<DOCUMENT>
<TYPE>EX-99.(R)
<SEQUENCE>14
<FILENAME>b48195isexv99wxry.txt
<DESCRIPTION>CODE OF ETHICS
<TEXT>
<PAGE>
                                                                   EXHIBIT 99(r)

                                Code of Ethics of

                           John Hancock Advisers, LLC
                             each John Hancock fund
                             John Hancock Funds, LLC
                     (together, called "John Hancock Funds")

                                 March 15, 2003

<TABLE>
<S>                                                                                   <C>
1.   General Principles.........................................................       2
2.   To Whom Does This Code Apply?..............................................       2
3.   Overview of Policies.......................................................       3
4.   Policies Outside the Code of Ethics........................................       4
        Company Conflict & Business Practice Policy.............................       4
        Inside Information Policy and Procedures................................       4
5.   Policies in the Code of Ethics.............................................       5
        Restriction on Gifts....................................................       5
        Preclearance of Securities Transactions.................................       5
        Ban on Short-Term Profits...............................................       6
        Ban on IPOs.............................................................       6
        Disclosure of Private Placement Conflicts...............................       7
        Seven Day Blackout Period...............................................       7
6.   Reports and Other Disclosures Outside the Code of Ethics...................       8
        Broker Letter/Duplicate Confirm Statements..............................       8
7.   Reports and Other Disclosures In the Code of Ethics........................       8
        Initial Holdings Report and Annual Holdings Report......................       8
        Quarterly Transaction Reports...........................................       9
        Annual Certification....................................................       9
8.   Limited Access Persons.....................................................       9
9.   Subadvisers................................................................       9
10.  Reporting Violations.......................................................      10
11.  Interpretation and Enforcement.............................................      10
Appendix A: Categories of Personnel.............................................      11
Appendix B: Preclearance Procedures.............................................      12
Appendix C: Limited Access Persons..............................................      16
Appendix D:  Subadvisers........................................................      17
Appendix E:  Administration and Recordkeeping...................................      18
</TABLE>

<PAGE>

1.   General Principles

Each person within the John Hancock Funds organization is responsible for
maintaining the very highest ethical standards when conducting business. This
means that:

-    You have a duty at all times to place the interests of our clients first.

-    All of your personal securities transactions must be conducted consistent
     with this code of ethics and in such a manner as to avoid any actual or
     potential conflict of interest or other abuse of your position of trust and
     responsibility.

-    You should not take inappropriate advantage of your position or engage in
     any fraudulent or manipulative practice (such as frontrunning) with respect
     to our clients' accounts.

2.   To Whom Does This Code Apply?

This code of ethics applies to you if you are a director, officer or employee of
John Hancock Advisers, LLC, Sovereign Asset Management Co., John Hancock Funds,
LLC or a "John Hancock fund" (any fund or account advised by John Hancock
Advisers, LLC). It also applies to you if you are an employee of John Hancock
Life Insurance Co. or its subsidiaries who participates in making
recommendations for, or receives information about, portfolio trades of the John
Hancock funds. Please note that if a policy described below applies to you, it
applies to your personal accounts, those of a spouse, "significant other," minor
children or family members sharing a household, as well as all accounts over
which you have discretion or give advice or information. "Significant others"
are defined for these purposes as two people who (1) share the same primary
residence; (2) share living expenses; and (3) are in a committed relationship
and intend to remain in the relationship indefinitely.

There are three main categories for persons covered by this code of ethics,
taking into account their positions, duties and access to information regarding
fund portfolio trades. You have been notified about which of these categories
applies to you, based on the Compliance Department's understanding of your
current role. If you have a level of investment access beyond your assigned
category, or if you are promoted or change duties and as a result should more
appropriately be included in a different category, it is your responsibility to
notify Tom Connors, Vice President.

The basic definitions of the three main categories, with examples, are provided
below. The more detailed definitions of each category are attached as Appendix
A.

