<DOCUMENT>
<TYPE>EX-99.(A)(1)
<SEQUENCE>2
<FILENAME>e400995_ex99-a1.txt
<DESCRIPTION>CODE OF ETHICS PURSUANT TO ITEM 2(F)
<TEXT>

                                                                   DECEMBER 2004

                      ABERDEEN AUSTRALIA EQUITY FUND, INC.
                     ABERDEEN ASIA-PACIFIC INCOME FUND, INC.
                        ABERDEEN GLOBAL INCOME FUND, INC.
                                    ("FUNDS")

          CODE OF ETHICS FOR PRINCIPAL EXECUTIVE AND FINANCIAL OFFICERS
                   PURSUANT TO THE SARBANES-OXLEY ACT OF 2002

I. Introduction and Application

In accordance with the Sarbanes-Oxley Act of 2002 ("Sarbanes-Oxley") and the
rules promulgated thereunder by the Securities and Exchange Commission, each of
the Funds is required to publicly disclose on Form N-CSR whether it has adopted
a code of ethics (as defined in Item 2(b) of Form N-CSR) applicable to its
principal executive officer and principal financial officer (each a "Covered
Officer").

Recognizing the importance of high ethical standards in the conduct of the
Funds' business, each Fund's Board of Directors ("Board"), including a majority
of its Independent Directors (as defined below), has adopted this Code of Ethics
("Code").

All recipients of the Code are directed to read it carefully, retain it for
future reference, and abide by the rules and policies set forth herein. Any
questions concerning the applicability or interpretation of such rules and
policies, and compliance therewith, should be directed to the Funds' Chief
Compliance Officer ("CCO") or to Fund counsel.

II. Purpose

The Code is designed to deter wrongdoing and to promote, with respect to each
Fund:

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

      (B) full, fair, accurate, timely and understandable disclosure in reports
and documents the Fund files with, or submits to, the SEC or in other public
communications made by the Fund;

      (C) compliance with applicable governmental laws, rules and regulations;

      (D) prompt internal reporting of violations of this Code to an appropriate
person or persons identified in the Code; and

      (E) accountability for adherence to the Code.

III. Definitions

      (A) "Covered Officer" with respect to a Fund means the principal executive
officer of the Fund and senior financial officers of the Fund, including the
principal financial officer, controller or principal accounting officer, or
persons performing similar functions, regardless of whether these persons are
employed by the Fund or a third party. The Covered Officers are listed on
Appendix A.

<PAGE>

      (B) "Executive Officer" of a Fund has the same meaning as set forth in
Rule 3b-7 under the Securities Exchange Act of 1934, as amended. Subject to any
changes in that rule, the term "executive officer," when used in the Code, means
the president, any vice president, any officer who performs a policy making
function, or any other person who performs similar policy making functions for a
Fund. Each Fund's Executive Officers who are not also Covered Officers are
listed on Appendix A.

      (C) "Independent Director" means a Director of a Fund who is not an
"interested person" of that Fund within the meaning of Section 2(a)(19) of the
1940 Act.

      (D) "Waiver" means the approval by a Fund's CCO of a material departure
from a provision of the Code. "Waiver" includes an "Implicit Waiver," which is a
Fund's failure to take action within a reasonable period of time regarding a
material departure from a provision of this Code that has been made known to an
Executive Officer of the Fund.

IV. Honest and Ethical Conduct

      (A) General Objectives. Each Covered Officer should adhere to a high
standard of business ethics and should be sensitive to, and try to avoid, any
situations that may present, or appear to present, a conflict of interest. A
Fund's Covered Officers are expected to place the interests of the Fund above
the Covered Officer's own personal interests.

      (B) Conflicts of Interests. A "conflict of interest" exists where the
interests or benefits of a Fund's Covered Officer conflict with the interests or
benefits of the Fund. The following list of examples of specific types of
conflicts of interest that may arise is not intended to be comprehensive and
each Covered Officer is expected to treat even an appearance of impropriety as a
potential conflict of interest that should be avoided or brought to the
attention of the CCO.

            (1) Personal Business Transactions. A Fund's Covered Officer may not
cause the Fund to engage in any business transaction with his or her family
members or relatives or utilize the Covered Officer's relationship with the Fund
to cause any third party to engage in any business transaction with his or her
family members or relatives. This provision is not intended, however, to
restrict Covered Officers and their family members or relatives from purchasing
or selling shares of the Fund as long as such transactions are conducted in
accordance with the Fund's Code of Ethics.

            (2) Use of Nonpublic or Confidential Information. A Fund's Covered
Officer may not use, or disclose to a third party, non-public or confidential
information about the Fund or its activities or those of any of the Fund's
service providers for the purpose of personal gain by the Covered Officer or his
or her family members or relatives (including, but not limited to, securities
transactions based on such information).

