Exhibit P

EX-99 10 ex-p.htm CODE OF ETHICS Exhibit P

American Century Investments

American Century Investments
Working with Integrity...

Code of Ethics

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Terms that are in bold italics in the text are defined in Appendix 1.
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I. Purpose of Code.

The Code of Ethics was developed to guide the personal investment
activities of American Century employees, officers and directors,
including members of their immediate family. In doing so, it is intended
to aid in the elimination and detection of personal securities
transactions by American Century personnel that might be viewed as
fraudulent or might conflict with the interests of our client portfolios.
Primary among such transactions are the misuse for personal benefit of
client trading information (so-called "front-running"), the
misappropriation of investment opportunities that may be appropriate for
investment by client portfolios, and excessive personal trading that may
affect our ability to provide services to our clients.

The Directors of American Century's registered investment companies (our
"Fund Clients"1) who are not "interested persons" (the "Independent
Directors") are covered under a separate Code applicable only to them.

II. Why Do We Have a Code of Ethics?

A. Investors have placed their trust in American Century.

American Century is entrusted with the assets of our clients for
investment purposes. This fiduciary relationship requires American
Century personnel to place the interests of our clients before their own
and to avoid even the appearance of a conflict of interest. Persons
subject to this Code must adhere to this general principle as well as
comply with the Code's specific provisions. This is how we earn and keep
our clients' trust. To protect this trust, we will hold ourselves to the
highest ethical standards.

B. American Century wants to give you flexible investing options.

Management believes that American Century's own mutual funds and other
pooled investment vehicles provide a broad range of investment
alternatives in virtually every segment of the securities market. We
encourage American Century employees to use these vehicles for their
personal investments. We do not encourage active trading by our
employees. We recognize, however, that individual needs differ and that
there are other attractive investment opportunities. As a result, this
Code is intended to give you and your family flexibility to invest,
without jeopardizing relationships with our clients.

American Century employees are able to undertake personal transactions in
stocks and other individual securities subject to the terms of this Code
of Ethics. This Code of Ethics requires preclearance of all such
transactions by Access, Investment, and Portfolio Persons (so-called
"covered persons"), places further limitations on personal investments by
Investment and Portfolio Persons, and requires transaction reporting by
all employees.

1 See Schedule A for a listing of all of our Fund Clients.

C. Federal law requires that we have a Code of Ethics

The Investment Company Act of 1940 and the Investment Advisers Act of
1940 require that we have safeguards in place to prevent personal
investment activities that might take inappropriate advantage of our
fiduciary position. These safeguards are embodied in this Code of
Ethics.2

III. Does the Code of Ethics apply to You?

Yes! All American Century employees and contract personnel must observe
the principles contained in the Code of Ethics. However, there are
different requirements for different categories of employees. The
category in which you have been placed generally depends on your job
function, although unique circumstances may prompt us to place you in a
different category. The range of categories is as follows:

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Fewest Restrictions Most Restrictions
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Non-Access Person Access Person Investment Person Portfolio Person
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The standard profile for each of the categories is described below:

A. Portfolio Persons.

Portfolio Persons include portfolio managers (equity or fixed
income) and any other person with authority to enter purchase/sale
orders on behalf of the funds on the firm's equity trade order
management system.

B. Investment Persons.

Investment Persons are persons who make or participate in making
recommendations regarding the purchase or sale of securities by
the client portfolios. Such persons include investment analysts,
equity traders, research and financial analyst personnel and
certain client service personnel who work closely with the
portfolios.

C. Access Persons.

Access Persons are persons who, in connection with their regular
function and duties, consistently obtain information regarding
current recommendations with respect to the purchase or sale of
securities or real-time trading information concerning client
portfolios. Examples include:

2 Rule 17j-1 under the Investment Company Act of 1940 and Rule 204-2 under the
Investment Advisers Act of 1940 serve as a basis for much of what is contained
in American Century's Code of Ethics.

