quarter in which securities were held during the quarter (this includes accounts that hold those
	securities described above in Section 5.1).
	5.3 Quarterly Transactions Report for Independent Directors
	Directors of the Funds who are not affiliated with a UBS Global Advisor (“Independent Directors”)
	must file a Quarterly Transactions Report with the Compliance Department only if the Independent
	Director knew, or in the ordinary course of fulfilling his/her official duties as a director of a Fund
	should have known, that during the 15 days immediately preceding or following the date of a
	securities transaction in the Independent Director’s Covered Accounts that:
	•	the security was purchased or sold by a Fund; or
	•	a purchase or sale of the security was considered for a Fund.
	Independent Directors must file these reports within ten days of the end of the calendar quarter in
	which the trade occurred.
	5.4 Annual Certification for Covered Persons, Interested Directors and Independent Directors
	Annually, Covered Persons, Interested Directors and Independent Directors must certify that they
	have read and understand the Code, that they have complied with its requirements during the
	preceding year, and that they have disclosed or reported all personal transactions/holdings
	required to be disclosed or reported.
6.	Administration and Enforcement
	6.1 Review of Personal Trading Information
	All information regarding a Covered Person’s personal investment transactions, including the
	reports required by Section 5, will be reviewed by the Compliance Department, and all violations
	will be reported to the Chief Compliance Officer. All such information may also be available for
	inspection by the Boards of Directors of the Funds, the Chief Executive Officer and Legal Counsel
	of UBS Global AM, any party to which any investigation is referred by any of the foregoing, a
	Covered Person's supervisor (where necessary), the Securities and Exchange Commission, any
	self-regulatory organization of which UBS Global is a member, and any state securities
	commission.
	6.2 Annual Reports to Mutual Fund Boards of Directors and UBS Global CEOs
	The Compliance Department will review the Code at least annually in light of legal and business
	developments and experience in implementing the Code. The Compliance Department will
		12

UBS Global Asset Management—Americas: Code of Ethics
prepare an annual report to the Boards of Directors of the Funds and the CEO of UBS Global AM
that:
•	describes issues that arose during the previous year under the Code, including, but not limited
	to, information about material Code violations and sanctions imposed in response to those
	material violations;
•	recommends changes in existing restrictions or procedures based on the experience
	implementing the Code, evolving industry practices, or developments in applicable laws or
	regulations; and
•	certifies to the Boards that procedures have been adopted that are designed to prevent Access
	Persons12 from violating the Code.
6.3 Sanctions and Remedies
If the Compliance Department determines that a Covered Person or Fund Director has violated the
Code, it may, in consultation with senior management, impose sanctions and take other actions
deemed appropriate, including issuing a letter of education, suspending or limiting personal trading
activities, imposing a fine, suspending or terminating employment, and/or informing regulators if
the situation warrants.
As part of any sanction, the Compliance Department may require the violator to reverse the
trade(s) in question and forfeit any profit or absorb any loss from the trade. Senior management
will determine the appropriate disposition of any money forfeited pursuant to this section.
12 “Access Person” is generally defined under Rule 17j-1 under the Investment Company Act to include any director or
officer of a fund or its investment adviser, and any employee of a fund’s investment adviser who, in connection with his or
her regular functions or duties, participants in the selection of a fund’s portfolio securities or who has access to information
regarding a fund’s future purchases or sales of portfolio securities.
	13

UBS Global Asset Management—Americas: Code of Ethics 

List of funds 

The names listed in italics are the Trust names and the indented names are the fund names within each 

Trust. 

UBS Cashfund Inc. 

