<DOCUMENT>
<TYPE>EX-99.CODE ETH
<SEQUENCE>14
<FILENAME>co1.txt
<TEXT>

                             THE PUTNAM FUNDS

                              Code of Ethics

Each of The Putnam Funds (the "Funds") has determined to adopt this Code
of Ethics with respect to certain types of personal securities
transactions by officers and Trustees of the Funds which might be deemed
to create possible conflicts of interest and to establish reporting
requirements and enforcement procedures with respect to such
transactions.

I. Rules Applicable to Officers and Trustees Affiliated with Putnam
Investments Trust or Its Subsidiaries

A. Incorporation of Adviser's Code of Ethics.  The provisions of the
Code of Ethics for employees of Putnam Investments Trust and its
subsidiaries (the "Putnam Investments Code of Ethics"), which is
attached as Appendix A hereto, are hereby incorporated herein as the
Funds' Code of Ethics applicable to officers and Trustees of the Funds
who are employees of the Funds or officers, directors or employees of
Putnam Investments Trust or its subsidiaries.  A violation of the Putnam
Investments' Code of Ethics shall constitute a violation of the Funds'
Code.

B. Reports.  Officers and Trustees of each of the Funds who are made
subject to the Putnam Investments' Code of Ethics pursuant to the
preceding paragraph shall file the reports required by the Putnam
Investments' Code of Ethics with the Code of Ethics Officer designated
therein.  A report filed with the Code of Ethics Officer shall be deemed
to be filed with each of the Funds of which the reporting individual is
an officer or Trustee.

C. Review and Reporting.

(1) The Code of Ethics Officer shall cause the reported personal
securities transactions to be compared with completed and contemplated
portfolio transactions of each of the Funds to determine whether a
violation of this Code may have occurred.  Before making any
determination that a violation has been committed by any person, the
Code of Ethics Officer shall give such person an opportunity to supply
additional explanatory material.

(2) If the Code of Ethics Officer determines that a violation of any
provision of this Code has or may have occurred, he shall submit his
written determination, together with any additional explanatory
material, to the Audit and Pricing Committee of the Funds at its next
meeting.

D. Sanctions.  In addition to reporting violations of this Code to the
Audit and Pricing Committee of the Funds as provided in Section I-C(2),
the Code of Ethics officer shall also report to such Committee any
sanctions imposed with respect to such violations.  The Committee
reserves the right to impose such additional sanctions as it deems
appropriate.

II. Rules Applicable to Unaffiliated Trustees

A. Definitions.

(1) "Beneficial ownership" shall be interpreted in the same manner as it
would be in determining whether a person is subject to the provisions of
Section 16 of the Securities Exchange Act of 1934 and the rules and
regulations thereunder.

(2) "Control" means the power to exercise a controlling influence over
the management or policies of a company, unless such power is solely the
result of an official position with such company.

(3) "Interested Trustee" means a Trustee of a Fund who is an "interested
person" of the Fund within the meaning of the Investment Company Act.

(4) "Purchase or sale of a security" includes, among other things, the
writing of an option to purchase or sell a security.

(5) "Security" shall have the same meaning as that set forth in Section
2(a)(36) of the Investment Company Act (in effect, all securities)
except that it shall not include securities issued by the Government of
the United States or an agency thereof, bankers' acceptances, bank
certificates of deposit, commercial paper and high-quality short-term
debt investments, including repurchase agreements, and shares of
registered open-end investment companies, but shall include any security
convertible into or exchangeable for a security.

(6) "Unaffiliated Trustee" means a Trustee who is not made subject to
the Putnam Investments Code of Ethics pursuant to Part I hereof.

B. Prohibited Purchases and Sales.  No Unaffiliated Trustee of any of
the Funds shall purchase or sell, directly or indirectly, any security
in which he has, or by reason of such transaction acquires, any direct
or indirect beneficial ownership and which to his actual knowledge at
the time of such purchase or sale:

(1) is being considered for purchase or sale by the Fund;

(2) is being purchased or sold by the Fund; or

(3) was purchased or sold by the Fund within the most recent five days
if such person participated in the recommendation to, or the decision
by, Putnam Investment Management to purchase or sell such security for
the Fund.

C. Exempted Transactions.  The prohibitions of Section II-B of this Code
shall not apply to:

(1) purchases or sales of securities effected in any account over which
the Unaffiliated Trustee has no direct or indirect influence or control;

(2) purchases or sales of securities which are non-volitional on the
part of either the Unaffiliated Trustee or the Fund;

(3) purchases of securities which are part of an automatic dividend
reinvestment plan;

(4) purchases of securities effected upon the exercise of rights issued
by an issuer pro rata to all holders of a class of its securities, to
the extent such rights were acquired from such issuer, and sales of such
rights so acquired;

(5) purchases or sales of securities other than those exempted in (1)
through (4) above which do not cause the Unaffiliated Trustee to gain
improperly a personal benefit through his relationship with the Fund and
are only remotely potentially harmful to a Fund because they would be
very unlikely to affect a highly institutional market, and are
previously approved by the Legal and Compliance Liaison Officer of the
Funds, in consultation with the Code of Ethics Officer, which approval
shall be confirmed in writing.

