INVESCO Asset Management (Japan) Limited

Code of Ethics

Fundamental Liabilities and Social Responsibilities

1. We will recognize the importance of the basic liabilities and social
responsibilities as an asset management company and acquire the trust of the
investors by the sound business

In our Global Compliance Manual, there is a clear message that we will have to
adhere to the fiduciary duties stipulated as a code of conduct. We consider that
to fulfill the fiduciary duty ultimately results in the accomplishment of the
fundamental liability as an asset management company. As a principle, we hereby
stipulates in the manual for business operations as an investment trust
management company that "In conducting the business operations, we will perform
the fiduciary duties in compliance with the principle of the investment trust
management company." And also in the manual for business operations as a
discretionary investment management company that "In conducting the business
operations, we will comply with the customer contracts and perform the fiduciary
duties in compliance with the principle of the investment advisory company law."
This idea reflects the specific articles of Investment

Trust Law (1) and Investment Advisory Law (2) as described below:

(1) "Funds of investors are pooled and managed as investments principally in
securities,~, by a person other than such investors through the use of an
investment trust~, the fruits thereof are distributed to such investors, ~"
(excerpt from Article 1 of ITM Law)

(2) "An investment advisor is entrusted with the whole or any part of the
authority to make investment decisions based on an analysis of the value of
securities, etc., and also with the authority necessary to invest clients'
assets on behalf of such client based on such investment decisions"(Section 4 of
Article 2 of Investment Advisory Law)

Social Responsibilities

An asset management company collects money from the investors in general and
invests and returns the money with the yields based on the fiduciaries duties.
We will have to recognize the sociability and public nature of an asset
management company in the financial capital market and be requested to behave
ourselves based on the rigid principle and self-responsibility. This will lead
to the efficient investment of the funds and contribute to the sound development
of the economic society and the protection of the investors.


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INVESCO Asset Management (Japan) Limited

Compliance with the laws and regulations

2. We will comply with the related laws and regulations and fulfill the sincere
and sound business operations.

COMPLIANCE

INVESVO is regulated by Investment Trust Law, Investment Advisory Law,
Securities and Exchange Law, Financial Product Sales Law and other related laws
and regulations. In the meanwhile as to the trades with the overseas
counterparties, we are also requested to abide by the laws and regulations
overseas. This is an asset management company will fulfill the social
responsibilities by the compliance with the laws and regulations as well as the
sound business operations.

SINCERE AND SOUND BUSINESS OPERATIONS

In compliance with not only the related laws and regulations but also the
association rules and the internal rules, we will have to realize our business
principle by conducting the daily operations sincerely and soundly. All
directors and employees should conduct the daily operations in recognition of
the above fact.

PRINCIPLE OF CONDUCT

It is important for each of us to recognize our own responsibilities and powers
and understand completely the related laws and regulations as well as the
internal rules and


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INVESCO Asset Management (Japan) Limited

to implement the scheme which each of us makes the voluntary actions based on
our own accord.

Every department makes the own check on a daily routines basis as the first
checking function, by the independent internal auditor as the second checking
function and the audit by the statutory auditor and the external accountants as
the third checking function. This is the realistic checking scheme.

Violation of the laws is the most crucial risk(linked to the social
responsibilities) that the management should pay attention in terms of risk
management. Once the violation occurs, the management should try to grasp the
issues swiftly and having the continuous contact with the related departments
out of its responsibilities, and find out the reasons and settle as soon as
possible and work out the countermeasures to prevent its recurrence.

Provision of the High Quality of the Asset Management Service

3 We will contribute to the development of the economic society by providing the
high quality of the asset management service in compliance with the investment
purpose of the investors.

PROVISION OF THE HIGH QUALITY OF THE ASSET MANAGEMENT SERVICE

The investment needs of investors are constantly increasing under the change of
the current investment circumstance.

To comply with these needs, we will have to make efforts to increase investment
efficiency and quality of the providing service. In terms of the investor
protection, we will have to make efforts to strengthen the internal control
scheme and risk management set up in line with the diversification and the
complexity of the financial capital market.


