BANK INVESTMENT FUND
CONFLICT OF INTEREST/
CODE OF ETHICS POLICY

General

      This policy establishes the standards of ethical business behavior
and personal conduct for the members of the Board of Directors,
officers and employees of the Bank Investment Fund (the
Corporation) in accordance with the provisions of Rule 17j-1 under
the Investment Company Act of 1940, as amended.

      Every director, officer and employee of the Corporation shall
avoid any situation where their personal interest might conflict with, or
even appear to conflict with, the interests of the Corporation and which
might affect independent judgment thereon.

      Each director, officer or employee is expected to report
promptly to the Chairman of the Board or the President the existence
of any relationship or interest which actually or potentially involves, or
appears to involve, a conflict of interest.  This reporting shall also
extend to the general counsel of the Corporation, where applicable.

      Each director, officer or employee shall also comply with all
requirements as to disclosure of conflicts of interest imposed by law
and by rules and regulations of organizations governing the
Corporation s activities and shall comply with any prohibitions on
his/her individual activities if a conflict of interest exists.

      The Corporation, its directors, officers and employees will at all
times address their responsibilities with the utmost of integrity and the
highest of ethical standards.

Compliance

      The Corporation, through its officers, shall maintain knowledge
of and shall comply with all applicable laws, rules and regulations of
any government, governmental agency and regulatory organization
governing its professional, financial or business activities, as well as
with this policy.  The primary regulatory agencies would be the
Commissioner of Banks for the Commonwealth of Massachusetts
(state) and the Securities and Exchange Commission (federal).
Additional (secondary) federal and state agencies may, or will, also be
applicable in this regard on matters of taxation, labor, etc.

      No officer, director or employee, in accordance with Rule
17j-1, shall:  employ any device, scheme or artifice to defraud the
Corporation; make any untrue statement of material fact to the
Corporation, omit to make or disclose any material fact to the
Corporation, or otherwise mislead the Corporation; engage in any act,
practice or course of business which operates as a fraud or deceit upon
the Corporation; or engage in any manipulative practice with respect to
the Corporation.

      No officer, director or employee of the Corporation shall
knowingly participate in, or assist, any acts in violation of any
applicable law, rule or regulation of any government, governmental


agency, or regulatory organization governing his/her professional,
financial or business activities, nor any act which would violate any
provision of this policy.

      No officer, director or employee shall commit a criminal act
that, upon conviction, materially reflects adversely on his honesty,
trustworthiness or fitness for service to the Corporation, or engage in
conduct involving dishonesty, fraud, deceit or misrepresentation.

      The officers of the Corporation shall exercise reasonable
supervision over those subordinate employees subject to their control
to prevent any violation by such persons of applicable statutes,
regulations or provisions of this policy.  In so doing, the employee is
entitled to rely upon reasonable procedures established by the
Corporation.

Performance Presentation

      No officer, director or employee shall make any statements,
orally or in writing, which misrepresent the investment performance
that the Corporation (or any of its individual funds) has accomplished
or can reasonably be expected to achieve.  Every reasonable effort
should be made to ensure that such performance information is fair,
accurate and complete.

      The Corporation will, at all times, comply with disclosure
requirements of the SEC, especially as they relate to yields and total
returns.

Outside Employment

      No officer or employee shall undertake independent
employment which could result in compensation or other benefit in
competition with the Corporation unless he has received written
consent from both the Corporation and the person for whom he
undertakes independent employment, except to the extent that such
officer or employee is employed by The Co-operative Central Bank.
(This section would apply for a term of one year following employment
termination with the Corporation.)

Professional Conduct

      Directors, officers and/or employees shall preserve the
confidentiality of any information that he/she may receive in the normal
course of the Corporation s business which may be deemed insider or
confidential.  In protecting the privacy of investors account
information, the directors, officers and/or employees shall not share any
non-public information concerning our investor banks with any other
party except as necessary to process transactions or service accounts.
Questions on confidentiality may be directed to the President or
Corporate Counsel.

      Directors, officers and/or employees shall use care and good
judgment to achieve and maintain corporate independence and
objectivity.

      Directors, officers and/or employees shall use care and good
judgment in determining applicable fiduciary duty and shall comply with
such duty as is owed.


      Directors, officers or employees shall not accept gifts from
service providers whose value exceeds $100 without disclosure to and
agreement of management.

      No director, officer or employee shall offer to pay, pay, offer to
accept or accept any compensation, fee or other benefit for investment
transactions, goods or services.