 "Investment Access" person                      "Regular Access" person
   "Non-Access" person

                                                A person who regularly obtains
                                           information regarding fund portfolio
                                                        trades.
A person who regularly participates in
A person who does not regularly
       a fund's investment process.
participate in a fund's investment         examples:

process or obtain information              -     personnel in Investment
regarding fund portfolio trades.                 Operations or Compliance

examples:

-    portfolio managers                    -     most FFM  personnel

examples:

-    analysts wholesalers                  -     Technology personnel with
                                                 access to investment systems

-    traders inside wholesalers who        -     attorneys and some legal
     don't attend investment                     administration personnel
     "morning meetings"
     certain administrative personnel      -     investment admin. personnel

                                        2

<PAGE>

3.   Overview of Policies

Please refer to the following chart to determine which policies apply to your
category. These policies are described in detail below.

<TABLE>
<CAPTION>
                                                       Investment Access
                                                            Person          Regular Access Person    Non-Access Person
                                                       -----------------    ---------------------    -----------------
<S>                                                    <C>                  <C>                      <C>
General principles                                            yes                    yes                    yes
Policies outside the code
Conflict of interest policy                                   yes                    yes                    yes
Inside information policy                                     yes                    yes                    yes
Policies in the code
Restriction on gifts                                          yes                    yes                    yes
Pre-clearance requirement                                     yes                    yes                  Limited
Ban on short-term profits                                     yes                    no                     no
Ban on IPOs                                                   yes                    no                     no
Disclosure of private placement conflicts                     yes                    no                     no
Seven day blackout period                                     yes                    no                     no
Reports and other disclosures outside the code
Broker letter/duplicate confirms                              yes                    yes                    yes
Reports and other disclosures in the code
Annual recertification form                                   yes                    yes                    yes
Initial/annual holdings reports                               yes                    yes                    no
Quarterly transaction reports                                 yes                    yes                    no
</TABLE>

                                        3

<PAGE>

4.   Policies Outside the Code of Ethics

John Hancock Funds has certain policies that are not part of the code of ethics,
but are equally important. The two most important of these policies are (1) the
Company Conflict and Business Practice Policy; and (2) the Inside Information
Policy.

     Company Conflict & Business Practice Policy

A conflict of interest occurs when your private interests interfere or could
potentially interfere with your responsibilities at work. You must not place
yourself or the company in a position of actual or potential conflict.

Applies to:       Investment Access Persons
                  Regular Access Persons
                  Non-Access Persons

This Policy covers a number of important issues. For example, you cannot serve
as a director of any company without first obtaining the required written
executive approval.

Other important issues in this Policy include:

-    personal investments or business relationships

-    misuse of inside information

-    receiving or giving of gifts, entertainment or favors

-    misuse or misrepresentation of your corporate position

-    disclosure of confidential or proprietary information

-    antitrust activities

-    political campaign contributions and expenditures on public officials

     Inside Information Policy and Procedures

The antifraud provisions of the federal securities laws generally prohibit
persons with material non-public information from trading on or communicating
the information to others. Sanctions for violations can include civil
injunctions, permanent bars from the securities industry, civil penalties up to
three times the profits made or losses avoided, criminal fines and jail
sentences. While Investment Access persons are most likely to come in contact
with material non-public information, the rules (and sanctions) in this area
apply to all John Hancock Funds personnel and extend to activities both related
and unrelated to your job duties.

Applies to:       Investment Access Persons
                  Regular Access Persons
                  Non-Access Persons

The Inside Information Policy and Procedures covers a number of important
issues, such as: o The misuse of material non-public information o The
information barrier procedure o The "restricted list" and the "watch list" o
broker letters and duplicate confirmation statements (see section 5 of this code
of ethics)

                                        4

<PAGE>

5.   Policies in the Code of Ethics

     Restriction on Gifts

You and your family cannot accept preferential treatment or favors from
securities brokers or dealers or other organizations with which John Hancock
Funds might transact business except in accordance with the Company Conflict and
Business Practice Policy. For the protection of both you and John Hancock Funds,
the appearance of a possible conflict of interest must be avoided. You should
exercise caution in any instance in which business travel and lodging are paid
for by someone other than John Hancock Funds. The purpose of this policy is to
minimize the basis for any charge that you used your John Hancock Funds position
to obtain for yourself opportunities which otherwise would not be offered to
you. Please see the Company Conflict and Business Practice Policy's
"Compensation and Gifts" section for additional details regarding restrictions
on gifts and exceptions for "nominal value" gifts.