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* Persons who are directly involved in the execution, clearance,
and settlement of purchases and sales of securities (e.g. fund
accountants);

* Persons whose function requires them to evaluate trading activity
on a real time basis (e.g. attorneys, accountants, portfolio
compliance personnel);

* Persons who assist in the design and implementation of investment
management technology systems (e.g. certain I/T personnel);

* Support staff and supervisors of the above if they are required to
obtain such information as a part of their regular function and
duties (e.g. investment manager's administrative assistants and
their supervisors).

In addition, you are an Access Person if you are any of the
following:

* An officer or "interested" director of our Fund Clients; OR

* An officer or director of American Century Investment
Management, Inc.

Single, infrequent, or inadvertent instances of access to current
recommendations or real-time trading information or the
opportunity to obtain such information through casual observance
or bundled data security access is not sufficient to qualify you
as an Access Person.

D. Non-Access Persons.

If you are an officer, director, employee or contractor of
American Century AND you do not fit into any of the above
categories, you are a Non-Access Person. While your trading is not
subject to preclearance and other restrictions applicable to
covered persons, you are still subject to the remaining provisions
of the Code and are required to provide duplicate trade
confirmations of your personal securities transactions to American
Century.3

IV. Restrictions on Personal Investing Activities.

A. Preclearance of Personal Securities Transactions
[Access, Investment, and Portfolio Persons]

Preclearance of personal securities transactions allows American
Century to prevent certain trades that may conflict with client
trading activities. The nature of securities markets makes it
impossible for us to perfectly predict those conflicts. As a
consequence, even trades that are precleared can result in
potential conflicts between your trades and those effected for
clients. You are responsible for avoiding such conflicts with any
client portfolios for which you make investment recommendations.
You have an obligation to American Century and its clients to
avoid even a perception of a conflict of interest with respect to
personal trading activities.

All covered persons must comply with the following preclearance
procedures prior to entering into

3 See Reporting Requirements - Duplicate Confirmations for details on
duplicate trade confirmation reporting.

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- the purchase or sale of a security for your own account or

- the purchase or sale of a security for an account for which you
are a beneficial owner4:

1. Is the security a "Code-Exempt Security"?

Check Appendix 3 to see if the security is listed as a
code-exempt security. If it is, then you may execute the
transaction. Otherwise, proceed to the next step.

2. Preclear the transaction with the Legal Department's
Compliance Group.5

There are two ways to do this:

a. Use the "PTRA" routine in the CICS system and enter your
request at the Personal Trade System screen.

b. If you do not have access to "PTRA," e-mail your request to
"LG-Personal Security Trades"
(or "LG-Personal_Security_Trades@americancentury.com," if
sending from outside American Century's Lotus Notes system),
and provide the following information:

* Issuer name;

* Ticker symbol or CUSIP number;

* Type of security (stock, bond, note, etc.);

* Number of shares;

* Maximum expected dollar amount of proposed transaction;
AND

* Nature of transaction (purchase or sale).

3. Use the "PTRB" routine in the CICS system to view the status
of your trade requests.

4. If you receive preclearance for the transaction,6 you have five
(5) business days to execute your transaction. If you do not
execute your transaction within five (5) business days, you
must repeat the preclearance procedure prior to undertaking
the transaction.

American Century reserves the right to restrict the purchase and
sale by covered persons of any security at any time. Such
restrictions are imposed through the use of a Restricted List that
will cause the Code of Ethics system to deny the approval of
preclearance to transact in the security. Securities may be
restricted for a variety of reasons including, without limitation,
the possession of material non-public information by American
Century or its employees.

4 See Appendix 2 for an explanation of beneficial ownership.

5 If you are ACIM's Chief Investment Officer, you must receive your preclearance
from the General Counsel or his or her designee.

