Code of Ethics



Gabelli Funds, LLC

GAMCO Investors, Inc.

Gabelli & Company, Inc.

Gabelli Advisers, Inc.

Gabelli Fixed Income LLC



Each Registered Investment Company or

     series thereof (each of which is

     considered to be a Company for this

     purpose) for which any of the

     Companies listed above presently or

     hereafter provides investment

     advisory or principal underwriting

     services, other than a money market

     fund or a fund that does not invest

     in Securities.



                                  Introduction



         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. Some of the rules are imposed

specifically by law. For example, the laws that govern investment advisers

specifically prohibit fraudulent activity, making statements that are not true

or that are misleading or omit something that is significant in the context

and engaging in manipulative practices. These are general words, of course,

and over the years the courts, the regulators and investment advisers have

interpreted these words and established codes of conduct for their employees

and others who have access to their investment decisions and trading

activities. Indeed, the rules obligate investment advisers to adopt written

rules that are reasonably designed to prevent the illegal activities described

above and must follow procedures that will enable them to prevent such

activities.



     This Code is intended to assist the companies in fulfilling their

obligations under the law. The first part lays out who the Code applies to,

the second part deals with personal investment activities, the third part

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.



I.       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) whose job regularly

                  involves him in the investment process. This includes the

                  formulation and making of investment recommendations and

                  decisions, the purchase and sale of securities for clients

                  and the utilization of information about investment

                  recommendations, decisions and trades. Due to the manner in

                  which the Companies and the Affiliates conduct their

                  business, every employee should assume that he is subject to

                  the Code unless the Compliance Officer specifies otherwise.



            3.    With respect to all of the Companies, Affiliates and Fund

                  Clients except Gabelli & Company, Inc., any natural person

                  who controls any of the Companies, Affiliates or Fund

                  Clients and who obtains information regarding the Companies'

                  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, for example, are excluded from coverage under

                  this item.



            4.    With respect to all of the Companies and Fund Clients except

                  Gabelli & Company, Inc., 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 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 Persons 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 spouse and minor children

                  living with the Access Person. A substantial proportionate

                  economic interest will generally be 10% of the equity in the

                  account in the case of any single 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

                  II(I)7, bona fide market making accounts of Gabelli &

                  Company, Inc. are not Access Person Accounts.



                  As a further exception, subject to the provisions of Article

                  II(I)7, bona fide error accounts of the Companies and the

                  Affiliates are not Access Person Accounts.



            3.    Associate Portfolio Managers. Access Persons who are engaged

                  in securities research and analysis for designated Clients

                  or are responsible for investment recommendations for

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