Applies to:       Investment Access Persons
                  Regular Access Persons
                  Non-Access Persons

     Preclearance of Securities Transactions

If you are an Investment Access person or Regular Access person, you must
"preclear" (i.e.: receive advance approval of) any personal securities
transactions. The preclearance policy applies to trades for your personal
accounts, those of a spouse, "significant other," minor Also, for a limited
category of trades: children or family members sharing your household, as well
as all accounts over which you have discretion or give advice or information.
Due to this preclearance requirement, participation in investment clubs is
prohibited.

Applies to:       Investment Access Persons
                  Regular Access Persons
                  Non-Access Persons

Preclearance of private placements requires some special considerations--the
decision will take into account whether, for example: (1) the investment
opportunity should be reserved for John Hancock Funds clients; and (2) it is
being offered to you because of your position with John Hancock Funds.

The following securities are exempt from the preclear policy: (1) direct
obligations of the U.S. Government, (2) shares of all open-end mutual funds, (3)
bankers' acceptances, bank certificates of deposit, commercial paper & high
quality short-term debt instruments, including repurchase agreements.

If you are a Non-Access person, you must preclear transactions in securities of
any closed-end funds advised by John Hancock Advisers, LLC. A Non-Access person
is not required to preclear other trades. However, please keep in mind that a
Non-Access person is required to report securities transactions after every
trade (even those that are not required to be precleared) by submitting
duplicate confirmation statements, as described in section 5 of this code of
ethics.

The preclearance policy is designed to proactively identify possible "problem
trades" that raise frontrunning or other conflict of interest concerns (example:
when an Investment Access person trades a security on the same day as a John
Hancock fund). Please keep in mind that even if you receive a preclearance, or
are exempt from preclearing a securities transaction, you are still prohibited
from engaging in any fraud or manipulative practice (such as frontrunning) with
respect to a John Hancock fund.

                                        5

<PAGE>

You preclear a trade by following the steps outlined in the preclearance
procedures, which are attached as Appendix B. Please note that:

-    You may not trade until clearance is received.

-    Clearance approval is valid only for the date granted.

-    A separate procedure should be followed for requesting preclearance of a
     private placement or a derivative, as detailed in Appendix B. The
     Compliance Department must maintain a five-year record of all clearances of
     private placement purchases by Investment Access persons, and the reasons
     supporting the clearances.

     Ban on Short-Term Profits

If you are an Investment Access person, you cannot profit from the purchase and
sale (or sale and purchase) of the same (or equivalent) securities within 60
calendar days. The purpose of this policy is to address the risk, real or
perceived, of frontrunning or other abusive practices involving short-term
personal trading. Any profits realized on short-term trades must be surrendered
by check payable to John Hancock Advisers, LLC and will be contributed by John
Hancock Advisers, LLC to a charity.

Applies to:       Investment Access Persons

This policy applies to trades for your personal accounts, those of a spouse,
"significant other," minor children or family members sharing a household, as
well as all accounts over which you have discretion or give advice or
information. If you give away a security, it is considered a sale.

You may invest in derivatives or sell short provided the transaction period
exceeds the 60-day holding period.

You may request an exemption from this policy for involuntary sales due to
unforeseen corporate activity (such as a merger), or hardship reasons (such as
unexpected medical expenses) by sending an e-mail to Tom Connors, Vice
President.

     Ban on IPOs

If you are an Investment Access person, you may not acquire securities in an
initial public offering. You may not purchase any newly-issued securities until
the next business (trading) day after the offering date.

Applies to:       Investment Access Persons

This policy applies to trades for your personal accounts, those of a spouse,
"significant other," minor children or family members sharing your household, as
well as all accounts over which you have discretion or give advice or
information.

There are two main reasons for this prohibition: (1) these purchases may suggest
that persons have taken inappropriate advantage of their positions for personal
profit; and (2) these purchases may create at least the appearance that an
investment opportunity that should have been available to the John Hancock funds
was diverted to the personal benefit of an individual employee.

                                        6

<PAGE>

You may request an exemption for certain investments that do not create a
potential conflict of interest, such as: (1) securities of a mutual bank or
mutual insurance company received as compensation in a demutualization and other
similar non-voluntary stock acquisitions; or (2) fixed rights offerings.

     Disclosure of Private Placement Conflicts

If you are an Investment Access person and you own securities purchased in a
private placement, you must disclose that holding decision to purchase or sell
that same issuer's securities for a John Hancock fund.

