EX-99.(2)(R)(2) 24 b90494a1exv99wx2yxryx2y.htm CODE OF ETHICS DATED FEBRUARY 2011 OF THE SUBADVISER
Code of Ethics
Manulife Asset Management (US) is required by law to adopt a Code of Ethics. The purposes of a Code of Ethics are to ensure that companies and their “covered employees”1 comply with all applicable laws and to prevent abuses in the investment advisory business that can arise when conflicts of interest exist between the employees of an investment advisor and its clients. By adopting and enforcing a Code of Ethics, we strengthen the trust and confidence entrusted in us by demonstrating that at Manulife Asset Management (US), client interests come first.
The Code of Ethics (the “Code”) that follows represents a balancing of important interests. On the one hand, as a registered investment adviser, Manulife Asset Management (US) owes a duty of undivided loyalty to its clients, and must avoid even the appearance of a conflict that might be perceived as abusing the trust they have placed in Manulife Asset Management (US). On the other hand, Manulife Asset Management (US) does not want to prevent conscientious professionals from investing for their own accounts where conflicts do not exist or that are immaterial to investment decisions affecting the Manulife Asset Management (US) clients.
When conflicting interests cannot be reconciled, the Code makes clear that, first and foremost, covered employees owe a fiduciary duty to Manulife Asset Management (US) clients. In most cases, this means that the affected employee will be required to forego conflicting personal securities transactions. In some cases, personal investments will be permitted, but only in a manner, which, because of the circumstances and applicable controls, cannot reasonably be perceived as adversely affecting Manulife Asset Management (US) client portfolios or taking unfair advantage of the relationship Manulife Asset Management (US) employees have to Manulife Asset Management (US) clients.
The Code contains specific rules prohibiting defined types of conflicts. Since every potential conflict cannot be anticipated by the Code, it also contains general provisions prohibiting conflict situations. In view of these general provisions, it is critical that any covered employee who is in doubt about the applicability of the Code in a given situation seek a determination from Code of Ethics Administration or the Chief Compliance Officer about the propriety of the conduct in advance.
It is critical that the Code be strictly observed. Not only will adherence to the Code ensure that Manulife Asset Management (US) renders the best possible service to its clients, it will help to ensure that no individual is liable for violations of law.
It should be emphasized that adherence to this policy is a fundamental condition of employment at Manulife Asset Management (US). Every covered employee is expected to adhere to the requirements of the Code despite any inconvenience that may be involved. Each employee is expected to adhere to the highest standard of professional and ethical conduct and should be sensitive to situations that may give rise to an actual conflict or the appearance of a conflict with our clients’ interests, or have the potential to cause damage to the Manulife Asset Management (US) or its affiliates’ reputation. To this end, each employee must act with integrity, honesty, dignity and in a highly ethical
manner. Each employee is also required to comply with all applicable securities laws. Moreover, each employee must exercise reasonable care and professional judgment to avoid engaging in actions that put the image of Manulife Asset Management (US) or its reputation at risk. While it is not possible to anticipate all instances of potential conflict or unprofessional conduct, the standard is clear. Any covered employee failing to do so may be subject to disciplinary action, including financial penalties and termination of employment in conjunction with the Manulife Asset Management (US) Schedule of Fines and Sanctions or as determined by Senior Management of Manulife Asset Management (US).
This Code recognizes that our fiduciary obligation extends across all of our affiliates, satisfies our regulatory obligations and sets forth the policy regarding employee conduct in those situations in which conflicts with our clients’ interests are most likely to develop.
1 “Covered employees” includes all “supervised persons” as defined under SEC Rule 204A-1 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”).

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Table of Contents

Section 1: General Principles |  |  | 1 |
Section 2: To Whom Does This Code Apply? |  |  | 1 |
Section 3: Which Accounts and Securities are Subject to the Code’s Personal Trading Requirements? |  |  | 4 |
Preferred Brokerage Account Requirements: |  |  | 5 |
Section 4: Overview of Policies |  |  | 6 |
Section 5: Policies in the Code of Ethics |  |  | 7 |
Restriction on Gifts |  |  | 7 |
John Hancock Affiliated Funds Reporting Requirement and Holding Period |  |  | 7 |
Pre-clearance Requirement of Securities Transactions |  |  | 8 |
Pre-clearance of Manulife Financial Corporation securities |  |  | 8 |
Heightened Pre-clearance of Securities Transactions for “Significant Personal Positions” |  |  | 9 |
Ban on Short-Term Profits |  |  | 9 |
Ban on IPO’s |  |  | 9 |
Ban on Speculative Transactions in MFC |  |  | 10 |
Ban on Restricted Securities |  |  | 10 |
Excessive Trading |  |  | 10 |
Disclosure of Private Placement Conflicts |  |  | 10 |
Seven Day Blackout Period |  |  | 10 |
Restriction on Securities under Active Consideration |  |  | 11 |
Section 6: Policies Outside of the Code of Ethics |  |  | 11 |
MFC Code of Business Conduct & Ethics |  |  | 11 |
Manulife Asset Management (US) Insider Trading Policy |  |  | 12 |
Manulife Asset Management (US) Portfolio Holdings Disclosure Policy |  |  | 12 |
MFC Anti-Fraud Policy |  |  | 12 |
MFC Electronic Communications Disclosure Guidelines |  |  | 12 |
Section 7: Reports and Other Disclosures outside the Code of Ethics |  |  | 13 |
Broker Letter/Duplicate Confirm Statements |  |  | 13 |
Investment Professional Disclosure of Personal Securities Conflicts |  |  | 13 |
Section 8: Reporting Requirements and Other Disclosures inside the Code of Ethics |  |  | 14 |
Initial Holdings Report and Annual Holdings Report |  |  | 14 |
Reporting of Gifts, Donations, and Inheritances |  |  | 14 |
Trading in Broad Based Stock Index Futures and Options |  |  | 14 |
Quarterly Transaction Certification |  |  | 14 |
Quarterly Brokerage Account Certification |  |  | 15 |
Annual Certification of the Code |  |  | 16 |
Section 9: Reporting Violations |  |  | 16 |
Section 10: Interpretation and Enforcement |  |  | 16 |
Section 11: Exemptions & Appeals |  |  | 17 |
Section 12: Education of Employees |  |  | 17 |
Section 13: Recordkeeping |  |  | 17 |
Section Appendix A: Access Person Categories |  |  | 17 |
Section Appendix B: Affiliated Funds — December 2009 |  |  | 19 |
Section Appendix C: Pre-clearance Procedures |  |  | 27 |
Section Appendix D: Investment Professional Disclosure of Personal Securities Conflicts |  |  | 29 |
Section Appendix E: Manulife Asset Management (US) Schedule of Fines and Sanctions |  |  | 30 |
Section Appendix F: Chief Compliance Officer and Compliance Contacts |  |  | 31 |

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1: General Principles
Each covered employee within the Manulife Asset Management (US) organization is responsible for maintaining the very highest ethical standards when conducting our business.
This means that:

| • |  | You have a fiduciary duty at all times to place the interests of our clients and fund investors first.
| • |  | All of your personal securities transactions must be conducted consistent with the provisions of the Code that apply to you 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 front-running or manipulative market timing) with respect to our clients’ accounts or fund investors.
| • |  | You must treat as confidential any information concerning the identity of security holdings and financial circumstances of clients or fund investors.
| • |  | You must comply with all applicable federal securities laws, which, for purposes of the Code, means the Securities Act of 1933, as amended (the “Securities Act”), the Securities Exchange Act of 1934, the Sarbanes-Oxley Act of 2002, Rule 204A-1 of the Advisers Act of 1940, as amended, Title V of the Gramm-Leach-Bliley Act, any rules adopted by the SEC under any of these statutes, the Bank Secrecy Act as it applies to funds and investment advisers, and any rules adopted thereunder by the SEC or the Department of the Treasury.
| • |  | The term “Employee” for purposes of this Code, includes all employees, including temporary personnel compensated directly by Manulife Asset Management (US) and other temporary personnel to the extent that their tenure with Manulife Asset Management (US) exceeds 90 days.
| • |  | All employees are subject to this Code and adherence to the Code is a basic condition of employment. If an employee has any doubt as to the appropriateness of any activity, believes that he or she has violated the Code, or becomes aware of a violation of the Code by another employee, he or she should promptly consult the Chief Compliance Officer of Manulife Asset Management (US) — see Appendix F.
| • |  | It is essential that you understand and comply with the general principles, noted above, in letter and in spirit as no set of rules can anticipate every possible problem or conflict situation.

As described in section 10 “Interpretation and Enforcement” on page 18 of the Code, failure to comply with the general principles and the provisions of the Code may result in disciplinary action, including termination of employment.
2: To Whom Does This Code Apply?
This Code applies to you if you are:
A director, officer or other “supervised employee”2 of Manulife Asset Management (US);
Please note that if a policy described below applies to you, it also applies to all accounts over which you have a beneficial interest. Normally, you will be deemed to have a beneficial interest in your personal accounts, those of a spouse, “significant other,” minor children or family members sharing the same 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 categories for persons covered by the Code, 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 Code of Ethics Administration’s understanding of your current role.
2 A “supervised employee” is defined by the Advisers Act to mean a partner, officer, director (or other person occupying a similar status or performing similar functions) or employee, as well as any other person who provides advice on behalf of the adviser and is subject to the adviser’s supervision and control. However, in reliance on the Prudential no-action letter, Manulife Asset Management (US) does not treat as a “supervised employee” any of its “non-advisory personnel”, as defined below. In reliance on the Prudential no-action letter, Manulife Asset Management (US) treats as an “advisory person” any “supervised employee” who is involved, directly, or indirectly, in Manulife Asset Management (US)’s investment advisory activities, as well as any “supervised employee” who is an “access person”. Manulife Asset Management (US) treats as “non-advisory personnel”, and does not treat as a “supervised person”, those individuals who have no involvement, directly or indirectly, in Manulife Asset Management (US)’s investment advisory activities, and who are not “access persons”

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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 Code of Ethics Administration.sharing the same 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.