UBS Index Trust 

         UBS S&P 500 Index Fund 

UBS Investment Trust 

         UBS Tactical Allocation Fund 

         UBS U.S. Allocation Fund 

UBS Money Series 

         UBS Cash Reserves Fund 

         UBS Liquid Assets Fund 

         UBS Select Prime Institutional Fund 

         UBS Select Tax-Free Institutional Fund 

         UBS Select Treasury Institutional Fund 

         UBS Select Prime Investor Fund 

         UBS Select Tax-Free Investor Fund 

         UBS Select Treasury Investor Fund 

         UBS Select Prime Preferred Fund 

         UBS Select Tax-Free Preferred Fund 

         UBS Select Treasury Preferred Fund 

UBS Managed Municipal Trust 

         UBS RMA New York Municipal Money Fund 

         UBS RMA California Municipal Money Fund 

UBS Master Series, Inc. 

         UBS Money Market Fund 

UBS Municipal Money Market Series 

         UBS RMA New Jersey Municipal Money Fund 

UBS RMA Money Fund, Inc. 

         UBS RMA Money Market Portfolio 

         UBS RMA U.S. Government Portfolio 

         UBS Retirement Money Fund 

UBS RMA Tax-Free Fund, Inc. 

UBS Series Trust 

         Tactical Allocation Portfolio 

         U.S. Allocation Portfolio 

Master Trust 

                                                                                                                                                                                                                                                                             14 

UBS Global Asset Management—Americas: Code of Ethics
Prime Master Fund
Tax-Free Master Fund
Treasury Master Fund
The UBS Funds
UBS Absolute Return Bond Fund
UBS Dynamic Alpha Fund
UBS Emerging Markets Debt Fund
UBS Emerging Markets Equity Fund
UBS Global Allocation Fund
UBS Global Bond Fund
UBS Global Equity Fund
UBS Global Frontier Fund
UBS High Yield Fund
UBS International Equity Fund
UBS Real Estate Equity Fund
UBS U.S. Bond Fund
UBS U.S. Equity Alpha Fund
UBS U.S. Large Cap Equity Fund
UBS U.S. Large Cap Growth Fund
UBS U.S. Large Cap Value Equity Fund
UBS U.S. Mid Cap Growth Equity Fund
UBS U.S. Mid Cap Growth Fund
UBS U.S. Small Cap Equity Fund
UBS U.S. Small Cap Growth Fund
UBS Relationship Funds
UBS Absolute Return Bond Relationship Fund
UBS Absolute Return Investment Grade Bond Fund
UBS All Country World Ex US Relationship Fund
UBS Corporate Bond Relationship Fund
UBS Defensive High Yield Relationship Fund
UBS Emerging Markets Debt Relationship Fund
UBS Emerging Markets Equity Completion Relationship Fund
UBS Emerging Markets Equity Relationship Fund
UBS Enhanced Yield Relationship Fund
UBS Global Aggregate Bond Relationship Fund
UBS Global Equity Relationship Fund
UBS Global (ex-US) Bond Relationship Fund
UBS Global ex U.S. Smaller Cap Equity Relationship Fund
UBS Global Securities Relationship Fund
UBS High Yield Relationship Fund
UBS International Equity Relationship Fund
UBS Large Cap Select Equity Relationship Fund
	15

