AMENDMENT TO DELARATION OF TRUST

To the Secretary of State of
Commonwealth of Massachusetts

It is herby stated that:

1. This document constitutes an Amendment to the Declaration of Trust (hereinafter called the "Declaration") of John Hancock Strategic Series (hereinafter called the "business trust").

2. The Declaration amended by this document was filed with the Secretary of State of the Commonwealth of Massachusetts on April 16, 1986.

3. The amendment to the Declaration effected by this document is as follows:

The principal office address has been changed effective July 1, 2005 to:

601 Congress Street
Boston, MA 02210

4. The amendment herein provided for was authorized in accordance with law.

IN WITNESS WHEREOF, the undersigned has signed these presents all on June 24, 2005.

/s/ Alfred P. Ouellette
-----------------------
Alfred P. Ouellette, AVP

(This document may be executed by an officer of the business trust.)

JOHN HANCOCK STRATEGIC SERIES

John Hancock High Income Fund

Abolition of John Hancock High Income Fund and Amendment of Section 5.11

Abolition of John Hancock High Income Fund

The undersigned, being a majority of the Trustees of John Hancock Strategic Series, a Massachusetts business trust (the "Trust"), acting pursuant to Section 8.3 of the Amended and Restated Declaration of Trust dated March 8, 2005, as amended from time to time (the "Declaration of Trust"), do hereby abolish the John Hancock High Income Fund (Class A Shares, Class B Shares, Class C Shares and Class I Shares) and in connection therewith do hereby extinguish any and all rights and preferences of such John Hancock High Income Fund, Class A Shares, Class B Shares, Class C Shares and Class I Shares, as set forth in the Declaration of Trust and the Trust's Registration Statement on Form N-1A. The abolition of the Fund is effective as of December 31, 2005.

Amendment of Section 5.11

The undersigned, being a majority of the Trustees of John Hancock Strategic Series, a Massachusetts business trust (the "Trust"), acting pursuant to Section 8.3 of the Amended and Restated Declaration of Trust dated March 8, 2005, as amended from time to time, do hereby amend Section 5.11, effective December 31, 2005, as follows:

1. Section 5.11 (a) shall be deleted and replaced with the following:

Without limiting the authority of the Trustees set forth in Section 5.1 to establish and designate any further Series or Classes, the Trustees hereby establish the following Series: John Hancock Strategic Income Fund which consists of Class A Shares, Class B Shares, Class C Shares, Class I Shares and Class R Shares (the "Existing Shares").

IN WITNESS WHEREOF, the undersigned have executed this instrument on the 6th day of December 2005.

/s/James R. Boyle                                       /s/Charles L. Ladner
-----------------                                       --------------------
James R. Boyle                                          Charles L. Ladner

/s/James F. Carlin                                      /s/John A. Moore
------------------                                      ----------------
James F. Carlin                                         John A. Moore

/s/Richard P. Chapman, Jr.                              /s/Patti McGill Peterson
--------------------------                              ------------------------
Richard P. Chapman, Jr.                                 Patti McGill Peterson

/s/William H. Cunningham                                /s/Steven R. Pruchansky
------------------------                                -----------------------
William H. Cunningham                                   Steven R. Pruchansky

/s/Ronald R. Dion
-----------------
Ronald R. Dion

The Declaration of Trust, a copy of which, together with all amendments thereto, is on file in the office of the Secretary of State of The Commonwealth of Massachusetts, provides that no Trustee, officer, employee or agent of the Trust or any Series thereof shall be subject to any personal liability whatsoever to any Person, other than to the Trust or its shareholders, in connection with Trust Property or the affairs of the Trust, save only that arising from bad faith, willful misfeasance, gross negligence or reckless disregard of his/her duties with respect to such Person; and all such Persons shall look solely to the Trust Property, or to the Trust Property of one or more specific Series of the Trust if the claim arises from the conduct of such Trustee, officer, employee or agent with respect to only such Series, for satisfaction of claims of any nature arising in connection with the affairs of the Trust.

JOHN HANCOCK FUNDS

SUB-ADVISORY AGREEMENT

AGREEMENT made this 31st day of December, 2005, among John Hancock Advisers, LLC, a Delaware limited liability company (the "Adviser"), Sovereign Asset Management LLC, a Delaware limited liability company (the "Sub-adviser"), and each of the trusts that is a signatory hereto (each, a "Trust" and together, as applicable, the "Trusts"). In consideration of the mutual covenants contained herein, the parties agree as follows:

1. APPOINTMENT OF SUB-ADVISER

The Sub-adviser undertakes to act as investment sub-adviser to each of the Trusts and the series thereof (each a "Fund"), in each case listed on Appendix A to this Agreement, as such Appendix may be amended by the affected Trust(s), the Adviser and the Sub-adviser from time to time, and, subject to the supervision and control of the Trustees of each Trust and the terms of this Agreement, to manage the investment and reinvestment of the assets of the Funds. The Sub-adviser will be an independent contractor and will have no authority to act for or represent any Trust, any Fund or the Adviser in any way except as expressly authorized in this Agreement or another writing by the applicable Trust or the Adviser. The Sub-adviser and the Adviser are currently affiliates under the common control of Manulife Financial Corporation.

2. SERVICES TO BE RENDERED BY THE SUB-ADVISER TO THE TRUSTS AND THE FUNDS

a. Subject always to the direction and control of the Trustees of each Trust, the Sub-adviser shall have investment discretion over the assets of each Fund and will manage the investments and determine the composition of these assets in accordance with the applicable Trust's registration statement, as amended. In fulfilling its obligations to manage the investments and reinvestments of the assets of each Fund, the Sub-adviser will:

i. obtain and evaluate pertinent economic, statistical, financial and other information affecting the economy generally and individual companies or industries the securities of which are included in a Fund's portfolio or are under consideration for inclusion in a Fund's portfolio;

ii. formulate and implement a continuous investment program for each Fund that is consistent with the investment objectives and related investment policies for such Fund as described in the applicable Trust's registration statement, as amended, copies of which shall be furnished to the Sub-adviser promptly upon amendment;

iii. take whatever steps are necessary to implement these investment programs by the purchase and sale of securities, including the placing of orders for such purchases and sales;

iv. regularly report to the Trustees of each Trust and to the Adviser with respect to the implementation of these investment programs; and

v. provide assistance to each Trust's custodian regarding the fair value of securities held by each Fund for which market quotations are not readily available.

b. The Sub-adviser, at its expense, will furnish all necessary investment and management facilities, including salaries of personnel required for it to execute its duties faithfully.

c. The Sub-adviser will select brokers and dealers to effect all transactions subject to the following conditions: The Sub-adviser will place all necessary orders with brokers, dealers, or issuers and will negotiate brokerage commissions, if applicable. The Sub-adviser is directed at all times to seek to execute brokerage transactions for each Fund in accordance with such policies or practices as may be established by the Trustees and described in the applicable Trust's registration statement, as amended, and consistent with its fiduciary obligation to seek best execution. Subject to policies established from time to time by the Board of Trustees of the Trusts, the Sub-adviser may pay a broker-dealer which provides research and brokerage services a higher spread or commission for a particular transaction than otherwise might have been charged by another broker-dealer if the Sub-adviser determines that the higher spread or commission is reasonable in relation to the value of the brokerage and research services that such broker-dealer provides, viewed in terms of either the particular transaction or the Sub-adviser's overall responsibilities with respect to accounts managed by the Sub-adviser. The Sub-adviser may use for the benefit of the Sub-adviser's other clients, or make available to companies affiliated with the Sub-adviser or to its directors for the benefit of their clients, any such brokerage and research services that the Sub-adviser obtains from brokers or dealers.

d. On occasions when the Sub-adviser deems the purchase or sale of a security to be in the best interest of a Fund as well as other clients of the Sub-adviser, the Sub-adviser, to the extent permitted by applicable laws and regulations, may, but shall be under no obligation to, aggregate the securities to be purchased or sold to attempt to obtain a more favorable price or lower brokerage commissions and efficient execution. In such event, allocation of the securities so purchased or sold, as well as the expenses incurred in the transaction, will be made by the Sub-adviser in the manner the Sub-adviser considers to be the most equitable and consistent with its fiduciary obligations to each Fund and to its other clients.

e. The Sub-adviser will maintain all accounts, books and records with respect to each Fund as are required of an investment sub-adviser of a registered investment company pursuant to the Investment Company Act of 1940, as amended (the "Investment Company Act") and Investment Advisers Act of 1940, as amended (the "Investment Advisers Act") and the rules thereunder.

f. The Sub-adviser shall vote proxies relating to each Fund's investment securities in accordance with the applicable Trust's proxy voting policies and procedures, which provide that the Sub-adviser shall vote all proxies relating to securities held by a Fund and, subject to the applicable Trust's policies and procedures, shall use proxy voting policies and procedures adopted by the Sub-adviser in conformance with Rule 206(4)-6 under the Investment Advisers Act. The Sub-adviser shall review its proxy voting activities on a periodic basis with the Trustees and with the Adviser.

3. COMPENSATION OF SUB-ADVISER

The Adviser will pay the Sub-adviser with respect to each Fund the compensation specified in Appendix A to this Agreement.

4. LIABILITY OF SUB-ADVISER

Neither the Sub-adviser nor any of its directors, officers or employees shall be liable to the Adviser or any Trust or Fund for any error of judgment or mistake of law or for any loss suffered by the Adviser, Trust or Fund in connection with the matters to which this Agreement relates, except for losses resulting from willful misfeasance, bad faith or gross negligence in the performance of, or from the reckless disregard of, the duties of the Sub-adviser or any of its directors.

5. CONFLICTS OF INTEREST

It is understood that trustees, officers, agents, members and shareholders of the Trusts are or may be interested in the Sub-adviser as trustees, officers, partners, shareholders, members or otherwise; that employees, agents, shareholders, members and partners of the Sub-adviser are or may be interested in a Trust as trustees, officers, shareholders, members or otherwise; that the Sub-adviser may be interested in the Trusts; and that the existence of any such dual interest shall not affect the validity hereof or of any transactions hereunder, except as otherwise provided in the Agreement and Declaration of Trust of the applicable Trust and the limited liability company agreement of the Sub-adviser, respectively, or by specific provision of applicable law.

6. REGULATION

The Sub-adviser shall comply with all applicable laws and regulations in providing the services contemplated hereunder. Without limiting the foregoing, the Sub-adviser shall provide all information reasonably requested of it by the Board of Trustees of the Trusts in accordance with its duty to do so under
Section 15(c) of the Investment Company Act and the Sub-adviser shall submit to all regulatory and administrative bodies having jurisdiction over the services provided pursuant to this Agreement any information, reports or other material which any such body, by reason of this Agreement, may request or require pursuant to applicable laws and regulations.