Applies to:       Investment Access Persons

Private placements are securities exempt from SEC registration under section
4(2), section 4(6) or rules 504 -506 of the Securities Act of 1933.

The investment decision must be subject to an independent review by investment
personnel with no personal interest in the issuer. This policy applies to
holdings in your personal accounts, those of a spouse, "significant other,"
minor children or family members sharing your household, as well as all accounts
over which you have discretion or give advice or information.

The purpose of this policy is to provide appropriate scrutiny in situations in
which there is a potential conflict of interest.

     Seven Day Blackout Period

If you are a portfolio manager (or were identified to the Compliance Department
as part of a portfolio management Persons team) you are prohibited from buying
or selling a security within seven calendar days before and after that security
is traded for a fund that you manage unless no conflict of interest exists in
relation to that security.

Applies to:       Investment Access

In addition, all investment access persons are prohibited from knowingly buying
or selling a security within seven calendar days before and after that security
is traded for a John Hancock fund unless no conflict of interest exists in
relation to that security. If a John Hancock fund trades in a security within
seven calendar days before or after you trade in that security, you may be
required to demonstrate that you did not know that the trade was being
considered for that John Hancock fund.

You will be required to sell any security purchased in violation of this policy
unless it is determined that no conflict of interest exists in relation to that
security. Any profits realized on trades during a seven day blackout period must
be surrendered by check payable to John Hancock Advisers, LLC and will be
contributed by John Hancock Advisers, LLC to a charity.

                                        7

<PAGE>

This policy applies to holdings in your personal accounts, those of a spouse,
"significant other" or family members sharing your household, as well as all
accounts over which you have discretion or give advice or information.

6.   Reports and Other Disclosures Outside the Code of Ethics

     Broker Letter/Duplicate Confirm Statements

As required by the Inside Information Policy, you must inform your stockbroker
that you are employed by an investment adviser or broker. Regular Access Persons
Your broker is subject to certain rules Non-Access Persons designed to prevent
favoritism toward your accounts.

Applies to:       Investment Access Persons

You may not accept negotiated commission rates that you believe may be more
favorable than the broker grants to accounts with similar characteristics. When
you open a brokerage account, before any trades are made, you must:

-    Notify the Compliance Department (attn: Fred Spring) so the Compliance
     Department can send to the broker a letter notifying the broker of the
     requirement to send duplicate confirmation statements and certain other
     requirements.

-    ensure that your broker sends duplicate confirmations and copies of all
     periodic statements on a timely basis to the Compliance Department, 10th
     Floor, 101 Huntington Ave., Boston, MA 02199.

These requirements apply to holdings in your personal accounts, those of a
spouse, "significant other," minor children or family members sharing your
household, as well as all accounts over which you have discretion or give advice
or information.

7.   Reports and Other Disclosures In the Code of Ethics

     Initial Holdings Report and Annual Holdings Report

You must file an initial holdings report within 10 calendar days after becoming
an Investment Access person or a Regular Access person. You must also file an
annual holdings report (as of December 31st) within 30 calendar days after the
calendar year end. These reports must cover all holdings in your personal
accounts, those of a spouse, "significant other," minor children or family
members sharing your household, as well as all accounts over which you have
discretion or give advice or information. You must report:

Applies to:       Investment Access Persons
                  Regular Access Persons

-    holdings of all securities except: (1) direct obligations of the U.S.
     Government, (2) shares of open-end mutual funds, (3) bankers' acceptances,
     bank certificates of deposit, commercial paper and high quality short-term
     debt instruments, including repurchase agreements.

-    all brokerage accounts that contain securities (including brokerage
     accounts that only contain securities exempt from reporting, such as shares
     of open-end mutual funds).

                                        8

<PAGE>

     Quarterly Transaction Reports

You must file a quarterly transaction report within 10 calendar days after the
end of a calendar quarter if you are an Investment Access person or a Regular
Access person. This report must cover all transactions during the past calendar
quarter in your personal accounts, those of a spouse, "significant other," minor
children or family members sharing your household, as well as all accounts over
which you have discretion or give advice or information.

Applies to:       Investment Access Persons
                  Regular Access Persons

You must report:

-    transactions in all securities except: (1) direct obligations of the U.S.
     Government, (2) open-end mutual funds, (3) bankers' acceptances, bank
     certificates of deposit, commercial paper and high quality short-term debt
     instruments, including repurchase agreements.