UBS Global Asset Management—Americas: Code of Ethics
UBS Opportunistic Emerging Markets Debt Relationship Fund
UBS Opportunistic High Yield Relationship Fund
UBS Opportunistic Loan Relationship Fund
UBS Short Duration Relationship Fund
UBS Short-Term Relationship Fund
UBS Small-Cap Equity Relationship Fund
UBS U.S. Bond Relationship Fund
UBS U.S. Cash Management Prime Relationship Fund
UBS U.S. Core Plus Relationship Fund
UBS U.S. Equity Alpha Fund
UBS U.S. Equity Alpha Value Relationship Fund
UBS U.S. Large-Cap Equity Relationship Fund
UBS U.S. Large-Cap Growth Fund
UBS U.S. Large Cap Growth Equity Relationship Fund
UBS U.S. Large Cap Select Growth Equity Relationship Fund
UBS U.S. Large Cap Value Equity Relationship Fund
UBS U.S. Intermediate Cap Equity Relationship Fund
UBS U.S. Securitized Mortgage Relationship Fund
UBS U.S. Smaller Cap Equity Completion Relationship Fund
UBS U.S. Small Mid Cap Core Equity Relationship Fund
UBS U.S. Small Mid Cap Growth Equity Relationship Fund
UBS U.S. Treasury Inflation Protected Securities Relationship Fund
UBS U.S. Large-Cap Value Equity Relationship Fund
UBS PACE Select Advisors Trust
UBS PACE Alternative Strategies Investments
UBS PACE Global Fixed Income Investments
UBS PACE Global Real Estate Securities Investments
UBS PACE Government Securities Fixed Income Investments
UBS PACE High Yield Investments
UBS PACE Intermediate Fixed Income Investments
UBS PACE International Emerging Markets Equity Investments
UBS PACE International Equity Investments
UBS PACE Large Co Growth Equity Investments
UBS PACE Large Co Value Equity Investments
UBS PACE Money Market Investments
UBS PACE Municipal Fixed Income Investments
UBS PACE Small/Medium Co Growth Equity Investments
UBS PACE Small/Medium Co Value Equity Investments
UBS PACE Strategic Fixed Income Investments
UBS Collective Funds
UBS ALIS Active Member Fund
UBS ALIS Retired Member Fund
	16

UBS Global Asset Management—Americas: Code of Ethics
UBS All Country World (ex.-U.S.) Equity
UBS Bond SurPlus Fund
UBS EME Fund
UBS Emerging Markets Bond
UBS Emerging Markets Completion Collective Fund
UBS Emerging Markets Equity Completion
UBS Global (Ex US and Japan) Bond
UBS Global (Ex-US) Bond
UBS Global (Ex-US) Equity
UBS Global (Ex-US) Equity (Stock Only)
UBS Global EX Small Cap Growth Fund
UBS Global (Ex-US) Small Cap Equity Comp Fund
UBS Global Aggregate Bond
UBS Global Bond Fund
UBS Global Securities Portfolio
UBS Multi-Asset Portfolio
UBS Opportunistic Emerging Markets Debt Fund
UBS Opportunistic High Yield
UBS Stable Value
UBS U.S. All-Cap Equity Fund
UBS U.S. Balanced Fund
UBS U.S. Bond Fund
UBS U.S. Cash Mgmt Prime Fund
UBS U.S. Core Plus
UBS U.S. Equity Alpha Fund
UBS U.S. High Yield Bond Fund
UBS U.S. Large-Cap Equity Fund
UBS U.S. Large Cap Equity Grow Fund
UBS U.S. Large Cap Value Equity Fund
UBS U.S. Real Estate Securities Equity Fund
UBS U.S. Securitized Mortgage Fund
UBS Small Cap Equity Fund
UBS U.S. Small Cap Equity Growth Fund
UBS U.S. Value Equity Fund
CLOSED-END FUNDS
Fort Dearborn Income Securities, Inc. (FTD)
Global High Income Dollar Fund Inc. (GHI)
Insured Municipal Income Fund Inc. (PIF)
Investment Grade Municipal Income Fund Inc. (PPM)
Managed High Yield Plus Fund Inc. (HYF)
Strategic Global Income Fund, Inc. (SGL)
FUNDS SUBADVISED BY UBS GLOBAL ASSET MANAGEMENT
	17

