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1.    Definitions

2.    Purpose of Code

3.    Prohibited Purchase and Sales

4.    Exempt Transactions

5.    Prohibited Business Conduct

6.    Reporting of Securities Holdings and Transactions

7.    Preclearance of IPOs and Limited Offerings

8.    Reporting of Violations and Sanctions

9.    Applicability of Code to Subadvisers

10.   Enforcement of this Code

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1.   Definitions



     1.1 Trust. As used in this Code, "Trust" shall mean John Hancock Trust, a

Massachusetts business trust registered as an open-end diversified investment

company under the Investment Company Act of 1940 (the "1940 Act").



     1.2 Access Person. As used in this Code, the term "access person" shall

mean any trustee or officer of the Trust and any "advisory person" (as defined

below) of the Trust or of any investment adviser or subadviser of the Trust. If

the investment adviser's or subadviser's primary business is advising mutual

funds or other advisory





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clients, all of the investment adviser's or subadviser's directors, officers,

and general partners are presumed to be access persons of the Trust.



     1.3 Advisory Person. As used in this Code, the term "advisory person" shall

mean: (i) any trustee, director, officer, general partner or employee of (x) the

Trust, (y) any investment adviser or subadviser of the Trust, or (z) any company

in a control relationship to the Trust or to any investment adviser or

subadviser of the Trust, who, in connection with his or her regular functions or

duties, makes, participates in, or obtains information regarding, the purchase

or sale of a covered security by the Trust, or whose functions relate to the

making of any recommendations with respect to such purchases or sales including

any "Investment Person" or "Portfolio Manager" as defined below; and



(ii) any natural person in a control relationship to the Trust or any investment

adviser or subadviser of the Trust who obtains information concerning

recommendations made to the Trust with regard to the purchase or sale of a

security.



     1.4 Active Consideration. As used in this Code, a covered security will be

deemed under "active consideration" when a recommendation to purchase or sell a

covered security has been made and communicated to the person or persons

ultimately making the decision to buy or sell the security. A covered security

will also be deemed under "active consideration" whenever an advisory person

focuses on a specific security and seriously considers recommending the covered

security to the Trust.



     A covered security will be deemed under "active consideration" until the

Trust implements or rejects the recommendation or until the proper advisory

person decides not to recommend the purchase or sale of the covered security to

the Trust.



     A covered security will not be deemed under "active consideration" if the

security is being reviewed only as part of a general industrial survey or other

broad monitoring of the securities market.



     1.5 Automatic Investment Plan. As used in this Code, "Automatic Investment

Plan" shall mean a program in which regular periodic purchases (or withdrawals)

are made automatically in (or from) investment accounts in accordance with a

predetermined schedule and allocation. An Automatic Investment Plan includes a

dividend reinvestment plan.





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     1.6 Beneficial Ownership. As used in this Code, "Beneficial ownership"

shall be interpreted in the same manner as it would be under Rule 16a-1(a)(2)

under the Securities Exchange Act of 1934 ("1934 Act") 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 that the determination

of direct or indirect beneficial ownership shall apply to all securities whether

or not such securities are the kind that could subject a person to the

provisions of Section 16 of the 1934 Act and to all shares of the Trust that

serve as underlying investments.



     1.7 Chief Compliance Officer. As used in this Code, "Chief Compliance

Officer" shall mean the Chief Compliance Officer of the Trust, his or her

designee, or such other person as may be authorized to perform the functions of

a chief compliance officer.



     1.8 Control. As used in this Code, "control" shall have the same meaning as

that set forth in Section 2(a)(9) of the Investment Company Act of 1940 (the

"1940 Act").



     1.9 Covered Security. As used in this Code, "Covered Security" shall mean a

security as defined in Section 2(a)(36) of the 1940 Act, except that it shall

not include:



     (a)  direct obligations of the U.S. Government;



     (b)  bankers' acceptances, bank certificates of deposit, commercial paper

          and high quality, short term debt instruments(1), including repurchase

          agreements;



     (c)  shares of money market funds;



     (d)  shares of registered open-end investment companies (i.e., mutual

          funds) other than Reportable Funds; and



     (e)  units of a unit investment trust if the unit investment trust is

          invested exclusively in one or more open-end investment companies

          (other than Reportable Funds).



     1.10 Covered Security Held or to be Acquired by the Trust. As used in this

Code, "covered security held or to be acquired by the Trust" shall mean (i) any

covered security which, within the most recent 15 days is, or has been, held by

the Trust or is being, or has been, considered by the Trust or its investment

adviser or any of its



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(1)  A high quality, short term debt instrument means any debt instrument that

     has a maturity at issuance of less than 366 days and that is rated in one

     of the two highest rating categories by a Nationally Recognized Statistical

     Rating Organization.





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subadvisers for purchase by the Trust and (ii) any option to purchase or sell,

and any security convertible into or exchangeable for, such a covered security.



     1.11 Disinterested Trustee. As used in this Code, "disinterested trustee"

shall mean a trustee of the Trust who is not an "interested person" of the Trust

within the meaning of Section 2(a)(19) of the 1940 Act.



     1.12 Initial Public Offering. As used in this Code, "Initial Public

Offering" shall mean an offering of securities registered under the Securities

Act of 1933 ("1933 Act"), the issuer of which, immediately before the

registration, was not subject to the reporting requirements of Sections 13 or

15(d) of the 1934 Act.



     1.13 Investment Person. As used in this Code, "Investment Person" shall

mean (i) any employee of: (x) the Trust, (y) the investment adviser or

subadviser of the Trust or (z) any company in a control relationship to the

Trust or an investment adviser or subadviser of the Trust, who in connection

with his or her regular functions or duties makes, or participates in making,

recommendations regarding the purchase or sale of securities by any series of

the Trust or (ii) any natural person who controls (y) the Trust (or any series

thereof) or (z) any investment adviser or subadviser of the Trust, who obtains

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