-    the opening of any brokerage account that contains securities (including
     brokerage accounts that only contain securities exempt from reporting, such
     as shares of open-end mutual funds).

     Annual Certification

You must provide an annual certification at a date designated by the Compliance
Department that: (1) you have read and understood this code of ethics; (2) you
recognize that you are subject to its policies; and (3) you have complied with
its requirements.

Applies to:       Investment Access Persons
                  Regular Access Persons
                  Non-Access Persons

You are required to make this certification to demonstrate that you understand
the importance of these policies and your responsibilities under the Code.

8.   Limited Access Persons

There is an additional category of persons called "Limited Access" persons. This
category consists only of directors of John Hancock Advisers, LLC or the John
Hancock funds who:

          (a) are not also officers of John Hancock Advisers, LLC; and

          (b) do not ordinarily obtain information about fund portfolio trades.

A more detailed definition of Limited Access persons, and a list of the policies
that apply to them, is attached as Appendix C.

9.   Subadvisers

A subadviser to a John Hancock fund has a number of responsibilities under this
code of ethics, as described in Appendix D.

                                        9

<PAGE>

10.  Reporting Violations

If you know of any violation of our code of ethics, you have a responsibility to
immediately report it. You should also report any deviations from the controls
and procedures that safeguard John Hancock Funds and the assets of our clients.

You can report confidentially to:


-    Tom Connors (375-1724) or Tim Fagan (375-6205); or

-    Your manager or department head


11.  Interpretation and Enforcement

This code of ethics cannot anticipate every situation in which personal
interests may be in conflict with the interests of our clients. You should be
responsive to the spirit and intent of this code of ethics as well as its
specific provisions.

When any doubt exists regarding any code of ethics provision or whether a
conflict of interest with clients might exist, you should discuss the
transaction beforehand with the Legal Department (contacts: Tom Connors
(375-1724) or Tim Fagan (375-6205)). The code of ethics is designed to detect
and prevent fraud against clients and fund investors, and to avoid the
appearance of impropriety. If you feel inequitably burdened by any policy, you
should feel free to contact Tom Connors, Vice President, or the Ethics and
Business Practices Committee. Exceptions may be granted where warranted by
applicable facts and circumstances.

To provide assurance that policies are effective, the Compliance Department will
monitor and check personal securities transaction reports and certifications
against fund portfolio transactions. Other internal auditing procedures may be
adopted from time to time. Additional administration and recordkeeping
procedures are described in Appendix E.

The Ethics and Business Practices Committee of John Hancock Funds has general
responsibility for this code of ethics. The Legal Department will refer
violations to the Ethics Committee for review and appropriate action. The
following factors will be considered when the Ethics Committee determines a fine
or other disciplinary action:

-    the person's position and function (senior personnel may be held to a
     higher standard);

-    the amount of the trade;

-    whether the funds or accounts hold the security and were trading the same
     day;

-    whether the violation was by a family member.

-    whether the person has had a prior violation and which policy was involved.

-    whether the employee self-reported the violation.

You can request reconsideration of any disciplinary action by submitting a
written request to the Ethics Committee.

No less frequently than annually, a written report of all material violations
and sanctions, significant conflicts of interest and other related issues will
be submitted to the boards of directors of the John Hancock funds for their
review. Sanctions for violations could include fines, limitation of personal
trading activity, suspension or termination of the violator's position with John
Hancock Funds and/or a report to the appropriate regulatory authority.

                                       10

<PAGE>

Appendix A: Categories of Personnel

You have been notified about which of these categories applies to you, based on
the Compliance Department's understanding of your current role. If you have a
level of investment access beyond that category, or if you are promoted or
change duties and as a result should more appropriately be included in a
different category, it is your responsibility to immediately notify Tom Connors,
Vice President.

1)   Investment Access person: You are an Investment Access person if you are an
     employee of John Hancock Advisers, LLC, a John Hancock fund, or John
     Hancock Life Insurance Company or its subsidiaries who, in connection with
     your regular functions or duties, makes or participates in making
     recommendations regarding the purchase or sale of securities by a John
     Hancock fund.