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Access Person Categories:
The basic definitions of three categories, with examples, are provided below. The more detailed definitions of each category are attached as Appendix A.

“Access Level I” |  | “Access Level II” |  | “Access Level III”
Investment Access |  | Regular Access |  | Periodic Access
A person who, in connection with his/her regular functions or duties, makes or participates in making recommendations regarding the purchase or sale of securities for any John Hancock Affiliated Fund or account advised by Manulife Asset Management (US)3. Examples: |  | A person who, in connection with his/her regular functions or duties, has regular access to nonpublic information regarding any clients’ purchase or sale of securities, or nonpublic information regarding the portfolio holdings of any John Hancock Affiliated Fund or account advised by Manulife Asset Management (US) who has regular access to securities recommendations that are made to clients of Manulife Asset Management (US). Examples: |  | A person who, in connection with his/her regular functions or duties, has periodic access to non-public information regarding any clients’ purchase or sale of securities, or non-public information regarding the portfolio holdings of any John Hancock Affiliated Fund or account advised by Manulife Asset Management (US). Examples:
• Portfolio Managers |  | • Office of the CCO |  | • Business Financial Analysts
• Analysts |  | • Investment Operations |  | • Technical Associates
• Traders |  | • Administration |  | • Select Technical Resources Associates
• Administrative Personnel for Access Level I Persons |  | • Technology Resources Personnel |  |
|  | • Private Client Group Personnel |  |
|  | • Legal Staff |  |
|  | • Sales/Marketing |  |
|  | • Client Service & Products |  |
|  | • Administrative Personnel for Access Level II Persons |  |

3 A John Hancock Affiliated Fund includes any fund advised by either John Hancock Advisers, LLC or John Hancock Investment Management Services, LLC (“John Hancock Advisers”). A complete list of the John Hancock Affiliated Funds is included in appendix B.

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3: Which Accounts and Securities are Subject to the Code’s Personal Trading Requirements?
If the Code describes “Personal Trading Requirements” (i.e., John Hancock Mutual Fund reporting requirement and holding period, the pre-clearance requirement, the ban on short-term profits, the ban on IPO’s, the disclosure of private placement conflicts and the reporting requirements) that apply to your access category as described above, then the requirements apply to trades for any account in which you have a beneficial interest. A covered employee is considered to have a beneficial interest in any transaction in which the employee has the opportunity to directly or indirectly profit or share in the profit derived from the securities transacted. An employee is presumed to have a beneficial interest in, and therefore an obligation to pre-clear and report, the following:

| • |  | Securities owned by a covered employee in his or her name.
| • |  | Securities owned by an individual covered employee indirectly through an account or investment vehicle for his or her benefit, such as an IRA, family trust or family partnership.
| • |  | Securities owned in which the covered employee has a joint ownership interest, such as property owned in a joint brokerage account.
| • |  | Securities owned by trusts, private foundations or other charitable accounts for which the covered employee has investment discretion (other than client accounts of the firm).

Typically, this includes 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. This includes all brokerage accounts that contain securities (including brokerage accounts that only contain securities exempt from reporting, e.g., brokerage accounts holding shares of non-affiliated mutual funds).
This also includes all accounts holding John Hancock Affiliated Funds as well as accounts in the Manulife Asset Management (US) Share Ownership Plan.
Accounts over which you have no direct or indirect influence or control are exempt. To prevent potential violations of the Code, you are strongly encouraged to submit a written request for clarification for any accounts that are in question.
These personal trading requirements do not apply to the following securities:

| • |  | Direct obligations of the U.S. Government (e.g., treasury securities) and indirect obligations of the U.S. Government having less than one year to maturity;
| • |  | Securities Futures and options on direct obligations of the U.S. Government;
| • |  | Bankers’ acceptances, bank certificates of
| • |  | deposit, commercial paper, and high quality short-term debt obligations, including repurchase agreements;
| • |  | Shares issued by money market funds and all other open-end mutual funds registered under the 1940 Act that are not advised or sub-advised by a John Hancock Adviser or another Manulife entity4;
| • |  | Commodities and options and futures on commodities;
| • |  | Securities in accounts over which you have no direct or indirect influence or control;
| • |  | Variable insurance products not managed by a John Hancock Adviser or another Manulife entity; and
| • |  | Foreign currency transactions.

Except as noted above, the Personal Trading Requirements apply to all securities, including the following and therefore must be precleared and reported:

| • |  | Stocks;
| • |  | Bonds;
| • |  | Government securities that are not direct obligations of the U.S. Government, such as Fannie Mae, or municipal securities, in each case that mature in more than one year;
| • |  | John Hancock Affiliated Funds;
| • |  | Closed-end funds;
| • |  | Options on securities, on indexes, and on currencies;
| • |  | Broad based stock index futures and options5;
| • |  | Interest rate swaps;
| • |  | Limited partnerships and limited liability company
| • |  | interests;

4 Different requirements apply to shares of John Hancock Affiliated Funds. See the section titled “John Hancock Affiliated Funds Reporting Requirement and Holding Period” on page 8 of this Code. A list of Affiliated Funds can be found in Appendix B.
5 No pre-clearance requirement on broad based stock index futures and options but trading activity in these securities need to be reported. Please see “Trading in Broad Based Stock Index Futures and Options” on page 16 of this Code.

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| • |  | Exchange traded funds;
| • |  | Domestic unit investment trusts;
| • |  | Non-US unit investment trusts and non-US mutual funds;
| • |  | Private investment funds and hedge funds;
| • |  | Futures, investment contracts or any other instrument that is considered a “security” under the Securities Act of 1933; and
| • |  | Warrants, rights, etc., whether publicly traded or privately held.

Preferred Brokerage Account Requirements:
This rule applies to new access persons commencing employment after March 1, 2008.
While employed by Manulife Asset Management (US), you must maintain your accounts at one of the preferred brokers approved by Manulife Asset Management (US). The following are the preferred brokers for you to maintain your covered accounts:

| • |  | Charles Schwab
| • |  | Citigroup Smith Barney
| • |  | E*trade
| • |  | Fidelity
| • |  | Merrill Lynch
| • |  | Morgan Stanley
| • |  | Scottrade
| • |  | TDAmeritrade
| • |  | UBS Financial

Exceptions: With approval from Code of Ethics Administration, you can maintain a brokerage account at a broker/dealer other than the ones listed above if any of the following applies:

| • |  | it contains only securities that can’t be transferred;
| • |  | it exists solely for products or services that one of the above broker/dealers cannot provide;
| • |  | it exists solely because your spouse’s or significant other’s employer prohibits external covered accounts;
| • |  | it is managed by a third-party registered investment adviser;
| • |  | it is restricted to trading interests in non-John Hancock 529 College Savings Plans;
| • |  | it is associated with an ESOP (employee stock option plan) or an ESPP (employee stock purchase plan) in which a related covered person is the participant;
| • |  | it is required by a direct purchase plan, a dividend reinvestment plan, or an automatic investment plan with a public company in which regularly scheduled investments are made or planned;
| • |  | it is required by a trust agreement;
| • |  | it is associated with an estate of which you are the executor, but not a beneficiary, and your involvement with the account is temporary; or
| • |  | transferring the account would be inconsistent with other applicable rules.

What do I need to do to comply?
You will need to transfer assets of current brokerage accounts to one of the preferred brokers/dealers listed above within 45 days of commencement of employment and close your current accounts.
Or
You should contact Code of Ethics Administration to obtain an exemption request form to request permission to maintain a brokerage account with a broker/dealer not on Manulife Asset Management (US)’s preferred broker list.

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4: Overview of Policies

|  | Access Level |  |  | Access Level |  |  | Access Level |
|  | I Person |  |  | II Person |  |  | III Person |
General principles |  | Yes |  | Yes |  | Yes
Restrictions on gifts |  | Yes |  | Yes |  | Yes
Reporting requirement and holding period for positions in John Hancock Affiliated Funds |  | Yes |  | Yes |  | Yes
Pre-clearance requirement |  | Yes |  | Yes |  | Limited
Pre-clearance requirement for initial public offerings (“IPO’s”) |  | Prohibited |  | Yes |  | Yes
Heightened pre-clearance of securities transactions for “significant personal positions” |  | Yes |  | No |  | No
Pre-clearance requirement on private placements/limited offerings |  | Yes |  | Yes |  | Yes
Ban on IPO’s |  | Yes |  | No |  | No
Ban on short-term profits |  | Yes |  | Yes |  | No
Seven day blackout period rule |  | Yes |  | Yes |  | No
Ban on speculative trading in Manulife Financial Corporation stock |  | Yes |  | Yes |  | Yes
Reporting of gifts, donations, and inheritances |  | Yes |  | Yes |  | Yes
Duplicate confirms & statements |  | Yes |  | Yes |  | Yes
Initial & annual certification of the Code |  | Yes |  | Yes |  | Yes
Initial & annual holdings reporting |  | Yes |  | Yes |  | Yes
Quarterly personal transaction reporting |  | Yes |  | Yes |  | Yes
Disclosure of private placement conflicts |  | Yes |  | No |  | No
Manulife Financial Corporation Code of Business Conduct & Ethics |  | Yes |  | Yes |  | Yes
John Hancock Insider Trading Policy |  | Yes |  | Yes |  | Yes
Policy regarding dissemination of portfolio information |  | Yes |  | Yes |  | Yes
Investment Professional Personal Security Ownership Disclosure |  | Yes |  | No |  | No

