JENNISON ASSOCIATES LLC



                                 CODE OF ETHICS,



                            POLICY ON INSIDER TRADING



                                       AND



                             PERSONAL TRADING POLICY



                             as Amended, May 8, 2003

                             -----------------------



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                                    Section I

                                    ---------



                                 CODE OF ETHICS



                                       FOR



                             JENNISON ASSOCIATES LLC



     This Code sets forth rules, regulations and standards of conduct for the

employees of Jennison Associates LLC. It bears the approval of the Corporation's

Board of Directors and applies to Jennison Associates and all subsidiaries.



     The Code incorporates The Prudential Insurance Company of America's ethics

policies as well as additional policies specific to Jennison Associates LLC.

Prudential's Code of Ethics, "Making the Right Choices," may be found as

Exhibit Q in Jennison Associates' Compliance Manual.



     The prescribed guidelines assure that the high ethical standards long

maintained by Jennison continue to be applied. The purpose of the Code is to

preclude circumstances which may lead to or give the appearance of conflicts of

interest, insider trading, or unethical business conduct. The rules prohibit

certain activities and personal financial interests as well as require

disclosure of personal investments and related business activities of all

directors, officers and employees.



     ERISA and the federal securities laws define an investment advisor as a

fiduciary who owes his clients a duty of undivided loyalty, who shall not engage

in any activity in conflict with the interests of the client. As a fiduciary,

our personal and corporate ethics must be above reproach. Actions which expose

any of us or the organization to even the appearance of impropriety must not

occur.



     The excellent name of our firm continues to be a direct reflection of the

conduct of each of us in everything we do.



     Being fully aware of and strictly adhering to the Code of Ethics is the

responsibility of each Jennison Associates employee.



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     1.   CONFIDENTIAL INFORMATION

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     Employees may become privy to confidential information (information not

generally available to the public) concerning the affairs and business

transactions of Jennison, companies researched by us for investment, our present

and prospective clients, suppliers, officers and other staff members.

Confidential information also includes trade secrets and other proprietary

information of the Corporation such as business or product plans, systems,

methods, software, manuals and client lists. Safeguarding confidential

information is essential to the conduct of our business. Caution and discretion

are required in the use of such information and in sharing it only with those

who have a legitimate need to know.



          A) Personal Use:



          Confidential information obtained or developed as a result of

     employment with the Corporation is not to be used or disclosed for the

     purpose of furthering any private interest or as a means of making any

     personal gain. Use or disclosure of such information could result in civil

     or criminal penalties against the Corporation or the individual responsible

     for disclosing such information.



     Further guidelines pertaining to confidential information are contained in

the "Policy Statement on Insider Trading" (Set forth on page 7 in the section

dedicated specifically to Insider Trading).



          B) Release of Client Information:



          All requests for information concerning a client (other than routine

     inquiries), including requests pursuant to the legal process (such as

     subpoenas or court orders) must be promptly referred to Karen E. Kohler. No

     information may be released, nor should the client involved be contacted,

     until so directed by Karen E. Kohler.



          In order to preserve the rights of our clients and to limit the firm's

     liability concerning the release of client proprietary information, care

     must be taken to:



               [ ] Limit use and discussion of information obtained on the job

          to normal business activities.



               [ ] Request and use only information which is related to our

          business needs.



               [ ] Restrict access to records to those with proper authorization

          and legitimate business needs.



               [ ] Include only pertinent and accurate data in files which are

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