     (examples: portfolio managers, analysts, traders)

2)   Regular Access person: You are a Regular Access person if:

     -    You are an officer (vice president and higher) or director of John
          Hancock Advisers, LLC or a John Hancock fund. (Some directors may be
          Limited Access persons--please see Appendix C for this definition.)

     -    You are:

       -  an employee of John Hancock Advisers, LLC, a John Hancock fund or John
          Hancock Life Insurance Co. or its subsidiaries , or

       -  a director, officer (vice president and higher) or employee of John
          Hancock Funds, LLC

          who: (i) in connection with your regular functions or duties, makes,
          participates in, or obtains information regarding the purchase or
          sale of securities by a John Hancock fund; or (ii) your functions
          relate to the making of any recommendation to the fund regarding the
          purchase or sale of securities by a John Hancock fund.

     (examples: Investment Operations personnel, Compliance Department
     personnel, most Fund Financial Management personnel, investment
     administrative personnel, Technology Resources personnel with access to
     investment systems, attorneys and some legal administration personnel)

3)   Non-Access person: You are a non-access person if you are an employee of
     John Hancock Advisers, LLC, John Hancock Funds, LLC or a John Hancock fund
     who does not fit the definitions of any of the other three categories
     (Investment Access Person, Regular Access Person or Limited Access Person).
     To be a non-access person, you must not obtain information regarding the
     purchase or sale of securities by a John Hancock fund in connection with
     your regular functions or duties.

     (examples: wholesalers, inside wholesalers, certain administrative staff)

4)   Limited Access Person: Please see Appendix C for this definition.

                                       11

<PAGE>

Appendix B: Preclearance Procedures

                                 CODE OF ETHICS
                            PRE-CLEARANCE PROCEDURES

You should read the Code of Ethics to determine whether you must obtain a
preclearance before you enter into a securities transaction. If you are required
to obtain a preclearance, you should follow the procedures detailed below.

1. Pre-clearance for Public Securities including Derivatives, Futures, Options
and Selling Short:

A request to pre-clear should be entered into the John Hancock Personal Trading
& Reporting System.

The John Hancock Personal Trading & Reporting System is located under your Start
Menu on your Desktop. It can be accessed by going to JH Applications/Personal
Trading & Reporting/ Personal Trading & Reporting and by entering your Web
Security Services user id and password.

If JH Applications or the John Hancock Personal Trading & Reporting System is
not on your Desktop, please contact the HELP Desk at (617) 375-4357 for
assistance.

The Trade Request Screen:

At times you may receive a message like "System is currently unavailable". The
system is scheduled to be offline from 8:00 PM until 7:00 AM each night.

                               [GRAPHIC OMITTED]

                                       12

<PAGE>

Ticker/Security Cusip: Fill in this one of these fields with the proper
information of the security you want to buy or sell. Then click the [Lookup]
button. Select one of the hyperlinks for the desired security, and the system
will populate the proper fields Ticker, Security Cusip, Security Name and
Security Type automatically on the Trade Request Screen.

If You Don't Know the Ticker, Cusip, or Security Name:

If you do not know the full ticker, you may type in the first few letters
followed by an asterisk * and click the [Lookup] button. For example, let's say
you want to buy some shares of Intel, but all you can remember of the ticker is
that it begins with int, so you enter int* for Ticker. If any tickers beginning
with int are found, they are displayed on a new screen. Select the hyperlink of
the one you want, and the system will populate Security Cusip, Security Name and
Security Type automatically on the Trade Request Screen. If you do not know the
full cusip, you may type in the first few numbers followed by an asterisk * and
click the [Lookup] button. For example, let's say you want to buy some shares of
Microsoft, but all you can remember of the cusip is that it begins with 594918,
so you enter 594918* for Ticker. If any cusips beginning with 594918 are found,
they are displayed on a new screen. Select the hyperlink of the one you want,
and the system will fill in Ticker, Security Name and Security Type
automatically on the Trade Request Screen. If you do not know the Ticker but
have an idea of what the Security Name is, you may type in an asterisk, a few
letters of the name and an asterisk * and click the [Lookup] button. For
example, let's say you want to buy some shares of American Brands, so you enter
*amer* for Security Name. Any securities whose names have amer in them are
displayed on a new screen, where you are asked to select the hyperlink of the
one you want, and the system will fill in Ticker, Cusip and Security Type
automatically on the Trade Request Screen.

