Code of Ethics

As investment professionals and AIMSE members, we are committed to conducting business with the highest ethical standards. Trust and integrity are the foundations of the investment management industry, attributes that takes years to establish and just days to destroy. Promoting and sustaining a "fiduciary culture" is a business imperative. Accordingly, AIMSE members have a special obligation to:

1. In all endeavors, act with honesty, integrity and professionalism, avoiding actual or apparent conflicts of interest between personal and professional relationships. The interests of our clients always come first.
   
   
2. Commensurate with your responsibilities, ensure your firm is in full compliance with the law, all applicable rules and regulations, and company policy, in accordance with the letter and spirit of the law. It is critically important to be aware of state and local laws, particularly when dealing with public pension funds. Fully disclose any third party business relationships to current or prospective clients.
   
   
3. Promote fair dealing with all clients, fellow employees, vendors and competitors. Never malign your competition.
   
   
4. Always maintain the confidentiality of information entrusted to you by your employer, clients, prospects and their advisors.
   
   
5. Strive to be experts in the services you offer to clients, prospective clients and consultants. Always present truthful information.
   
   
6. Take ownership and responsibility for all actions.
   
   
7. Conduct client entertainment in a prudent and ethical manner.
   
   
8. Sustain AIMSE's role as the respected leader within the investment management industry worldwide.
   
   

April 5, 2005