Exhibit A.
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EX.99.MISC.
The Crowley Portfolio Group, Inc.
Code of Ethics for the
Principal Executive Officer & Principal Financial Officer
The Crowley Portfolio Group, Inc. (the "Fund") requires the Principal Executive
Officer, Principal Financial Officer, or other Fund officers performing similar
functions (the "Principal Officers"), to maintain the highest ethical and legal
standards while performing their duties and responsibilities to the Fund, with
particular emphasis on those duties that relate to the preparation and reporting
of the financial information of the Fund. The following principles and
responsibilities shall govern the professional conduct of the Principal
Officers:
1. HONEST AND ETHICAL CONDUCT
The Principal Officers shall act with honesty and integrity, ethically
handle actual or apparent conflicts of interest between personal and
professional relationships, and shall report any material transaction or
relationship that reasonably could be expected to give rise to a conflict
of interest between their interests and those of the Fund to the Audit
Committee, the full Board of Directors of the Fund, and, in addition, to
any other appropriate person or entity that may reasonably be expected to
deal with any conflict of interest in timely and expeditious manner.
The Principal Officers shall act in good faith, responsibly, with due care,
competence and diligence, without misrepresenting material facts or
allowing their independent judgment to be subordinated or compromised.
2. FINANCIAL RECORDS AND REPORTING
The Principal Officers shall provide full, fair, accurate, timely and
understandable disclosure in the reports and/or other documents to be filed
with or submitted to the Securities and Exchange Commission or other
applicable body by the Fund, or that is otherwise publicly disclosed or
communicated. The Principal Officers shall comply with applicable rules and
regulations of federal, state, and local governments, and other appropriate
private and public regulatory agencies.
The Principal Officers shall respect the confidentiality of information
acquired in the course of their work and shall not disclose such
information except when authorized or legally obligated to disclose. The
Principal Officers will not use confidential information acquired in the
course of their duties as Principal Officers.
The Principal Officers shall share knowledge and maintain skills important
and relevant to the Fund's needs; shall proactively promote ethical
behavior of the Fund's employees and as a partner with industry peers and
associates; and shall maintain control over and responsibly manage assets
and resources employed or entrusted to them by the Fund.
3. COMPLIANCE WITH LAWS, RULES AND REGULATIONS
The Principal Officers shall establish and maintain mechanisms to oversee
the compliance of the Fund with applicable federal, state or local law,
regulation or administrative rule, and to identify, report and correct in a
swift and certain manner, any detected deviations from applicable federal,
state or local law, regulation or rule.
4. COMPLIANCE WITH THIS CODE OF ETHICS
The Principal Officers shall promptly report any violations of this Code of
Ethics to the Audit Committee as well as the full Board of Directors of the
Fund and shall be held accountable for strict adherence to this Code of
Ethics. A proven failure to uphold the standards stated herein shall be
grounds for such sanctions as shall be reasonably imposed by the Board of
Directors of the Fund.
5. AMENDMENT AND WAIVER
This Code of Ethics may only be amended or modified by approval of the
Board of Directors. Any substantive amendment that is not technical or
administrative in nature or any material waiver, implicit or otherwise, of
any provision of this Code of Ethics shall be communicated publicly in
accordance with Item 2 of Form N-CSR under the Investment Company Act of
1940, as amended.