Other Items on the Trade Request Screen:

Brokerage Account: Click on the dropdown arrow to the right of the Brokerage
Account field to choose the account to be used for the trade.

Transaction Type: Choose one of the values displayed when you click the dropdown
arrow to the right of this field.

Trade Date: You may only submit trade requests for the current date.

Note: One or more of these fields may not appear on the Request Entry screen if
the information is not required. Required fields are determined by the
compliance department.

Click the [Submit Request] button to send the trade request to your compliance
department.

Once you click the [Submit Request] button, you will be asked to confirm the
values you have entered. Review the information and click the [Confirm] button
if all the information is correct. After which, you will receive immediate
feedback in your web browser. (Note: We suggest that you print out this
confirmation and keep it as a record of the trade you have made). After this,
you can either submit another trade request or logout.

                                       13

<PAGE>

Attention Investment Access Persons: If the system identifies a potential
violation of the Ban on Short Term Profits Rule, your request will be sent to
the Compliance Department for review and you will receive feedback via the
e-mail system.

Starting Over:

To clear everything on the screen and start over, click the [Clear Screen]
button.

Exiting Without Submitting the Trade Request:

If you decide not to submit the trade request before clicking the [Submit
Request] button, simply exit from the browser by clicking the [X] button on the
upper right or by pressing [Alt+F4], or by clicking the Logout hyperlink on the
lower left side of the screen.

Ticker/Security Name Lookup Screen:

You arrive at this screen from the Trade Request Screen, where you've clicked
the [Lookup] button (see above, "If You Don't Know the Ticker, Cusip, or
Security Name"). If you see the security you want to trade, you simply select
its corresponding hyperlink, and you will automatically return to the Trade
Request Screen, where you finish making your trade request. If the security you
want to trade is not shown, that means that it is not recognized by the system
under the criteria you used to look it up. Keep searching under other names
(click the [Return to Request] button) until you are sure that the security is
not in the system. If you determine that the desired security is not in the
system, please contact a member of the compliance department to add the security
for you. Contacts are listed below:

Fred Spring x54987          Michelle Yung x54883      MaryEllen Logee x54967

Adding Brokerage Accounts:

To access this functionality, click on the Add Brokerage Account hyperlink on
the left frame of your browser screen. You will be prompted to enter the
Brokerage Account Number, Brokerage Account Name, Date Opened, and Broker. When
you click the [Create New Brokerage Account] button, you will receive a message
that informs you whether the account was successfully created.

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3.   Pre-clearance for Private Placements and Initial Public Offerings:

                                [GRAPHIC OMITTED]

You may request a preclearance of private placement securities or an Initial
Public Offering by contacting Fred Spring via Microsoft Outlook (please "cc."
Tim Fagan on all such requests). Please keep in mind that the code of ethics
prohibits Investment Access persons from purchasing securities in an initial
public offering.

The request must include:

[_]  the associate's name;

[_]  the associate's John Hancock Funds' company;

[_]  the complete name of the security;

[_]  the seller and whether or not the seller is one with whom the associate
     does business on a regular basis;

[_]  any potential conflict, present or future, with fund trading activity and
     whether the security might be offered as inducement to later recommend
     publicly traded securities for any fund; and

|_|  the date of the request.

Clearance of private placements or initial public offerings may be denied if the
transaction could create the appearance of impropriety. Clearance of initial
public offerings will also be denied if the transaction is prohibited for a
person due to his or her access category under the code of ethics.

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Appendix C: Limited Access Persons

You are a Limited Access person if you are a director of John Hancock Advisers,
LLC or a John Hancock fund and you meet the two following criteria:

     (a)  you are not an officer of John Hancock Advisers, LLC or a John Hancock
          fund; and

     (b)  you do not obtain information in the ordinary course of business
          regarding the purchase or sale of securities by a John Hancock fund.

(examples: certain directors of John Hancock Advisers, LLC or a John Hancock
fund)

The following policies apply to your category. These policies are described in
detail in the code of ethics.

-    Fundamental concept

-    Inside information policy and procedures*

-    Broker letter/Duplicate Confirms*

-    Initial/annual holdings reports*

-    Quarterly transaction reports*

-    Annual recertification*

*Exception: If you are an independent director of a John Hancock fund:

-    you are exempt from the broker letter/duplicate confirms requirement

-    you are exempt from the inside information policy and procedures

-    you do not have to file an initial holdings report.

