EXHIBIT 99p(ii)

                     HARTFORD INVESTMENT MANAGEMENT COMPANY
 HARTFORD INVESTMENT SERVICES, INC. (EACH AN "ADVISER" AND TOGETHER
                                 THE "ADVISERS")


                                 CODE OF ETHICS


SECTION 1 - INTRODUCTION

In accordance with Federal securities laws, the Hartford-sponsored mutual funds
and each Hartford affiliated registered investment adviser must adopt and
administer a code of ethics (the "Code"). The adoption and administration of the
Code is predicated upon the following principles: (1) at all times the interests
of investment company shareholders and advisory account clients should be placed
first; (2) all personal securities transactions should be conducted consistent
with the Code and in such a manner as to avoid any actual or potential conflict
of interest or any abuse of an individual's position of trust and
responsibility; and (3) investment personnel should not take inappropriate
advantage of their positions.

SECTION 2 - DEFINITIONS

(a)  "Access Person" means any director, officer, general partner or Advisory
Person of an Adviser, including persons defined below as Investment Personnel
and Portfolio Managers.

(b)  "Account" means any registered investment company or advisory account for
which an Adviser is the investment adviser or sub-adviser.

(c)  "Advisory Person" means (i) any employee of an Adviser (or of any company
in a control relationship to the Adviser), 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 any Account, or whose
functions relate to the making of any recommendations with respect to such
purchases or sales; and (ii) any natural person in a control relationship to any
Account or Adviser who obtains information concerning recommendations made to
the Account with regard to the purchase or sale of a Covered Security.

(d)  "Being Considered for Purchase or Sale" as to a Covered Security means when
a recommendation to purchase or sell such Covered Security has been made and
communicated.



(e)  "Covered Security" means any interest or instrument commonly known as a
security, except that it shall not include securities issued by the government
of the United States, bankers' acceptances, bank certificates of deposit,
commercial paper, high quality short-term instruments, shares of registered
open-end investment companies and securities issued by The Hartford Financial
Services Group, Inc.

(f) "Investment Personnel" means Portfolio Managers, analysts and traders of the
Advisers who take part in the process of making decisions about Account
investments.

(g)  "Portfolio Managers" means personnel of the Advisers who make decisions
about Account investments.

(h)  "Purchase or Sale of a Covered Security" includes, among other things, the
writing of an option to purchase or sell a Covered Security.

SECTION 3 - PROHIBITION ON CERTAIN PURCHASES AND SALES OF SECURITIES AND RELATED
REQUIREMENTS

(a)  TRADING RESTRICTION ON ACCESS PERSONS - An Access Person shall not purchase
or sell, directly or indirectly, any Covered Security in which he or she has, or
by reason of such transaction acquires, any direct or indirect beneficial
ownership and which to his or her actual knowledge at the time of such purchase
or sale:

     (1)   Is being considered for purchase or sale by any Account; or

     (2)   Is being purchased or sold by any Account.

(b)  TRADING RESTRICTION ON PORTFOLIO MANAGERS - A Portfolio Manager may not buy
or sell for his or her account a Covered Security within the seven calendar day
period before or after an Account that he or she manages, buys or sells that
Covered Security. Any profits realized on such trades will be disgorged as
determined by the compliance officer.

(c)  IPOs - Investment Personnel may not acquire any equity security in an
initial public offering.

(d)  PRIVATE PLACEMENTS - Investment Personnel may not acquire any security in a
private placement without express prior approval by the compliance officer of
the Advisers. If, after the purchase, the purchasing party may play a part in
the Account's subsequent consideration of an investment in the issuer, the
Investment Personnel must make a disclosure to the compliance officer of the
Advisers of this conflicting interest. If a decision is made to purchase such a
security for the Account, an independent review of the investment decision will
be made by Investment Personnel with no personal interest in the issuer.

(e)  SHORT-TERM TRADES - Investment Personnel may not profit from the purchase
and sale, or sale and purchase of a Covered Security for his or her account
within 30 calendar days without a written exemption from the compliance officer.
Any profits realized in such short-term trades



will be disgorged as determined by the compliance officer. Equity securities
with a market capitalization of at least $5 billion are not subject to this
restriction.

(f)  GIFTS - Investment Personnel may not accept gifts or other items of more
than de minimis value from any person or entity that does business with or on
behalf of any Account.

(g)  SERVICE ON BOARDS OF DIRECTORS - Investment Personnel may not serve on the
Boards of Directors of publicly held companies without prior approval by the
compliance officer of the Advisers.