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INVESCO Asset Management (Japan) Limited

At the same time, we will have to make the correct disclosure and accountability
to the investors in line with the profundity and complexity of the proposed
products.

CONTRIBUTION TO THE ECONOMIC SOCIETY

One of the social roles of an asset management company is to support the
economic activities of the investors. We will fulfill our social
responsibilities to make best efforts to the efficient investment of the funds,
the better performance to respond to the needs of the investors.

First Priority on the Customers' Interests

4 We will fulfill the fundamental responsibility to prioritize the customer's
interests and conduct the proper business operations as an asset management
company.

FIRST PRIORITY ON THE CUSTOMERS' INTERESTS

The high quality of the service provision is not always the better performance
of the funds but the total service including other service, e.g., the efficient
and correct operations, proper trade monitoring, etc. In principle, we should
prioritize the customer's interests and effort to maximize their interest. We
can realize the above service by the better performance of the invested funds,
the efficient operations, the proper risk management, the better customer
service as well as the compliance with the laws and regulations and the risk
management.

PROTECTION OF CONFLICTS OF INTERESTS

As described above, for the better service provision, it is important to the
better performance, the compliance with laws and regulations, the establishment
of the risk management but in


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INVESCO Asset Management (Japan) Limited

considering the maximization of the investors'interests, It is very vital to
protect the conflicts of interests.

Transparent Business Operations

5. We will realize the transparent business operations by the appropriate
disclosure.

IMPORTANCE OF DISCLOSURE

We can obtain the trust from the investors by the correct disclosure in order to
fulfill the fundamental liabilities and the social responsibilities. We should
pay attention to the sufficient and correct disclosure of the trusted assets and
the corporate information which are vital for the investors' investment decision
making. As to the disclosure content and method, etc., we are legally requested
to be sound and correct, etc.

TRANSPARENT BUSINESS OPERATIONS

We are liable of the disclosure against the beneficiaries, Customers, investors,
and the market and its accomplishment is one of our social responsibilities.

To clarify the content of the daily operations and the judgment base for the
everyone, it is our responsibilities to realize the transparent business
operations.


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INVESCO Asset Management (Japan) Limited

EXCLUSION OF ANTI-SOCIAL FORCES

It is necessary to establish the pre-clearance set-up and the organization to
accomplish the social responsibilities to ensure the compliance with the laws
and regulations. We are exposed to the risk which we should stand firm against
the anti-social forces during the daily operations. As a social member, it is
very important for each of us to have the strong faith to stand firm against the
anti-social forces which impairs the social order.

COUNTERMEASURES

It is very important for us to proceed the correct operations in the course of
the daily operations to comply with the anti-social forces and keep the close
communication with the related departments in terms of the protection of the
troubles.

Just in case where we encounter the case, to make the swift contact with the
related departments and recognize the alliance and cooperation with the other
departments and consider the consultation to the outside police offices, etc.

ALLIANCE WITH THE OUTSIDE PARTIES

The most effective way is to stand firm against the anti-social forces. In this
regard, we will have to consult with the police officers and outside legal
counsels to comply with the swift


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handling. It is very important to have close communications with the police
offices, legal counsels to exchange information and comply with this issue.

MONEY LAUNDERING

In accordance with Law concerning Anti-Organization Crimes to have been
implemented effective February 1, 2000, the definition of the illegal earnings
is more widely defined so that the regulatory reporting on the suspicious trades
which used to be limited to the drug trafficking has been expanded substantially
to all illegal trades(Criminal Codes, Commercial Codes, Securities and Exchange
Law, Foreign Exchange Law, etc.).

It is very important for all directors and employees to recognize and pay
attention that the identification of the principal and the report on the
suspicious transactions are regulated and so be cautious about the money
launderings.

Upon discovery of the money laundering or the case of involvement in the money
laundering, immediate report to the person in charge of money laundering and
regulatory report to be made accordingly dependent upon the case.


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