6 See Appendix 4 for a description of the preclearance process.

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B. Additional Trading Restrictions
[Investment and Portfolio Persons]
The following additional trading restrictions apply if you are an
Investment or Portfolio Person:

1. Initial Public Offerings.

You cannot acquire securities issued in an initial public
offering.

2. Private Placements.

Before you acquire any securities in a private placement, you
must obtain approval from ACIM's Chief Investment Officer.7
Request for preclearance can be submitted by entering your
request in PTRA and accessing the Private Placement screen
(PF9 after your initials are entered) or by sending your
request to "LG-Personal Security Trades". You may not
participate in any consideration of an investment in
securities of the private placement issuer for any client
portfolios while your preclearance is pending or during any
period that you own, or are a beneficial owner of, the
privately-placed security.

3. Short-Term Trading Profits.

You cannot profit from any purchase and sale, or sale and
purchase, of the same (or equivalent) securities within sixty
(60) calendar days.

C. Seven-Day Blackout Period
[Portfolio Persons]

If you are a Portfolio Person, you may also not purchase or sell a
security within seven (7) calendar days before and after it has
been traded as a part of a client portfolio that you manage.

D. Trading on Inside Information
[All Employees]

As you are aware, federal law prohibits you from trading based on
material nonpublic information received from any source. This
includes any confidential information that may be obtained by
American Century employees regarding the advisability of
purchasing or selling specific securities on behalf of clients.
You are expected to abide by the highest ethical and legal
standards in conducting your personal securities transactions. For
more information regarding what to do when you believe you are in
possession of material non-public information, please consult
American Century's Insider Trading Policy.

7 See Appendix 3 for a listing of code-exempt securities that must be reported.

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V. Reporting Requirements.
A. Initial Holdings Report
[Access, Investment, and Portfolio Persons]

Within ten (10) calendar days of becoming an Access, Investment,
or Portfolio Person, you must submit an Initial Holdings Report
which includes the following:

1. A list of all securities, other than certain code-exempt
securities8, that you own or in which you have a beneficial
ownership interest. This listing must include the name,
number of shares, and principal amount of each covered security.

2. Information regarding each securities brokerage account
maintained by you or a person whose trades you must report
because you are a beneficial owner ("reportable brokerage
accounts"). This information should include the name of the
account holder, the name of the broker, dealer or bank, the
account number, and the date the account was established.

3. Your certification that you have read, understand, and will
comply with this Code of Ethics.

B. Quarterly Transactions Report
[Access, Investment, and Portfolio Persons]

All covered persons must submit a Quarterly Transactions Report
within ten (10) calendar days of the end of each calendar quarter.
Covered persons will be reminded by electronic mail of the dates
and requirements for filing the report. This reminder will contain
a link to a database that will generate a report of the
transactions for which we have received duplicate trade
confirmations during the quarter. It is your responsibility to
review the completeness and accuracy of this report, provide any
necessary changes, and certify its contents when submitted. The
Quarterly Transactions Report must contain the following
information about each personal securities transaction undertaken
during the quarter:

* The date of the transaction, the description and number of shares,
and the principal amount of each security involved;

* The nature of the transaction, that is, purchase, sale, or any
other type of acquisition or disposition;

* The transaction price; AND

* The name of the bank, broker, or dealer through whom the
transaction was executed.

In addition, information regarding your reportable brokerage
accounts should be updated at this time.

C. Annual Holdings Report
[Access, Investment, and Portfolio Persons]

Each year all covered persons must submit an Annual Holdings
Report and update their brokerage accounts. The Annual Holdings
Report must be submitted within 30 calendar days after December
31st of each year and the information submitted must be current as
of a date no more than 30 calendar days before the report is
filed. Covered persons will be reminded by electronic mail of the
dates and requirements for filing the report. The Annual Holdings
Report must include the following:

8 See Apendix 3 for a listing of code-exempt securities that must be reported.

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1. A list of all securities subject to this Code in which you have
a direct or beneficial ownership interest. This listing must
include the name, number of shares, and principal amount of
each covered security.

