SUMMIT MUTUAL FUNDS, INC.

CODE OF ETHICS
FOR
PRINCIPAL EXECUTIVE
AND
SENIOR FINANCIAL OFFICERS

I.	Covered Officers/Purpose of the Code

Summit Mutual Funds, Inc.'s code of ethics (this "Code") for the
investment companies within the
complex (collectively, "Funds" and each, "Company") applies to the
Company's principal Executive Officer,
principal financial officer, and principal accounting officer (the
"Covered Officers", each of whom are set forth
in Exhibit A), for the purpose of promoting:

?	Honest and ethical conduct, including ethical handling of
actual or apparent conflicts of interest
between personal and professional relationships;
?	Full, fair, accurate, timely and understandable disclosure
in reports and documents that a
registrant files with, or submits to, the Securities and Exchange
Commission ("SEC") and in
other public communications made by the Company;
?	Compliance with applicable laws and governmental rules and
regulations;
?	The prompt internal reporting of violations of the Code to
an appropriate person or persons
identified in the Code; and
?	Accountability for adherence to the Code.

Each Covered Officer should adhere to a high standard of business
ethics and should be sensitive to
situations that may give rise to apparent as well as actual
conflicts of interest.

II.	Covered Officers Should Handle Ethically Actual and Apparent
Conflicts of Interest

Overview. A "conflict of interest" occurs when a Covered Officer's
private interest interferes with the
interests of, or his service to, the Company. For example, a
conflict of interest would arise if a Covered Officer,
or a member of his family, receives improper personal benefits as
a result of his position with the Company.

Certain conflicts of interest arise out of the relationships
between Covered Officers and the Company
and already are subject to conflict of interest provisions in the
Investment Company Act of 1940 ("Investment
Company Act") and the Investment Advisers Act of 1940 ("Investment
Advisers Act"). For example, Covered
Officers may not individually engage in certain transactions (such
as the purchase or sale of securities or other
property) with the Company because of their status as "affiliated
persons" of the Company. The Company's and
the investment adviser's compliance programs and procedures are
designed to prevent, or identify and correct,
violations of these provisions.  This Code does not, and is not
intended to, repeat or replace these programs and
procedures, and such conflicts fall outside of the parameters of
this Code.

Although typically not presenting an opportunity for improper
personal benefit, conflicts arise from, or
as a result of, the contractual relationship between the Company
and the investment adviser of which the
Covered Officers are also officers or employees. As a result, this
Code recognizes that the Covered Officers
will, in the normal course of their duties (whether formally for
the Company or for the adviser, or for both), be
involved in establishing policies and implementing decisions that
will have different effects on the adviser and
the Company. The participation of the Covered Officers in such
activities is inherent in the contractual
relationship between the Company and the adviser and is consistent
with the performance by the Covered
Officers of their duties as officers of the Company. Thus, if
performed in conformity with the provisions of the
Investment Company Act and the Investment Advisers Act, such
activities will be deemed to have been
handled ethically. In addition, it is recognized by the Funds'
Boards of Directors ("Boards") that the Covered
Officers may also be officers or employees of one or more other
investment companies covered by this or other
codes.

Other conflicts of interest are covered by the Code, even if such
conflicts of interest are not subject to
provisions in the Investment Company Act and the Investment
Advisers Act. The following list provides
examples of conflicts of interest under the Code, but Covered
Officers should keep in mind that these examples
are not exhaustive. The overriding principle is that the personal
interest of a Covered Officer should not be
placed improperly before the interest of the Company.

Each Covered Officer must:

?	Not use his personal influence or personal relationships
improperly to influence investment
decisions or financial reporting by the Company whereby the
Covered Officer would benefit
personally to the detriment of the Company;

?	Not cause the Company to take action, or fail to take
action, for the individual personal benefit
of the Covered Officer rather than the benefit the Company;

?	Not use material non-public knowledge of portfolio
transactions made or contemplated for the
Company to trade personally or cause others to trade personally in
contemplation of the market
effect of such transactions;

There are some conflict of interest situations that should always
be discussed with the Company's in-
house legal counsel ("Legal Counsel") if material. Examples of
these include:'

?	Service as a director on the board of any public or private
company;

?	The receipt of any non-nominal gifts;

?	The receipt of any entertainment from any company with which
the Company has current or
prospective business dealings unless such entertainment is
business related, reasonable in cost,
appropriate as to time and place, and not so frequent as to raise
any question of impropriety;

?	Any ownership interest in, or any consulting or employment
relationship with, any of the
Company's service providers, other than its investment adviser,
principal underwriter,
administrator or any affiliated person thereof;

?	A direct or indirect financial interest in commissions,
transaction charges or spreads paid by the
Company for effecting portfolio transactions or for selling or
redeeming shares other than an
interest arising from the Covered Officer's employment, such as
compensation or equity
ownership.