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5: Policies in the Code of Ethics
Restriction on Gifts
Applies to: All Access Levels
You and your family cannot accept preferential treatment or favors (e.g., gifts) from securities brokers/ dealers or other organizations with which Manulife Asset Management (US) might transact business, except in accordance with the Manulife Financial Corporation (MFC) Code of Business Conduct and Ethics, and Manulife Asset Management (US) Gift Policy. For the protection of both you and Manulife Asset Management (US), the appearance of a possible conflict of interest must be avoided. You may not accept travel and lodging which is paid for by someone other than Manulife Asset Management (US) without prior approval from your business head and your Chief Compliance Officer. The purpose of this policy is to minimize the basis for any charge that you used your Manulife Asset Management (US) position to obtain for yourself opportunities which otherwise would not be offered to you.
John Hancock Affiliated Funds Reporting Requirement and Holding Period
Applies to: All Access Levels
You must follow the reporting requirement and the holding period requirement specified below if you purchase either:

| • |  | a “John Hancock Mutual Fund” (i.e., a 1940 Act Mutual Fund that is advised or sub-advised by John Hancock Advisers or by another Manulife entity);
| • |  | a “John Hancock Variable Product” (i.e., contracts funded by insurance company separate accounts that use one or more portfolios of John Hancock Trust); or
| • |  | any other mutual fund advised or sub advised by Manulife Asset Management (US)

The reporting requirement and the holding period requirement for positions in John Hancock Affiliated Funds do not include money market funds and any dividend reinvestment, payroll deduction, systematic investment/withdrawal and/or other program trades.
Reporting Requirement: You must report your holdings and your trades in a John Hancock Affiliated Fund held in an outside brokerage account. This is not a pre-clearance requirement, you can report your holdings after you trade by submitting duplicate confirmation statements to Code of Ethics Administration. If you are an Access Level I Person, Access Level II Person, or Access Level III Person, you must also make sure that your holdings in a John Hancock Affiliated Fund are included in your Initial Holdings Report (upon hire or commencement of access designation).
If you purchase a John Hancock Variable Product, you must notify Code of Ethics Administration of your contract or policy number.
Code of Ethics Administration will rely on the operating groups of John Hancock for administration of trading activity, holdings and monitoring of market timing policies for John Hancock Affiliated Funds. Accordingly employees will not be required to file duplicate transaction and holdings reports for these products as long as the accounts holding these products are held with the respective John Hancock operating group, i.e. John Hancock Signature Services, Inc. and the contract administrators supporting the John Hancock variable products.
Code of Ethics Administration will have access to this information upon request.
Holding Requirement: You cannot profit from the purchase and sale of a John Hancock Affiliated Fund advised by Manulife Asset Management (US) within 30 calendar days. The purpose of this policy is to address the risk, real or perceived, of manipulative market timing or other abusive practices involving short-term personal trading in the John Hancock Affiliated Funds. Any profits realized on short-term trades must be surrendered by check payable to John Hancock Advisers, LLC, which will be contributed to a charity of its choice. You may request an exemption from this policy for involuntary sales due to unforeseen corporate activity (such as a merger), or for sales due to hardship reasons (such as unexpected medical expenses) by sending an e-mail to the Chief Compliance Officer.

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Pre-clearance Requirement of Securities Transactions
Applies to: Access Level I and Access Level II Persons Also, for a limited category of trades: Access Level III Persons
Access Level I Persons and Access Level II Persons: If you are an Access Level I Person or Access Level II Person, you must “pre-clear” (i.e., receive advance approval of) any personal securities transactions in the categories described in Section 3: “Which Accounts and Securities are Subject to the Code’s Personal Trading Requirements” on page 4 of the Code.
Clearance for personal securities transactions will be in effect solely for the day on which they were approved.
Due to this pre-clearance requirement, participation in investment clubs and special orders, such as “good until canceled orders” and “limit orders,” are prohibited.
Place day orders only, i.e., orders that automatically expire at the end of the trading session. Be sure to check the status of all orders at the end of the trading day and cancel any orders that have not been executed. If any Access Person leaves an order open and it is executed the next day (or later), the transaction will constitute a violation of the Code.
Limited Category of Trades for Access Level III Persons: If you are an Access Level III Person, you must pre-clear transactions in securities of any closed-end funds advised by Manulife Asset Management (US) or a John Hancock Adviser, as well as transactions in IPO’s, private placements and limited offerings. An Access Level III Person is not required to pre-clear other trades. However, please keep in mind that an Access Level III Person is required to report securities transactions after every trade (even those that are not required to be pre-cleared) by requiring your broker to submit duplicate confirmation statements, as described in section 7 of the Code.
Pre-clearance of IPO’s, Private Placements and Limited Offerings: Pre-clearance requests for these securities require some special considerations; the decision will take into account whether, for example: (1) the investment opportunity should be reserved for Manulife Asset Management (US) clients; and (2) is it being offered to you because of your position with Manulife Asset Management (US) and other relevant factors on a case-by-case basis. A separate procedure should be followed for requesting pre-clearance on these securities. See Appendix C.
Pre-clearance of Manulife Financial Corporation securities
Applies to: Access Level I and Access Level II Persons
All personal transactions in MFC securities including stock, company issued options, and any other securities such as debt must be pre-cleared excluding trades in the Manulife Asset Management (US) Share Ownership Plan.
Pre-clearance Process: You may pre-clear a trade through the Personal Trading & Reporting System by following the steps outlined in the pre-clearance procedures. See Appendix C.
Please note that:

| • |  | You may not trade until clearance approval is received
| • |  | Clearance approval is valid only for the date granted (i.e., the pre-clearance requested date and the trade date should be the same)
| • |  | A separate procedure should be followed for requesting pre-clearance of an IPO, a private placement, a limited offering as detailed in Appendix C.

Code of Ethics Administration must maintain a five-year record of all pre-clearances of private placement purchases by Access Level I Persons, and the reasons supporting the clearances.
The pre-clearance policy is designed to proactively identify potential “problem trades” that raise front-running, manipulative market timing or other conflict of interest concerns (i.e., when an Access Level I Person trades a security on the same day as a John Hancock Affiliated Fund). Certain transactions in securities that would normally require pre-clearance are exempt from the pre-clearance requirement in the following situations: (1) shares are being purchased as part of an automatic investment plan; (2) shares are being purchased as part of a dividend reinvestment plan; or (3) transactions are being made in an account over which you have designated a third party as having discretion to trade (you must have approval from the Chief Compliance Officer to establish a discretionary account).

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Heightened Pre-clearance of Securities Transactions for “Significant Personal Positions”
Applies to: Access Level I Persons
If you are an Access Level I Person with a personal securities position that is worth $100,000 or more, this is deemed to be a “Significant Personal Position”. This applies to any personal securities positions in the categories described above in the section “Which Accounts and Securities are Subject to the Code’s Personal Trading Requirements”. Before you make personal trades to establish, increase or decrease a Significant Personal Position, you must notify either the Chief Fixed Income Officer or the Chief Equity Officer that (1) you intend to trade in a Significant Personal Position and (2) confirm that you are not aware of any clients for whom related trades should be completed first. You must receive their pre-approval to proceed. Their approval will be based on their conclusion that your personal trade in a Significant Personal Position will not “front-run” any action that John Hancock Affiliated Funds should take for a client. This heightened pre-clearance requirement is in addition to, not in place of, the regular pre-clearance requirement described above—you must also receive the regular pre-clearance before you trade.
Ban on Short-Term Profits
Applies to: Access Level I and Access Level II Persons
If you are an Access Level I Person or Access Level II Person, you cannot profit from the purchase and sale (or sale and purchase) of the same (or equivalent) securities within 60 calendar days. This applies to any personal securities trades in the categories described in Section 3: “Which Accounts and Securities are Subject to the Code’s Personal Trading Requirements” on page 4 of the Code, except for personal security trades of John Hancock Affiliated Funds which you can not profit from within 30 days.
You may invest in derivatives, excluding certain equity options on MFC securities6 or sell short provided the transaction period exceeds the 60-day holding period.Remember, if you donate or gift a security, it is considered a sale and is subject to this rule.
This restriction does not apply to trading within a sixty calendar day period if you do not realize a profit.
The purpose of this policy is to address the risk, real or perceived, of front-running, manipulative market timing or other abusive practices involving short-term personal trading. Any profits in excess of $100.00 realized on short-term trades must be surrendered by check payable to John Hancock Advisers, LLC, which will be contributed to a charity of its choice.
You may request an exemption from this policy for involuntary sales due to unforeseen corporate activity (such as a merger), or for sales due to hardship reasons (such as unexpected medical expenses) from Code of Ethics Administration. In addition, transactions in securities with the following characteristics will typically be granted an exemption from this provision.
Large Cap Securities Exception: Pre-clearance requests in a security with a market capitalization of $5 billion or more would, in most cases, not be subject to, the ban on short-term profits rule because management determined that transactions in these types of companies do not present any conflict of interest to the John Hancock Affiliated Funds.
Ban on IPO’s
Applies to: Access Level I Persons
If you are an Access Level I Person, you may not acquire securities in an IPO. You may not purchase any newly-issued securities until the next business (trading) day after the offering date. This applies to any personal securities trades in the categories described above in the section “Which Accounts and Securities are Subject to the Code’s Personal Trading Requirements”.
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 Manulife Asset Management (US) clients was diverted to the personal benefit of an individual employee.
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; (2) fixed rights offerings; or (3) a family member’s participation as a form of employment compensation in their employer’s IPO.

6 |  | You may not buy put options and sell call options or sell short securities of MFC.

