Preview | Code of Business Conduct and Ethics |

A Message from Lewis A. Sanders,

Chief Executive Officer of AllianceBernstein

Trust is the foundation of an investment management company, an attribute that takes years to establish, constant vigilance to maintain, and just days to destroy. Honesty, integrity, and high ethical standards must therefore be practiced on a daily basis in order to protect this most critical asset.

Enhancing our sensitivity to our fiduciary obligations, and ensuring that we meet those obligations is an imperative for all. The Internal Compliance Controls Committee, the Code of Ethics Oversight Committee, the Conflicts Officer and the Office of the Company Ombudsman provide AllianceBernstein employees with comprehensive guidance and multiple avenues in which to explore work-related issues or questions.

AllianceBernstein has long been committed to maintaining and promoting high ethical standards and business practices. We have prepared this Code of Business Conduct and Ethics (the ?Code?) in order to establish a common vision of our ethical standards and practices. The Code is intended to establish certain guiding principles for all of us and not to be an exhaustive guide to all the detailed rules and regulations governing the conduct of business in the various countries where we do business. Separately, we have prepared a series of fiduciary and business-related policies and procedures, which set forth detailed requirements to which all employees are subject. We also have prepared various Compliance Manuals, which provide in summary form, an overview of the concepts described in more detail in this Code and in our other policies and procedures.

You should take the time to familiarize yourself with the policies in this Code and use common sense in applying them to your daily work environment and circumstances. Your own personal integrity and good judgment are the best guides to ethical and responsible conduct. If you have questions, you should discuss them with your supervisor, the General Counsel, the Chief Compliance Officer or a representative of the Legal and Compliance Department or Human Resources. If the normal channels for reporting are not appropriate, or if you feel uncomfortable utilizing them, issues may be brought to the attention of the Company Ombudsman, who is an independent, informal and confidential resource for concerns about AllianceBernstein business matters that may implicate issues of ethics or questionable practices.

Our continued success depends on each of us maintaining high ethical standards and business practices. I count on each of you to apply good ethics and sound judgment in your daily responsibilities in order to help ensure that success.

Lewis A. Sanders

AllianceBernstein L.P

CODE OF BUSINESS CONDUCT AND ETHICS


1.	Introduction	1
2.	The AllianceBernstein Fiduciary Culture	2
3.	Compliance with Laws, Rules and Regulations	2
4.	Conflicts of Interest Unlawful Actions	3
5.	Insider Trading	4
6.	Personal Trading: Summary of Restrictions	4
7.	Outside Directorships and Other Outside Activities and Interests	6
	(a) Board Member or Trustee	6
	(b) Other Affiliations	7
	(c) Outside Financial or Business Interests	7
8.	Gifts, Entertainment and Inducements	8
9.	Dealings with Government Personnel	9
10.	Political Contributions by or on behalf of AllianceBernstein	9
11.	?Ethical Wall? Policy	10
12.	Corporate Opportunities and Resources	10
13.	Antitrust and Fair Dealing	11
14.	Recordkeeping and Retention	11
15.	Improper Influence on Conduct of Audits	11
16.	Accuracy of Disclosure	12
17.	Confidentiality	12
18.	Protection and Proper Use of AllianceBernstein Assets	13
19.	Policy on Intellectual Property	13
	(a) Overview	13
	(b) Employee Responsibilities	14
	(c) Company Policies and Practices	14
20.	Compliance Practices and Policies of Group Subsidiaries	15
21.	Exceptions from the Code	15

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22.	Regulatory Inquiries and Litigation	16
	(a) Requests for Information	16
	(b) Types of Inquiries	16
	(c) Responding to Information Requests	16
	(d) Use of Outside Counsel	16
	(e) Regulatory Investigation	17
	(f) Litigation	17
23.	Compliance and Reporting of Misconduct ?Whistleblower? Protection	17
24.	Company Ombudsman	17
25.	Sanctions	18
26.	Annual Certifications	18

APPENDIX A

PERSONAL TRADING POLICIES AND PROCEDURES


1.	Overview	A-1
	(a) Introduction	A-1
	(b) Definitions	A-1
2.	Requirements and Restrictions ? All Employees	A-5
	(a) General Standards	A-5
	(b) Disclosure of Personal Accounts	A-6
	(c) Designated Brokerage Accounts	A-6
	(d) Pre-Clearance Requirement	A-7
	(e) Limitation on the Number of Trades	A-8
	(f) Short-Term Trading	A-9
	(g) Short Sales	A-10
	(h) Trading in AllianceBernstein Units and Closed-End Mutual Funds	A-10
	(i) Securities Being Considered for Purchase or Sale	A-10
	(j) Restricted List	A-10
	(k) Dissemination of Research Information	A-12
	(l) Initial Public Offerings	A-14
	(m) Limited OfferingsPrivate Placements	A-14

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3.	Additional Restrictions ? Growth, Blend & Fixed Income Portfolio Managers	A-14
	(a) Blackout Periods (if exception applies)	A-15
	(b) Actions During Blackout Periods	A-15
	(c) Transactions Contrary to Client Positions	A-15
4.	Additional Restrictions ? Bernstein Value Portfolio Management Groups	A-15
	(a) Value SPMs and Investment Policy Groups	A-16
	(b) Bernstein Value SBU	A-16
	(c) Discretionary Accounts	A-16
5.	Additional Restrictions ? Research Analysts	A-16
	(a) Blackout Periods (if exception applies)	A-16
	(b) Actions During Blackout Periods	A-17
	(c) Actions Contrary to Ratings	A-17
6.	Reporting Requirements	A-17
	(a) Duplicate Confirmations and Account Statements	A-17
	(b) Initial Holdings Reports by Employees	A-17
	(c) Quarterly Reports by Employees	A-18
	(d) Annual Holdings Reports by Employees	A-18
	(e) Report and Certification to the Board of Directors of Fund Clients

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