(ii) "Fund" means any registered investment company adopting this Code of Ethics. | |
(iii) "Compliance Officer" means the person so designated by the Adviser to act in that capacity. | |
Adviser does not include any consultant or sub-advisor whose only role is to advise on general principles. |
( i ) any employee of the Adviser or Fund who, in connection with his regular functions or duties, makes, participates in, or obtains information regarding the purchase or sale of a security by the clients of the Adviser or the Fund, or whose functions relate to the making of any recommendations with respect to such purchases or sales; and | |
(ii) any natural person in a control relationship to any client of the Adviser or Fund who obtains information concerning recommendations made to the client concerning the purchase or sale of a security. |
(g) "Disinterested Trustee" means a trustee of a Fund who is not an "interested person" of the Fund. Only for purposes of this Code, it shall include a trustee of a Fund who, though an interested person of the Adviser by virtue being solely a consultant to a Fund, is not an employee, officer or director of the Adviser.
(i) any affiliated person of such company, | |
(ii) any member of the immediate family of any natural person who is an affiliated person of such company, | |
(iii) any interested person of any investment adviser or principal underwriter for such company, | |
(iv) any person or partner or employee of any person who at any time since the beginning of the last two fiscal years of such company has acted as legal counsel for such company, | |
(v) any broker or dealer registered under the Securities Exchange Act of 1934 or any affiliated person of such a broker or dealer, and | |
(vi) any natural person whom the Securities and Exchange Commission by order shall have determined to be an interested person by reason of having had, at any time since the beginning of the last two fiscal years of such company, a material business or professional relationship with such company or with the principal executive officer of such company or with any other Investment Company having the same Investment Adviser or principal underwriter or with the principal executive officer of such other Investment Company. Provided, That no person shall be deemed to be an interested person of an Investment Company solely because of (a) his being a member of its Board of Trustees or advisory board or an owner of its securities, or (b) his membership in the immediate family of any person specified in clause (a) of this proviso. | |
For the purposes of this paragraph (h), "member of the immediate family" means any parent, spouse of a parent, child, spouse of a child, spouse, brother, or sister, and includes step and adoptive relationships. |
"Security" does not include securities issued by the Government of the United States, including short term debt securities that are government securities within the meaning of the Investment Company Act of 1940, bankers' acceptances, bank certificates of deposit, commercial paper, other high quality short-term debt instruments, shares of registered open-end investment companies, and securities based upon a recognized market index [including derivatives (such as options or futures) based on a market index].
(i) is or has been held by such client, or |
(ii) is being or has been considered by such client or the Adviser for purchase by such client. |
(1) Purchases or sales that result in an open (long or short) security position (or options thereon) no larger than 1% of the average daily trading volume for the last month. | |
(2) Purchases or sales that result in an open security position no larger than 2,000 shares (or options thereon) for any stock in the Standard & Poor's 500 Index, or 500 shares (or options thereon) for any stock in the Standard & Poor's 400 Mid-Cap Index or Standard & Poor's 600 Small-Cap Index. |
(1) is being considered, or within five days preceding the proposed transaction has been considered, for purchase or sale by any client; or | |
(2) is being purchased or sold by any client, or was purchased or sold by a client within the five days preceding the access person's transactions; or | |
(3) is designated by the Adviser as a "Recommended Security" for consideration of any client for purchase or sale. |
acquires, any direct or indirect beneficial ownership and which to his actual knowledge at the time of such purchase or sale, is the subject of an initial public offering. | |
(2) Private Placements; Exempt Transactions. No advisory person may purchase, directly or indirectly, any security in which he has or because of such transaction acquires, any direct or indirect beneficial ownership, if such transaction is not in the open market, or if such transaction is made pursuant to any exemption from the registration provisions of the federal securities laws unless such transaction has been approved in advance by the Compliance Officer. | |
Provided, that in determining whether to grant permission for such private placement, the Compliance Officer (or directors, as applicable) shall consider, among other things, whether such offering should be reserved for an investment company or other client of the Adviser, and whether such transaction is being offered to the person because of his or her position with the Adviser. | |
Provided further, that any such person who has received such permission shall be required to disclose such an investment when participating in any subsequent consideration of such security for purchase or sale by clients of the Adviser, and that the decision to purchase or sell such security should be made by persons with no personal direct or indirect interest in the security. |
(1) Employees and access persons desiring to trade securities for their own accounts are strongly encouraged, but not required, to open and maintain accounts with Saturna Brokerage Services and to place all securities trades through Saturna Brokerage. No employee or access person may open or maintain a securities trading account, of any type, in which he or she has any direct or indirect interest unless such account has been reported to and approved in advance by the Compliance Officer. Any person maintaining any such account shall instruct the broker with which such account is maintained to send copies of confirmations of all personal securities transactions and copies of periodic statements with respect to such account directly to the Compliance Officer. | |
(2) All access persons not maintaining a securities trading account with Saturna Brokerage shall be responsible for maintaining on the NEPTUNE recordkeeping system of Investors National an accurate inventory of all securities held by such person that are required to be reported under this Code of Ethics. The name of the broker, dealer or bank with which any account is established, and the date the account is established, must be reported to the Compliance Officer. |
(e) Insider Trading.
(1) Employees obtaining material non-public information should refrain from disclosing that information to anyone. Additionally, employees should not trade in the securities to which the information relates. | |
(2) Employees who are aware of the misuse of material non-public information should report such to the Compliance Officer. |
(1) The date of the transaction, the title and the number of shares, and the principal amount of each security involved; | |
(2) The nature of the transaction (i.e., purchase, sale or any other type of acquisition or disposition); | |
(3) The price at which the transaction was effected; and, | |
(4) The name of the broker, dealer or bank with or through whom the transaction was effected. |
(1)The Compliance Officer shall be responsible for a quarterly review, as prepared by the Adviser's NEPTUNE system, that compares the reported personal securities transactions of employees with completed portfolio transactions of clients to determine whether a violation of this Code of Ethics may have occurred. The Compliance Officer shall review initial and annual holdings reports. The Adviser will maintain the names of the persons reviewing these reports. | |
(2) At their first regular meeting in each calendar year, the Fund boards must be provided and review an annual report from the Adviser on compliance for the previous year. The Boards must receive a certification that the Fund and the Adviser "have adopted procedures reasonably necessary to prevent Access Persons from violating" their codes (a) before approving this Code of Ethics and (b) "not less frequently than annually" thereafter. The annual report to the Fund boards must describe any issues and material violations arising under this Code since the last report. |
(a) letter of censure; | |
(b) suspension or termination of the employment; | |
(c) reversal of a securities trade at the violator's expense and risk, including disgorgement of any profit; and | |
(d) in serious cases, referral to law enforcement or regulatory authorities. |