7. DURATION AND TERMINATION OF AGREEMENT

This Agreement shall become effective with respect to each Fund on the later of (i) its execution, (ii) the date of the meeting of the Board of Trustees of the applicable Trust, at which meeting this Agreement is approved as described below and (iii) immediately following the close of business on December 31, 2005. The Agreement will continue in effect with respect to a Fund for a period more than two years from its effective date only so long as such continuance is specifically approved at least annually either by the Trustees of the applicable Trust or by a majority of the outstanding voting securities of the applicable Fund, provided that in either event such continuance shall also be approved by the vote of a majority of the Trustees of the applicable Trust

who are not interested persons (as defined in the Investment Company Act) of any party to this Agreement cast in person at a meeting called for the purpose of voting on such approval. Any required shareholder approval of the Agreement or of any continuance of the Agreement shall be effective with respect to any Fund if a majority of the outstanding voting securities of the series (as defined in Rule 18f-2(h) under the Investment Company Act) of shares of that Fund votes to approve the Agreement or its continuance, notwithstanding that the Agreement or its continuance may not have been approved by a majority of the outstanding voting securities of any other Fund affected by the Agreement.

If any required shareholder approval of this Agreement or any continuance of the Agreement is not obtained, the Sub-adviser will continue to act as investment sub-adviser with respect to such Fund pending the required approval of the Agreement or its continuance or of a new contract with the Sub-adviser or a different adviser or sub-adviser or other definitive action; provided, that the compensation received by the Sub-adviser in respect of such Fund during such period is in compliance with Rule 15a-4 under the Investment Company Act.

This Agreement may be terminated at any time, without the payment of any penalty, as to a Fund by the Trustees of the applicable Trust or by the vote of a majority of the outstanding voting securities of the applicable Fund, on sixty days' written notice to the Adviser and the Sub-adviser, or by the Adviser or Sub-adviser on sixty days' written notice to the applicable Trust and the other party. This Agreement will automatically terminate, without the payment of any penalty, in the event of its assignment (as defined in the Investment Company Act) or in the event the advisory agreement between the Adviser and the applicable Trust terminates for any reason.

8. PROVISION OF CERTAIN INFORMATION BY SUB-ADVISER

The Sub-adviser will promptly notify the Adviser and the Trusts in writing of the occurrence of any of the following events:

a. the Sub-adviser fails to be registered as an investment adviser under the Investment Advisers Act or under the laws of any jurisdiction in which the Sub-adviser is required to be registered as an investment adviser in order to perform its obligations under this Agreement;

b. the Sub-adviser is served or otherwise receives notice of any action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, public board or body, involving the affairs of any Trust; and

c. any change in actual control or management of the Sub-adviser or the portfolio manager of any Fund.

9. SERVICES TO OTHER CLIENTS

The Adviser understands, and has advised each Trust's Board of Trustees, that the Sub-adviser now acts, or may in the future act, as an investment adviser to fiduciary and other managed accounts and as investment adviser or sub-adviser to other investment companies. Further, the Adviser understands, and has advised each Trust's Board of Trustees, that the Sub-adviser and its affiliates may give advice and take action for other accounts, including investment companies, which differs from advice given or the timing or nature of action taken for a Fund. The Sub-adviser is not obligated to initiate

transactions for a Fund in any security that the Sub-adviser, its partners, affiliates or employees may purchase or sell for their own accounts or other clients.

10. CONSULTATION WITH OTHER SUB-ADVISERS

As required by Rule 17a-10 under the Investment Company Act, the Sub-adviser is prohibited from consulting with the entities listed below concerning transactions for a Fund in securities or other assets:

1. other sub-advisers to the Fund
2. other sub-advisers to any other Fund
3. other sub-advisers to a Fund under common control with such Fund

provided, however, the Sub-adviser may consult with any entity listed above that is an affiliate of the Sub-adviser.

11. ONGOING RESPONSIBILITIES OF THE ADVISER

The Adviser understands, and has advised the Trustees of the Trusts, that during the term of this Agreement the Adviser shall retain responsibility for
(i) providing the services set forth in Section 2 of this Agreement to the Trusts in the event the Sub-adviser fails, for whatever reason, to provide such services and (ii) ensuring that the services provided by the Sub-adviser to the Trusts pursuant to this Agreement are rendered in a manner such that the nature and quality of such services are at least comparable to the nature and quality of the investment advisory services heretofore rendered to the Trusts by the Adviser. Nothing in this Agreement is intended to limit or terminate the Adviser's responsibilities under the Advisory Agreement, which obligations, including the indemnification provisions thereof, shall remain in full force and effect.

12. AMENDMENTS TO THE AGREEMENT

This Agreement (with the exception of Appendix A, which may be amended by the Adviser and the Sub-adviser from time to time) may be amended by the parties hereto only if such amendment is specifically approved by the vote of a majority of the Trustees of each affected Trust and by the vote of a majority of the Trustees of each affected Trust who are not interested persons of any party to this Agreement cast in person at a meeting called for the purpose of voting on such approval. Any required shareholder approval shall be effective with respect to any Fund if a majority of the outstanding voting securities of that Fund votes to approve the amendment, notwithstanding that the amendment may not have been approved by a majority of the outstanding voting securities of (a) any other Fund affected by the amendment or (b) all the Funds of the applicable Trust. No amendment shall be effective unless it is in writing and signed by all parties hereto.

13. ENTIRE AGREEMENT

This Agreement contains the entire understanding and agreement of the parties.

14. HEADINGS

The headings in the sections of this Agreement are inserted for convenience of reference only and shall not constitute a part hereof.

15. NOTICES

All notices required to be given pursuant to this Agreement shall be delivered or mailed to the last known business address of the affected Trusts or applicable party in person or by registered mail or a private mail or delivery service providing the sender with notice of receipt. Notice shall be deemed given on the date delivered or mailed in accordance with this paragraph.

16. SEVERABILITY

Should any portion of this Agreement for any reason be held to be void in law or in equity, this Agreement shall be construed, insofar as is possible, as if such portion had never been contained herein.

17. GOVERNING LAW

The provisions of this Agreement shall be construed and interpreted in accordance with the laws of The Commonwealth of Massachusetts, or any of the applicable provisions of the Investment Company Act. To the extent that the laws of The Commonwealth of Massachusetts, or any of the provisions in this Agreement, conflict with applicable provisions of the Investment Company Act, the latter shall control.

18. LIMITATION OF LIABILITY

The Agreement and Declaration of Trust of each Trust, a copy of which, together with all amendments thereto (the "Declaration"), is on file in the office of the Secretary of The Commonwealth of Massachusetts, provides that the name of the applicable Trust refers to the Trustees under the Declaration collectively as Trustees, but not as individuals or personally; and no Trustee, shareholder, officer, employee or agent of the Trust shall be held to any personal liability, nor shall resort be had to their private property, for the satisfaction of any obligation or claim, in connection with the affairs of the Trust or any Fund thereof, but only the assets belonging to the Trust, or to the particular Fund with respect to which such obligation or claim arose, shall be liable.

19. CONFIDENTIALITY OF FUND HOLDINGS

The Sub-adviser agrees to treat the portfolio security positions of each Fund as confidential information in accordance with the applicable Trust's "Policy Regarding Disclosure of Fund Holdings," as such policy may be amended from time to time, and to prohibit its employees from trading on any such confidential information. The policy and any such amendment shall not be binding upon the Sub-adviser until a copy has been provided to the Sub-adviser.

20. COMPLIANCE

Upon execution of this Agreement, the Sub-adviser shall provide the Adviser and the Trusts with the Sub-adviser's written policies and procedures ("Compliance Policies") as required by Rule 206(4)-7 under the Investment Advisers Act. Throughout the term of this Agreement, the Sub-adviser shall

promptly submit to the affected Trust and the Adviser: (i) any material changes to the Compliance Policies, (ii) notification of the commencement of any regulatory examination of the Sub-adviser and documentation describing the results of any such examination and of any periodic testing of the Compliance Policies, and (iii) notification of any material compliance matter that relates to the services provided by the Sub-adviser to any Trust, including but not limited to any material violation of the Compliance Policies or of the Sub-adviser's code of ethics. Throughout the term of this Agreement, the Sub-adviser shall provide the Adviser and the Trust with any certifications, information and access to personnel and resources (including those resources that will permit testing of the Compliance Policies by the Adviser) that the Trust and/or the Adviser may reasonably request to enable the Trusts to comply with Rule 38a-1 under the Investment Company Act.

(THE REMAINDER OF THIS SPACE HAS BEEN INTENTIONALLY LEFT BLANK)

IN WITNESS WHEREOF, the parties hereto have caused this Agreement to be executed under seal by their duly authorized officers as of the date first mentioned above.

JOHN HANCOCK ADVISERS, LLC

By:    /s/John G. Vrysen
Name:  John G. Vrysen
Title: Executive Vice President and
       Chief Financial Officer

SOVEREIGN ASSET MANAGEMENT LLC

By:    /s/Barry H. Evans
Name:  Barry H. Evans
Title: Senior Vice President and
       Chief Operating Officer

IN WITNESS WHEREOF, the parties hereto have caused this Agreement to be executed under seal by their duly authorized officers as of the date first mentioned above.

JOHN HANCOCK CURRENT INTEREST
on behalf of
John Hancock Money Market Fund
John Hancock U.S. Government Cash Reserve

JOHN HANCOCK SOVEREIGN BOND FUND
on behalf of
John Hancock Bond Fund

JOHN HANCOCK STRATEGIC SERIES
on behalf of
John Hancock Strategic Income Fund

JOHN HANCOCK BOND TRUST
on behalf of
John Hancock Government Income Fund
John Hancock High Yield Fund
John Hancock Investment Grade Bond Fund

JOHN HANCOCK TAX-EXEMPT SERIES FUND
on behalf of
John Hancock Massachusetts Tax-Free Income Fund
John Hancock New York Tax-Free Income Fund

JOHN HANCOCK CALIFORNIA TAX-FREE INCOME FUND

JOHN HANCOCK MUNICIPAL SERIES TRUST
on behalf of
John Hancock High Yield Municipal Bond Fund
John Hancock Tax-Free Bond Fund

JOHN HANCOCK EQUITY TRUST
on behalf of
John Hancock Growth Trends Fund
John Hancock Technology Leaders Fund

JOHN HANCOCK INVESTMENT TRUST II
on behalf of
John Hancock Financial Industries Fund
John Hancock Regional Bank Fund
John Hancock Small Cap Equity Fund

JOHN HANCOCK INVESTMENT TRUST III
on behalf of
John Hancock Mid Cap Growth Fund

JOHN HANCOCK WORLD FUND
on behalf of
John Hancock Health Sciences Fund

JOHN HANCOCK SERIES TRUST
on behalf of
John Hancock Focused Equity Fund
John Hancock Mid Cap Equity Fund
John Hancock Multi Cap Growth Fund
John Hancock Real Estate Fund
John Hancock Small Cap Growth Fund
John Hancock Technology Fund

