CODE OF ETHICS
Pursuant to  the requirements of Sections 406 and 407 of the Sarbanes-Oxley Act
of 2002 the Vally Forge Fund, (the "Fund"), hereby adopts the following Code of
Ethics that applies to the Fund's principal executive, financial and accounting
officers or persons performing similar functions regardless of whether these
individuals are employed by the Fund or a third party in order to prepare these
written standards that are reasonably designed to deter wrongdoing and to

a) Honest and ethical conduct, including the sthical handling of actual or
apparent conflicts of interest between personal and professional relationships;

b) Full, fair, accurate, timely and understandable disclosure in reports and
documents that the Fund files with, or submits to, the Securities & Exchange
Commission and in all public communications;

c) Compliance with all applicable governmental laws, rules and regulations;

d) Prompt internal reporting of violations of the code, should any ever occur,
to all principal officers of the Fund and all appropriate persons identified in
the code; and

e) The principal executive officer of the Fund will be held accountable for
adherence to the code as presented above.




































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