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Ban on Speculative Transactions in MFC
Applies to: All Access Levels
All Covered employees under this Code are prohibited from engaging in speculative transactions involving securities of MFC, since these transactions might be seen as evidencing a lack of confidence in, and commitment to, the future of MFC or as reducing the incentive to maximize the performance of MFC and its stock price. Accordingly, all covered employees, as well as their family members, are prohibited from entering into any transaction involving MFC securities for their personal account which falls into the following categories:

| • |  | Short sales of MFC securities
| • |  | Buying put options or selling call options on MFC securities

Ban on Restricted Securities
Applies to: All Access Levels
No pre-clearance will be approved for securities appearing on the Manulife Asset Management (US) Restricted List.
Securities are placed on the Restricted List if:

| • |  | Manulife Asset Management (US) or a member of Manulife Asset Management (US) has received material non-public inside information on a security or company; or
| • |  | In the judgment of the Legal Department, circumstances warrant addition of a security to this list

The Restricted List is a confidential list of companies that is maintained in the possession of the Legal Department.
Excessive Trading
Applies to: All Access Levels
While active personal trading may not in and of itself raise issues under applicable laws and regulations, we believe that a very high volume of personal trading can be time consuming and can increase the possibility of actual or apparent conflicts with portfolio transactions. Accordingly, an unusually high level of personal trading activity is strongly discouraged and may be monitored by Code of Ethics Administration to the extent appropriate for the category of person, and a pattern of excessive trading may lead to the taking of appropriate action under the Code.
An Access Person effecting more than 45 trades in a quarter, or redeeming shares of a John Hancock Affiliated Fund within 30 days of purchase, should expect additional scrutiny of his or her trades and he or she may be subject to limitations on the number of trades allowed during a given period.
Disclosure of Private Placement Conflicts
Applies to: Access Level I Persons
If you are an Access Level I Person and you own securities purchased in a private placement, you must disclose that holding when you participate in a decision to purchase or sell that same issuer’s securities for a John Hancock Affiliated Fund. This applies to any private placement holdings in the categories described above in Section 3: “Which Accounts and Securities are Subject to the Code’s Personal Trading Requirements” on page 4 of the Code. Private placements are securities exempt from SEC registration under section 4(2), section 4(6) and/or rules 504 — 506 under the Securities Act.
The investment decision must be subject to an independent review by investment personnel with no personal interest in the issuer.
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
Applies to: Access Level I and Access Level II Persons
Blackout Periods: No Access person may engage in covered security transactions involving securities or instruments which the access person knows are actively contemplated for transactions on behalf of clients, even through no buy or sell orders have been placed. This restriction applies from the moment that an access person has been informed in any fashion that any Portfolio Manager intends to purchase or sell a specific security or instrument. In this area each access person must exercise caution to avoid actions which, to his or her knowledge, are in conflict or in competition with the interests of clients.
An Access Level I Person is prohibited from buying or selling a security within seven calendar days before and after that security is traded for a fund that the person manages unless no conflict of interest exists in relation to that security (as determined by Senior Management of Manulife Asset Management (US).

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In addition, Access Level I and Access Level II 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 Affiliated Fund unless no conflict of interest exists in relation to that security. This applies to any personal securities trades in the categories described above in section 3: “Which Accounts and Securities are Subject to the Code’s Personal Trading Requirements” on page 4 of the Code. If a John Hancock Affiliated Fund trades in a security within seven calendar days before or after an Access Level I and Access Level II Person trades in that security, the person may be required to demonstrate that he or she did not know that the trade was being considered for that John Hancock Affiliated 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 (as determined by Senior Management of Manulife Asset Management (US). Any profits realized on trades determined by Senior Management of Manulife Asset Management (US) to be in violation of this policy must be surrendered by check payable to John Hancock Advisers, LLC, which will be contributed to a charity of its choice.
Restriction on Securities under Active Consideration
Applies to: Access Level I and Access Level II Persons
Access Level I and Access Level II Persons are prohibited from buying or selling a security if the security is under active consideration by a John Hancock Affiliated Fund.
Exceptions: The Personal Trading and Reporting System will utilize the following exception criteria when determining approval or denial of pre-clearances requests:
De Minimis Trading Rule: Pre-clearance requests for 500 shares or less of a particular security with a market value of $25,000.00 or less, aggregated daily, would, in most cases, not be subject to the blackout period restrictions and the restriction on actively traded securities because management has determined that transactions of this size do not present any conflict of interest as long as the requestor is not associated with the conflicting fund or account.
Large Cap Securities Exception: Pre-clearance requests in a security with a market capitalization of $5 billion or more would in most cases, not be subject to the blackout period restrictions and the restriction on actively traded securities because management determined that transactions in these types of companies do not present any conflict of interest as long as the requestor is not associated with the conflicting fund or account.
6: Policies Outside of the Code of Ethics
Information acquired in connection with employment by the organization, including information regarding actual or contemplated investment decisions, portfolio composition, research, research recommendations, firm activities, or client interests, is confidential and may not be used in any way that might be contrary to, or in conflict with the interests of clients or the firm. Employees are reminded that certain clients have specifically required their relationship with Manulife Asset Management (US) to be treated confidentially.
There are certain policies that apply to Manulife Asset Management (US) that are not part of the Code, but are equally important. Five important policies are the: (1) Manulife Asset Management (US) Code of Business Conduct & Ethics; (2) John Hancock Insider Trading Policy; (3) Manulife Asset Management (US) Portfolio Holdings Disclosure Policy; (4) Manulife Financial Corporation Anti-Fraud Policy; and (5) Electronic Communication Disclosure Guidelines.
MFC Code of Business Conduct & Ethics
Applies to: All Covered Employees
The MFC Code of Business Conduct and Ethics (the “MFC Code”) provides standards for ethical behavior when representing the Company and when dealing with employees, field representatives, customers, investors, external suppliers, competitors, government authorities and the public.
The MFC Code applies to directors, officers and employees of MFC, its subsidiaries and controlled affiliates. Sales representatives and third party business associates are also expected to abide by all applicable provisions of the MFC Code and adhere to the principles and values set out in the MFC Code when representing Manulife to the public or performing services for, or on behalf of, Manulife.
Other important issues in the MFC Code include:

| • |  | MFC values — P.R.I.D.E.;
| • |  | Ethics in workplace;
| • |  | Ethics in business relationships;
| • |  | Misuse of inside information;
| • |  | Receiving or giving of gifts, entertainment or favors;

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| • |  | Misuse or misrepresentation of your corporate position;
| • |  | Disclosure of confidential or proprietary information;
| • |  | Disclosure of outside business activities;
| • |  | Antitrust activities; and
| • |  | Political campaign contributions and expenditures relating to public officials.

Manulife Asset Management (US) Insider Trading Policy
Applies to: All Covered Employees
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 Access Level I Persons are most likely to come in contact with material non-public information, the rules (and sanctions) in this area apply to all persons covered under this code and extend to activities both related and unrelated to your job duties.
The Manulife Asset Management (US) Insider Trading Policy (the “Insider Trading Policy”) covers a number of important issues, such as:

| • |  | The misuse of material non-public information;
| • |  | The information barrier procedure;
| • |  | The “restricted list”; and
| • |  | Broker letters and duplicate confirmation statements (see section 7: “Reports and Other Disclosures outside the Code of Ethics” on page 15 of the Code).

Manulife Asset Management (US) Portfolio Holdings Disclosure Policy
Applies to: All Covered Employees
Information about securities held in a John Hancock Affiliated Fund or any other client portfolio sub-advised by Manulife Asset Management (US) cannot be disclosed except in accordance with the Portfolio Holdings Disclosure Policy, which generally requires time delays of approximately one month and public posting of the information to ensure that it uniformly enters the public domain.
MFC Anti-Fraud Policy
Applies to: All Covered Employees
The prevention, identification, and detection of fraud are vital to Manulife Financial Corporation. The Anti-Fraud Policy describes the framework within which the Company strives to: (1) prevent, identify, and detect fraud; and (2) ensures that adequate controls are in place to accomplish those objectives.
Suspicions or allegations of possible fraud, fraudulent activity, and dishonest activity in relation to the Company shall be handled by all MFC directors, officers, and employees on a timely basis and with the utmost care. Failure to do so may result in a wide range of risks, including but not limited to reputation risk to the Company.
To maintain the Company’s reputation for conducting business with integrity, any suspicion or allegation of fraud, fraudulent activity, or dishonest activity, in relation to the Company shall be reported promptly and according to the Reporting Protocols and Responsibilities described in the Policy.
MFC Electronic Communications Disclosure Guidelines
Applies to: All Covered Employees
Employees must use e-mail in a professional manner and must not engage in any activity which contravenes the Manulife Financial Code of Business Conduct and Ethics (“Manulife Code of Conduct”) and all e-mail content, attachments, tag lines or signatures must be consistent with the Manulife Code of Conduct.
Employees are reminded that their corporate e-mail address is a Company address and that all correspondence received and sent via e-mail is to be considered corporate correspondence.
Manulife prohibits its employees from participating in Internet chat rooms or newsgroups in discussions relating to the Company or its securities.
Communications over the Internet via e-mail may not be secure. Employees should be aware of the danger of transmitting the Company’s confidential information externally via unencrypted e-mail.
If an employee becomes aware of a rumor on a chat room, newsgroup or any other source, that may have a significant effect on the price of the Company’s share price, they should notify Corporate Communications.

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Non-compliance with these Guidelines may result in disciplinary action against an employee, up to and including termination of employment.
The complete policies can be found on MFCentral under Company Policies/Global Compliance/ Policies.
7: Reports and Other Disclosures outside the Code of Ethics
Broker Letter/Duplicate Confirm Statements
Applies to: All Access Levels
In accordance with Rule 204A-1(b) under the Advisers Act, you are required to report to Code of Ethics Administration each transaction in any reportable security. This applies to any personal securities trades in the categories described above in section 3: “Which Accounts and Securities are Subject to the Code’s Personal Trading Requirements” on page 4 of the Code, as well as trades in John Hancock Affiliated Funds.
To comply with these rules noted above you are required by this Code and by the Insider Trading Policy to inform your broker/dealer that you are employed by a financial institution. Your broker/dealer is subject to certain rules designed to prevent favoritism toward your accounts. You may not accept negotiated commission rates that you believe may be more favorable than the broker grants to accounts with similar characteristics.
When a brokerage account in which you have a beneficial interest is opened you must do the following before any trades are made:

| • |  | Notify the broker/dealer with which you are opening an account that you are an employee of Manulife Asset Management (US) and whether or not you are registered with the Financial Industry Regulatory Authority;
| • |  | Notify Code of Ethics Administration, in writing, to disclose the new brokerage account before you place any trades,

Code of Ethics Administration will notify the broker/ dealer to have duplicate written confirmations of any trade, as well as statements or other information concerning the account, sent to John Hancock, Code of Ethics Administration, 601 Congress Street, 11th Floor, Boston, MA 02210-2805.
Code of Ethics Administration may rely on information submitted by your broker as part of your reporting requirements under the Code.
Investment Professional Disclosure of Personal Securities Conflicts
Applies to: Access Level I Persons
As an investment professional, you must promptly disclose your direct or indirect beneficial interest in a security that is under consideration for purchase or sale in a John Hancock Affiliated Fund or Client account. See Appendix D.
Applies to: All Access Levels
Outside Activities: All outside business affiliations (e.g., directorships, officerships or trusteeships) of any kind or membership in investment organizations (e.g., an investment club) must be approved by the Employee’s Business Manager and cleared by the Chief Compliance Officer or General Counsel prior to the acceptance of such a position to ensure that such affiliations do not present a conflict with our clients’ interests. New Employees are required to disclose all outside business affiliations to their Business Manager upon joining the firm. As a general matter, directorships in public companies or companies that may reasonably be expected to become public companies will not be authorized because of the potential for conflicts that may impede our freedom to act in the best interests of clients. Service with charitable organizations generally will be authorized, subject to considerations related to time required during working hours, use of proprietary information and disclosure of potential conflicts of interest. Employees who engage in outside business and charitable activities are not acting in their capacity as employees of Manulife Asset Management (US) and may not use Manulife Asset Management (US)’s name.
Outside Employment: Employees who are officers of the firm may not seek additional employment outside of Manulife Asset Management (US) without the prior written approval of the Human Resources Department. All new Employees are required to disclose any outside employment to the Human Resources Department upon joining the firm.