2. Information regarding all reportable brokerage accounts.

3. Your certification that you have read, understand, and have
complied with this Code of Ethics.

D. Duplicate Confirmations
[All Employees]

All American Century employees (including Non-Access Persons) must
instruct their broker-dealer to send duplicate confirmations of
all transactions in reportable brokerage accounts to:

American Century Investments
Attention: Compliance
P.O. Box 410141
Kansas City, MO 64141-0141

Please note that "reportable brokerage accounts" includes both of
the following:

* A brokerage account maintained by you; AND

* A brokerage account maintained by a person whose trades you must
report because you are a beneficial owner.

VI. Can there be any exceptions to the restrictions?
Yes. The General Counsel or his or her designee may grant limited
exemptions to specific provisions of the Code on a case-by-case basis.

A. How to Request an Exemption

E-mail a written request to "LG-Personal Security Trades" (or
"LG-Personal_Security_Trades@americancentury.com" if sending from
outside American Century's Lotus Notes system) detailing your
situation.

B. Factors Considered
In considering your request, the General Counsel or his or her
designee will grant your exemption request if he or she is
satisfied that:

* Your request addresses an undue personal hardship imposed on you
by the Code of Ethics;

* Your situation is not contemplated by the Code of Ethics; and

* Your exemption, if granted, would be consistent with the
achievement of the objectives of the Code of Ethics.

Page 7

C. Exemption Reporting

All exemptions must be reported to the Boards of Directors of our
Fund Clients at the next regular meeting following the initial
grant of the exemption. Subsequent grants of an exemption of a
type previously reported to the Boards may be effected without
reporting. The Boards of Directors may choose to delegate the task
of receiving and reviewing reports to a committee comprised of
Independent Directors.

D. 30 Day Denial Exemption On Sales

An exemption may be requested when a request to sell a security
has been denied once a week for a four (4) week timeframe. The
covered person must be able to verify that they have entered a
request to sell a security in PTRA at least once a week for four
(4) weeks. A written request must be e-mailed to "LG-Personal
Security Trades" to request the exemption. The General Counsel or
his or her designee will review the request and determine if the
exemption is warranted. If approval is granted, compliance will
designate a short trading window during which the sale can take
place.

E. Nonvolitional Transaction Exemption

Certain nonvolitonal purchase and sale transactions shall be
exempt from the preclearance requirements of the Code. These
transactions shall include stock splits, stock dividends,
exchanges and conversions, mandatory tenders, pro rata
distributions to all holders of a class of securities, gifts,
inheritances, margin/maintenance calls (where the securities to be
sold are not directed by the covered person), dividend
reinvestment plans, and employer sponsored payroll deduction
plans. These purchase and sale transactions, however, shall not be
exempt from the Quarterly Transaction Report and Annual Holdings
Report provisions of the Code.

F. Blind Trust Exemption

An exemption from the preclearance and reporting requirements of
the Code may be requested for securities that are held in a blind
or quasi-blind trust arrangement. For the exemption to be
available, you or a member of your immediate family must not have
authority to advise or direct securities transactions of the
trust. The request will only be granted once the covered person
and the trust's investment adviser certify that the covered person
or members of their immediate family will not advise or direct
transactions. American Century must receive statements at least
quarterly for transactions within the trust.

VII. Confidential Information.

All information about Clients' securities transactions, actual or
contemplated, is confidential. You must not disclose, except as required
by the duties of your employment, securities transactions of Clients,
actual or contemplated, or the contents of any written or oral
communication, study, report or opinion concerning any security. This
does not apply to information which has already been publicly disclosed.