JOHN HANCOCK INVESTMENT TRUST
on behalf of
John Hancock Balanced Fund
John Hancock Large Cap Equity Fund
John Hancock Large Cap Intrinsic Value Fund
John Hancock Small Cap Intrinsic Value Fund
John Hancock Sovereign Investors Fund

JOHN HANCOCK PATRIOT PREFERRED DIVIDEND FUND

JOHN HANCOCK PREFERRED INCOME FUND III

JOHN HANCOCK PATRIOT SELECT DIVIDEND TRUST

JOHN HANCOCK PATRIOT GLOBAL DIVIDEND FUND

JOHN HANCOCK PREFERRED INCOME FUND

JOHN HANCOCK PREFERRED INCOME FUND II

JOHN HANCOCK PATRIOT PREMIUM DIVIDEND FUND I

JOHN HANCOCK BANK AND THRIFT OPPORTUNITY FUND

JOHN HANCOCK PATRIOT PREMIUM DIVIDEND FUND II

JOHN HANCOCK INCOME SECURITIES TRUST

JOHN HANCOCK INVESTORS TRUST

JOHN HANCOCK TAX-ADVANTAGED DIVIDEND INCOME
FUND

Executed on behalf of each Trust and its
relevant Series referenced above:

By:     /s/Keith F. Hartstein
Name:   Keith F. Hartstein
Title:  President and Chief Executive Officer

Trust and Fund                 Percentage of
                             Average Daily Net
                                  Assets


          (See attachment to Appendix A)

The Sub-adviser Fee for each Fund shall be accrued for each calendar day, and the sum of the daily fee accruals shall be paid monthly to the Sub-adviser within 30 calendar days of the end of each month. The daily fee accruals will be computed by multiplying the fraction of one over the number of calendar days in the year by the applicable Sub-adviser Fee, and multiplying this product by the net assets of the Fund. The Adviser shall provide the Sub-adviser with such information as the Sub-adviser may reasonably request supporting the calculation of the fees paid to it hereunder. Fees shall be paid either by wire transfer or check, as directed by the Sub-adviser.

If, with respect to any Fund, this Agreement becomes effective or terminates, or if the manner of determining the applicable Sub-adviser Fee changes, before the end of any month, the fee (if any) for the period from the effective date to the end of such month or from the beginning of such month to the date of termination or from the beginning of such month to the date of such change, as the case may be, shall be pro rated according to the proportion which such period bears to the full month in which such effectiveness or termination or change occurs.

--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Balanced Fund                                  to $2 bil   > $2 bil

                                  Subadvisory    0.300%     0.250%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Bond   Fund                                      to $1.5     $1.5 -     $2.0 -      > $2.5 bil
                                                  bil       2.0 bil    2.5 bil

                                  Subadvisory     0.200%     0.125%      0.100%      0.100%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
California Tax-Free Income Fund                  to $500m   next $500m  > $1 bil

                                  Subadvisory     0.200%     0.150%      0.150%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Financial Industries  Fund                       to $500m  next $500m   next bil   > $2 bil

                                  Subadvisory     0.400%     0.300%      0.250%     0.250%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Focused Equity Fund                              to $800m    > $800m

                                  Subadvisory     0.350%     0.300%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Government Income Fund                           to $300m  next $300m   >$600m

                                  Subadvisory     0.200%     0.150%      0.100%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Growth Trends Fund                             to $2.4 bil > $2.4 bil

                                  Subadvisory     0.350%     0.250%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Health Sciences Fund                            to $200m    > $200m

                                  Subadvisory    0.450%     0.400%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
High Yield Fund                                 to $75m    next $75m  $150m-$2.5b $2.5b-$5.0b  > $5 bil

                                  Subadvisory    0.275%     0.275%      0.225%      0.150%     0.150%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
High Yield Municipal Bond Fund                  to $75m    next $75m   > $150m

                                  Subadvisory    0.200%     0.200%      0.200%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Investment Grade Bond Fund                     to $1.5 bil > $1.5 bil

                                  Subadvisory    0.200%     0.100%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Large Cap Equity Fund                           to $3 bil   > $3 bil


                                  Subadvisory     0.325%     0.200%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Large Cap Intrinsic Value Fund                  All Assets
                                   Advisory      0.750%
                                   Subadvisory   0.325%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------

--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
MA Tax-Free Income Fund                         to $250m   next $250m $500m-$1 bil next $250m > $1.25 bil


                                  Subadvisory    0.200%      0.200%      0.150%      0.150%     0.150%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Mid Cap Equity Fund                             to $500m   next $500m  > $1 bil

                                  Subadvisory    0.350%     0.300%      0.250%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Mid Cap Growth Fund                             to $500m   next $500m  > $1 bil

                                  Subadvisory    0.350%     0.300%      0.250%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Money Market Fund                               to $500m   next $250m  next $250m  next $500m next $500m  next $500m  > $2.5 bil

                                  Subadvisory    0.050%      0.020%      0.020%      0.020%     0.020%      0.020%      0.020%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Multi Cap Growth Fund                           to $750m    > $750m

                                  Subadvisory    0.350%     0.250%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
New York Tax-Free Income Fund                   to $250m   next $250m $500m-$1 bil next $250m > $1.25 bil

                                  Subadvisory    0.200%      0.200%      0.150%      0.150%     0.150%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Real Estate  Fund                              to $1.5 bil > $1.5 bil

                                  Subadvisory     0.350%     0.300%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Regional Bank Fund                              to $500m   next $500m  next bil    > $2 bil

                                  Subadvisory    0.400%      0.300%     0.250%      0.250%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Small Cap Equity Fund                           to $1 bil   > $1 bil

                                  Subadvisory    0.450%     0.400%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Small Cap Growth Fund                          to $1.5 bil > $1.5 bil

                                  Subadvisory    0.450%     0.400%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Small Cap Intrinsic Value Fund                  to $500m   next $500m  > $1 bil

                                  Subadvisory    0.500%      0.450%     0.400%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Sovereign Investors Fund                        to $750m   next $750m  next bil    > $2.5 bil

                                  Subadvisory    0.325%      0.250%      0.250%      0.200%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------

--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Strategic Income Fund                           to $100m   $100-$250m $250-$500m  $500-$650m  $650m-$1bil   >$1bil

                                  Subadvisory    0.275%      0.275%     0.275%      0.200%      0.200%      0.150%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Tax-Free Bond Fund                              to $500m   next $500m  > $1 bil

                                  Subadvisory    0.200%      0.150%     0.100%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Technology Fund                                 to $100m   next $700m   > $800m

                                  Subadvisory    0.450%     0.400%      0.350%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Technology Leaders Fund                        All Assets
                                  Advisory       1.000%
                                  Subadvisory    0.400%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
US Gov't Cash Reserve                           to $500m   next $250m next $250m  next $500m  next $500m  next $500m > $2.5 bil

                                  Subadvisory    0.050%      0.020%     0.020%      0.020%     0.020%      0.020%      0.020%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Bank & Thrift Opportunity Fund                 All Assets

                                  Subadvisory    0.400%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Income Securities Trust                         to $150m   next $50m  next $100m   > $300m

                                  Subadvisory    0.200%     0.200%      0.200%      0.150%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Investors Trust                                 to $150m   next $50m  next $100m   > $300m

                                  Subadvisory    0.200%     0.200%      0.200%      0.150%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
JH Preferred Income Fund                        All Assets

                                  Subadvisory    0.150%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
JH Preferred Income Fund II                     All Assets


                                  Subadvisory    0.150%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
JH Preferred Income Fund III                    All Assets


                                  Subadvisory    0.150%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
JH Tax-Advantaged Dividend Income               All Assets
Fund

                                  Subadvisory    0.150%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Patriot Global Dividend Fund                    All Assets

                                  Subadvisory    0.200%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------

--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Patriot Preferred Dividend Fund                All Assets

                                  Subadvisory    0.200%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Patriot Premium Dividend Fund I                All Assets

                                  Subadvisory    0.200%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Patriot Premium Dividend Fund II               All Assets

                                  Subadvisory    0.200%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------
Patriot Select Dividend Trust                  All Assets

                                  Subadvisory    0.200%
--------------------------------- ------------ ----------- ---------- ----------- ----------- ---------- ----------- -----------

ACCOUNTING AND LEGAL SERVICES AGREEMENT
AMENDMENT DATED MARCH 8, 2005

The Accounting and Legal Services Agreement dated January 1, 1996, as amended July 1, 2004, between the John Hancock Funds listed on Schedule A ("Funds") and John Hancock Advisers, LLC ("Administrator") is amended as follows, effective April 1, 2005:

1. (B) Services. Legal services shall include services of the John Hancock Life Insurance Company's JH Funds legal group and responses prepared by the John Hancock Life Insurance Company legal staff on behalf of the Funds to subpoenas and appropriate information requests for shareholder records.

JOHN HANCOCK FUNDS (See Schedule A)

JOHN HANCOCK ADVISERS, LLC

September 27, 2006

John Hancock Sovereign Bond Fund
601 Congress Street
Boston, MA 02210

RE: John Hancock Strategic Series (the "Trust") John Hancock Strategic Income Fund (the "Fund") File Nos. 33-5186; 811-4651 (0000792858)

Ladies and Gentlemen:

In connection with the filing of Post Effective Amendment No. 43 under the Securities Act of 1933, as amended, and Amendment No. 43 under the Investment Company Act of 1940, as amended, for John Hancock Strategic Series it is the opinion of the undersigned that the Trust's shares when sold will be legally issued, fully paid and nonassessable.

In connection with this opinion it should be noted that the Fund is an entity of the type generally known as a "Massachusetts business trust." The Trust has been duly organized and is validly existing under the laws of the Commonwealth of Massachusetts. Under Massachusetts law, shareholders of a Massachusetts business trust may be held personally liable for the obligations of the Trust. However, the Trust's Declaration of Trust disclaims shareholder liability for obligations of the Trust and indemnifies the shareholders of a Fund, with this indemnification to be paid solely out of the assets of that Fund. Therefore, the shareholder's risk is limited to circumstances in which the assets of a Fund are insufficient to meet the obligations asserted against that Fund's assets.

Sincerely,

/s/Alfred A. Ouellette
----------------------
Alfred A. Ouellette
AVP, Senior Counsel
Assistant Secretary

We hereby consent to the incorporation by reference in this Registration Statement on Form N-1A of our reports dated July 14, 2006, relating to the financial statements and financial highlights which appear in the May 31, 2006 Annual Reports to Shareholders of John Hancock Bond Fund, John Hancock Government Income Fund, John Hancock High Yield Fund, John Hancock Investment Grade Bond Fund and John Hancock Strategic Income Fund, which are also incorporated by reference into the Registration Statement. We also consent to the references to us under the heading "Independent Registered Public Accounting Firm" in such Registration Statement.