<PAGE>

            (3) Outside Employment or Activities. A Fund's Covered Officer may
not engage in any outside employment or activity that interferes with his or her
duties and responsibilities with respect to the Fund or is otherwise in conflict
with or prejudicial to the Fund. A Covered Officer must disclose to the CCO any
outside employment or activity that may constitute, or appear to constitute, a
conflict of interest and obtain the CCO's approval before engaging in such
employment or activity. Any such employment or activity is permissible only if
it would not be inconsistent with the best interests of the Fund and its
stockholders.

            (4) Gifts. A Fund's Covered Officer may not accept any gift,
entertainment, favor, or loan from any person or entity that does or seeks to do
business with the Fund which goes beyond the courtesies generally associated
with accepted business practice. Non-cash gifts of a de minimis nature are
considered to be within accepted business practices. Cash gifts of any amount
are strictly prohibited. Entertainment (in the form of meals, tickets to events
or otherwise) must be reasonable in cost, appropriate as to time and place, and
not so frequent as to raise any question of impropriety.

            (5) Corporate Opportunities. A Fund's Covered Officer may not
exploit, for his or her own personal gain or the personal gain of family members
or relatives, opportunities that are discovered through the use of Fund
property, information, or the Covered Officer's position unless the opportunity
is fully disclosed, in writing, to the Fund's Board and the Board declines to
pursue such opportunity on behalf of the Fund.

            (6) Other Situations. Because other conflicts of interest may arise,
it is not practical to list in the Code all possible situations that could
result in a conflict of interest. If a proposed transaction, interest, personal
activity, or investment raises any questions, concerns or doubts, a Covered
Officer should consult with the Fund's CCO or Fund counsel before engaging in
the transaction, making the investment or pursuing the interest or activity.

Each Covered Officer should handle actual or apparent conflicts of interest in
an ethical manner. In the event that a Fund's Covered Officer intends to engage
in a transaction, activity or relationship that the Covered Officer reasonably
believes that the Fund's Board would view as giving rise to a material conflict
of interest, the Covered Officer must (i) avoid (or cease) such transaction,
activity or relationship; or (ii) consult with the CCO and provide an accurate
description of the transaction, activity or relationship. Upon such
consultation, the CCO (in consultation with Fund counsel if the CCO deems
appropriate) shall conduct a review to determine (i) whether engaging in such
transaction, activity or relationship reasonably could be expected to give rise
to a conflict of interest, and (ii) the appropriate resolution of any such
conflict.

Based on its review, the CCO may provide instructions to the Covered Officer to
resolve any potential conflict of interest. The Covered Officer shall either (i)
comply with such instructions; or (ii) request a review of the instructions by
the Fund's president, a vice president or the Board (provided that the review is
not undertaken by a person involved in the matter giving rise to the possible
conflict of interest), any determination following such review being conclusive
(provided that the Board may act in its discretion in any event). The records of
any consultation with the CCO in this regard, and of any review by the Fund's
president, a vice president or the Board shall be retained in the manner set
forth below in Section IX of the Code.

<PAGE>

V. Full, Fair, Accurate, Timely and Understandable Disclosure

      (A) General Policy. The Code is intended to promote full, fair, accurate,
timely and understandable disclosure in reports and other documents filed by
each Fund with the SEC or made in other public communications by the Funds.
Accordingly, the Covered Officers of a Fund are expected to consider it central
to their roles as officers of the Fund to ensure that full, fair, accurate,
timely and understandable disclosure is made in the Fund's reports and other
documents filed with the SEC and in other public communications by the Fund.

      (B) Responsibilities. Each Covered Officer of a Fund shall:

            (1) be familiar with the disclosure requirements generally
applicable to the Fund;

            (2) not knowingly misrepresent, or cause others to misrepresent,
facts about the Fund to others, whether within or outside the Fund, including
the Fund's directors and auditors, governmental regulators and self-regulatory
organizations;

            (3) to the extent appropriate within his or her area of
responsibility; consult with other officers and employees of the Fund, the
Fund's investment adviser and other Fund service providers with the goal of
promoting full, fair, accurate, timely and understandable disclosure in the
reports and documents that the Fund files with, or submits to, the SEC and in
other public communications made by the Fund; and

            (4) promote compliance with the standards and restrictions imposed
by applicable laws, rules and regulations.

