Code of Ethics

                      Lincoln Financial Distributors, Inc.

CREDO
It is the duty of all Lincoln Financial Distributors, Inc. employees, officers,
and directors to conduct themselves with integrity and at all times to place the
interests of shareholders and clients first. In the interest of this credo, all
personal securities transactions will be conducted consistent with the Code of
Ethics 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.
The fundamental standard of this Code is that personnel should not take any
inappropriate advantage of their position.

                              Prohibited Activities

The following restrictions apply to Lincoln Financial Distributors, Inc. (LFD)
employees, officers, and directors:

o No individual shall engage in any act, practice or course of conduct, which
  would violate the provisions of Rule 17j-1.

  o Insider Trading
    Insider trading is a prohibited practice of trading in securities based on
    material, non-public information. Officers, directors, Registered Principals
    and Registered Representatives of Lincoln Financial Distributors and any
    associated persons are prohibited from trading, either personally or on
    behalf of others (including family), on material non-public information or
    from communicating material non-public information to others. These
    individuals are also prohibited from giving advice based on inside
    information.

  o Use Of Unapproved Advertisements and Sales Materials
    All advertisements and all sales materials which will be used with more than
    one prospect or client must be approved by Compliance prior to use. Failure
    to submit an advertisement or sales material may subject an individual to
    sanctions including fine, suspension or termination.


o No registered representative can participate in, or conduct business in, a
     number of activities that are identified below. The prohibitions are
     necessary in order to protect the investing public.

  o Selling Away
    A representative must obtain written approval from LFD Compliance prior to
    participating in any private securities transaction. A private securities
    transaction is any securities transaction that is executed outside, or away
    from LFD. The definition includes money-raising activities, offerings
    involving a limited number of purchases or sales, issuing promissory notes,
    and some multi-level marketing programs.

  o Purchase of Initial Public Offerings or Hot Issues
    An initial public offering (IPO) is a new securities issue that is publicly
    traded at a premium above the initial offering price. When a new issue sells
    at an increase in the secondary market then that issue would be considered a
    "hot issue". This rule applies to all associated persons and their immediate
    family members with limited exceptions.

  o Engage In Prohibited Sales and Marketing Practices
    Certain sales practices are specifically prohibited by various Federal and
    State laws, including the NAIC Model Unfair Trade Practices Act, which has
    been adopted by many states. Among the sale practices that Registered
    Representatives and employees should not engage in include:

    o Arranging For Credit
    o Bashing
    o Business Valuation
    o Churning
    o Deceptive Practices
    o Fraud
    o High Pressure Tactics
    o Rebating
    o Unfair Trade Practices
    o Twisting

A comprehensive list of policies and procedures are included in the LFD
Compliance Policies.


                                Required Reports

The following reports are required to be made by all Access Persons:

o Initial Holdings Report within 10 days of hire
o Quarterly Transaction Report, no later than the tenth day after the end of
  the calendar quarter
o Annual Holdings Report - this report must be current as of a date no more than
  30 days before the report is submitted