Page 8

VIII. Conflicts of Interest.

You must receive prior written approval from the General Counsel or his
or her designee, as appropriate, to do any of the following:

* Negotiate or enter into any agreement on a Client's behalf with any
business concern doing or seeking to do business with the Client if you,
or a person related to you, has a substantial interest in the business
concern;

* Enter into an agreement, negotiate or otherwise do business on the
Client's behalf with a personal friend or a person related to you; OR

* Serve on the board of directors of, or act as consultant to, any
publicly traded corporation.

IX. What happens if you violate the rules in the Code of Ethics? If you
violate the rules of the Code of Ethics, you may be subject to serious
penalties. Violations of the Code and proposed sanctions are documented
by the Code of Ethics Manager and submitted to the Code of Ethics Review
Committee for review. The Committee consists of representatives of the
Investment, Trading, Compliance, and Legal Departments of American
Century. It is responsible for determining the materiality of a violation
of the Code and appropriate sanctions.

A. Materiality of Violation

In determining the materiality of a violation, the Committee
considers:

* Evidence of violation of law;

* Indicia of fraud, neglect, or indifference to Code provisions;

* Frequency of repeat violations;

* Monetary value of the violation in question; and

* Level of influence of the violator.

B. Penalty Factors

In assessing the appropriate penalties, the Committee will consider the
foregoing in addition to any other factors they deem applicable, such
as:

* Extent of harm to client interests;

* Extent of unjust enrichment;

* Tenure and prior record of the violator;

* The degree to which there is a personal benefit from unique knowledge
obtained through employment with American Century;

* The level of accurate, honest and timely cooperation from the covered
person; and

* Any mitigating circumstances that may exist.

Page 9

C. The penalties which may be imposed include:

* First non-material violation

* Warning (notice sent to manager); and

* Attendance at Code of Ethics training session.

* Second non-material violation within 12 months

* Notice sent to manager; and

* Suspension of trading privileges for up to 90 days.

* Penalties for material or more frequent non-material violations will be
determined based on the circumstances. These penalties could include,
but are not limited to

* Suspension of trading privileges;

* Fine; and/or

* Suspension or termination of employment.

In addition, you may be required to surrender to American Century any
profit realized from any transaction(s) in violation of this Code of
Ethics.

X. American Century's Quarterly Report to Fund Directors.

American Century will prepare a quarterly report to the Board of
Directors of each Fund Client of any material violation of this Code of
Ethics.

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APPENDIX 1: DEFINITIONS

1. "Beneficial Ownership"

See "Appendix 2: What is Beneficial Ownership?".

2. "Code-Exempt Security"

A "code-exempt security" is a security in which you may invest without
preclearing such transactions with American Century. The list of
code-exempt securities appears in Appendix 3.

3. "Initial Public Offering"

"Initial public offering" means an offering of securities for which a
registration statement has not previously been filed with the SEC and for
which there is no active public market in the shares.

4. "Member of Your Immediate Family"

A "member of your immediate family" means any of the following

* Your spouse or domestic partner;

* Your minor children; OR

* A relative who shares your home

For the purpose of determining whether any of the foregoing relationships
exist, a legally adopted child of a person is considered a child of such
person.

5. "Private Placement"

"Private placement" means an offering of securities in which the issuer
relies on an exemption from the registration provisions of the federal
securities laws, and usually involves a limited number of sophisticated
investors and a restriction on resale of the securities.

6. "Security"

A "security" includes a great number of different investment vehicles.
However, for purposes of this Code of Ethics, "security" includes any of
the following:

* Note,

* Stock,

* Treasury stock,

* Bond,

* Debenture,

* Exchange traded funds or similar securities (ETFs),

* Evidence of indebtedness,

* Certificate of interest or participation in any profit-sharing agreement,

* Collateral-trust certificate,

Appendix 1-Page 1

* Preorganization certificate or subscription,

* Transferable share,

* Investment contract,

* Voting-trust certificate,

* Certificate of deposit for a security,

* Fractional undivided interest in oil, gas or other mineral rights,

* Any put, call, straddle, option, future, or privilege on any security
or other financial instrument (including a certificate of deposit) or
on any group or index of securities (including any interest therein or
based on the value thereof),

* Any put, call, straddle, option, future, or privilege entered into on
a national securities exchange relating to foreign currency,

* In general, any interest or instrument commonly known as a
"security," or

* Any certificate of interest or participation in, temporary or interim
certificate for, receipt for, guarantee of, future on or warrant or
right to subscribe to or purchase, any of the foregoing.

