Exhibit 99.1



                            MERRILL LYNCH & CO., INC.
                                 CODE OF ETHICS
                                       FOR
                             FINANCIAL PROFESSIONALS

The Board of Directors of Merrill Lynch & Co., Inc. (together with its
affiliates, the "Company" or "Merrill Lynch") has adopted the following Code of
Ethics, which applies to all Company Financial Professionals worldwide, to
ensure the continuing integrity of financial reporting and transactions.
"Financial Professional" means any professional employee in the area of finance
(including core and business finance, accounting, and financial reporting),
corporate audit, corporate risk management, corporate tax, investor relations or
treasury, and also includes the Chief Executive Officer ("CEO"), Chief Financial
Officer ("CFO"), Controller, the Head of each of the major business segments of
the Company, and any member of Executive Management who has similar operating or
oversight responsibilities regardless of such person's designated title.

The Company's Guidelines for Business Conduct: Merrill Lynch's Code of Ethics
for Directors, Officers and Employees ("Guidelines for Business Conduct") sets
forth the fundamental principles and key policies and procedures that govern the
conduct of all of the Company's directors, officers and employees. Financial
Professionals are required to conduct their personal and professional affairs in
a manner that is consistent with the ethical and professional standards set
forth in the Guidelines for Business Conduct, as well as this supplemental Code
of Ethics.

All Financial Professionals must:

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

2.            Take all reasonable measures to protect the confidentiality of
              non-public information about Merrill Lynch or any subsidiary and
              Merrill Lynch customers obtained or developed in connection with
              their activities and to prevent the unauthorized disclosure of
              such information unless required by applicable law or regulation
              or legal or regulatory process;

3.            Produce full, fair, accurate, timely, and understandable
              disclosure, in compliance with applicable accounting standards, in
              reports and documents that Merrill Lynch or any subsidiary files
              with, or submits to, the U.S. Securities and Exchange Commission
              or any applicable regulatory body and in other public
              communications made by Merrill Lynch or any subsidiary;

4.            Act in good faith, responsibly, with due care, competence,
              prudence and diligence, without misrepresenting material facts or
              allowing one's independent judgment or decisions to be
              subordinated;

5.            Comply with governmental laws, rules and regulations, as well as
              rules and regulations of self-regulatory organizations applicable
              to Merrill Lynch, its subsidiaries, and their respective
              businesses; and

6.            Promptly bring to the attention of the Disclosure Committee of the
              Company and to senior management any information he or she may
              have concerning (i) significant or material deficiencies or
              weaknesses in the design or operation of the Company's internal
              controls, (ii) any fraud, whether or not material, or any actual
              or apparent conflict of interest between personal and professional
              relationships, involving any member of management or other
              employee who has a significant role in the Company's financial
              reporting, disclosures or internal controls, or (iii) any other
              matters which could have a material adverse effect on the
              Company's ability to record, process, summarize and report
              financial data.


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Financial Professionals shall facilitate the work of the Company's independent
public auditors and shall not, directly or indirectly, take any action to
fraudulently influence, coerce, manipulate or mislead Merrill Lynch's
independent public auditors.

Each Financial Professional is accountable for his or her adherence to this Code
of Ethics and the Company's policies. Any violation of this Code of Ethics may
result in disciplinary action, including immediate dismissal.

Any Financial Professional who believes, in the exercise of reasonable judgment
after a review of the facts, that a violation of this Code of Ethics has
occurred shall promptly report such violation to the General Counsel of
Corporate Law and to the Head of Corporate Audit. In the alternative, reports of
violations of this Code of Ethics and auditing or accounting related concerns
may be made confidentially and anonymously through the Ethics Hotline as set
forth in the Guidelines for Business Conduct.

Merrill Lynch policy prohibits retaliation against an employee who reports a
violation of this Code of Ethics in good faith. As provided by law, Merrill
Lynch is not permitted to fire, demote, suspend, harass or discriminate against
an employee in retaliation for such employee providing information to, or
otherwise assisting or participating in, any investigation or proceeding by a
regulatory or law enforcement agency, any member of the U.S. Congress or a
Congressional committee, or by the Company, relating to what the employee
reasonably believes is a violation of the securities laws, an act of fraud or a
violation of any wage or discrimination laws. No Merrill Lynch director,
officer, employee or representative is permitted to take any such retaliatory
action.


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