CODE OF ETHICS FOR
                PRINCIPAL EXECUTIVE AND SENIOR FINANCIAL OFFICERS

                    THE DIVERSIFIED INVESTORS FUNDS GROUP,
                    THE DIVERSIFIED INVESTORS FUNDS GROUP II,
               DIVERSIFIED INVESTORS STRATEGIC VARIABLE FUNDS AND
                        DIVERSIFIED INVESTORS PORTFOLIOS

The Diversified Investors Funds Group,The Diversified Investors Funds Group
II, The Diversified Investors Strategic Variable Funds and Diversified Investors
Portfolios (collectively, the "Funds") have adopted this Code of Ethics to
effectuate compliance with Section 406 under the Sarbanes-Oxley Act of 2002 and
the rules adopted to implement Section 406.

This Code applies to each Fund's principal executive officer, principal
financial officer, principal accounting officer or controller, or persons
performing similar functions ("Covered Officers"). A listing of positions
currently within the ambit of Covered Officers is attached Exhibit A.

1.    PURPOSE OF THE CODE. This Code sets forth standards and procedures that
      are reasonably designed to deter wrongdoing and promote:

      -     honest and ethical conduct, including the ethical handling of actual
            or apparent conflicts of interest between personal and professional
            relationships;

      -     full, fair, accurate, timely, and understandable disclosure in
            reports and documents that a Fund files with, or submits to, the
            U.S. Securities and Exchange Commission ("SEC") and in other public
            communications made by the Fund;

      -     compliance with applicable governmental laws, rules and regulations;

      -     the prompt internal reporting of violations of this Code to the
            party or parties identified below; and

      -     accountability for adherence to this Code.

2.    DUTIES OF COVERED OFFICERS. It is the responsibility of the Covered
      Officers, by their words and actions, to foster a corporate culture that
      encourages honest and ethical conduct, including the ethical resolution
      of, and appropriate disclosure of, conflicts of interest. The Covered
      Officers should work to assure a working environment that is characterized
      by respect for law and compliance with applicable rules and regulations.
      The Covered Officers must:

      -     act with integrity;



      -     familiarize themselves with the disclosure requirements generally
            applicable to the Funds and, to the extent appropriate within the
            Covered Officer's area of responsibility, take appropriate steps
            with the goal of promoting full, fair, accurate, timely and
            understandable disclosure in reports and documents the Funds file
            with the SEC and in other public communications made by the Funds;

      -     not knowingly misrepresent, or cause others to misrepresent, facts
            about the Funds; and

      -     not use personal influence or personal relationships improperly to
            influence investment decisions or financial reporting by the Funds
            whereby the Covered Officer would benefit personally to the
            detriment of the Funds;

      -     not cause the Funds to take action, or fail to take action, for the
            individual personal benefit of the Covered Officer rather than the
            benefit of the Funds; and

      -     not use material non-public knowledge of portfolio transactions made
            or contemplated for the Funds to trade personally or cause others to
            trade personally in contemplation of the market effect of such
            transactions.

3.    OTHER POTENTIAL CONFLICTS. Any potential conflict of interest or
      appearance of conflict of interest must be discussed by a Covered Officer
      with the General Counsel of Diversified Investment Advisors, Inc. (the
      "GC"), including:

      -     service as a director on the board of directors or trustees of any
            public or private company (other than a not-for-profit
            organization);

      -     the receipt of any non-nominal gifts; and

      -     the receipt of any entertainment from any company with which the
            Funds have current or prospective business dealings unless such
            entertainment is business-related, reasonable in cost, appropriate
            as to time and place, and not so frequent as to raise any question
            of impropriety.

4.    REPORTING. Upon receipt of this Code, and annually thereafter, the Covered
      Officers must sign an acknowledgement stating that he or she has received,
      read and understands the Code.

