<DOCUMENT>
<TYPE>EX-99.CODE ETH
<SEQUENCE>2
<FILENAME>dex99codeeth.txt
<DESCRIPTION>CODE OF ETHICS
<TEXT>
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                          THE SWISS HELVETIA FUND, INC.
                     CODE OF ETHICS FOR PRINCIPAL EXECUTIVE
                          AND SENIOR FINANCIAL OFFICERS

I.   COVERED OFFICERS/PURPOSE OF THE CODE

     This code of ethics (the "Code") for The Swiss Helvetia Fund, Inc. (the
"Fund") applies to the Fund's Principal Executive Officer and Principal
Financial Officer, or other persons performing similar functions, each of whom
is listed on Exhibit A (the "Covered Officers"), for the purpose of promoting:

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

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

     .    compliance with applicable laws and governmental rules and
          regulations;

     .    the prompt internal reporting of violations of the Code to an
          appropriate person or persons identified in the Code; and

     .    accountability for adherence to the Code.

     Each Covered Officer should adhere to a high standard of business ethics
and should be sensitive to situations that may give rise to actual as well as
apparent conflicts of interest.

II.  COVERED OFFICERS SHOULD HANDLE ETHICALLY ACTUAL AND APPARENT CONFLICTS OF
     INTEREST

     OVERVIEW. A "conflict of interest" occurs when a Covered Officer's private
interest interferes with the interests of, or his service to, the Fund. For
example, a conflict of interest would arise if a Covered Officer, or a member of
his family, receives improper personal benefits as a result of his position with
the Fund.

     Certain conflicts of interest arise out of the relationships between
Covered Officers and the Fund and already are subject to conflict of interest
provisions in the Investment Company Act of 1940, as amended (the "Investment
Company Act"), and the Investment Advisers Act of 1940, as amended (the
"Investment Advisers Act"). For example, Covered Officers may not individually
engage in certain transactions (such as the purchase or sale of securities or
other property) with the Fund because of their status as "affiliated persons" of
the Fund. The compliance programs and procedures of the Fund and the Fund's
investment advisor (the "Advisor") are designed to prevent, or identify and
correct, violations of these provisions. The Code does not, and is not intended
to, repeat or replace these programs and procedures.

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     Although typically not presenting an opportunity for improper personal
benefit, conflicts arise from, or as a result of, the contractual relationship
between the Fund and the Advisor of which the Covered Officers are also officers
or employees. As a result, the Code recognizes that the Covered Officers, in the
ordinary course of their duties (whether formally for the Fund or for the
Advisor, or for both), will be involved in establishing policies and
implementing decisions that will have different effects on the Advisor and the
Fund. The participation of the Covered Officers in such activities is inherent
in the contractual relationship between the Fund and the Advisor and is
consistent with the performance by the Covered Officers of their duties as
officers of the Fund and, if addressed in conformity with the provisions of the
Investment Company Act and the Investment Advisers Act, will be deemed to have
been handled ethically.

     Other conflicts of interest are covered by the Code, even if such conflicts
of interest are not subject to provisions in the Investment Company Act and the
Investment Advisers Act. Covered Officers should keep in mind that the Code
cannot enumerate every possible scenario. The overarching principle of the Code
is that the personal interest of a Covered Officer should not be placed
improperly before the interest of the Fund.

     Each Covered Officer must:

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

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

     .    not retaliate against any employee or Covered Officer for reports of
          potential violations that are made in good faith.

III. DISCLOSURE AND COMPLIANCE

     .    Each Covered Officer should familiarize himself with the disclosure
          requirements and disclosure controls and procedures generally
          applicable to the Fund within his area of responsibility;

     .    each Covered Officer should not knowingly misrepresent, or cause
          others to misrepresent, facts about the Fund to others, whether within
          or outside the Fund, including to the Fund's Board members and
          auditors, and to governmental regulators and self-regulatory
          organizations; and

     .    to the extent appropriate within his area of responsibility, each
          Covered Officer should consult with other officers and employees of
          the Fund and the Advisor and take other appropriate steps with the
          goal of promoting full, fair, accurate, timely and understandable
          disclosure in the reports and documents the Fund files with, or
          submits to, the SEC and in other public communications made by the
          Fund; and

                                      -2-

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     .    it is the responsibility of each Covered Officer to promote compliance
          with the standards and restrictions imposed by applicable laws, rules
          and regulations.

IV.  REPORTING AND ACCOUNTABILITY

     Each Covered Officer must:

     .    upon adoption of the Code (or thereafter, as applicable, upon becoming
          a Covered Officer), affirm in writing to the Board that he has
          received, read, and understands the Code;

     .    annually thereafter affirm to the Board that he has complied with the
          requirements of the Code; and

     .    notify the Audit Committee (the "Committee") promptly if he knows of
          any violation of the Code. Failure to do so is itself a violation of
          the Code.

     The Audit Committee is responsible for applying the Code to specific
situations in which questions are presented under it and has the authority to
interpret the Code in any particular situation and to grant waivers sought by
any Covered Officer. The Fund will follow these procedures in investigating and
enforcing the Code:

     .    the Committee will take all appropriate action to investigate any
          potential violations reported to it;

     .    if, after such investigation, the Committee believes that no violation
          has occurred, the Committee is not required to take any further
          action;

     .    if the Committee determines that a violation has occurred, it will
          inform and make a recommendation to the Board, which will consider
          appropriate action, which may include review of, and appropriate
          modifications to, applicable policies and procedures; notification to
          appropriate personnel of the Advisor or its board; or a recommendation
          to dismiss the Covered Officer; and

     .    any waivers of or amendments to the Code, to the extent required, will
          be disclosed as provided by SEC rules.

V.   OTHER POLICIES AND PROCEDURES

     The Code shall be the sole code of ethics adopted by the Fund for purposes
of Section 406 of the Sarbanes-Oxley Act of 2002 and the rules and forms
applicable to registered investment companies thereunder. Insofar as other
policies and procedures of the Fund, the Advisor or other service providers
govern or purport to govern the behavior or activities of the Covered Officers
who are subject to the Code, they are superceded by the Code to the extent that
they overlap or conflict with the provisions of the Code. The Fund's and the
Advisor's codes of ethics under Rule 17j-1 under the Investment Company Act and
the Advisor's additional policies and procedures are separate requirements
applying to the Covered Officers and others, and are not part of the Code.

                                      -3-

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VI.  AMENDMENTS

     Except as to Exhibit A, the Code may not be amended except in written form,
which is specifically approved or ratified by a majority vote of the Fund's
Board, including a majority of independent Board members.

VII. CONFIDENTIALITY

     All reports and records prepared or maintained pursuant to the Code will be
considered confidential and shall be maintained and protected accordingly.
Except as otherwise required by law or the Code, such matters shall not be
disclosed to anyone other than the Fund and its counsel, the Board (or
Committees thereof) and its counsel, and the Advisor.

VIII. INTERNAL USE

     The Code is intended solely for the internal use by the Fund and does not
constitute an admission, by or on behalf of the Fund, as to any fact,
circumstance, or legal conclusion.

Date: September 17, 2003

                                      -4-

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EXHIBIT A

Rodolphe E. Hottinger   Chief Executive Officer

Rudolf S. Millisits     Chief Financial Officer

                                      -5-
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