III.	Disclosure and Compliance

?	Each Covered Officer should familiarize himself with the
disclosure requirements generally
applicable to the Company;

?	Each Covered Officer should not knowingly misrepresent, or
cause others to misrepresent, facts
about the Company to others, whether within or outside the
Company, including to the
Company's directors and auditors, and to governmental regulators
and self-regulatory
organizations;

?	Each Covered Officer should, to the extent appropriate
within his area of responsibility, consult
with other officers and employees of the Funds and the adviser
with the goal of promoting full,
fair, accurate, timely and understandable disclosure in the
reports and documents the Funds file
with, or submit to, the SEC and in other public communications
made by the Funds; and

?	It is the responsibility of each Covered Officer to promote
compliance with the standards and
restrictions imposed by applicable laws, rules and regulations.

IV.	Reporting and Accountability

Each Covered Officer must:

?	Upon adoption of the Code (or thereafter as applicable, upon
becoming a Covered Officer),
affirm in writing to the Board that he has received, read, and
understands the Code;

?	Annually thereafter affirm to the Board that he has complied
with the requirements of the Code;

?	Annually report to the Legal Counsel affiliations or other
relationships related to conflicts of
interest.

?	Not retaliate against any other Covered Officer or any
employee of the Funds or their affiliated
persons for reports of potential violations that are made in good
faith; and

?	Notify the Legal Counsel promptly if he knows of any
violation of this Code. Failure to do so is
itself a violation of this Code.

The Legal Counsel is responsible for applying this Code to
specific situations in which questions are
presented under it and has the authority to interpret this Code in
any particular situation.  However, any
approvals or waivers sought by the Principal Executive Officer
will be considered by the Audit Committee (the
"Committee").

The Funds will follow these procedures in investigating and
enforcing this Code:

?	The Legal Counsel will take all appropriate action to
investigate any potential violations
reported to him;

?	If, after such investigation, the Legal Counsel believes
that no violation has occurred, he is not
required to take any further action;
?	Any matter that the Legal Counsel believes is a violation
will be reported to the Committee;

?	If the Committee concurs that a violation has occurred, it
will inform and make a
recommendation to the Board, which will consider appropriate
action, which may include
review of, and appropriate modifications to, applicable policies
and procedures; notification to
appropriate personnel of the investment adviser or its board; or a
recommendation to dismiss the
Covered Officer;

?	The Committee will be responsible for granting waivers, as
appropriate; and

?	Any changes to or waivers of this Code will, to the extent
required, be disclosed as provided by
SEC rules.

A report on compliance with this Code will be presented at each
regular meeting of the Boards.

V. 	Other Policies and Procedures

This Code shall be the sole code of ethics adopted by the Funds
for purposes of Section 406 of the
Sarbanes-Oxley Act and the rules and forms applicable to
registered investment companies thereunder. Insofar
as other policies or procedures of the Funds, the Funds' adviser,
principal underwriter, or other service providers
govern or purport to govern the behavior or activities of the
Covered Officers who are subject to this Code, they
are superseded by this Code to the extent that they overlap or
conflict with the provisions of this Code. The
Funds' and their investment adviser's codes of ethics under Rule
17j- 1 under the Investment Company Act are
separate requirements applying to the Covered Officers and others,
and are not part of this Code.

VI. 	Amendments

Any amendments to this Code, other than amendments to Exhibit A,
must be approved or ratified by a
majority vote of the Board, including a majority of independent
directors.

VII 	Confidentiality

All reports and records prepared or maintained pursuant to this
Code will be considered confidential and
shall be maintained and protected accordingly. Except as otherwise
required by law or this Code, such matters
shall not be disclosed to anyone.

VIII. 	Internal Use

The Code is intended solely for the internal use by the Funds and
does not constitute an admission, by or
on behalf of any Company, as to any fact, circumstance, or legal
conclusion.

Date: August 11, 2003


Exhibit A

Persons covered by this Code of Ethics:

Steven R. Sutermeister

Thomas G. Knipper
1.