SECTION 4 - EXEMPTED TRANSACTIONS

The trading restrictions of Section 3 of this Code shall not apply to:

(a)  Purchases or sales effected in any personal investment account over which
the Access Person has no direct influence or control. (An Access Person is
presumed to have direct influence or control over the account of a spouse, minor
child or other dependent relatives.);

(b)  Purchases or sales of securities or the purchase, sale or exercise of
options related to securities which are not eligible for purchase or sale by any
Account such as securities of The Hartford Financial Services Group, Inc.;

(c)  Purchases or sales which are non-volitional on the part of either the
Access Person or an Account;

(d)  Purchases which are part of any automatic dividend reinvestment plan or
stock purchase plan;

(e)  Purchases effected upon the exercise of rights issued by an issuer pro-rata
to all holders of a class of its securities, to the extent such rights were
acquired from such issuer, and sales of such rights so acquired; and

(f)  Purchases and sales of U.S. or foreign government securities, bankers'
acceptances, bank certificates of deposit, commercial paper, high quality
short-term instruments, shares of open-end mutual funds and any exchange traded
securities designed to replicate specific indices, or sub-components of an
index, such as SPDRS, Diamonds, Midcap SPDRS and WEBS.



SECTION 5 - COMPLIANCE PROCEDURES

(a)  INITIAL AND ANNUAL HOLDINGS REPORT - Within ten days of becoming an Access
Person and not later than January 30th, thereafter, each Access Person must
submit a report to the compliance officer with the information listed below.

     (1)  The title, number of shares and principal amount of all Covered
     Securities owned by the Access Person.

     (2)  The name of any broker, dealer or bank with whom the Access Person
     maintains an account.

     (3)  The date the report is submitted.

     The  report should contain information that is no more than 30 days old.

(b)  QUARTERLY REPORTING - Every Access Person shall, within ten days of
the end of each calendar quarter, report to the compliance officer, with respect
to transactions in any Covered Security in which such Access Person has, or by
reason of such transaction acquires, any direct or indirect beneficial ownership
in the Covered Security, the information listed below.

     (1)  The date of the transaction, the title and the number of shares,
     and the principal amount of each Covered Security involved.

     (2)  The nature of the transaction (i.e. purchase, sale or any other type
     of acquisition or disposition).

     (3)  The price at which the transaction was effected.

     (4)  The name of the broker, dealer or bank with or through whom the
     transaction was effected.

     (5)  If the Access Person has established a brokerage account during the
     quarterly period, the name of the broker, dealer or bank and the date the
     account was established.

     (6)  The date the report is submitted.

(c)  REVIEW OF REPORTS - The compliance officer or a designee shall be
responsible for reviewing all reports referenced above.

(d)  CONFIRMATIONS - Access Persons must direct their brokers to send duplicate
copies of confirmations for all Covered Security transactions to the compliance
officer.

(e)  PRE-CLEARANCE - In addition to the pre-clearance requirements discussed in
Sections 3(d) and 3(g), Access Persons must preclear with the compliance officer
of the Advisers trades in all



fixed income securities except U.S. or foreign government securities, bankers'
acceptances, bank certificates of deposit, commercial paper and high quality
short-term instruments. In addition, all private sector personnel must preclear
equity securities except securities subject to automatic dividend reinvestment
plans and automatic employee stock purchase plans, shares of open-end mutual
funds, any exchange traded securities designed to replicate specific indices, or
sub-components of an index, such as SPDRS, Diamonds, Midcap SPDRS and WEBS, and
securities issued by The Hartford Financial Services Group, Inc. ANY
PRE-CLEARANCE APPROVAL WILL REMAIN IN EFFECT FOR TWO BUSINESS DAYS AFTER THE
DATE ON WHICH APPROVAL WAS GRANTED.

(f)  ANNUAL CERTIFICATION - Access Persons must certify annually that they have
read and understand the Code and have complied with its requirements.

(g)  REPORT TO BOARD - On an annual basis management of HIMCO must submit to the
Boards of Directors of the Hartford-sponsored mutual funds a written report
which:

     (1)  Describes any issues arising under the Code or procedures since the
     last report to the Board of Directors, including, but not limited to,
     information about material violations of the Code or procedures and
     sanctions imposed in response to the material violations relating to funds
     managed by HIMCO; and

     (2)  Certifies that HIMCO has adopted procedures reasonably necessary
     to prevent Access Persons from violating the Code.

(h)  The reporting requirements above shall not apply to transactions effected
for, and Covered Securities held in, any account over which the person has no
direct or indirect influence or control (e.g. blind trusts, employee stock
purchase plans or option grants).

SECTION 6 - SANCTIONS

Upon discovering a violation of this Code, the Advisers may impose such
sanctions as they deem appropriate, including, among other things, a letter of
sanction, suspension or termination of the employment of the violator. All
material violations of this Code and any sanctions imposed with respect thereto
shall be reported periodically to the Advisers' President.

SECTION 7 - EXEMPTIVE PROCEDURE

The compliance officer of the Advisers may grant exemptions from the
requirements in this Code in appropriate circumstances. In addition, violations
of the provisions regarding personal trading will presumptively be subject to
being reversed in the case of a violative purchase, and to disgorgement of any
profit realized from the position by payment of the profit to any client
disadvantaged by the transaction, or to a charitable organization, as determined
by the appropriate Adviser, unless the violator establishes to the satisfaction
of the Adviser that under the particular circumstances disgorgement would be an
unreasonable remedy for the violation.

Revised: August, 2003