Introduction
Honesty and integrity are hallmarks of Advisors Capital Management, LLC. We maintain the highest standards of ethics and conduct in all of our business relationships. This Code of Business Conduct and Ethics covers a wide range of business practices and procedures and applies to the officers and employees of the firm in their conduct of the business and affairs. It does not cover every issue that may arise, but it sets out basic principles to guide the officers and employees in discharging their duties. This Code has been adopted by the principals of Advisors Capital Management with the objectives of deterring wrongdoing and promoting (1) honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships, (2) full, fair, accurate, timely and understandable disclosure in reports and documents which the firm files with the Securities and Exchange Commission and in other public communications made by the firm, (3) compliance with applicable governmental laws, rules and regulations, (4) prompt internal reporting of violations of this Code, and (5) accountability for adherence to this Code. All records and reports created or maintained pursuant to this Code are intended solely for the internal use of Advisors Capital Management, are confidential, and in no event constitute an admission by any person as to any fact, circumstance or legal conclusion.

Compliance with Laws, Rules and Regulations
Advisors Capital Management expects its officers and employees to comply with all laws, rules and regulations applicable to the firm's operations and business. Officers and employees should seek guidance whenever they are in doubt as to the applicability of any law, rule or regulation regarding any contemplated course of action. Advisors Capital Management holds information and training sessions to promote compliance with laws, rules and regulations, including insider-trading laws. As a registered investment advisory firm, Advisors Capital Management is subject to regulation by the Securities and Exchange Commission, and compliance with federal, state and local laws. Advisors Capital Management insists on strict compliance with the spirit and the letter of these laws and regulations.

Conflicts of Interest
Each officer and employee should be scrupulous in avoiding any conflict of interest with regard to the Advisors Capital Management interests. A "conflict of interest" occurs when an individual's private interest interferes with the interests of the firm. A conflict situation can arise when an officer or employee pursues interests that prevent the individual from performing his duties to the firm objectively and effectively. Conflicts of interest also arise when an officer or employee or member of the individual's family receives undisclosed, improper benefits as a result of the individual's position with the firm. Any conflict of interest that arises in a specific situation or transaction must be disclosed by the individual and resolved before taking any action. Matters involving a conflict of interest are prohibited as a matter of firm policy. Conflicts of interest may not always be evident, and individuals should consult with higher levels of management or the firm's legal counsel if they are uncertain about any situation. In no event, however, shall investment in any security made in accordance with Advisors Capital Management's Policy on Personal Securities Transactions (or comparable policy or code then in effect) be considered a conflict of interest with the Firm.

Corporate Opportunities
Officers and employees shall not take for themselves personally opportunities that are discovered through the use of their position with the firm, except with the approval of the officers. Officers and employees owe a duty to the firm to advance its legitimate interests when the opportunity to do so arises. In no event, however, shall investment in any security made in accordance with the firm's Policy on Personal Securities Transactions (or comparable policy or code then in effect) be considered a business opportunity of the firm.

Confidentiality
Officers and employees shall exercise care in maintaining the confidentiality of any confidential information respecting the firm, except where disclosure is authorized or legally mandated. Officers and employees should consult with the firm's legal counsel if they believe they have a legal obligation to disclose confidential information. Confidential information includes non-public information of the firm that may be helpful to competitors, or otherwise harmful to the Advisors Capital Management. The obligation to preserve confidentiality of this information continues after association with Advisors Capital Management ends.

Fair Dealing
Officers and employees should endeavor to deal fairly with the firm's service providers and competitors, and shall not seek unfair advantage through improper concealment, abuse of improperly acquired confidential information, misrepresentation of material facts when the other party is known by the officer or employee to rely justifiably on the individual to disclose those facts truthfully, or improper and unfair dealing.

Business Gifts and Entertainment
The purpose of business entertainment and gifts in a commercial setting is to create goodwill and sound working relationships, not to gain unfair advantage. No gift or entertainment should ever be offered, given, provided or accepted by any officer or employee in connection with the firm's business unless it (1) is not a cash gift, (2) is consistent with customary business practices, (3) is not excessive in value, (4) cannot be construed as a bribe, payoff or kickback and (5) does not violate any laws or regulations.

Protection and Proper Use of Trust Assets
All officers and employees should endeavor to protect the firm's assets and pursue their efficient investment in accordance with the Advisors Capital Management business purposes and declaration of trust. Any suspected incident of fraud or theft should be immediately reported for investigation as hereinafter described under the caption "Reporting Illegal or Unethical Behavior." The obligation of officers and employees to protect the firm's assets includes its proprietary information. Proprietary information includes intellectual property such as trademarks and copyrights, as well as business, marketing and service plans, databases, records, salary information and any unpublished financial data and reports. Unauthorized use or distribution of this information violates this Code.

Insider Trading
All officers and employees should pay particular attention to potential violations of insider trading laws. Insider trading is both unethical and illegal and will be dealt with decisively if it occurs. Officers and employees are expected to familiarize themselves with the Policy Statement on Insider Trading, adopted in the firm's policy and procedures manual. If they have questions about these guidelines, they should consult with the firm's compliance officer.

Reporting Illegal or Unethical Behavior
The firm encourages each employee to talk to senior officers and or the compliance officers, about observed illegal or unethical behavior, or when the officer is in doubt about the best course of action in a particular situation. Officers should report actual and suspected violations of laws, rules, regulations or this Code to appropriate personnel. If the individual's concerns require confidentiality, then this confidentiality will be protected, subject to applicable law, regulation or legal proceedings. The firm will not permit retaliation of any kind by or on behalf of the firm or its officers and employees against good faith reports or complaints of violations of this Code or other illegal or unethical conduct.

Reporting and Disclosure
As a registered investment advisory firm, it is of critical importance that Advisors Capital Management's filings with the Securities and Exchange Commission contain full, fair, accurate, timely and understandable disclosure. Each officer and employee should become familiar with the disclosure laws and regulations applicable to the firm, consistent with the individual's authority and duties. Each officer and employee may be called upon to provide necessary information to ensure that the firm's public reports are complete, fair and understandable. The firm expects officers and employees to take this responsibility very seriously and to provide prompt and accurate answers to inquiries related to the firm's public disclosure requirements. Officers may be asked to certify as to the accuracy of all responses and information provided for inclusion in the firm's public reports and filings.

Recordkeeping
Advisors Capital Management requires accurate recording and reporting of information in order to make responsible business decisions. The firm expect each of it's officers, consistent with the officer's individual authority and duties, to maintain the firm's books, records, accounts and financial statements in reasonable detail, and to appropriately reflect the firm's transactions in conformity with applicable legal requirements and the firm's system of internal controls.

Accounting and Financial Reporting Concerns
Advisors Capital Management seeks to comply with all applicable financial reporting and accounting regulations applicable to the firm. Employees who have concerns or complaints regarding questionable accounting or auditing matters or procedures involving the firm are encouraged to submit those concerns or complaints to the firm's principals or compliance officer which will, subject to their duties arising under applicable law, regulations and legal proceedings, treat such submissions confidentially.

Waivers of the Code of Business Conduct and Ethics
Any waiver of this Code for any officer or employee may be made only by the firm's principals and will be promptly disclosed as required by law or by Securities and Exchange Commission regulations. The firm's managing principal only upon the individual's making full disclosure in advance of the transaction in question may make waivers of this Code for any other individual. This Code may be amended or modified at any time by the firm's principals.
Code of Ethics
 
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