D. Reporting.

(1) Whether or not one of the exemptions listed in Section II-C applies
and except as provided in Section II-C(5), every Unaffiliated Trustee of
a Fund shall file with the Funds' Legal and Compliance Liaison Officer a
report containing the information described in Section II-D(2) of this
Code with respect to purchases or sales of any security in which such
Unaffiliated Trustee has, or by reason of such transaction acquires, any
direct or indirect beneficial ownership, if such Trustee, at the time of
that transaction, knew or, in the ordinary course of fulfilling his
official duties as a Trustee of the Fund, should have known that, during
the 15-day period immediately preceding or after the date of the
transaction by the Trustee:

(a) such security was or is to be purchased or sold by the Fund or

(b) such security was or is being considered for purchase or sale by the
Fund;

provided, however, that an Unaffiliated Trustee shall not be required to
make a report with respect to transactions effected for any account over
which such person does not have any direct or indirect influence or
control.

(2) Every report shall be made not later than 10 days after the end of
the calendar quarter in which the transaction to which the report
relates was effected, and shall contain the following information:

(a) The date of the transaction, the title, the number of shares, the
interest rate and maturity date (if applicable) and the principal amount
of each security involved;

(b) The nature of the transaction (i.e., purchase, sale or any other
type of acquisition or disposition);

(c) The price at which the transaction was effected; and

(d) The name of the broker, dealer or bank with or through whom the
transaction was effected; and

(e) the date that the report is submitted by each Unaffiliated Trustee.

(3) Every report concerning a purchase or sale prohibited under Section
II-B hereof with respect to which the reporting person relies upon one
of the exemptions provided in Section II-C shall contain a brief
statement of the exemption relied upon and the circumstances of the
transaction.

(4) Any such report may contain a statement that the report shall not be
construed as an admission by the person making such report that he has
any direct or indirect beneficial ownership in the security to which the
report relates.

(5) Notwithstanding anything to the contrary contained herein, an
Unaffiliated Trustee who is an "interested person" of the Funds shall
file the reports required by Rule 17j-1(d)(1) under the Investment
Company Act of 1940 with the Code of Ethics Officer of Putnam
Investments.  Such reports shall be reviewed by such Officer as provided
in Section I-C(1) and any related violations shall be reported by him to
the Audit and Pricing Committee as provided in Section I-C(2).  The
Committee may impose such additional sanctions as it deems appropriate.

E. Review and Reporting.

(1) The Legal and Compliance Liaison Officer of the Funds, in
consultation with the Code of Ethics Officer of Putnam Investments,
shall cause the reported personal securities transactions that he
receives pursuant to Section II-D(1) to be compared with completed and
contemplated portfolio transactions of the Funds to determine whether
any transaction ("Reviewable Transactions") listed in Section II-B
(disregarding exemptions provided by Section II-C(1) through (5)) may
have occurred.

(2) If the Legal and Compliance Liaison Officer determines that a
Reviewable Transaction may have occurred, he shall then determine
whether a violation of this Code may have occurred, taking into account
all the exemptions provided under Section II-C.  Before making any
determination that a violation has occurred, the Legal and Compliance
Liaison Officer shall give the person involved an opportunity to supply
additional information regarding the transaction in question.

F. Sanctions.  If the Legal and Compliance Liaison determines that a
violation of this Code has occurred, he shall so advise the Funds' Audit
and Pricing Committee, and provide the Committee with a report of the
matter, including any additional information supplied by such person.
The Committee may impose such sanctions as it deems appropriate.

III. Miscellaneous

A. Amendments to the Putnam Investments' Code of Ethics.  Any amendment
to the Putnam Investments' Code of Ethics shall be deemed an amendment
to Section I-A of this Code effective 30 days after written notice of
such amendment shall have been received by the Chairman of the Funds,
unless the Trustees of the Funds expressly determine that such amendment
shall become effective at an earlier or later date or shall not be
adopted.

B. Records.  The Funds shall maintain records in the manner and to the
extent set forth below, which records may be maintained on microfilm
under the conditions described in Rule 31a-2(f)(1) under the Investment
Company Act and shall be available for examination by representatives of
the Securities and Exchange Commission.

(1) A copy of this Code and any other code which is, or at any time
within the past five years has been, in effect shall be preserved in an
easily accessible place;

(2) A record of any violation of this Code and of any action taken as a
result of such violation shall be preserved in an easily accessible
place for a period of not less than five years following the end of the
fiscal year in which the violation occurs;

(3) A copy of each report made by an officer or Trustee pursuant to this
Code shall be preserved for a period of not less than five years from
the end of the fiscal year in which it is made, the first two years in
an easily accessible place; and

(4) A list of all persons who are, or within the past five years have
been, required to make reports pursuant to this Code shall be maintained
in an easily accessible place.

To the extent any record required to be kept by this section is also
required to be kept by Putnam Investments pursuant to the Putnam
Investments' Code of Ethics, Putnam Investments shall maintain such
record on behalf of the Funds as well.

C. Confidentiality.  All reports of securities transactions and any
other information filed with any Fund pursuant to this Code shall be
treated as confidential, but are subject to review as provided herein
and by personnel of the Securities and Exchange Commission.

D. Interpretation of Provisions.  The Trustees may from time to time
adopt such interpretations of this Code as they deem appropriate.

E. Delegation by Chairman.  The Chairman of the Funds may from time to
time delegate any or all of his responsibilities under this Code, either
generally or as to specific instances, to such officer or Trustee of the
Funds as he may designate.

As revised
November 1, 2004
</TEXT>
</DOCUMENT>