Personal Securities Transaction Reporting

      Access persons will provide an initial listing to the review
officer, no later than ten days after becoming an access person, of any
personal securities holdings which are "covered securities", as defined
in Section 2(a)(36) of the Investment Company Act of 1940.  Within
ten days after the end of each quarter thereafter, a report (in the form
of Exhibit A) must be submitted to the review officer reporting certain
securities transactions (reportable) for the quarter then ended.  The
report should include the name of the security, quantity, date of
transaction, whether the security was purchased or sold, the price, and
the name of the broker-dealer through which the transaction was
performed.  Reports need not include mutual fund transactions, money
market instruments, direct obligations of the United States or of a U.S.
government agency, purchase or sale of securities affected in any
account over which you or members of your immediate family residing
with you have no direct or indirect influence or control, automatic
dividend reinvestment, rights and tenders of securities owned, options
or futures on broad-based stock indexes (e.g., the S&P 500), gifts or
bequests of securities (if these securities are later sold, the restricted
list and reporting requirements could apply), or commodities.  Each
quarterly submission should include a statement indicating the
individual s continuing compliance with policy.  Quarterly reportable
security transactions are all securities except for the exempt categories
indicated above.  An alternate review officer would receive and review
the quarterly reports required hereunder from the review officer; he/she
may also receive and review reports of other officers in the absence of
the review officer.

      The approved list securities (restricted transactions securities)
will be continuously maintained by the Corporation and copies of the
list will be provided to access persons at quarter end.  Additional
interim copies of the list will be provided upon request.

Access persons are restricted from making any purchases or sales of
securities on the approved securities list (restricted transaction
securities) within 15 days following the initial approved listing or within
15 days following the purchase or sale of such listed security by the
Corporation.  Access persons should also seek to avoid purchases and
sales of such securities within 15 days prior to any purchases and sales
of such securities by the Corporation.  Access persons are encouraged
to contact the review officer for pre-approval of any individual
proposed purchases and sales of such securities.

      Any questions on reporting or restrictions may be directed to
the review officer and/or corporate counsel.




Review of Reports

      The review officer shall compare the reported personal
securities transactions of each access person with portfolio transactions
of the Corporation to determine whether any transactions that violate
this Code may have occurred.  In the case of reports of personal
securities transactions of the review officer, the alternate review officer
shall perform such comparison.  Before making any determination that
a violation has been committed by any access person, the review officer
(or alternate review officer, as the case may be) shall provide such
access person an opportunity to supply additional explanatory material
for the purposes of demonstrating that such transactions did not violate
this Code.

      On an annual basis, the review officer shall prepare for the
Board of Directors a summary of the level of compliance by all access
persons with this Code during the previous year, including without
limitation the percentage of reports timely filed and the number and
nature of all material violations.  Also on an annual basis, the review
officer shall prepare a report identifying any recommended changes to
existing restrictions or procedures based upon the Corporation s
experience under this Code, evolving industry practices and
developments in applicable laws or regulations.  The alternate review
officer shall prepare reports with respect to compliance by the review
officer.

      All reports of securities transactions and any other information
filed with the review officer pursuant to this Code shall be treated as
confidential, except that reports of securities transactions hereunder
will be made available to the Commission or any other regulatory or
self-regulatory organization to the extent required by law or regulation
or to the extent the Corporation considers necessary or advisable in
cooperating with an investigation or inquiry by the Commission or any
other regulatory or self-regulatory organization.

Sanctions

      Sanctions for violation of this Code include, but are not limited
to, one or more of the following: removal or suspension from office,
termination of employment, a letter of censure and/or restitution to the
Corporation of an amount equal to the advantage that the offending
person gained by reason of such violation.  In addition, as part of any
sanction, the access person may be required to reverse the trade(s) at
issue and forfeit any profit or absorb any loss from the trade.  It is
noted that violations of this Code by an access person may also result in
criminal prosecution or civil action.


Definitions

      As used herein, the following terms shall have the following
meaning:

      (Access person) with respect to the Corporation shall mean all
officers who participate in the daily operations of the Corporation.

      (Review officer) shall mean the officer of the Corporation
designated from time to time to receive and review reports of purchases
and sales by access persons.

      (Alternate review officer) shall mean the officer of the
Corporation designated from time to time to receive and review reports
of purchases and sales by the review officer and who shall act in all
respects in the manner prescribed herein for the review officer.

      (Security) shall have the same meaning as that set forth in
Section 2(a)(36) of the Investment Company Act (in effect, all
securities), except that it shall not include securities issued by the
Government of the United States or an agency thereof within the
meaning of Section 2(a)(16) of the Investment Company Act, bankers
acceptances, bank certificates of deposit, commercial paper, shares of
registered open-end investment companies and options on broad based
market indices.

Responsibility

      The primary accountability and responsibility for the Code of
Ethics and Conflict of Interest policy rests with each individual
director, officer and employee, and is demonstrated best by example
what compliance with this policy means.



ADOPTED: 9/18/97
LAST AMENDED:  9/19/02
REVIEWED AND APPROVED BY A VOTE OF THE BOARD OF
DIRECTORS OF THE BANK INVESTMENT FUND ON THE 25TH
DAY OF SEPTEMBER 2003.