5.    VIOLATIONS. Any person who becomes aware of an apparent violation of this
      Code must report it to the GC. The GC is authorized to investigate any
      such violations and report his or her findings to the Chairperson of the
      Audit Committees of the Funds. The Chairperson may report violations of
      the Code to

                                       2


      the Board of Trustees if he or she believes such reporting is appropriate.
      The Chairperson may also determine the appropriate sanction for any
      violations of this Code, including removal from office, provided that
      removal from office shall only be carried out with the approval of the
      Boards of Trustees of the Funds.

6.    AMENDMENTS. Technical, administrative or other non-substantive amendments
      to this Code must be approved by the Chairperson of the Audit Committees
      of the Funds and any material amendment must be approved by the Board of
      Trustees. Amendments must be filed with the SEC as required by applicable
      rules. All amendments must be in writing.

7.    RELATIONSHIP TO CODES OF ETHICS. The Funds and its principal service
      providers have adopted codes of ethics under Rule 17j-1 under the
      Investment Company Act of 1940. Those codes are separate requirements and
      are not part of this Code.

8.    CONFIDENTIALITY. All reports and records prepared or maintained pursuant
      to this Code shall be confidential and shall be maintained and protected
      accordingly. Except as otherwise required by law or this Code, such
      matters shall not be disclosed to anyone.




                                       3


                                                                       EXHIBIT A

                     PERSONS COVERED BY THIS CODE OF ETHICS

Mark Mullin, Principal Executive Officer

Joseph Carusone, Principal Financial Officer

Suzanne Montemurro, Assistant Treasurer




                            FORM N-CSR CERTIFICATION

I, Joseph Carusone, certify that:

1.    I have reviewed this report on Form N-CSR of Diversified Investors
      Strategic Variable Funds.

2.    Based on my knowledge, this report does not contain any untrue statement
      of a material fact or omit to state a material fact necessary to make the
      statements made, in light of the circumstances under which such statements
      were made, not misleading with respect to the period covered by this
      report;

3.    Based on my knowledge, the financial statements, and other financial
      information included in this report, fairly present in all material
      respects the financial condition, results of operations, changes in net
      assets, and cash flows (if the financial statements are required to
      include a statement of cash flows) of the registrant as of, and for, the
      periods presented in this report;

4.    The registrant's other certifying officers and I are responsible for
      establishing and maintaining disclosure controls and procedures (as
      defined in Rule 30a-3(c) under the Investment Company Act of 1940) and
      internal control over financial reporting (as defined in Rule 30a-3(d)
      under the Investment Company Act of 1940) for the registrant and have:

      a)    Designed such disclosure controls and procedures, or caused such
            disclosure controls and procedures to be designed under our
            supervision, to ensure that material information relating to the
            registrant, including its consolidated subsidiaries, is made known
            to us by others within those entities, particularly during the
            period in which this report is being prepared;

      b)    Designed such internal control over financial reporting, or caused
            such internal control over financial reporting to be designed under
            our supervision, to provide reasonable assurance regarding the
            reliability of financial reporting and the preparation of financial
            statements for external purposes in accordance with generally
            accepted accounting principles;

      c)    Evaluated the effectiveness of the registrant's disclosure controls
            and procedures and presented in this report our conclusions about
            the effectiveness of the disclosure controls and procedures, as of a
            date within 90 days prior to the filing date of this report based on
            such evaluation; and

      d)    Disclosed in this report any change in the registrant's internal
            control over financial reporting that occurred during the second
            fiscal quarter of the period covered by this report that has
            materially affected, or is reasonably likely to materially affect,
            the registrant's internal control over financial reporting; and





5.    The registrant's other certifying officers and I have disclosed to the
      registrant's auditors and the audit committee of the registrant's board of
      directors (or persons performing the equivalent functions):

      a)    All significant deficiencies and material weaknesses in the design
            or operation of internal control over financial reporting which are
            reasonably likely to adversely affect the registrant's ability to
            record, process, summarize, and report financial information; and

      b)    Any fraud, whether or not material, that involves management or
            other employees who have a significant role in the registrant's
            internal control over financial reporting.

Date:  March 1, 2005

/s/ Joseph Carusone

Joseph Carusone
Principal Financial Officer