/s/PricewaterhouseCoopers
-------------------------
PricewaterhouseCoopers LLP

Boston, Massachusetts
September 27, 2006

Code of Ethics for the Independent Directors/Trustees of the John Hancock Funds

Effective December 6, 2005

The Board of Directors/Trustees (the "Board") of each open-end and closed-end fund that is listed in Appendix A hereto (individually, a "John Hancock Fund" and collectively, the "John Hancock Funds"), as may be updated from time to time, has adopted this code of ethics (this "Code"). This Code applies only to Directors/Trustees who are not "interested persons," as defined in Section 2(a)(19) of the Investment Company Act of 1940 (the "1940 Act"), of the John Hancock Funds (the "Independent Trustees"). This Code is intended to comply with the requirements of Rule 17j-1 under the 1940 Act insofar as they apply to the Independent Trustees.

The Board recognizes that the John Hancock Funds' officers and access persons (with the exception of the Independent Trustees) are covered by a separate code of ethics adopted by the Board, which may be combined with the code of ethics of John Hancock Advisers, LLC, Sovereign Asset Management Co. and/or John Hancock Funds, LLC. The Board, after considering the limited nature of access by the Independent Trustees to current information with respect to security transactions being effected or considered on behalf of the John Hancock Funds, adopts this Code specifically and separately to cover the Independent Trustees.

Please note that the policies described below apply to all accounts over which you have a beneficial interest. Normally, you will be deemed to have a beneficial interest in your personal accounts, those of a spouse, "significant other," minor children or family members sharing a household, as well as all accounts over which you have discretion or give advice.

Set forth below are policies applicable to the Independent Trustees.

I. Statements of Policy

A. General Principles

It is unlawful for any Independent Trustee covered by this Code, directly or indirectly, in connection with his or her purchase or sale of a security held or to be acquired by a John Hancock Fund, to:
o employ any device, scheme or artifice to defraud a John Hancock Fund;
o make any untrue statement of a material fact to a John Hancock Fund or omit to state a material fact necessary in order to make the statements made to a John Hancock Fund, in light of the circumstances under which they are made, not misleading;
o engage in any act, practice or course of business that operates or would operate as a fraud or deceit on a John Hancock Fund; or
o engage in any manipulative practice with respect to a John Hancock Fund.

The General Principles discussed above govern all conduct, whether or not the conduct is also covered by more specific standards and procedures in this Code. Failure to comply with this Code may result in disciplinary action, including potentially removal from the Board in accordance with the terms of the John Hancock Fund charter documents.

B. Transactions in John Hancock Funds

The Independent Trustees are subject to the same policies against excessive trading that apply to all shareholders of the open-end John Hancock Funds. These policies are described in the John Hancock Funds' prospectuses and are subject to change.

C. Annual Certification

At least annually, you must provide a certification at a date designated by the Chief Compliance Officer of John Hancock Funds that:

(1) you have read and understand this Code;
(2) you recognize that you are subject to its requirements; and
(3) you have complied, to the best of your knowledge, with its requirements.

You are required to make this certification to demonstrate that you understand the importance of these policies and your responsibilities under the Code.

D. Quarterly Transaction Reports

You will not generally be required to submit quarterly transaction reports. You will, however, be required to submit a quarterly transaction report if you knew (or, in the ordinary course of fulfilling your official duties as an Independent Trustee, should have known) that during the 15 calendar days before or after you trade a security, either:

(i) a John Hancock Fund purchased or sold the same security, or
(ii) a John Hancock Fund or its investment adviser considered purchasing or selling the same security.

If these circumstances occur, it is your responsibility to contact the Chief Compliance Officer of the John Hancock Funds and he will assist you with the requirements of the quarterly transaction report.

You must submit a quarterly transaction report within 30 calendar days after the end of a calendar quarter if required in the limited circumstances described above. This report is triggered by and must cover all transactions during the calendar quarter that are personal securities transactions, as described below in Section II Personal Securities Transactions.

Your quarterly transaction report must include the following information about these transactions:
o the date of the transaction, the title, and as applicable, the exchange ticker symbol or CUSIP number, interest rate and maturity date (if applicable), number of shares, and principal amount of each reportable security involved;
o the nature of the transaction (i.e., purchase, sale or any other type of acquisition or disposition);
o the price at which the transaction was effected;
o the name of the broker, dealer or bank with or through which the transaction was effected; and
o the date that you submit the report.

With respect to any account established by an Independent Trustee in which any securities were held during the quarter for his or her direct or indirect benefit, the quarterly transaction report must also include the following account information:
o the name of the broker, dealer or bank with whom you have established an account;
o the date the account was established; and

o the date that you submit the report.

II. Personal Securities Transactions

A Personal Securities Transaction is a transaction in a security in which an Independent Trustee subject to this Code of has a beneficial interest. Normally, this includes securities transactions in your personal accounts, those of a spouse, "significant other," minor children or family members sharing your household, as well as all accounts over which you have discretion or give advice or information. In identifying your accounts, you must identify all brokerage accounts that contain securities, including brokerage accounts that only contain securities exempt from reporting. Accounts over which you have no direct or indirect influence or control are exempt. To prevent potential violations of this Code, you are strongly encouraged to request clarification for any transactions or accounts that are in question.

A. Included Personal Securities Transactions

Except as noted below, Personal Securities Transactions include transactions in all securities, including:
o Stocks or bonds;
o Government securities that are not direct obligations of the U.S. government, such as Fannie Mae or municipal securities;
o Shares of all closed-end funds;
o Shares of open-end mutual funds that are advised or sub-advised by John Hancock Advisers or by John Hancock or Manulife entities (other than money market funds);
o Options on securities, on indexes, and on currencies;
o All kinds of limited partnerships;
o Foreign unit trusts and foreign mutual funds;
o Private investment funds and hedge funds; and
o Futures, investment contracts or any other instrument that is considered a "security" under the Investment Advisers Act of 1940.

B. Exempt Personal Securities Transactions

Personal Securities Transactions do not include transactions in the following securities:
o Direct obligations of the U.S. government (e.g., treasury securities);
o Bankers' acceptances, bank certificates of deposit, commercial paper, and high quality short-term debt obligations, including repurchase agreements;
o Shares of open-end mutual funds that are not advised or sub-advised by John Hancock Advisers or by John Hancock or Manulife entities;
o Shares issued by money market funds; and
o Securities in accounts over which you have no direct or indirect influence or control.

III. Administration of the Code of Ethics

A. Review of Reports

The Chief Compliance Officer of the John Hancock Funds shall review any reports delivered by an Independent Trustee pursuant to this Code. Any such review shall give special attention to evidence, if any, of conflicts or potential conflicts with the securities transactions of the John Hancock Funds or violations or potential violations of the antifraud provisions of the federal securities law or the policies of this Code.

B. Investigations of Potential Violations

The Chief Compliance Officer shall investigate any potential violation of the provisions of this Code. After completion of any such investigation, the Chief Compliance Officer shall determine whether a violation has occurred and, if so, make a report to the Board. The Board shall determine what action should be taken in response to a violation of this Code.

C. Annual Reports

At least on an annual basis, the Chief Compliance Officer shall provide the Board with (i) a written report that describes issues that arose under this Code since the prior such report, including, but not limited to, information relating to material violations of this Code and any actions taken, and (ii) a certification that the John Hancock Funds have adopted procedures reasonably necessary to prevent the Independent Trustees from violating this Code.

D. Record Retention Requirements

The Chief Compliance Officer shall maintain the following records at the John Hancock Funds' principal place of business, and shall make these records available to the Securities and Exchange Commission at any time and from time to time for reasonable periodic, special or other examination:

o A copy of this Code that is currently in effect, or at any time within the past five years was in effect, must be maintained in an easily accessible place.
o A record of any violation of this Code, and any action taken as a result of a violation, must be maintained in an easily accessible place for at least five years after the end of the fiscal year in which the violation occurs.
o A copy of each report made by an Independent Trustee under this Code and any report made under Section III.C. above must be maintained for at least five years after the end of the fiscal year in which the report is made, the first two years in an easily accessible place.
o A record of all Independent Trustees, currently or within the past five years, who are subject to this Code, and of individual(s) who are responsible for reviewing reports made under this Code, must be maintained in an easily accessible place.

E. Amendments

Any amendments to this Code after its adoption must be approved by a majority of the Independent Trustees.

Appendix A

John Hancock Funds

John Hancock Bank and Thrift Opportunity Fund

John Hancock Bond Trust
John Hancock Government Income Fund
John Hancock High Yield Bond Fund
John Hancock Investment Grade Bond Fund

John Hancock California Tax-Free Income Fund

John Hancock Capital Series
John Hancock Classic Value Fund
John Hancock Core Equity Fund
John Hancock Large Cap Select Fund

John Hancock U.S. Global Leaders Growth Fund

John Hancock Current Interest John Hancock Money Market Fund John Hancock U.S. Government Cash Reserve

John Hancock Equity Trust John Hancock Growth Trends Fund

John Hancock Income Securities Trust

John Hancock Institutional Series Trust

John Hancock Independence Diversified Core Equity Fund II

John Hancock Investment Trust John Hancock Balanced Fund John Hancock Large Cap Equity Fund John Hancock Sovereign Investors Fund

John Hancock Investment Trust II John Hancock Financial Industries Fund John Hancock Regional Bank Fund John Hancock Small Cap Equity Fund

John Hancock Investment Trust III John Hancock International Fund John Hancock Large Cap Growth Fund John Hancock Mid Cap Growth Fund

John Hancock Investors Trust

John Hancock Patriot Global Dividend Fund

John Hancock Patriot Preferred Dividend Fund

John Hancock Patriot Premium Dividend Fund I

John Hancock Patriot Premium Dividend Fund II

John Hancock Patriot Select Dividend Trust

John Hancock Preferred Income Fund

John Hancock Preferred Income Fund II

John Hancock Preferred Income Fund III

John Hancock Tax-Advantaged Dividend Income Fund

John Hancock Series Trust
John Hancock Focused Equity Fund
John Hancock Mid Cap Equity Fund
John Hancock Multi Cap Growth Fund
John Hancock Real Estate Fund
John Hancock Small Cap Growth Fund
John Hancock Technology Fund

John Hancock Sovereign Bond Fund
John Hancock Bond Fund

John Hancock Strategic Series
John Hancock High Income Fund
John Hancock Strategic Income Fund

John Hancock Tax-Exempt Series Fund

John Hancock Massachusetts Tax-Free Income Fund John Hancock New York Tax-Free Income Fund

John Hancock Municipal Securities Trust John Hancock High-Yield Municipal Bond Fund John Hancock Tax-Free Bond Fund

John Hancock World Fund John Hancock Biotechnology Fund John Hancock Health Sciences Fund

Name: ________________________________

Code of Ethics Certification For The Independent Trustees/Directors of the Funds

In accordance with the Code of Ethics' Annual Certification requirement, please review the Code of Ethics and certify by signing below. Please return the signed certificate by January 31, 2006 to:

Compliance Department, 601 Congress Street, Boston, Massachusetts 02210 Attn: Frank Knox, CCO

If you have any questions, please contact Frank Knox at (617) 663-2430 or fknox@jhancock.com.