VI. Accountability and Reporting under this Code

      (A) Certifications and Accountability. Each Covered Officer of a Fund
shall:

            (1) upon adoption of the Code (or thereafter as applicable upon
becoming a Covered Officer), affirm in writing in accordance with Appendix B
hereto that the Covered Officer has received, read, and understands the Code;

            (2) annually thereafter affirm in the form of Appendix B hereto that
the Covered Officer has complied with the requirements of the Code; and

            (3) not retaliate against any other Covered Officer or employee of
the Fund or its affiliated persons for reports of potential violations that are
made in good faith.

      (B) Reporting of Violations of Applicable Laws and Regulations. A Fund's
Covered Officer, upon learning of a violation of any applicable law, rule or
regulation by a Fund or a person acting with or on behalf of the Fund, must
report such violation to the CCO and assist with the resolution of such
violation. A Covered Officer should seek guidance whenever he or she is in doubt
as to the applicability of any law, rule, or regulation with respect to the
contemplated course of action. If a Covered Officer is unsure of what to do in
any situation, he or she should seek guidance before acting.

<PAGE>

      (C) Reporting of Violations of the Code. Each Covered Officer must
promptly notify the CCO if he or she knows of any actual or potential departure
from the Code, whether the violation or potential violation was committed by the
Covered Officer personally or by another Covered Officer. Each Executive Officer
must promptly notify the CCO if any actual or potential departure from the Code
by a Covered Officer is known to the Executive Officer. In either case, failure
to do so is itself a violation of the Code. If no written report is made by a
Covered Officer or Executive Officer, the CCO must document his or her receipt
of any oral report of a suspected material violation of the Code received.

      (D) Action by Chief Compliance Officer. Upon receiving a report from a
Fund's Covered Officer or an Executive Officer, the Fund's CCO must conduct an
internal investigation into the potential violation(s) of the Code, consulting
with Fund counsel as necessary, to determine whether a violation of the Code has
occurred and whether such violation has had or may have a material adverse
impact upon the Fund.

            (1) If, after such investigation, the CCO determines that no
violation has occurred, the CCO is not required to take any further action.

            (2) If, after such investigation, the CCO, after consultation with
Fund counsel, concludes that there has been a violation of the Code, but the
violation has not caused a material adverse impact on the Fund, the CCO, upon
consultation with Fund counsel, shall determine what sanctions, if any, may be
appropriate.

            (3) If, after such investigation, the CCO, after consultation with
Fund counsel, concludes that there has been a violation of the Code, and that
such violation has had or may have a material adverse effect on the Fund, the
CCO shall report the violation and together with proposed sanctions to the Audit
Committee. The Audit Committee shall be entitled to consult with independent
legal counsel to determine whether the violation actually has had a material
adverse impact upon the Fund and to formulate appropriate actions or sanctions
that the Audit Committee, in its business judgment, determines to be necessary
or advisable. The Audit Committee shall have the discretion, in its business
judgment, to impose sanctions on the Covered Officer if it deems such action to
be necessary or appropriate.

      (E) Periodic Reports to the Board. The CCO of each Fund shall report to
the Board at each regularly scheduled Board meeting any and all violations of
the Code (whether or not they caused a material adverse impact on the Fund), any
Waivers, and any sanctions imposed since the last Board meeting, if any.

      (F) Waivers. Notwithstanding the foregoing, the CCO shall be entitled to
grant a Waiver of one or more provisions of this Code as set forth in Section
VII of the Code.

VII. Waivers of Provisions of the Code

      (A) Waivers. A Fund's Covered Officer may seek, and the Fund's CCO may
grant, Waivers from a provision of the Code in circumstances that would
otherwise constitute a violation of the Code. Waivers will only be granted under
extraordinary or special circumstances. No Waivers will be granted where such a
Waiver would result in a violation of SEC rules or other applicable laws. The
procedure for obtaining and granting a Waiver are as follows:

<PAGE>

            (1) The Covered Officer must submit to the CCO a written request for
a Waiver describing the transaction, activity or relationship for which the
Covered Officer seeks a Waiver that briefly explains the reason for engaging in
the transaction, activity or relationship.

            (2) The determination with respect to the Waiver must be made by the
CCO, in consultation with Fund counsel. If the CCO and Fund counsel determine
that a Waiver is appropriate, the decision must be submitted to the Board for
ratification.

            (3) The CCO must document all Waiver determinations. The
documentation must remain in the records of the Fund for a period of not less
than six years following the end of the fiscal year in which the Waiver
occurred.

      (B) Public Reporting of Waivers, Amendments to Code. To the extent
required by applicable law, Waivers and amendments to the Code will be publicly
disclosed on a timely basis. A Fund may document Waivers and Code amendments in
its Form N-CSR submitted subsequent to the date of the Waiver or post the Waiver
and amendment on its website within five business days following the date of the
Waiver provided that it discloses in its Form N-CSR its intent to post Waivers
and amendments on the Fund's website and maintains the posting for a period of
at least twelve months.