Appendix 1-Page 2

APPENDIX 2: WHAT IS "BENEFICIAL OWNERSHIP"?

A "beneficial owner" of a security is any person who, directly or indirectly,
through any contract, arrangement, understanding, relationship, or otherwise,
has or shares in the opportunity, directly or indirectly, to profit or share in
any profit derived from a purchase or sale of the security.

1. Are securities held by family members or domestic partners "beneficially
owned" by me?

Probably. As a general rule, you are regarded as the beneficial owner of
securities held in the name of

* A member of your immediate family OR

* Any other person IF:

* You obtain from such securities benefits substantially similar to
those of ownership. For example, if you receive or benefit from some
of the income from the securities held by your spouse, you are the
beneficial owner; OR

* You can obtain title to the securities now or in the future.

2. Are securities held by a company I own an interest in also "beneficially
owned" by me?

Probably not. Owning the securities of a company does not mean you
"beneficially own" the securities that the company itself owns. However,
you will be deemed to "beneficially own" the securities owned by the
company if:

* You directly or beneficially own a controlling interest in or otherwise
control the company; OR

* The company is merely a medium through which you, members of your
immediate family, or others in a small group invest or trade in securities
and the company has no other substantial business.

3. Are securities held in trust "beneficially owned" by me?

Maybe. You are deemed to "beneficially own" securities held in trust if any
of the following is true:

* You or a member of your immediate family are a trustee or have a
vested interest in the income or corpus of the trust OR

* You or a member of your immediate family are a settlor or grantor of
the trust and have the power to revoke the trust without obtaining the
consent of all the beneficiaries.

A blind trust exemption from the preclearance and reporting requirements of
the Code may be requested if you or members or your immediate family do not
have authority to advise or direct securities transactions of the trust.

Appendix 2-Page 1

4. Are securities in pension or retirement plans "beneficially owned" by me?

Maybe. Beneficial ownership does not include indirect interest by any
person in portfolio securities held by a pension or retirement plan
holding securities of an issuer whose employees generally are the
beneficiaries of the plan.

However, your participation in a pension or retirement plan is considered
beneficial ownership of the portfolio securities if you can withdraw and
trade the securities without withdrawing from the plan or you can direct
the trading of the securities within the plan (IRAs, 401ks, etc.).

5. Examples of Beneficial Ownership

Securities Held by Family Members or Domestic Partners

Example 1: Tom and Mary are married. Although Mary has an independent
source of income from a family inheritance and segregates her funds from
those of her husband, Mary contributes to the maintenance of the family
home. Tom and Mary have engaged in joint estate planning and have the
same financial adviser. Since Tom and Mary's resources are clearly
significantly directed towards their common property, they shall be
deemed to be the beneficial owners of each other's securities.

Example 2: Mike's adult son David lives in Mike's home. David is
self-supporting and contributes to household expenses. Mike is a
beneficial owner of David's securities.

Example 3: Joe's mother Margaret lives alone and is financially
independent. Joe has power of attorney over his mother's estate, pays all
her bills and manages her investment affairs. Joe borrows freely from
Margaret without being required to pay back funds with interest, if at
all. Joe takes out personal loans from Margaret's bank in Margaret's
name, the interest from such loans being paid from Margaret's account.
Joe is a significant heir of Margaret's estate. Joe is a beneficial owner
of Margaret's estate.