Certification of the John Hancock Funds Code of Ethics:

A. I certify that I have received, read and understood the Code of Ethics applicable to the Independent Trustees dated December 6, 2005;

B. I certify that, to the best of my knowledge, I have been in compliance with the policies applicable to me under the Code of Ethics, during the period since its adoption or the past 12 months, whichever is shorter.

Signature Date Print Name

Code of Ethics

July 1, 2006

This is the code of ethics of:

o John Hancock Advisers, LLC

o Sovereign Asset Management LLC

o each open-end and closed-end fund advised by John Hancock Advisers, LLC

o John Hancock Funds, LLC

(together, called "John Hancock Funds")

1. General Principles

Each person within the John Hancock Funds organization is responsible for maintaining the very highest ethical standards when conducting our business.

This means that:

o You have a fiduciary duty at all times to place the interests of our clients and fund investors first.

o All of your personal securities transactions must be conducted consistent with the provisions of this code of ethics that apply to you and in such a manner as to avoid any actual or potential conflict of interest or other abuse of your position of trust and responsibility.

o You should not take inappropriate advantage of your position or engage in any fraudulent or manipulative practice (such as front-running or manipulative market timing) with respect to our clients' accounts or fund investors.

o You must treat as confidential any information concerning the identity of security holdings and financial circumstances of clients or fund investors.

o You must comply with all applicable federal securities laws.

o You must promptly report any violation of this code of ethics that comes to your attention to the Chief Compliance Officer of your company.

The General Principles discussed above govern all conduct, whether or not the conduct is also covered by more specific standards and procedures in this code of ethics. As described below under the heading "Interpretation and Enforcement", failure to comply with the code of ethics may result in disciplinary action, including termination of employment.

2. To Whom Does This Code Apply?

This code of ethics applies to you if you are a director, officer or employee of John Hancock Advisers, LLC, Sovereign Asset Management LLC, John Hancock Funds, LLC or a John Hancock open-end or closed-end fund registered under the '40 Act and advised by John Hancock Advisers, LLC or Sovereign Asset Management LLC ("John Hancock funds"). It also applies to you if you are trustee of the John Hancock Financial Trends Fund or an employee of John Hancock Life Insurance Co. or its subsidiaries who participates in making recommendations for, or receives information about, portfolio trades or holdings of the John Hancock funds or accounts. However, notwithstanding anything herein to the contrary, it does not apply to any trustees/directors of any open-end or closed-end funds advised by John Hancock Advisers, LLC who are not "interested persons" of such funds as defined in Section 2(a)(19) of the Investment Company Act of 1940 (the "'40 Act"), so long as they are subject to a separate Code of Ethics (each, an "Excluded Independent Director"). Also, in some cases only a limited number of provisions will apply to you, based on your access category. For example, only a limited number of provisions apply to independent directors of the John Hancock mutual funds and closed-end funds who are not Excluded Independent Directors -- see Appendix C for more information.

Please note that if a policy described below applies to you, it also applies to all accounts over which you have a beneficial interest. Normally, you will be deemed to have a beneficial interest in your personal accounts, those of a spouse, "significant other," minor children or family members sharing a household, as well as all accounts over which you have discretion or give advice or information. "Significant others" are defined for these purposes as two people who (1) share the same primary residence; (2) share living expenses; and
(3) are in a committed relationship and intend to remain in the relationship indefinitely.

There are three main categories for persons covered by this code of ethics, taking into account their positions, duties and access to information regarding fund portfolio trades. You have been notified about which of these categories applies to you, based on the Investment Compliance Department's understanding of your current role. If you have a level of investment access beyond your assigned category, or if you are promoted or change duties and as a result should more appropriately be included in a different category, it is your responsibility to notify the Chief Compliance Officer of your company.

The basic definitions of the three main categories, with examples, are provided below. The more detailed definitions of each category are attached as Appendix
A.

-----------------------------------------------------------------------------------------------------------
     "Investment Access" person           "Regular Access" person              "Non-Access" person
                                     A person who regularly has access     A person who does not regularly
                                      to (1) fund portfolio tradesor          participate in a fund's
                                         (2) non-public information         investment process or obtain
                                      regarding holdings or securities        information regarding fund
A person who regularly participates     recommendations to clients.                portfolio trades
 in a fund's investment process or
makes securities recommendations to   examples:                              examples:
              clients.                                                       o wholesalers
examples:                             o personnel in Investment Operations   o inside wholesalers
                                        or Compliance                          who don't attend
o portfolio managers                  o most FFM  personnel                    investment "morning
o analysts                            o Technology personnel                   meetings"
o traders                               with access to                       o certain administrative
                                        investment systems                     personnel
                                      o attorneys and some
                                        legal administration
                                        personnel
                                      o investment admin.
                                        personnel
-----------------------------------------------------------------------------------------------------------

3. Which Accounts and Securities are Subject to the Code's Personal Trading Restrictions?

If this code of ethics describes "Personal Trading Requirements" (i.e. John Hancock Mutual Fund reporting requirement and holding period, the preclearance requirement, the ban on short-term profits, the ban on IPOs, the disclosure of private placement conflicts and the reporting requirements) that apply to your access category as described above, then the requirements apply to trades for any account in which you have a beneficial interest. Normally, this includes your personal accounts, those of a spouse, "significant other," minor children or family members sharing your household, as well as all accounts over which you have discretion or give advice or information. This includes all brokerage accounts that contain securities (including brokerage accounts that only contain securities exempt from reporting). Accounts over which you have no direct or indirect influence or control are exempt. To prevent potential violations of this code of ethics, you are strongly encouraged to request clarification for any accounts that are in question.

These personal trading requirements do not apply to the following securities:

o Direct obligations of the U.S. government (e.g., treasury securities);

o Bankers' acceptances, bank certificates of deposit, commercial paper, and high quality short-term debt obligations, including repurchase agreements;

o Shares of open-end mutual funds registered under the Investment Company Act of 1940 ("40 Act") that are not advised or sub-advised by John Hancock Advisers, John Hancock Investment Management Services or another Manulife entity;

o Shares issued by money market funds; and

o Securities in accounts over which you have no direct or indirect influence or control.

Except as noted above, the Personal Trading Requirements apply to all securities, including:

o Stocks;

o Bonds;

o Government securities that are not direct obligations of the U.S. government, such as Fannie Mae or municipal securities;

o Closed-end funds;

o Options on securities, on indexes, and on currencies;

o Limited partnerships;

o Domestic unit investment trusts;

o Exchange traded funds;

o Non-US unit investment trusts and Non-US mutual funds;

o Private investment funds and hedge funds; and

o Futures, investment contracts or any other instrument that is considered a "security" under the Investment Advisers Act.

Different requirements apply to shares of open-end mutual funds that are advised or sub-advised by John Hancock Advisers or by John Hancock or Manulife entities--see the section below titled "John Hancock Mutual Funds Reporting Requirement and Holding Period".

4. Overview of Policies

-------------------------------------------------------------------------------------------------------------------------
                                                     Investment Access Person   Regular Access    Non-Access Person
                                                                                Person
-------------------------------------------------------------------------------------------------------------------------
General principles                                   yes                        yes               yes
-------------------------------------------------------------------------------------------------------------------------
Policies outside the code
-------------------------------------------------------------------------------------------------------------------------
Conflict of interest policy                          yes                        yes               yes
-------------------------------------------------------------------------------------------------------------------------
Inside information policy                            yes                        yes               yes
-------------------------------------------------------------------------------------------------------------------------
Policy regarding dissemination of mutual fund        yes                        yes               yes
portfolio information
-------------------------------------------------------------------------------------------------------------------------
Policies in the code
-------------------------------------------------------------------------------------------------------------------------
Restriction on gifts                                 yes                        yes               yes
-------------------------------------------------------------------------------------------------------------------------
John Hancock mutual funds reporting requirement and  yes                        yes               yes
holding period
-------------------------------------------------------------------------------------------------------------------------
Pre-clearance requirement                            yes                        yes               Limited


-------------------------------------------------------------------------------------------------------------------------
Heightened preclearance of securities transactions   yes                        yes               no
for "Significant Personal Positions"
-------------------------------------------------------------------------------------------------------------------------
Ban on short-term profits                            yes                        no                no
-------------------------------------------------------------------------------------------------------------------------

-------------------------------------------------------------------------------------------------------------------------
Ban on IPOs                                          yes                        no                no
-------------------------------------------------------------------------------------------------------------------------
Disclosure of private placement conflicts            yes                        no                no
-------------------------------------------------------------------------------------------------------------------------
Seven day blackout period                            yes                        no                no
-------------------------------------------------------------------------------------------------------------------------
Reports and other disclosures outside the code
-------------------------------------------------------------------------------------------------------------------------
Broker letter/duplicate confirms                     yes                        yes               yes
-------------------------------------------------------------------------------------------------------------------------
Reports and other disclosures in the code
-------------------------------------------------------------------------------------------------------------------------
Annual recertification form                          yes                        yes               yes
-------------------------------------------------------------------------------------------------------------------------
Initial/annual holdings reports                      yes                        yes               no
-------------------------------------------------------------------------------------------------------------------------
Quarterly transaction reports                        yes                        yes               no
-------------------------------------------------------------------------------------------------------------------------

5. Policies Outside the Code of Ethics

John Hancock Funds has certain policies that are not part of the code of ethics, but are equally important. The two most important of these policies are (1) the Company Conflict and Business Practice Policy; and (2) the Inside Information Policy.

Company Conflict & Business Practice Policy

Regular Access Persons

A conflict of interest occurs when your private interests interfere or could potentially interfere with your responsibilities at work. You must not place yourself or the company in a position of actual or potential conflict.

This Policy for officers and employees covers a number of important issues. For example, you cannot serve as a director of any company without first obtaining the required written executive approval.

This Policy includes significant requirements to be followed if your personal securities holdings overlap with John Hancock Funds investment activity. For example, if you or a member of your family own:

o a 5% or greater interest in a company, John Hancock Funds and its affiliates may not make any investment in that company;

o a 1% or greater interest in a company, you cannot participate in any decision by John Hancock Funds and its affiliates to buy or sell that company's securities;

o ANY interest in a company, you cannot recommend or participate in a decision by John Hancock Funds and its affiliates to buy or sell that company's securities unless your personal interest is fully disclosed at all stages of the investment decision.

(This is just a summary of these requirement--please read Section IV of the Company Conflict and Business Practices Policy for more detailed information.)

Other important issues in this Policy include:

o personal investments or business relationships

o misuse of inside information

o receiving or giving of gifts, entertainment or favors

o misuse or misrepresentation of your corporate position

o disclosure of confidential or proprietary information

o antitrust activities

o political campaign contributions and expenditures on public officials

Inside Information Policy and Procedures

Applies to: Investment Access Persons

Regular Access Persons

The antifraud provisions of the federal securities laws generally prohibit persons with material non-public information from trading on or communicating the information to others. Sanctions for violations can include civil injunctions, permanent bars from the securities industry, civil penalties up to three times the profits made or losses avoided, criminal fines and jail sentences. While Investment Access persons are most likely to come in contact with material non-public information, the rules (and sanctions) in this area apply to all John Hancock Funds personnel and extend to activities both related and unrelated to your job duties.