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8: Reporting Requirements and Other Disclosures inside the Code of Ethics
Initial Holdings Report and Annual Holdings Report
Applies to: All Access Levels
In accordance with Rule 204A-1(b) under the Advisers Act; you must file an initial holdings report within 10 calendar days after becoming an Access Person. The information must be current as of a date no more than 45 days prior to your becoming an Access Person.
In addition, on an annual basis you must also certify to an annual holdings report within 45 calendar days after the required certification date determined by Code of Ethics Administration. The information in the report must be current as of a date no more than 45 days prior to the date the report is submitted. This applies to any personal securities holdings in the categories described in section 3: “Which Accounts and Securities are Subject to the Code’s Personal Trading Requirements” found on page 4 of the Code. It also includes holdings in John Hancock Affiliated Funds, including holdings in the John Hancock 401(k) plan and variable insurance contracts issued by John Hancock.
You will receive an annual holdings certification request from Code of Ethics Administration. Your annual holdings certification requirement will ask you to log into the John Hancock Personal Trading and Reporting System to certify that the system has accurately captured all your reportable security holdings as of the certification date.
Holdings in John Hancock Affiliated Funds & John Hancock Variable Products must be reported if these holdings are held in an outside brokerage account.
Group Savings and Retirement Services is charged with the administration of the Global Share Ownership Plan. Accordingly employees will not be required to file a duplicate holding report for the shares held in this plan. Code of Ethics Administration will have access to this information upon request.
Prior to certifying, access persons must ensure that they provide all covered holdings on their initial holdings report and further ensure that Code of Ethics Administration capture all covered holdings on their annual reporting requirement. An access person that fails to file by the specified deadline, 10 days on initial reporting and 45 days for annual reporting will, at a minimum, be prohibited from engaging in personal trading until the reporting requirement is made and may give rise to other sanctions.
Even if you have no holdings to report you will be asked to complete this requirement.
Reporting of Gifts, Donations, and Inheritances
Applies to: All Access Levels

| • |  | If you gift or donate shares of a reportable security it is considered a sale and you must notify Code of Ethics Administration of the gift or donation on the date given. You must also make sure the transaction is properly reported on your next quarterly transaction certification.
| • |  | If you receive a gift or inherit a reportable security you must report the new holding to Code of Ethics Administration in a timely manner and you must make sure the holding is properly reported on your next annual holdings certification.

Trading in Broad Based Stock Index Futures and Options
Applies to: All Access Levels
The following Index securities do not require your pre-clearance, yet do require you to report these transactions:

| • |  | Options on, or exchange-traded funds that track, the S&P 100, S&P Midcap 400, S&P 500, FTSE 100, and Nikkei 225

Quarterly Transaction Certification
Applies to: All Access Levels
In accordance with Rule 204A-1(b) under the Advisers Act, on a quarterly basis, all access persons are required to certify that all covered transactions in their brokerage accounts, as well as transactions in John Hancock Affiliated Funds, have been effected in accordance with the Code. Within 30 calendar days after the end of each calendar quarter, you will be asked to log into the John Hancock Personal Trading and Reporting System to certify that the system has accurately captured all transactions for the preceding calendar quarter for accounts and trades which are required to be reported pursuant to section 3: “Which Accounts and Securities are Subject to the Code’s Personal Trading Requirements” on page 4 of the Code.

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Transactions in John Hancock Affiliated Funds and John Hancock Variable Products must be reported if these transactions are executed in an outside brokerage account.
Group Savings and Retirement Services is charged with the administration of the Global Share Ownership Plan. Accordingly employees will not be required to file a duplicate transaction report for this plan. Code of Ethics Administration will have access to this information upon request.
All access persons are required to certify a quarterly report, even if there were no reportable transactions during the quarter.
Prior to certifying, access persons should ensure that Code of Ethics Administration has captured all reportable transactions such as:

| • |  | Transactions in all covered securities
| • |  | Gift Transactions
| • |  | Corporate actions including dividend reinvestments, mergers, stock splits, etc.

For each transaction required to be reported you must certify the following information was captured accurately:

| • |  | the date of the transaction, the title, and as applicable the exchange ticker symbol or CUSIP number, interest rate and maturity date, number of shares, and principal amount of each reportable security involved;
| • |  | the nature of the transaction (i.e. purchase, sale or any other type of acquisition or disposition);
| • |  | the price at which the transaction was effected; and
| • |  | the name of the broker/dealer or bank with or through which the transaction was effected.

At the end of each calendar quarter, access persons will be reminded of the reporting requirement. An access person that fails to certify within the 30 calendar day deadline will, at a minimum, be prohibited from engaging in personal trading until the reporting requirement is made and may give rise to other sanctions.
Quarterly Brokerage Account Certification
Applies to: All Access Levels
On a quarterly basis, all Access Persons will be required to certify to a listing of brokerage accounts as described in section 3: “Which Accounts and Securities are Subject to the Code’s Personal Trading Requirements” on page 4 of the Code. This includes all brokerage accounts, including brokerage accounts that only contain securities exempt from reporting.
This also includes all accounts holding John Hancock Affiliated Funds and John Hancock Variable Products as well as accounts in the Manulife Asset Management (US) Share Ownership Plan.
All access persons are required to certify a quarterly report, even if there were no existing or new accounts to report.
Prior to certifying, access persons should ensure that Code of Ethics Administration has captured all reportable accounts including any new or closed account during the quarter:
Within 30 calendar days after the end of each calendar quarter you will be asked to log into the John Hancock Personal Trading and Reporting System and certify that all brokerage accounts are listed and the following information is accurate:

| • |  | Account number;
| • |  | Account registration; and
| • |  | Brokerage firm

An access person that fails to file within the 30 calendar day deadline will, at a minimum, be prohibited from engaging in personal trading until the reporting requirement is made and may give rise to other sanctions.

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Annual Certification of the Code
Applies to: All Access Levels
At least annually (or additionally when the Code has been materially changed), you must provide a certification at a date designated by Code of Ethics Administration that you:

| 1. |  | have read and understood the Code;
| 2. |  | recognize that you are subject to its policies; and
| 3. |  | have complied with its requirements

You are required to make this certification to demonstrate that you understand the importance of these policies and your responsibilities under the Code.
An access person that fails to certify within the specified deadline will, at a minimum, be prohibited from engaging in personal trading until the reporting requirement is made and may give rise to other sanctions.
9: Reporting Violations
If you know of any violation of the Code, you have a responsibility to promptly report it to the Chief Compliance Officer. You should also report any deviations from the controls and procedures that safeguard Manulife Asset Management (US) and the assets of our clients.
Since we cannot anticipate every situation that will arise, it is important that we have a way to approach questions and concerns. Always ask first, act later. If you are unsure of what to do in any situation, seek guidance before you act.
Speak to your manager, a member of the Human Resources Department or Law Department or the Chief Compliance Officer if you have:

| • |  | a doubt about a particular situation;
| • |  | a question or concern about a business practice; or
| • |  | a question about potential conflicts of interest

You may report suspected or potential illegal or unethical behavior without fear of retaliation. Manulife Asset Management (US) does not permit retaliation of any kind for good faith reports of illegal or unethical behavior.
Concerns about potential or suspected illegal or unethical behavior should be referred to a member of the Human Resources or Law Department.
Unethical, unprofessional, illegal, fraudulent or other questionable behavior may also be reported by calling the confidential toll free Ethics Hotline at 1-866-294-9534 or by visiting www.ManulifeEthics.com.
10: Interpretation and Enforcement
Compliance with the Code is expected and violations of its provisions are taken seriously. Employees must recognize that the Code is a condition of employment with Manulife Asset Management (US) and a serious violation of the Code or related policies may result in dismissal. Since many provisions of the Code also reflect provisions of the US Securities Laws, employees should be aware that violations could also lead to regulatory enforcement action resulting in suspension or expulsion from the securities business, fines and penalties, and imprisonment.
The Code cannot anticipate every situation in which personal interests may be in conflict with the interests of our clients and fund investors. You should be responsive to the spirit and intent of the Code as well as its specific provisions.
When any doubt exists regarding any Code provision or whether a conflict of interest with clients or fund investors might exist, you should discuss the situation in advance with the Chief Compliance Officer. The Code is designed to detect and prevent fraud against clients and fund investors, and to avoid the appearance of impropriety.
The Chief Compliance Officer has general administrative responsibility for the Code as it applies to the covered employees; an appropriate member of Code of Ethics Administration will administer procedures to review personal trading activity. Code of Ethics Administration also regularly reviews the forms and reports it receives. If these reviews uncover information that is incomplete, questionable, or potentially in violation of the rules in this document, Code of Ethics Administration will investigate the matter and may contact you.
Senior Management of Manulife Asset Management (US) approves amendments to the Code of Ethics and dispenses sanctions for violations of the Code of Ethics. Accordingly, Code of Ethics Administration will refer violations to Senior Management for review and recommended action based on the Manulife Asset Management (US) Schedule of Fines and Sanctions. See Appendix E.