Example 4: Bob and Nancy are engaged. The house they share is still in
Nancy's name only. They have separate checking accounts with an informal
understanding that both individuals contribute to the mortgage payments
and other common expenses. Nancy is the beneficial owner of Bob's
securities.

Securities Held by a Company

Example 5: ABC Company is a holding company with five shareholders owning
equal shares in the company. Although ABC Company has no business of its
own, it has several wholly-owned subsidiaries that invest in securities.
Stan is a shareholder of ABC Company. Stan has a beneficial interest in
the securities owned by ABC Company's subsidiaries.

Example 6: XYZ Company is a large manufacturing company with many
shareholders. Stan is a shareholder of XYZ Company. As a part of its cash
management function, XYZ Company invests in securities. Neither Stan nor
any members of his immediate family are employed by XYZ Company. Stan
does not beneficially own the securities held by XYZ Company.

Appendix 2-Page 2

Securities Held in Trust

Example 7: John is trustee of a trust created for his two minor children.
When both of John's children reach 21, each shall receive an equal share
of the corpus of the trust. John is a beneficial owner of any securities
owned by the trust.

Example 8: Jane placed securities held by her in a trust for the benefit
of her church. Jane can revoke the trust during her lifetime. Jane is a
beneficial owner of any securities owned by the trust.

Example 9: Jim is trustee of an irrevocable trust for his 21 year-old
daughter (who does not share his home). The daughter is entitled to the
income of the trust until she is 25 years old, and is then entitled to
the corpus. If the daughter dies before reaching 25, Jim is entitled to
the corpus. Jim is a beneficial owner of any securities owned by the
trust.

Example 10: Joan's father (who does not share her home) placed securities
in an irrevocable trust for Joan's minor children. Neither Joan nor any
member of her immediate family is the trustee of the trust. Joan is a
beneficial owner of the securities owned by the trust. She may, however,
be eligible for the blind trust exemption to the preclearance and
reporting of the trust securities.

Appendix 2-Page 3

APPENDIX 3: CODE-EXEMPT SECURITIES

Because they do not pose a likelihood for abuse, some securities, defined as
code-exempt securities, are exempt from the Code's preclearance and quarterly
reporting requirements. However, confirmations from your service providers are
required in all cases (except mutual funds) and some code-exempt securities must
be disclosed on your Initial and Annual Holdings Reports.

1. Code-Exempt Securities Not Subject to Disclosure on your Initial and
Annual Holdings Reports:

* Mutual funds (open-end funds)

* Closed-end funds

* Variable insurance and annuity products

* Bank Certificates of Deposit

* U.S. government securities (Treasury notes, etc.)

* Commercial paper

* Bankers acceptances

* High quality short-term debt instruments, including repurchase
agreements. A "high quality short-term debt instrument" means any
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 rating organization.

2. Code-Exempt Securities Subject to Disclosure on your Initial and Annual
Holdings Reports:

* Securities which are acquired through an employer-sponsored automatic
payroll deduction plan (only the acquisition of the security is exempt,
NOT the sale)

* Securities purchased through dividend reinvestment programs (only the
acquisition of the security is exempt, NOT the sale)

* Commodity futures contracts for tangible goods (corn, soybeans, wheat,
etc.) Futures contracts for financial instruments are not Code-exempt.

* Futures contracts on the following:

* Standard & Poor's 500 Index; or

* Standard & Poor's 100 Index.

We may modify this list of securities at any time, please send an e-mail to
"LG-Personal Security Trades" to request the most current list.

Appendix 3-Page 1

APPENDIX 4: HOW THE PRECLEARANCE PROCESS WORKS

[Text from Apendix 4-Page 2 depicted as flow chart here]

Appendix 4-Page 1

After your request is entered into our mainframe system, it is then subjected to
the following tests.

Step 1: Restricted Security List

* Is the security on the Restricted Security list?

If "YES", the system will send a message to you to DENY the personal trade
request.