The Inside Information Policy and Procedures covers a number of important issues, such as:

o The misuse of material non-public information

o The information barrier procedure

o The "restricted list" and the "watch list"

o broker letters and duplicate confirmation statements (see section 7 of this code of ethics)

Policy Regarding Dissemination of Mutual Fund Portfolio Information

Applies to: Investment Access Persons

Regular Access Persons

Information about securities held in a mutual fund cannot be disclosed except in accordance with this Policy, which generally requires time delays of approximately one month and public posting of the information to ensure that it uniformly enters the public domain.

6. Policies in the Code of Ethics

Restriction on Gifts

Applies to: Investment Access Persons

Regular Access Persons

You and your family cannot accept preferential treatment or favors (for example, gifts) from securities brokers or dealers or other organizations with which John Hancock Funds might transact business, except in accordance with the Company Conflict and Business Practice Policy. For the protection of both you and John Hancock Funds, the appearance of a possible conflict of interest must be avoided. You should exercise caution in any instance in which business travel and lodging are paid for by someone other than John Hancock Funds. The purpose of this policy is to minimize the basis for any charge that you used your John Hancock Funds position to obtain for yourself opportunities which otherwise would not be offered to you. Please see the Company Conflict and Business Practice Policy's "Compensation and Gifts" section for additional details regarding restrictions on gifts and exceptions for "nominal value" gifts.

John Hancock Mutual Funds Reporting Requirement and Holding Period

Applies to: Investment Access Persons

Regular Access Persons

You must follow the reporting requirement and the holding period requirement specified below if you purchase either:

o a "John Hancock Mutual Fund" (i.e. a '40 Act mutual fund that is advised by John Hancock Advisers, LLC, John Hancock Investment Management Services LLC or by another Manulife entity); or

o a "John Hancock Variable Product" (i.e. contracts funded by insurance company separate accounts that use one or more portfolios of John Hancock Trust).

The John Hancock mutual funds reporting requirement and the holding period requirement are excluded for the money market funds and any dividend reinvestment, payroll deduction, systematic investment/withdrawal and/or other program trades.

Reporting Requirement: You must report your holdings and your trades in a John Hancock Mutual Fund or a John Hancock Variable Product. This is not a preclearance requirement--you can report your holdings after you trade by submitting duplicate confirmation statements to the Investment Compliance Department. If you are an Investment Access Person or a Regular Access Person, you must also make sure that your holdings in a John Hancock '40 Act fund or a John Hancock variable product are included in your Initial Holdings Report (upon hire) and Annual Holdings Report (each year end).

If you purchase a John Hancock Variable Product, you must notify the Investment Compliance Department. The Investment Compliance Department will then obtain directly from the contract administrators the personal trade and holdings information regarding the portfolios underlying the Manulife or John Hancock variable insurance contracts.

The Investment Compliance Department will obtain personal securities trades and holdings information in the 401(k) plan for John Hancock Funds directly from the plan administrators.

Holding Requirement: You cannot profit from the purchase and sale of a John Hancock Mutual Fund within 30 calendar days. The purpose of this policy is to address the risk, real or perceived, of manipulative market timing or other abusive practices involving short-term personal trading in the John Hancock Mutual Funds. Any profits realized on short-term trades must be surrendered by check payable to John Hancock Advisers, LLC and will be contributed by John Hancock Advisers, LLC to a charity, upon determination by the Compliance and Business Practices Committee. If you donate or gift a security, it is considered a sale. You may request an exemption from this policy for involuntary sales due to unforeseen corporate activity (such as a merger), or for sales due to hardship reasons (such as unexpected medical expenses) by sending an e-mail to the Chief Compliance Officer of your company.

Preclearance of Securities Transactions

Applies to: Investment Access Persons

Regular Access Persons

Also, for a limited category of trades:

Limited Category of Trades for Non-Access Persons: If you are a Non-Access person, you must preclear transactions in securities of any closed-end funds advised by John Hancock Advisers, LLC. A Non-Access person is not required to preclear other trades. However, please keep in mind that a Non-Access person is required to report securities transactions after every trade (even those that are not required to be precleared) by requiring your broker to submit duplicate confirmation statements, as described in section 7 of this code of ethics.

Investment Access persons and Regular Access persons: If you are an Investment Access person or Regular Access person, you must "preclear" (i.e.: receive advance approval of) any personal securities transactions in the categories described above in the section "Which Accounts and Securities are Subject to the Code's Personal Trading Restrictions". Due to this preclearance requirement, participation in investment clubs is prohibited.

Preclearance of private placements requires some special considerations--the decision will take into account whether, for example: (1) the investment opportunity should be reserved for John Hancock Funds clients; and (2) it is being offered to you because of your position with John Hancock Funds.

How to preclear: You preclear a trade by following the steps outlined in the preclearance procedures, which are attached as Appendix B. Please note that:

o You may not trade until clearance is received.

o Clearance approval is valid only for the date granted (i.e. the preclearance date and the trade date should be the same).

o A separate procedure should be followed for requesting preclearance of a private placement or a derivative, as detailed in Appendix B. The Investment Compliance Department must maintain a five-year record of all clearances of private placement purchases by Investment Access persons, and the reasons supporting the clearances.

The preclearance policy is designed to proactively identify potential "problem trades" that raise front-running, manipulative market timing or other conflict of interest concerns (example: when an Investment Access person trades a security on the same day as a John Hancock fund).

Certain transactions in securities that would normally require pre-clearance are exempt from the pre-clearance requirement in the following situations; (1) shares are being purchased as part of an automatic investment plan; (2) shares are being purchased as part of a dividend reinvestment plan; or (3) transactions are being made in an account over which you have designated a third party as having discretion to trade (you must have approval from the Chief Compliance Officer to establish a discretionary account).

Heightened Preclearance of Securities Transactions for "Significant Personal Positions"

Applies to: Investment Access Persons

Regular Access Persons

If you are an Investment Access person or Regular Access person with a personal securities position that is worth $100,000 or more, this is deemed to be a "Significant Personal Position". This applies to any personal securities positions in the categories described above in the section "Which Accounts and Securities are Subject to the Code's Personal Trading Restrictions". Before you make personal trades to establish, increase or decrease a Significant Personal Position, you must notify either the Chief Fixed Income Officer or the Chief Equity Officer that (1) you intend to trade in a Significant Personal Position and (2) confirm that you are not aware of any clients for whom related trades should be completed first. You must receive their pre-approval to proceed--their approval will be based on their conclusion that your personal trade in a Significant Personal Position will not "front-run" any action that John Hancock Funds should take for a client. This Heightened Preclearance requirement is in addition to, not in place of, the regular preclearance requirement described above--you must also receive the regular preclearance before you trade.

Ban on Short-Term Profits

Applies to: Investment Access Persons

If you are an Investment Access person, you cannot profit from the purchase and sale (or sale and purchase) of the same (or equivalent) securities within 60 calendar days. This applies to any personal securities trades in the categories described above in the section "Which Accounts and Securities are Subject to the Code's Personal Trading Restrictions".

You may invest in derivatives or sell short provided the transaction period exceeds the 60-day holding period (30 days for '40 Act mutual funds advised by John Hancock Advisers, LLC, John Hancock Investment Management Services LLC or another Manulife entity). If you donate or gift a security, it is considered a sale.

The purpose of this policy is to address the risk, real or perceived, of front-running, manipulative market timing or other abusive practices involving short-term personal trading. Any profits realized on short-term trades must be surrendered by check payable to John Hancock Advisers, LLC and will be contributed by John Hancock Advisers, LLC to a charity, upon determination by the Compliance and Business Practices Committee.

You may request an exemption from this policy for involuntary sales due to unforeseen corporate activity (such as a merger), or for sales due to hardship reasons (such as unexpected medical expenses) by sending an e-mail to the Chief Compliance Officer of your company.

Ban on IPOs

Applies to: Investment Access Persons

If you are an Investment Access person, you may not acquire securities in an initial public offering (IPO). You may not purchase any newly-issued securities until the next business (trading) day after the offering date. This applies to any personal securities trades in the categories described above in the section "Which Accounts and Securities are Subject to the Code's Personal Trading Restrictions".

There are two main reasons for this prohibition: (1) these purchases may suggest that persons have taken inappropriate advantage of their positions for personal profit; and (2) these purchases may create at least the appearance that an investment opportunity that should have been available to the John Hancock funds was diverted to the personal benefit of an individual employee.

You may request an exemption for certain investments that do not create a potential conflict of interest, such as: (1) securities of a mutual bank or mutual insurance company received as compensation in a demutualization and other similar non-voluntary stock acquisitions; (2) fixed rights offerings; or (3) a family member's participation as a form of employment compensation in their employer's IPO.

Disclosure of Private Placement Conflicts

Applies to: Investment Access Persons

If you are an Investment Access person and you own securities purchased in a private placement, you must disclose that holding when you participate in a decision to purchase or sell that same issuer's securities for a John Hancock fund. This applies to any private placement holdings in the categories described above in the section "Which Accounts and Securities are Subject to the Code's Personal Trading Restrictions". Private placements are securities exempt from SEC registration under section 4(2), section 4(6) or rules 504 -506 of the Securities Act of 1933.

The investment decision must be subject to an independent review by investment personnel with no personal interest in the issuer.

The purpose of this policy is to provide appropriate scrutiny in situations in which there is a potential conflict of interest.

Seven Day Blackout Period

If you are a portfolio manager (or were identified to the Investment Compliance Department as part of a portfolio management team) you are prohibited from buying or selling a security within seven calendar days before and after that security is traded for a fund that you manage unless no conflict of interest exists in relation to that security (as determined by the Compliance and Ethics Committee).

In addition, all investment access persons are prohibited from knowingly buying or selling a security within seven calendar days before and after that security is traded for a John Hancock fund unless no conflict of interest exists in relation to that security. This applies to any personal securities trades in the categories described above in the section "Which Accounts and Securities are Subject to the Code's Personal Trading Restrictions". If a John Hancock fund trades in a security within seven calendar days before or after you trade in that security, you may be required to demonstrate that you did not know that the trade was being considered for that John Hancock fund.

You will be required to sell any security purchased in violation of this policy unless it is determined that no conflict of interest exists in relation to that security (as determined by the Compliance and Ethics Committee). Any profits realized on trades determined by the Compliance and Ethics Committee to be in violation of this policy must be surrendered by check payable to John Hancock Advisers, LLC and will be contributed by John Hancock Advisers, LLC to a charity.