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The following factors will be considered when determining 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 or nature of the violation;
| • |  | whether the John Hancock Affiliated Funds 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; and
| • |  | whether the employee self-reported the violation

You should be aware that other securities laws and regulations not addressed by the Code may also apply to you, depending on your role at Manulife Asset Management (US).
Manulife Asset Management (US) Senior Management and the Chief Compliance Officer retain the discretion to interpret the Code’s provisions and to decide how they apply to any given situation.
11: Exemptions & Appeals
Exemptions may be granted where warranted by applicable facts and circumstances. If you believe that you have a situation that warrants an exemption to the any of the rules and restrictions of this Code you need to complete a “Pre-Clearance Exemption Request Form” to request approval from Code of Ethics Administration and/or the Chief Compliance Officer.
Sole Discretion Exemption: A transaction does not need to be pre-cleared if it takes place in an account that Code of Ethics Administration has approved in writing as exempt from the pre-clearance requirement. In the sole discretion of Code of Ethics Administration and the Chief Compliance Officer, accounts that will be considered for exclusion from the pre-clearance requirement are only those for which an employee’s securities broker or investment advisor has complete discretion. Employees wishing to seek such an exemption must complete a “Pre-Clearance Waiver Form for Sole Discretion Accounts” and satisfy all requirements.
These forms can be found on the home page of the John Hancock Personal Trading and Reporting System under “Forms and Filings.”
You will be notified of the outcome of your request by the Code of Ethics Administrator and/or the Chief Compliance Officer.
Appeals: If you believe that your request has been incorrectly denied or that an action is not warranted, you may appeal the decision. To make an appeal, you need to give Code of Ethics Administration a written explanation of your reasons for appeal within 30 days of the date that you were informed of the decision. Be sure to include any extenuating circumstances or other factors not previously considered. During the review process, you may, at your own expense, engage an attorney to represent you. Code of Ethics Administration may arrange for senior management or other parties to be part of the review process.
You will be notified of the outcome of your appeal by the Code of Ethics Administrator and/or the Chief Compliance Officer.
12: Education of Employees
The Code constitutes the Code of Ethics required by Rule 204A-1 under the Advisers Act for Manulife Asset Management (US). Code of Ethics Administration will provide a paper copy or electronic version of the Code (and any amendments) to each person subject to the Code. Code of Ethics Administration will also administer training to employees on the principles and procedures of the Code.
13: Recordkeeping
Code of Ethics Administration will maintain:

| • |  | a copy of the current Code for Manulife Asset Management (US) 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, 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, 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. This record will also indicate who was responsible for reviewing these reports; and
| • |  | a record of any decision, and the reasons supporting the decision, to approve the acquisition by an Access Level 1 Person of an IPO or an access person of a private placement, for six years

Appendix A: Access Person Categories

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You have been notified about which of these categories applies to you, based on Code of Ethics Administration’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 the Chief Compliance Officer of your company.

| 1. |  | Access Level I — Investment Access Person: An associate, officer or non-independent board member of Manulife Asset Management (US) who, in connection with his/her regular functions or duties, makes or participates in making recommendations regarding the purchase or sale of securities by the John Hancock Affiliated Funds (i.e., Portfolio Managers, Analysts, and Traders).
| 2. |  | Access Level II — Regular Access Person: An associate of Manulife Asset Management (US) who, in connection with his/her regular functions or duties, has regular access to nonpublic information regarding any clients’ purchase or sale of securities, or non-public information regarding the portfolio holdings of any John Hancock Affiliated Fund or any Client account advised by Manulife Asset Management (US); or who is involved in making securities recommendations to clients, or who has regular access to such recommendations that are nonpublic (i.e., Office of the Chief Compliance Officer, Administration, Investment Operations, Administrative Personnel supporting Access Level I Persons, Technology Resources Personnel with access to investment systems, Private Client Group Personnel, and anyone else that Code of Ethics Administration deems to have regular access).
| 3. |  | Access Level III — Periodic Access Person: An associate of Manulife Asset Management (US) who, in connection with his/her regular functions or duties, has periodic access to non-public information regarding any clients’ purchase or sale of securities, or non-public information regarding the portfolio holdings of any John Hancock Affiliated Fund or any Client account advised by Manulife Asset Management (US) (i.e., Legal Staff, Client Services and Products, Administrative Personnel supporting Access Level II Persons, and anyone else that Code of Ethics Administration deems to have periodic access).

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Appendix B: Affiliated Funds – December 2009

JOHN HANCOCK FUNDS
Name of Trust and Fund(s): |  | Subadviser for Fund:
Open-End Funds: |  |
John Hancock Bond Trust: |  |
Government Income Fund |  | Manulife Asset Management (US) LLC
High Yield Fund |  | Manulife Asset Management (US) LLC
Investment Grade Bond Fund |  | Manulife Asset Management (US) LLC
John Hancock California Tax-Free Income Fund: |  |
California Tax-Free Income Fund |  | Manulife Asset Management (US) LLC
John Hancock Capital Series: |  |
Classic Value Fund |  | Pzena Investment Management, LLC
U. S. Global Leaders Growth Fund |  | Sustainable Growth Advisers, LP
John Hancock Current Interest: |  |
Money Market Fund |  | Manulife Asset Management (US) LLC
John Hancock Equity Trust: |  |
Small Cap Fund (proposed to merge away in Jan) |  | Lee Munder Capital Group, LLC
John Hancock Investment Trust: |  |
Balanced Fund |  | Manulife Asset Management (US) LLC
Global Opportunities Fund |  | Manulife Asset Management (US) LLC
Large Cap Equity Fund |  | Manulife Asset Management (US) LLC
Small Cap Intrinsic Value Fund |  | Manulife Asset Management (US) LLC
Sovereign Investors Fund |  | Manulife Asset Management (US) LLC
John Hancock Investment Trust II: |  |
Financial Industries Fund |  | Manulife Asset Management (US) LLC
Regional Bank Fund |  | Manulife Asset Management (US) LLC
Small Cap Equity Fund |  | Manulife Asset Management (US) LLC
John Hancock Investment Trust III: |  |
Greater China Opportunities Fund |  | Manulife Asset Management (North America) Limited
John Hancock Municipal Securities Trust: |  |
High Yield Municipal Bond Fund |  | Manulife Asset Management (US) LLC
Tax-Free Bond Fund |  | Manulife Asset Management (US) LLC

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JOHN HANCOCK FUNDS (Cont.)
Name of Trust and Fund(s): |  | Subadviser for Fund:
Open-End Funds: |  |
John Hancock Series Trust: |  |
Mid Cap Equity Fund |  | Manulife Asset Management (US) LLC
John Hancock Sovereign Bond Fund: |  |
Bond Fund |  | Manulife Asset Management (US) LLC
John Hancock Strategic Series: |  |
Strategic Income Fund |  | Manulife Asset Management (US) LLC
John Hancock Tax-Exempt Series Fund: |  |
Massachusetts Tax-Free Income Fund |  | Manulife Asset Management (US) LLC
New York Tax-Free Income Fund |  | Manulife Asset Management (US) LLC
Closed-End Funds: |  |
Bank & Thrift Opportunity Fund |  | Manulife Asset Management (US) LLC
Income Securities Trust |  | Manulife Asset Management (US) LLC
Investors Trust |  | Manulife Asset Management (US) LLC
Preferred Income Fund |  | Manulife Asset Management (US) LLC
Preferred Income Fund II |  | Manulife Asset Management (US) LLC
Preferred Income Fund III |  | Manulife Asset Management (US) LLC
Patriot Premium Dividend Fund II |  | Manulife Asset Management (US) LLC
Tax-Advantaged Dividend Income Fund |  | Manulife Asset Management (US) LLC Analytic Investors, LLC
Tax-Advantaged Global Shareholder Yield Fund |  | Epoch Investment Partners, Inc. / Analytic Investors, Inc.

JOHN HANCOCK FUNDS II
Name of Fund: |  | Subadviser for Fund:
Active Bond Fund |  | Manulife Asset Management (US) LLC and Declaration Management & Research LLC
Core Diversified Growth & Income Portfolio |  | Manulife Asset Management (North America) Limited
Core Fundamental Holdings Portfolio |  | Manulife Asset Management (North America) Limited
Core Global Diversification Portfolio |  | Manulife Asset Management (North America) Limited
All Cap Core Fund |  | Deutsche Investment Management Americas Inc.
All Cap Growth Fund |  | Invesco AIM Capital Management, Inc.
All Cap Value Fund |  | Lord, Abbett & Co. LLC.
Alpha Opportunities Fund |  | Wellington Management Company, LLP
Alternative Asset Allocation Fund |  | Manulife Asset Management (North America) Limited
Blue Chip Growth Fund |  | T. Rowe Price Associates, Inc.
Capital Appreciation Fund |  | Jennison Associates LLC