UBS Global Asset Management—Americas: Code of Ethics
AXA Enterprise Growth and Income Fund (Enterprise Group of Funds)
RiverSource Small Cap Growth
BB&T International Equity Fund
EQ/UBS Growth and Income Portfolio (Enterprise Accumulation Trust
Fiduciary Trust Company Fixed Income Index Portfolio
Fiduciary Trust Company GIC – Main Account
Fiduciary Trust Company GIC – Aegon fka Transamerica
Fiduciary Trust Company GIC International Core
Fiduciary Trust Company S&P 500 Index
Guardian UBS Large Cap Value Fund
Guardian UBS Small Cap Value Fund
Guardian UBS VC Large Cap Value Fund
Guardian UBS VC Small Cap Value Fund
ING UBS U.S. Allocation Portfolio
ING UBS U.S. Large –Cap Equity Fund
ING UBS U.S. Small Growth Portfolio
John Hancock Trust – Global Allocation Trust
John Hancock Trust – Large Cap Trust
John Hancock Funds II – Large Cap Fund
JP Morgan Multi-Manager Small Cap Growth Fund
Lincoln Variable Insurance Products Trust - Global Asset Allocation Fund
Principal Partners Small Cap Growth Fund II
Principal Small Cap Growth Fund, Inc.
Principal Variable Contracts Fund, Inc.
Principal Partners Large Cap Value Fund I
TA IDEX Large Cap Value Portfolio
SMA Relationship Trust – Municipal Bond Fund
SMA Relationship Trust – Taxable Fixed Income Fund
UBS Private Portfolio Trust
SMA Relationship Trust
Series M
Series T
Series A
	18

UBS Global Asset Management—Americas: Code of Ethics
Section 2.1	Report Covered Accounts to Compliance
	Consultants and temporary employees are required to disclose the name,
	account number, and firm at which he/she maintains a brokerage account at
	the time he/she is hired.
Section 3.4	Copy the Compliance Department on Trade Confirmations
	Consultants and temporary employees are only required to provide duplicate
	trade confirmations for each transaction executed during the period of
	employment.
Section 4	Trading Restrictions
	Consultants and temporary employees are required to preclear all trades and
	all transactions are subject to the holding periods, lockout period
	requirements and other restrictions outlined in this section.
Section 5	Reporting and Certification Requirements
	Consultants and temporary employees who wish to trade options are required
	to submit a list of all personal investments holdings (Initial Holdings Report) at
	the time they are hired.
Transaction Requirement Matrix
The following chart contains many of the common investment instruments, though it is not all-inclusive.
Please refer to the Code of Ethics for additional information.
		PRECLEARANCE	REPORTING/HOLDING
TRANSACTION		REQUIRED?	REQUIRED?
Mutual Funds
Mutual Funds (Open-End) not advised or		No	No
Subadvised by UBS Global
Mutual Funds (Closed-End)		Yes	Yes
Mutual Funds advised or subadvised		No	Yes
by UBS Global
Unit Investment Trusts		No	Yes
Variable & Fixed Annuities		No	No
			29

UBS Global Asset Management—Americas: Code of Ethics
Equities
UBS Stock	No	Yes
Common Stocks	Yes	Yes
ADRs	Yes	Yes
DRIPS	No	Yes
Stock Splits	No	Yes/N/A
Rights	No	Yes
Stock Dividend	No	Yes/N/A
Warrants (exercised)	Yes	Yes
Preferred Stock	Yes	Yes
IPOs	Prohibited	Prohibited
Naked Shorts against a client position	Prohibited	Prohibited
Options (Stock)
UBS (stock options)	No	Yes
Common Stocks	Yes	Yes
Exchange Traded Funds	Yes	Yes
Fixed Income
US Treasury	No	No
CDs	No	No
Money Market	No	No
GNMA	No	No
Fannie Maes	Yes	Yes
Freddie Macs	Yes	Yes
Bonds
US Government	No	No
Corporate	Yes	Yes
Convertibles (converted)	Yes	Yes
Municipal	Yes	Yes
Private Placements	Yes	Yes
Limited Partnerships	Yes	Yes
Exchange-Traded Funds
Broad based ETFs1	No	Yes
Industry or Sector Specific ETFs	Yes	Yes
All other Exchange Traded Funds	Yes	Yes
1 These are ETFs that are broadly diversified and based on a broad index.
			30