-    you do not have to file an annual holdings report.

-    you do not have to file a quarterly transaction report unless you knew (or
     should have known) that during the 15 calendar days before or after you
     trade a security, either:

     (i)  a John Hancock fund purchased or sold the same security, or

     (ii) a John Hancock fund or John Hancock Advisers, LLC considered
          purchasing or selling the same security.

          This policy applies to holdings in your personal accounts, those of a
          spouse, "significant other" or family members sharing your household,
          as well as all accounts over which you have discretion or give advice
          or information. If this situation occurs, it is your responsibility to
          contact Tom Connors, Vice President, at (617) 375-1724 and he will
          assist you with the requirements of the quarterly transaction report.

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Appendix D: Subadvisers

A subadviser to a John Hancock fund has a number of responsibilities under this
code of ethics. If John Hancock Advisers, LLC determines that a subadviser has
failed to comply with the provisions of Rule 17j-1, John Hancock Advisers, LLC
may deem the subadviser's directors, officers or employees to be subject to this
code of ethics.

     Approval of Code of Ethics

Each subadviser to a John Hancock fund must provide a copy of its code of ethics
to the trustees of the relevant John Hancock funds for approval initially and
within 60 calendar days of any material amendment. The trustees will give their
approval if they determine that the code:

-    contains provisions reasonably necessary to prevent the subadviser's Access
     Persons (as defined in Rule 17j-1) from engaging in any conduct prohibited
     by Rule 17j-1;

-    requires the subadviser's Access Persons to make reports to at least the
     extent required in Rule 17j-1(d);

-    requires the subadviser to institute appropriate procedures for review of
     these reports by management or compliance personnel (as contemplated by
     Rule 17j-1(d)(3));

-    provides for notification of the subadviser's Access Persons in accordance
     with Rule 17j-1(d)(4); and

-    requires the subadviser's Access Persons who are Investment Personnel to
     obtain the pre-clearances required by Rule 17j-1(e);

     Reports and Certifications

Each subadviser must provide an annual report and certification to John Hancock
Advisers, LLC and the fund's trustees in accordance with Rule 17j-1(c)(2)(ii).
The subadviser must also provide other reports or information that John Hancock
Advisers, LLC may reasonably request.

     Recordkeeping Requirements

The subadviser must maintain all records for its Access Persons as required by
Rule 17j-1(f).

                                       17

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Appendix E: Administration and Recordkeeping

     Adoption and Approval

The trustees of a John Hancock fund must approve the code of ethics of an
adviser, subadviser or affiliated principal underwriter before initially
retaining its services.

Any material change to a code of ethics of a John Hancock fund, John Hancock
Funds, LLC, John Hancock Advisers, LLC or a subadviser to a fund must be
approved by the trustees of the John Hancock fund, including a majority of
trustees who are not interested persons, no later than six months after adoption
of the material change.

     Administration

No less frequently than annually, John Hancock Funds, LLC, John Hancock
Advisers, LLC, each subadviser and each John Hancock fund will furnish to the
trustees of each John Hancock fund a written report that:

-    describes issues that arose during the previous year under the code of
     ethics or the related procedures, including, but not limited to,
     information about material code or procedure violations, and

-    certifies that each entity has adopted procedures reasonably necessary to
     prevent its access persons from violating its code of ethics.

     Recordkeeping

The Compliance Department will maintain:

-    a copy of the current code of ethics for John Hancock Funds, LLC, John
     Hancock Advisers, LLC, and each John Hancock fund, and a copy of each code
     of ethics in effect at any time within the past five years.

-    a record of any violation of the code of ethics, and of any action taken as
     a result of the violation, for six years.

-    a copy of each report made by an Access person under the code of ethics,
     for six years (the first two years in a readily accessible place).

-    a record of all persons, currently or within the past five years, who are
     or were required to make reports under the code of ethics. This record will
     also indicate who was responsible for reviewing these reports.

-    a copy of each code of ethics report to the trustees, for six years (the
     first two years in a readily accessible place).

-    a record of any decision, and the reasons supporting the decision, to
     approve the acquisition by an Investment Access person of initial public
     offering securities or private placement securities, for six years.

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