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JOHN HANCOCK FUNDS II (Cont.)
Name of Fund: |  | Subadviser for Fund:
Core Allocation Plus Fund |  | Wellington Management Company, LLP
Core Bond Fund |  | Wells Capital Management, Incorporated
Emerging Markets Debt Fund |  | Manulife Asset Management (US) LLC
Emerging Markets Value Fund |  | Dimensional Fund Advisers, Inc.
Equity-Income Fund |  | T. Rowe Price Associates, Inc.
Financial Services Fund |  | Davis Selected Advisers, L.P.
Floating Rate Income Fund |  | Western Asset Management Company
Fundamental Value Fund |  | Davis Selected Advisers, L.P.
Global Agribusiness Fund |  | Manulife Asset Management (North America) Limited
Global Infrastructure Fund |  | Manulife Asset Management (North America) Limited
Global Timber Fund |  | Manulife Asset Management (North America) Limited
Global Bond Fund |  | Pacific Investment Management Company LLC
Global Fund |  | Templeton Global Advisors Limited
Global High Yield Fund |  | Stone Harbor Investment Partners LP
Global Real Estate Fund |  | Deutsche Investment Management Americas Inc.
High Income Fund |  | Manulife Asset Management (US) LLC
High Yield Fund |  | Western Asset Management Company
Income Fund |  | Franklin Advisers, Inc.
Index 500 Fund |  | Manulife Asset Management (North America) Limited
International Equity Index Fund |  | SSgA Funds Management, Inc.
International Opportunities Fund |  | Marsico Capital Management, LLC
International Small Cap Fund |  | Templeton Investment Counsel LLC
International Small Company Fund |  | Dimensional Fund Advisors
International Value Fund |  | Templeton Investment Counsel LLC
Investment Quality Bond Fund |  | Wellington Management Company, LLP
Large Cap Fund |  | UBS Global Asset Management (Americas) Inc.
Large Cap Value Fund |  | BlackRock Investment Management LLC
Lifecycle 2010 Portfolio |  | Manulife Asset Management (North America) Limited
Lifecycle 2015 Portfolio |  | Manulife Asset Management (North America) Limited
Lifecycle 2020 Portfolio |  | Manulife Asset Management (North America) Limited
Lifecycle 2025 Portfolio |  | Manulife Asset Management (North America) Limited
Lifecycle 2030 Portfolio |  | Manulife Asset Management (North America) Limited
Lifecycle 2035 Portfolio |  | Manulife Asset Management (North America) Limited
Lifecycle 2040 Portfolio |  | Manulife Asset Management (North America) Limited
Lifecycle 2045 Portfolio |  | Manulife Asset Management (North America) Limited
Lifecycle 2050 Portfolio |  | Manulife Asset Management (North America) Limited
Lifestyle Aggressive Portfolio |  | Manulife Asset Management (North America) Limited and Deutsche Investment Management Americas, Inc.

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JOHN HANCOCK FUNDS II (Cont.)
Name of Fund: |  | Subadviser for Fund:
Lifestyle Balanced Portfolio |  | Manulife Asset Management (North America) Limited and Deutsche Investment Management Americas, Inc.
Lifestyle Conservative Portfolio |  | Manulife Asset Management (North America) Limited and Deutsche Investment Management Americas, Inc.
Lifestyle Growth Portfolio |  | Manulife Asset Management (North America) Limited and Deutsche Investment Management Americas, Inc.
Lifestyle Moderate Portfolio |  | Manulife Asset Management (North America) Limited and Deutsche Investment Management Americas, Inc.
Mid Cap Index Fund |  | Manulife Asset Management (North America) Limited
Mid Cap Stock Fund |  | Wellington Management Company, LLP
Mid Cap Value Equity Fund |  | Riversource Investments, LLC
Mid Cap Value Fund |  | Lord, Abbett & Co. LLC.
Money Market Fund |  | Manulife Asset Management (North America) Limited
Multi Sector Bond Fund |  | Stone Harbor Investment Partners LP
Natural Resources Fund |  | Wellington Management Company, LLP
Optimized Value Fund |  | Manulife Asset Management (North America) Limited
Real Estate Equity Fund |  | T. Rowe Price Associates, Inc.
Real Estate Securities Fund |  | Deutsche Investment Management Americas Inc.
Real Return Bond Fund |  | Pacific Investment Management Company LLC
Retirement Distribution Portfolio |  | Manulife Asset Management (North America) Limited
Retirement Rising Distribution Portfolio |  | Manulife Asset Management (North America) Limited
Science & Technology Fund |  | T. Rowe Price Associates, Inc., RCM Capital Management LLC
Short Term Gov’t Income Fund |  | Manulife Asset Management (US) LLC
Small Cap Growth Fund |  | Wellington Management Company, LLP
Small Cap Index Fund |  | Manulife Asset Management (North America) Limited
Small Cap Opportunities Fund |  | Munder Capital Management
Small Cap Value Fund |  | Wellington Management Company, LLP
Small Company Growth Fund |  | AIM Capital Management, Inc.
Small Company Value Fund |  | T. Rowe Price Associates, Inc.
Smaller Company Growth Fund |  | Frontier Capital Management Company, LLC; Perimeter Capital Management; Manulife Asset Management (North America) Limited
Spectrum Income Fund |  | T. Rowe Price Associates, Inc.
Strategic Bond Fund |  | Western Asset Management Company
Strategic Income Opportunities Fund |  | Manulife Asset Management (US) LLC
Technical Opportunities |  | Wellington Management Company, LLP
Total Bond Market Fund |  | Declaration Management & Research, LLC
Total Return Fund |  | Pacific Investment Management Company LLC

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JOHN HANCOCK FUNDS II (Cont.)
Name of Fund: |  | Subadviser for Fund:
Total Stock Market Index Fund |  | Manulife Asset Management (North America) Limited
U.S. Government Securities Fund |  | Western Asset Management Company
U.S. High Yield Bond Fund |  | Wells Capital Management, Incorporated
U.S. Multi Sector Fund |  | Grantham, Mayo, Van Otterloo & Co. LLC
Value & Restructuring Fund |  | Columbia Management Advisors
Value Fund |  | Morgan Stanley Investment Management Inc. (Van
|  | Kampen)
Vista Fund |  | American Century Investment Management, Inc.

JOHN HANCOCK FUNDS III
Name of Fund: |  | Subadviser for Fund:
Classic Value Mega Cap Fund |  | Pzena Investment Management, LLC
Core High Yield Fund |  | Manulife Asset Management (North America) Limited
Disciplined Value Fund |  | Robeco Investment Management, Inc.
Global Shareholder Yield Fund |  | Epoch Investment Partners, Inc.
Growth Opportunities Fund |  | GMO, LLC
International Allocation Portfolio |  | Manulife Asset Management (North America) Limited
International Core Fund |  | GMO, LLC
International Growth Fund |  | GMO, LLC
Leveraged Companies Fund |  | Manulife Asset Management (US) LLC
Rainier Growth Fund |  | Rainier Investment Management Inc.
Small Company Fund |  | Fiduciary Management Associates, LLC
Small Cap Opportunities Fund |  | Manulife Asset Management (US) LLC
U. S. Core Fund |  | GMO, LLC
Value Opportunities Fund |  | GMO, LLC

JOHN HANCOCK TRUST
Name of Fund: |  | Subadviser for Fund:
500 Index Trust |  | Manulife Asset Management (North America) Limited
500 Index Trust B |  | Manulife Asset Management (North America) Limited
Active Bond Trust |  | Manulife Asset Management (US) LLC and Declaration Management & Research LLC
All Cap Core Trust |  | Deutsche Investment Management Americas Inc. and RREEF America LLC
All Cap Growth Trust |  | Jennison Associates LLC
All Cap Value Trust |  | Lord, Abbett & Co. LLC.
Alpha Opportunities Trust |  | Wellington Management Company, LLP
American Asset Allocation Trust |  | Capital Research Management Company
American Blue Chip Income and Growth Trust |  | Capital Research Management Company
American Bond Trust |  | Capital Research Management Company
American Fundamental Holdings Trust |  | Manulife Asset Management (North America) Limited
American Global Diversification Trust |  | Manulife Asset Management (North America) Limited

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JOHN HANCOCK TRUST (Cont.)
Name of Fund: |  | Subadviser for Fund:
American Global Growth Trust |  | Capital Research Management Company
American Global Small Capitalization Trust |  | Capital Research Management Company
American Growth Trust |  | Capital Research Management Company
American Growth-Income Trust |  | Capital Research Management Company
American High-Income Bond Trust |  | Capital Research Management Company
American International Trust |  | Capital Research Management Company
American New World Trust |  | Capital Research Management Company
Balanced Trust |  | T. Rowe Price Associates, Inc.
Blue Chip Growth Trust |  | T. Rowe Price Associates, Inc.
Bond Trust |  | Manulife Asset Management (US) LLC
Capital Appreciation Trust |  | Jennison Associates LLC
Capital Appreciation Value Trust |  | T. Rowe Price Associates, Inc.
Core Allocation Trust |  | Manulife Asset Management (North America) Limited
Core Asset Allocation Plus Trust |  | Wellington Management Company, LLP
Core Balanced Trust |  | Manulife Asset Management (North America) Limited
Core Balanced Strategy Trust |  | Manulife Asset Management (North America) Limited
Core Bond Trust |  | Wells Capital Management, Incorporated
Core Disciplined Diversification Trust |  | Manulife Asset Management (North America) Limited
Core Diversified Growth & Income Trust |  | Manulife Asset Management (North America) Limited
Core Fundamental Holdings Trust |  | Manulife Asset Management (North America) Limited
Core Global Diversification Trust |  | Manulife Asset Management (North America) Limited
Core Strategy Trust |  | Manulife Asset Management (North America) Limited
Disciplined Diversification Trust |  | Dimensional Fund Advisors Inc.
Emerging Markets Value Trust |  | Dimensional Fund Advisers, Inc.
Equity-Income Trust |  | T. Rowe Price Associates, Inc.
Financial Services Trust |  | Davis Selected Advisers, L.P.
Floating Rate Income Trust |  | Western Asset Management Company
Franklin Templeton Founding Allocation Trust |  | Manulife Asset Management (North America) Limited
Fundamental Value Trust |  | Davis Selected Advisers, L.P.
Global Bond Trust |  | Pacific Investment Management Company LLC
Global Trust |  | Templeton Global Advisors Limited
Growth Equity Trust |  | Rainier Investment Management, Inc.
Growth Opportunities Trust |  | Grantham, Mayo, Van Otterloo & Co. LLC
Growth Trust |  | Grantham, Mayo, Van Otterloo & Co. LLC
Health Sciences Trust |  | T. Rowe Price Associates, Inc.
High Income Trust |  | Manulife Asset Management (US) LLC
High Yield Trust |  | Western Asset Management Company Limited
Income Trust |  | Franklin Advisers, Inc.