7. Reports and Other Disclosures Outside the Code of Ethics

Broker Letter/Duplicate Confirm Statements

Applies to: Investment Access Persons

Regular Access Persons

As required by the Inside Information Policy, you must inform your stockbroker that you are employed by an investment adviser or broker. Your broker is subject to certain rules designed to prevent favoritism toward your accounts. You may not accept negotiated commission rates that you believe may be more favorable than the broker grants to accounts with similar characteristics.

When a brokerage account is opened for which you have a beneficial interest, before any trades are made, you must:

o Notify the broker-dealer with which you are opening an account that you are a registered associate of John Hancock Funds;

o Ask the firm in writing to have duplicate written confirmations of any trade, as well as statements or other information concerning the account, sent to the John Hancock Funds Investment Compliance Department (contact: Fred Spring), 8th Floor, 101 Huntington Avenue, Boston, MA 02199; and

o Notify the John Hancock Funds Investment Compliance Department, in writing, that you have an account before you place any trades.

This applies to any personal securities trades in the categories described above in the section "Which Accounts and Securities are Subject to the Code's Personal Trading Restrictions" as well as trades in John Hancock Mutual Funds and John Hancock Variable Products. The Investment Compliance Department may rely on information submitted by your broker as part of your reporting requirements under this code of ethics.

8. Reports and Other Disclosures In the Code of Ethics

Initial Holdings Report and Annual Holdings Report

Applies to: Investment Access Persons

Regular Access Persons

You must file an initial holdings report within 10 calendar days after becoming an Investment Access person or a Regular Access person. The information must be current as of a date no more than 45 days prior to your becoming an Investment Access person or a Regular Access person.

You must also file an annual holdings report (as of December 31st) within 45 calendar days after the calendar year end. This applies to any personal securities holdings in the categories described above in the section "Which Accounts and Securities are Subject to the Code's Personal Trading Restrictions" as well as holdings in John Hancock Mutual Funds and John Hancock Variable Products.

Your reports must include:

o the title and type of security, and as applicable the exchange ticker symbol or CUSIP number, number of shares, and principal amount of each reportable security;

o the name of any broker, dealer or bank with which you maintain an account; and

o the date that you submit the report.

Quarterly Transaction Certification

Applies to: Investment Access Persons

Regular Access Persons

On a quarterly basis, Investment Access Persons and Regular Access persons are required to certify transactions in their brokerage accounts and the John Hancock Funds 401(k) Plan. Within 30 calendar days after the end of each calendar quarter you will be asked to log into the John Hancock Personal Trading and Reporting System to verify that the system has captured accurately all transactions for the preceding calendar quarter for accounts and trades which are required to be reported pursuant to the above noted section entitled "Which Accounts and Securities are Subject to the Code's Personal Trading Restrictions". Even if you have no transactions to report you will be asked to complete the certification.

For each transaction you must report the following information:

o the date of the transaction, the title, and as applicable the exchange ticker symbol or CUSIP number, interest rate and maturity date, number of shares, and principal amount of each reportable security involved;

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

o the price at which the transaction was effected;

o the name of the broker, dealer or bank with or through which the transaction was effected; and

Quarterly Brokerage Account Certification

Applies to: Investment Access Persons

Regular Access Persons

Each quarter, all Investment Access Persons, Regular Access Persons and Non-Access Persons will be required to provide a complete list of all brokerage accounts as described above in the section entitled "Which Accounts and Securities are Subject to the Code's Personal Trading Restrictions". This includes all brokerage accounts, including brokerage accounts that only contain securities exempt from reporting.

You will be asked to log into the John Hancock Personal Trading and Reporting System and verify that all brokerage accounts are listed and the following information is accurate:

o Account number;

o Account registration;

o Brokerage firm

Annual Certification

Applies to: Investment Access Persons

Regular Access Persons

Non-Access Persons

At least annually (or additionally when the code of ethics has been significantly changed), you must provide a certification at a date designated by the Investment Compliance Department that:

(1) you have read and understood this code of ethics;

(2) you recognize that you are subject to its policies; and

(3) you have complied with its requirements.

You are required to make this certification to demonstrate that you understand the importance of these policies and your responsibilities under the code of ethics.

9. Limited Access Persons

There is an additional category of persons called "Limited Access" persons. This category consists only of directors of John Hancock Advisers, LLC, trustees of the John Hancock Financial Trends Fund, Inc. or an "interested person" of the John Hancock '40 Act funds who:

(a) are not also officers of John Hancock Advisers, LLC; and

(b) do not ordinarily obtain information about fund portfolio trades

An "interested person" of the John Hancock '40 Act funds has the meaning given to the term in Section 2(a)(19) of the '40 Act.

A more detailed definition of Limited Access persons, and a list of the policies that apply to them, is attached as Appendix C.

10. Subadvisers

A subadviser to a John Hancock '40 Act fund has a number of code of ethics responsibilities, as described in Appendix D.

11. Reporting Violations

If you know of any violation of our code of ethics, you have a responsibility to promptly report it to the Chief Compliance Officer of your company. You should also report any deviations from the controls and procedures that safeguard John Hancock Funds and the assets of our clients. You can request confidential treatment of your reporting action.

12. Interpretation and Enforcement

This code of ethics cannot anticipate every situation in which personal interests may be in conflict with the interests of our clients and fund investors. You should be responsive to the spirit and intent of this code of ethics as well as its specific provisions.

When any doubt exists regarding any code of ethics provision or whether a conflict of interest with clients or fund investors might exist, you should discuss the situation in advance with the Chief Compliance Officer of your company. The code of ethics is designed to detect and prevent fraud against clients and fund investors, and to avoid the appearance of impropriety. If you feel inequitably burdened by any policy, you should feel free to contact your Chief Compliance Officer or the Compliance and Business Practices Committee. Exceptions may be granted where warranted by applicable facts and circumstances. For example, exemption from some Personal Trading Requirements may be granted for transactions effected pursuant to an automatic investment plan.

To provide assurance that policies are effective, the Investment Compliance Department will monitor and check personal securities transaction reports and certifications against fund portfolio transactions. Additional administration and recordkeeping procedures are described in Appendix E.

The Chief Compliance Officer of your company has general administrative responsibility for this code of ethics as it applies to the access persons of your company; an appropriate Compliance Department will administer procedures to review personal trading reports. The Compliance and Business Practices Committee of John Hancock Funds approves amendments to the code of ethics and dispenses employee/officer sanctions for violations of the code of ethics. The Boards of Trustees/Directors of the open-end mutual funds and closed-end funds also approve amendments to the code of ethics and dispenses sanctions for access persons of the Funds who are not employees/officers. Accordingly, the Investment Compliance Department will refer violations to the Compliance and Business Practices Committee and/or the Boards of Trustees/Directors of the John Hancock '40 Act funds, respectively, for review and appropriate action. The following factors will be considered when determining a fine or other disciplinary action:

o the person's position and function (senior personnel may be held to a higher standard);

o the amount of the trade;

o whether the funds or accounts hold the security and were trading the same day;

o whether the violation was by a family member.

o whether the person has had a prior violation and which policy was involved.

o whether the employee self-reported the violation.

You can request reconsideration of any disciplinary action by submitting a written request.

No less frequently than annually, a written report of all material violations and sanctions, significant conflicts of interest and other related issues will be submitted to the boards of directors of the John Hancock '40 Act funds for their review. Sanctions for violations could include (but are not limited to)

fines, limitation of personal trading activity, suspension or termination of the violator's position with John Hancock Funds and/or a report to the appropriate regulatory authority.

13. Education of Employees

The Investment Compliance Department will provide a paper copy or electronic version of the Code of Ethics (and any amendments) to each person subject to this Code of Ethics. The Investment Compliance Department will also administer training of employees on the principles and procedures of the code of ethics.

Appendix A: Categories of Personnel

You have been notified about which of these categories applies to you, based on the Investment Compliance Department's understanding of your current role. If you have a level of investment access beyond that category, or if you are promoted or change duties and as a result should more appropriately be included in a different category, it is your responsibility to immediately notify the Chief Compliance Officer of your company.

1) Investment Access person: You are an Investment Access person if you are an employee of John Hancock Advisers, LLC, Sovereign Asset Management LLC, a John Hancock fund, or Manulife Financial Corporation or its subsidiaries who, in connection with your regular functions or duties, makes or participates in making recommendations regarding the purchase or sale of securities by a John Hancock fund.

(examples: portfolio managers, analysts, traders)

2) Regular Access person: You are a Regular Access person if you do not fit the definition of Investment Access Person, but you do fit one of the following two sub-categories:

o You are an officer (vice president and higher) or director of John Hancock Advisers, LLC, Sovereign Asset Management LLC or a John Hancock fund, unless you qualify as a Limited Access person--please see Appendix C for this definition.)

o You are an employee of John Hancock Advisers, LLC, Sovereign Asset Management LLC, a John Hancock fund or Manulife Financial Corporation or its subsidiaries , or a director, officer (vice president and higher) or employee of John Hancock Funds, LLC who has access to nonpublic information regarding any clients' purchase or sale of securities, or nonpublic information regarding the portfolio holdings of any reportable fund or who is involved in making securities recommendations to clients, or who has access to such recommendations that are nonpublic.

(examples: Investment Operations personnel, Investment Compliance Department personnel, most Fund Financial Management personnel, investment administrative personnel, Technology Resources personnel with access to investment systems, attorneys and some legal administration personnel)

3) Non-Access person: You are a non-access person if you are an employee of John Hancock Advisers, LLC, Sovereign Asset Management LLC, John Hancock Funds, LLC or a John Hancock fund who does not fit the definitions of any of the other three categories (Investment Access Person, Regular Access Person or Limited Access Person). To be a non-access person, you must not have access to information regarding the purchase or sale of securities by a John Hancock fund or nonpublic information regarding the portfolio holdings in connection with your regular functions or duties.

(examples: wholesalers, inside wholesalers, certain administrative staff)

4) Limited Access Person: Please see Appendix C for this definition.

Appendix B: Preclearance Procedures

You should read the Code of Ethics to determine whether you must obtain a preclearance before you enter into a securities transaction. If you are required to obtain a preclearance, you should follow the procedures detailed below.

1. Pre-clearance for Public Securities including Derivatives, Futures, Options and Selling Short:

A request to pre-clear should be entered into the John Hancock Personal Trading & Reporting System.

The John Hancock Personal Trading & Reporting System is located under your Start Menu on your Desktop. It can be accessed by going to Programs/Personal Trading & Reporting/ Personal Trading & Reporting and by entering your Web Security Services user id and password.

If the John Hancock Personal Trading & Reporting System is not on your Desktop, please contact the HELP Desk at (617) 572-6950 for assistance.

The Trade Request Screen:

At times you may receive a message like "System is currently unavailable". The system is scheduled to be offline from 8:00 PM until 7:00 AM each night.

[GRAPHIC OMITTED]

Ticker/Security Cusip: Fill in either the ticker, cusip or security name with the proper information of the security you want to buy or sell. Then click the
[Lookup] button. Select one of the hyperlinks for the desired security, and the system will populate the proper fields Ticker, Security Cusip, Security Name and Security Type automatically on the Trade Request Screen.