If "NO", then your request is subject to Step 2.

Step 2: De Minimis Transaction Test (This test does not apply to the trade
requests of Portfolio and Investment Persons.)

* Is the security issuer's market capitalization greater than $1 billion?

* Will your proposed transaction, together with your other transactions
in the security for the current calendar quarter, be less than $10,000?

* Does the security trade on a national securities exchange or market,
such as the New York Stock Exchange (NYSE) or National Association of
Securities Dealers Automated Quotation System (NASDAQ)?

If the answer to ALL of these questions is "YES", the system will generate a
message and send it to you approving your proposed transaction.

If the answer to ANY of these questions is "NO", then your request is subject to
Step 3.

Step 3: Open Order Test

* Is there an open order for that security for any Client?

If "YES", the system will send a message to you to DENY the personal trade
request.

If "NO", then your request is subject to Step 4.

Step 4: Follow List Test

* Does any account or Fund own the security?

* Does the security appear on the computerized list of stocks American
Century is considering to purchase for a Client?

If the answer to BOTH of these questions is "NO", the system will send a message
to you to APPROVE your proposed transaction.

If the answer to EITHER of these questions is "YES", then your request is
subject to Step 5.

Step 5: Present Intentions Test

The system sends a message to our equity trading desk in Kansas City which
identifies the security described in your preclearance request. A trading desk
representative then contacts a representative from each of the portfolio
management teams and asks if any portfolio team is considering buying or selling
the security within the next five (5) business days.

If ALL of the portfolio management teams respond "NO", your request will be
APPROVED.

If ANY of the portfolio management teams respond "YES", your request will be
DENIED.

Appendix 4-Page 2

Step 6: Chief Investment Officer Requests

The General Counsel or his/her designee must approve any preclearance request by
ACIM's Chief Investment Officer before an APPROVAL message is generated.

The preclearance process can be changed at any time to ensure that the goals of
American Century's Code of Ethics are advanced.

Appendix 4-Page 3

SCHEDULE A

The Code of Ethics to which this Schedule is attached was most recently approved
by the Board of Directors/Trustees of the following Companies as of the dates
indicated:

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Investment Advisor Most Recent Approval Date
-----------------------------------------------------------------------------------------------------
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American Century Investment Management, Inc. December 9, 2002
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-----------------------------------------------------------------------------------------------

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Principal Underwriter Most Recent Approval Date
-----------------------------------------------------------------------------------------------------
-----------------------------------------------------------------------------------------------------
American Century Investment Services, Inc. December 9, 2002
-----------------------------------------------------------------------------------------------------

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Fund Clients Most Recent Approval Date
-----------------------------------------------------------------------------------------------------
American Century Avanti Funds, Inc. November 15, 2002
------------------------------------------------------------------
American Century California Tax-Free and Municipal Funds December 9, 2002
------------------------------------------------------------------
American Century Capital Portfolios, Inc. November 15, 2002
------------------------------------------------------------------
American Century Government Income Trust December 9, 2002
------------------------------------------------------------------
American Century International Bond Funds December 9, 2002
------------------------------------------------------------------
American Century Investment Trust December 9, 2002
------------------------------------------------------------------
American Century Municipal Trust December 9, 2002
------------------------------------------------------------------
American Century Mutual Funds, Inc. November 15, 2002
------------------------------------------------------------------
American Century Quantitative Equity Funds December 9, 2002
------------------------------------------------------------------
American Century Strategic Asset Allocations, Inc. November 15, 2002
------------------------------------------------------------------
American Century Target Maturities Trust December 9, 2002
------------------------------------------------------------------
American Century Variable Portfolios, Inc. November 15, 2002
------------------------------------------------------------------
American Century Variable Portfolios II, Inc. December 9, 2002
------------------------------------------------------------------
American Century World Mutual Funds, Inc. November 15, 2002
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Schedule A-Page 1