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JOHN HANCOCK TRUST (Cont.)
Name of Fund: |  | Subadviser for Fund:
International Core Trust |  | Grantham, Mayo, Van Otterloo & Co. LLC
International Equity Index Trust A |  | SSgA Funds Management, Inc.
International Equity Index Trust B |  | SSgA Funds Management, Inc.
International Growth Trust |  | Grantham, Mayo, Van Otterloo & Co. LLC
International Index Trust |  | Manulife Asset Management (North America) Limited
International Opportunities Trust |  | Marsico Capital Management, LLC
International Small Company Trust |  | Dimensional Fund Advisors Inc.
International Value Trust |  | Templeton Investment Counsel LLC
Intrinsic Value Trust |  | Grantham, Mayo, Van Otterloo & Co. LLC
Investment Quality Bond Trust |  | Wellington Management Company, LLP
Large Cap Trust |  | UBS Global Asset Management (Americas) Inc.
Large Cap Value Trust |  | BlackRock Investment Management LLC
Lifecycle 2010 Trust |  | Manulife Asset Management (North America) Limited
Lifecycle 2015 Trust |  | Manulife Asset Management (North America) Limited
Lifecycle 2020 Trust |  | Manulife Asset Management (North America) Limited
Lifecycle 2025 Trust |  | Manulife Asset Management (North America) Limited
Lifecycle 2030 Trust |  | Manulife Asset Management (North America) Limited
Lifecycle 2035 Trust |  | Manulife Asset Management (North America) Limited
Lifecycle 2040 Trust |  | Manulife Asset Management (North America) Limited
Lifecycle 2045 Trust |  | Manulife Asset Management (North America) Limited
Lifecycle 2050 Trust |  | Manulife Asset Management (North America) Limited
Lifestyle Aggressive Trust |  | Manulife Asset Management (North America) Limited and Deutsche Investment Management Americas, Inc.
Lifestyle Balanced Trust |  | Deutsche Investment Management Americas Inc.
Lifestyle Conservative Trust |  | Deutsche Investment Management Americas Inc. and Manulife Asset Management (North America) Limited
Lifestyle Growth Trust |  | Deutsche Investment Management Americas Inc. and Manulife Asset Management (North America) Limited
Lifestyle Moderate Trust |  | Deutsche Investment Management Americas Inc.
Mid Cap Index Trust |  | Manulife Asset Management (North America) Limited
Mid Cap Stock Trust |  | Wellington Management Company, LLP
Mid Cap Value Equity Trust |  | Riversource Investments, LLC
Mid Value Trust |  | T. Rowe Price Associates, Inc.
Money Market Trust |  | Manulife Asset Management (North America) Limited
Money Market Trust B |  | Manulife Asset Management (North America) Limited
Mutual Shares Trust |  | Franklin Mutual Advisers, LLC
Natural Resources Trust |  | Wellington Management Company, LLP
Optimized All Cap Trust |  | Manulife Asset Management (US) LLC

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JOHN HANCOCK TRUST (Cont.)
Name of Fund: |  | Subadviser for Fund:
Optimized Value Trust |  | Manulife Asset Management (US) LLC
Overseas Equity Trust |  | Templeton Investment Counsel, LLC
Real Estate Equity Trust |  | T. Rowe Price Associates, Inc.
Real Estate Securities Trust |  | Deutsche Investment Management Americas Inc.
Real Return Bond Trust |  | Pacific Investment Management Company LLC
Science & Technology Trust |  | T. Rowe Price Associates, Inc. and RCM Capital Management LLC
Short-Term Bond Trust |  | Declaration Management & Research, LLC
Short Term Government Income Trust |  | Manulife Asset Management (US) LLC
Small Cap Growth Trust |  | Wellington Management Company, LLP
Small Cap Index Trust |  | Manulife Asset Management (North America) Limited
Small Cap Opportunities Trust |  | Invesco Advisers and Dimensional Fund Advisors LP
Small Cap Value Trust |  | Wellington Management Company, LLP
Small Company Growth Trust |  | Invesco Advisers
Small Company Value Trust |  | T. Rowe Price Associates, Inc.
Smaller Company Growth Trust |  | Frontier Capital Management Company, LLC, Perimeter Capital Management, and Manulife Asset Management (North America) Limited
Spectrum Income Trust |  | T. Rowe Price Associates, Inc.
Strategic Bond Trust |  | Western Asset Management Company
Strategic Income Opportunities Trust |  | Manulife Asset Management (US) LLC and Declaration Management & Research LLC
Total Bond Market Trust A |  | Declaration Management & Research LLC
Total Bond Market Trust B |  | Declaration Management & Research LLC
Total Return Trust |  | Pacific Investment Management Company LLC
Total Stock Market Index Trust |  | Manulife Asset Management (North America) Limited
U.S. Government Securities Trust |  | Western Asset Management Company
U.S. High Yield Bond Trust |  | Wells Capital Management, Incorporated
U.S. Multi Sector Trust |  | Grantham, Mayo, Van Otterloo & Co. LLC
Utilities Trust |  | Massachusetts Financial Services Company
Value Trust |  | Morgan Stanley Investment Management Inc. (Van Kampen)
Value & Restructuring Trust |  | Columbia Management Advisors
Value Opportunities Trust |  | Grantham, Mayo, Van Otterloo & Co. LLC
Vista Trust |  | American Century Investment Management, Inc.

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Appendix C: Pre-clearance Procedures
You should read the Code to determine whether you must obtain a pre-clearance before you enter into a securities transaction. If you are required to obtain a pre-clearance, you should follow the procedures detailed below.
Pre-clearance for Covered Securities including Derivatives, Futures, Options:
A request for pre-clearance needs to be entered through the John Hancock Personal Trading & Reporting System which can be accessed through your Start Menu on your Desktop under Programs\Personal Trading & Reporting\Personal Trading & Reporting.
If the John Hancock Personal Trading & Reporting System is not on your Desktop, please use the following link:
https://cti-prd.prd.manulifeusa.com/iTrade3
The Trade Request Screen
At times you may receive a message “System is currently unavailable”. The system is scheduled to be off-line from 8:00 PM until 7:00 AM each night.
Required Information
Ticker/Security Cusip: Fill in either the ticker, cusip or security name 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.
Transaction Type: Choose one of the values displayed when you click the dropdown arrow to the right of this field.

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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.
Quantity: Enter the amount of shares you wish to trade.
Notes Text Box: Enter any applicable notes regarding your trade request.
Click the [Preview] button to review your trade request, if everything is correct hit the [Submit] button to present request for approval; after which you will receive immediate feedback unless the system identifies a potential violation of the Ban on Short Term Profits Rule.
In this case, your request will be forwarded to Code of Ethics Administration 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 Logout menu option.
Note: When submitting your request for approval, please make sure the information you are submitting for is correct. Submission of requests with incorrect brokerage account, incorrect trade direction, or incorrect security identifier (ticker/cusip) may subject you to fines and sanctions.
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 (ticker or cusip) 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.
You must contact Code of Ethics Administration to add the security to the system. Send an email including the following information; security name, security ticker symbol, security cusip number, security type and an attestation that the security is not an IPO or a Private Placement to Code of Ethics Administration:
Fred Spring (617) 663-3485
or Andrea Holthaus (617)-663-3484
Adding Brokerage Accounts: To access this functionality, click on the Brokerage Account\Add Brokerage Account menu item. You will be prompted to enter the Brokerage Account Number, Brokerage Account Name, Broker Contact Name, Broker Contact Email, and Initiated Dates. When you click the [Create New Brokerage Account] button, you will receive a message that informs you whether the account was successfully created.
Pre-clearance for Private Placements, IPO’s and Limited Offerings: You may request a pre-clearance of private placement securities, limited offerings, or an IPO by contacting Fred Spring via email (please “cc.” Frank Knox on all such requests). The request must include:

| • |  | the associate’s name;
| • |  | the complete name of the security;
| • |  | the seller (i.e. the selling party if identified and/ or the broker/dealer or placement agent) and whether or not the associate does business with those individuals or entities on a regular basis;
| • |  | the basis upon which the associate is being offered this investment opportunity;
| • |  | 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 or to trade through a particular broker/dealer or placement agent; and
| • |  | the date of the request

Clearance of private placements or IPO’s may be denied for any appropriate reason, such as if the transaction could create the appearance of impropriety. Clearance of IPO’s will also be denied if the transaction is prohibited for a person due to his or her access category under the Code of Ethics.
Please keep in mind that the Code of Ethics prohibits Access Level I Persons from purchasing securities in an IPO.

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Appendix D: Investment Professional Disclosure of Personal Securities Conflicts
As an investment professional, Access Level I Persons, you must promptly disclose your direct or indirect beneficial interest in a security that is under consideration for purchase or sale in a John Hancock Affiliated Fund or account advised by Manulife Asset Management (US). You are required to follow the following guidelines.
If you or a member of your family own:

| • |  | a 5% or greater interest in a company, John Hancock Affiliated Funds advised by Manulife Asset Management (US) and its affiliates may not make any investment in that company;
| • |  | a 1% or greater interest in a company, you cannot participate in any decision by John Hancock Affiliated Funds advised by Manulife Asset Management (US) and its affiliates to buy or sell that company’s securities;
| • |  | ANY other interest in a company, you cannot recommend or participate in a decision by John Hancock Affiliated Funds advised by Manulife Asset Management (US), and its affiliates to buy or sell that company’s securities unless your personal interest is fully disclosed at all stages of the investment decision

In such instances, you must initially disclose that beneficial interest orally to the primary portfolio manager (or other appropriate analyst) of the John Hancock Affiliated Fund or account advised by Manulife Asset Management (US) or the appropriate Chief Investment Officer. Following the oral disclosure, you must send a written acknowledgement to the primary portfolio manager with a copy to the Code of Ethics Administration Department.
For the purposes of this requirement investment professionals are defined as analysts and portfolio managers.

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Appendix E: Manulife Asset Management (US) Schedule of Fines and Sanctions

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Appendix F: Chief Compliance Officer and Compliance Contacts

Entity |  | Chief Compliance Officer |
Manulife Asset Management (US) |  | William Corson – 617-375-6850
Code of Ethics Contact |  | Phone number
Fred Spring |  |  | 617-663-3485 |
Andrea Holthaus |  |  | 617-663-3484 |

“Code” Edition: February, 2011

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