If You Don't Know the Ticker, Cusip, or Security Name:

If you do not know the full ticker, you may type in the first few letters followed by an asterisk * and click the [Lookup] button. For example, let's say you want to buy some shares of Intel, but all you can remember of the ticker is that it begins with int, so you enter int* for Ticker. If any tickers beginning with int are found, they are displayed on a new screen. Select the hyperlink of the one you want, and the system will populate Security Cusip, Security Name and Security Type automatically on the Trade Request Screen. If you do not know the full cusip, you may type in the first few numbers followed by an asterisk * and click the [Lookup] button. For example, let's say you want to buy some shares of Microsoft, but all you can remember of the cusip is that it begins with 594918, so you enter 594918* for Ticker. If any cusips beginning with 594918 are found, they are displayed on a new screen. Select the hyperlink of the one you want, and the system will fill in Ticker, Security Name and Security Type automatically on the Trade Request Screen. If you do not know the Ticker but

have an idea of what the Security Name is, you may type in an asterisk, a few letters of the name and an asterisk * and click the [Lookup] button. For example, let's say you want to buy some shares of American Brands, so you enter *amer* for Security Name. Any securities whose names have amer in them are displayed on a new screen, where you are asked to select the hyperlink of the one you want, and the system will fill in Ticker, Cusip and Security Type automatically on the Trade Request Screen.

Other Items on the Trade Request Screen:

Brokerage Account: Click on the dropdown arrow to the right of the Brokerage Account field to choose the account to be used for the trade.

Transaction Type: Choose one of the values displayed when you click the dropdown arrow to the right of this field.

Trade Date: You may only submit trade requests for the current date.

Note: One or more of these fields may not appear on the Request Entry screen if the information is not required. Required fields are determined by the Investment Compliance Department.

Click the [Submit Request] button to send the trade request to your Investment Compliance department.

Once you click the [Submit Request] button, you will be asked to confirm the values you have entered. Review the information and click the [Confirm] button if all the information is correct. After which, you will receive immediate feedback in your web browser. (Note: We suggest that you print out this confirmation and keep it as a record of the trade you have made). After this, you can either submit another trade request or logout.

Attention Investment Access Persons: If the system identifies a potential violation of the Ban on Short Term Profits Rule, your request will be sent to the Investment Compliance Department for review and you will receive feedback via the e-mail system.

Starting Over:

To clear everything on the screen and start over, click the [Clear Screen] button.

Exiting Without Submitting the Trade Request:

If you decide not to submit the trade request before clicking the [Submit Request] button, simply exit from the browser by clicking the [X] button on the upper right or by pressing [Alt+F4], or by clicking the Logout hyperlink on the lower left side of the screen.

Ticker/Security Name Lookup Screen:

You arrive at this screen from the Trade Request Screen, where you've clicked the [Lookup] button (see above, "If You Don't Know the Ticker, Cusip, or Security Name"). If you see the security you want to trade, you simply select its corresponding hyperlink, and you will automatically return to the Trade Request Screen, where you finish making your trade request. If the security you want to trade is not shown, that means that it is not recognized by the system under the criteria you used to look it up. Keep searching under other names (click the [Return to Request] button) until you are sure that the security is not in the system. If you determine that the desired security is not in the system, please contact a member of the Investment Compliance department to add the security for you. Contacts are listed below:

Fred Spring (617) 375-4987

Adding Brokerage Accounts:

To access this functionality, click on the Add Brokerage Account hyperlink on the left frame of your browser screen. You will be prompted to enter the Brokerage Account Number, Brokerage Account Name, Date Opened, and Broker. When you click the [Create New Brokerage Account] button, you will receive a message that informs you whether the account was successfully created.

[GRAPHIC OMITTED]

3. Pre-clearance for Private Placements and Initial Public Offerings:

You may request a preclearance of private placement securities or an Initial Public Offering by contacting Fred Spring via Microsoft Outlook (please "cc." Frank Knox on all such requests). Please keep in mind that the code of ethics prohibits Investment Access persons from purchasing securities in an initial public offering.

The request must include:

o the associate's name;

o the associate's John Hancock Funds' company;

o the complete name of the security;

o the seller (i.e the selling party if identified and/or the broker-dealer or placement agent) and whether or not the associate does business with those individuals or entities on a regular basis;

o the basis upon which the associate is being offered this investment opportunity;

o any potential conflict, present or future, with fund trading activity and whether the security might be offered as inducement to later recommend publicly traded securities for any fund or to trade through a particular broker-dealer or placement agent; and

o the date of the request.

Clearance of private placements or initial public offerings may be denied for any appropriate reason, such as if the transaction could create the appearance of impropriety. Clearance of initial public offerings will also be denied if the transaction is prohibited for a person due to his or her access category under the code of ethics.

Appendix C: Limited Access Persons

There are three types of Limited Access Persons--(1) Certain directors of the Adviser and (2) the trustees of the John Hancock Financial Trends Fund, Inc. and
(3) and the Directors of the John Hancock funds who are "interested persons" of the funds.

(1) Certain Directors of the Adviser:

You are a Limited Access person if you are a director of John Hancock Advisers, LLC or Sovereign Asset Management Co. and you meet the three following criteria:

(a) you are not also an officer of John Hancock Advisers, LLC, Sovereign Asset Management Co. or a John Hancock fund;

(b) you do not have access to nonpublic information regarding any clients' purchase or sale of securities, or nonpublic information regarding the portfolio holdings of any John Hancock fund or account; and

(c) you are not involved in making securities recommendations to clients and do not have access to such recommendations that are nonpublic.

(examples: directors of John Hancock Advisers, LLC or Sovereign Asset Management LLC who are not involved in the daily operations of the adviser)

If you are a Limited Access Person who fits this definition, the following policies apply to your category. These policies are described in detail in the code of ethics.

o General principles

o Inside information policy and procedures

o Broker letter/Duplicate Confirms*

o Initial/annual holdings reports*

o Quarterly transaction reports*

o Annual recertification

Preclearance requirement LIMITED: You only need to preclear any direct or indirect acquisition of beneficial ownership in any security in an initial public offering (an IPO) or in a limited offering (i.e. a private placement). To request preclearance of these securities, contact Fredrick Spring at fspring@jhancock.com and/or Frank Knox at Frank_Knox@manulifeusa.com.

*A Limited Access Person may complete this requirement under the code of ethics of another Manulife/John Hancock adviser or fund by the applicable regulatory deadlines and arrange for copies of the required information to be sent to the John Hancock Funds Compliance Department.

(2) The Independent Directors of the Funds: If you are a trustee of the John Hancock Financial Trends Fund, Inc. or a director to a John Hancock fund and an "interested person" of the fund within the meaning of the Investment Company Act of 1940, the following policies apply to your category. These policies are described in detail in the code of ethics.

o General principles

o Annual recertification

o Quarterly transaction report, but only if you knew (or should have known) that during the 15 calendar days before or after you trade a security, either:

(i) a John Hancock fund purchased or sold the same security, or

(ii) a John Hancock fund or John Hancock Advisers, LLC considered purchasing or selling the same security.

This policy applies to holdings in your personal accounts, those of a spouse, "significant other" or family members sharing your household, as well as all accounts over which you have discretion or give advice or information. If this situation occurs, it is your responsibility to contact the Chief Compliance Officer of your company and he will assist you with the requirements of the quarterly transaction report.

This means that the independent directors of the funds will not usually be required to file a quarterly transaction report--they are only required to file in the situation described above.

Appendix D: Subadvisers

Each subadviser to a John Hancock fund is subject to its own code of ethics, which must meet the requirements of Rule 17j-1 and Rule 204A-1.

Approval of Code of Ethics

Each subadviser to a John Hancock fund must provide a copy of its code of ethics to the trustees of the relevant John Hancock funds for approval initially and within 60 calendar days of any material amendment. The trustees will give their approval if they determine that the code:

o contains provisions reasonably necessary to prevent the subadviser's Access Persons (as defined in Rule 17j-1) from engaging in any conduct prohibited by Rule 17j-1;

o requires the subadviser's Access Persons to make reports to at least the extent required in Rule 17j-1(d);

o requires the subadviser to institute appropriate procedures for review of these reports by management or compliance personnel (as contemplated by Rule 17j-1(d)(3));

o provides for notification of the subadviser's Access Persons in accordance with Rule 17j-1(d)(4); and

o requires the subadviser's Access Persons who are Investment Personnel to obtain the pre-clearances required by Rule 17j-1(e);

Reports and Certifications

Each subadviser must provide an annual report and certification to John Hancock Advisers, LLC and the fund's trustees in accordance with Rule 17j-1(c)(2)(ii). The subadviser must also provide other reports or information that John Hancock Advisers, LLC may reasonably request.

Recordkeeping Requirements

The subadviser must maintain all records for its Access Persons as required by Rule 17j-1(f).

Appendix E: Administration and Recordkeeping

Adoption and Approval

The trustees of a John Hancock fund must approve the code of ethics of an adviser, subadviser or affiliated principal underwriter before initially retaining its services.

Any material change to a code of ethics of a John Hancock fund, John Hancock Funds, LLC, John Hancock Advisers, LLC or a subadviser to a fund must be approved by the trustees of the John Hancock Funds, including a majority of trustees who are not interested persons, no later than six months after adoption of the material change.

Administration

No less frequently than annually, John Hancock Funds, LLC, John Hancock Advisers, LLC, each subadviser and each John Hancock fund will furnish to the trustees of each John Hancock fund a written report that:

o describes issues that arose during the previous year under the code of ethics or the related procedures, including, but not limited to, information about material code or procedure violations, and

o certifies that each entity has adopted procedures reasonably necessary to prevent its access persons from violating its code of ethics.

Recordkeeping

The Investment Compliance Department will maintain:

o a copy of the current code of ethics for John Hancock Funds, LLC, John Hancock Advisers, LLC, Sovereign Asset Management LLC, and each John Hancock fund, and a copy of each code of ethics in effect at any time within the past five years.

o a record of any violation of the code of ethics, and of any action taken as a result of the violation, for six years.

o a copy of each report made by an Access person under the code of ethics, for six years (the first two years in a readily accessible place).

o a record of all persons, currently or within the past five years, who are or were required to make reports under the code of ethics. This record will also indicate who was responsible for reviewing these reports.

o a copy of each code of ethics report to the trustees, for six years (the first two years in a readily accessible place).

o a record of any decision, and the reasons supporting the decision, to approve the acquisition by an Investment Access person of initial public offering securities or private placement securities, for six years.

Appendix F: Chief Compliance Officers

Entity                                          Chief Compliance Officer

John Hancock Advisers, LLC                      Frank Knox
Sovereign Asset Management LLC                  Frank Knox
Each open-end and closed-end fund advised       Frank Knox
by John Hancock Advisers, LLC
John Hancock Funds, LLC                         Michael Mahoney