VIII. Sanctions

The matters covered in the Code are of the utmost importance to the Funds and
their stockholders and are essential to each Fund's ability to conduct its
business in accordance with its stated values. Each Covered Officer and each
Executive Officer is expected to adhere to these rules (to the extent
applicable) in carrying out his or her duties for the Funds. The conduct of each
Covered Officer and each Executive Officer can reinforce an ethical atmosphere
and positively influence the conduct of all officers, employees and agents of
the Funds. A Fund will, if appropriate, take action against any Covered Officer
whose actions are found to violate the Code. Appropriate sanctions for
violations of the Code will depend on the materiality of the violation to the
Fund.

Sanctions may include, among other things, a requirement that the violator
undergo training related to the violation, a letter or sanction or written
censure by the Board, the imposition of a monetary penalty, suspension of the
violator as an officer of a Fund or termination of the employment of the
violator. If a Fund has suffered a loss because of violations of the Code, the
Fund may pursue remedies against the individuals or entities responsible.

IX. Records; Confidentiality; Amendments; Disclosure

      (A) Records. The CCO must maintain a copy of the Code, any amendments
hereto, and any reports or other records created in relation to Waivers of the
provisions of the Code (including violations of the Code and implicit Waivers)
for a period of six years from the end of the fiscal year in which such document
was created.

<PAGE>

      (B) Confidentiality. All reports and records prepared and maintained
pursuant to the Code are 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 Board(s) of the affected
Fund(s) and Fund counsel.

      (C) Amendments. A Fund's Covered Officer, Executive Officer or CCO may
recommend amendments to the Code for the consideration and approval of the
Board. The Board may amend the Code in its discretion.

X. Other Policies and Procedures

The Code shall be the sole code of ethics adopted by the Funds for the purposes
of Section 406 of Sarbanes-Oxley and the rules and forms applicable to the Funds
thereunder. To the extent that other policies or procedures of the Funds or the
Funds' investment manager or investment adviser govern or purport to govern the
activities and behavior of the Covered Officers, they are superceded by the Code
to the extent that they overlap or conflict with the Code. The requirements of
the code of ethics adopted by the Funds and by its investment manager and
investment adviser pursuant to Rule 17j-1 under the 1940 Act are separate
requirements applying to the Covered Officers and others and are not part of
this Code.

XI. Internal Use

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

Dated: December 9, 2004

<PAGE>

                                                                      APPENDIX A

                  ABERDEEN AUSTRALIA EQUITY FUND, INC. ("IAF")
                 ABERDEEN ASIA-PACIFIC INCOME FUND, INC.("FAX")
                    ABERDEEN GLOBAL INCOME FUND, INC. ("FCO")

                                 CODE OF ETHICS
                   PURSUANT TO THE SARBANES-OXLEY ACT OF 2002

Covered Officers

Martin Gilbert, President (IAF, FAX, FCO)
Christian Pittard, Treasurer (IAF, FAX, FCO); Principal Financial Officer (IAF,
FAX, FCO)

Chief Compliance Officer

Andrew Smith (IAF, FAX, FCO)

Executive Officers

Bev Hendry, Vice President (IAF)
Steve Robinson, Vice President (IAF)
Alison Briggs, Vice President (FAX, FCO)

<PAGE>

                                   APPENDIX B

                      ABERDEEN AUSTRALIA EQUITY FUND, INC.
                     ABERDEEN ASIA-PACIFIC INCOME FUND, INC.
                        ABERDEEN GLOBAL INCOME FUND, INC.

                                 CODE OF ETHICS
                   PURSUANT TO THE SARBANES-OXLEY ACT OF 2002

                 Initial and Annual Certification of Compliance



--------------------------------------
Name (please print)

This is to certify that I have received a copy of the Code of Ethics Pursuant to
the Sarbanes-Oxley Act of 2002 ("Code") for Aberdeen Australia Equity Fund,
Inc., Aberdeen Asia-Pacific Income Fund, Inc. and Aberdeen Global Income Fund,
Inc. and that I have read and understand the Code. Moreover, I agree to promptly
report to the Chief Compliance Officer any violation or possible violation of
this Code of which I become aware. I understand that violation of the Code will
be grounds for disciplinary action or dismissal.

Check one:

Initial

|_| I further certify that I am subject to the Code and will comply with each of
the Code's provisions to which I am subject.

Annual

|_| I further certify that I have complied with and will continue to comply with
each of the provisions of the Code to which I am subject.



-----------------------------------------------
Signature


-----------------------------------------------
Date


Received by:
             ----------------------------------
             Name:
             Title:

Date:
      -----------------------------------------

</TEXT>
</DOCUMENT>
