THORNBURG INVESTMENT TRUST

                       CODE OF BUSINESS CONDUCT AND ETHICS

Introduction

Honesty and integrity are hallmarks of Thornburg Investment Trust (the "Trust").
We maintain the highest standards of ethics and conduct in all of our business
relationships. This Code of Business Conduct and Ethics covers a wide range of
business practices and procedures and applies to the officers and Trustees of
the Trust in their conduct of the business and affairs of the Trust. It does not
cover every issue that may arise, but it sets out basic principles to guide the
officers and Trustees of the Trust in discharging their duties for the Trust.
This Code has been adopted by the Trustees of the Trust with the objectives of
deterring wrongdoing and promoting (1) honest and ethical conduct, including the
ethical handling of actual or apparent conflicts of interest between personal
and professional relationships, (2) full, fair, accurate, timely and
understandable disclosure in reports and documents which the Trust files with
the Securities and Exchange Commission and in other public communications made
by the Trust, (3) compliance with applicable governmental laws, rules and
regulations, (4) prompt internal reporting of violations of this Code, and (5)
accountability for adherence to this Code.

This Code is intended as a code of ethics under Section 406 of the
Sarbanes-Oxley Act of 2002 and Item 2 of Form N-CSR under the Investment Company
Act of 1940, and is specifically applicable to the principal executive officer,
principal financial officer, and principal accounting officer (or persons
performing similar functions, whether or not as officers or employees of the
Trust) of the Trust (each a "Covered Officer").

All records and reports created or maintained pursuant to this Code are intended
solely for the internal use of the Trust, are confidential, and in no event
constitute an admission by any person as to any fact, circumstance or legal
conclusion.

Compliance with Laws, Rules and Regulations

The Trust expects its officers and Trustees to comply with all laws, rules and
regulations applicable to the Trust's operations and business. Officers and
Trustees should seek guidance whenever they are in doubt as to the applicability
of any law, rule or regulation regarding any contemplated course of action. The
Trust and its investment adviser hold information and training sessions to
promote compliance with laws, rules and regulations, including insider-trading
laws. Please consult the various guidelines and policies which the Trust has
prepared in accordance with specific laws and regulations. A good guideline, if
in doubt on a course of action, is "Always ask first, act later -- if you are
unsure of what to do in any situation, seek guidance before you act."

As a registered investment company, we are subject to regulation by the
Securities and Exchange Commission, and compliance with federal, state and local
laws. The Trust and its Trustees insist on strict compliance with the spirit and
the letter of these laws and regulations.






Conflicts of Interest

Each officer and Trustee of the Trust should be scrupulous in avoiding any
conflict of interest with regard to the Trust's interests. A "conflict of
interest" occurs when an individual's private interest interferes with the
interests of the Trust. A conflict situation can arise when an officer or
Trustee pursues interests that prevent the individual from performing his duties
to the Trust objectively and effectively. Conflicts of interest also arise when
an officer or Trustee or member of the individual's family receives undisclosed,
improper benefits as a result of the individual's position with the Trust. Any
conflict of interest that arises in a specific situation or transaction must be
disclosed by the individual and resolved before taking any action.

Matters involving a conflict of interest are prohibited as a matter of Trust
policy, except when approved by the Trustees or the Trust's audit committee for
any Covered Officer or Trustee, or except when approved by the Trust's president
for any other individual. Conflicts of interest may not always be evident, and
individuals should consult with higher levels of management or the Trust's legal
counsel if they are uncertain about any situation. In no event, however, shall
investment in any security made in accordance with the Trust's Policy on
Personal Securities Transactions (or comparable policy or code then in effect)
be considered a conflict of interest with the Trust.

Corporate Opportunities

Officers and Trustees shall not take for themselves personally opportunities
that are discovered through the use of their position with the Trust, except
with the approval of the Trustees or the Trust's audit committee for any Covered
Officer or Trustee, or except with the approval by the Trust's president for any
other individual. Officers and Trustees owe a duty to the Trust to advance its
legitimate interests when the opportunity to do so arises. In no event, however,
shall investment in any security made in accordance with the Trust's Policy on
Personal Securities Transactions (or comparable policy or code then in effect)
be considered a business opportunity of the Trust.

Confidentiality

Officers and Trustees shall exercise care in maintaining the confidentiality of
any confidential information respecting the Trust, except where disclosure is
authorized or legally mandated. Officers and Trustees should consult with the
Trust's legal counsel if they believe they have a legal obligation to disclose
confidential information. Confidential information includes non-public
information of the Trust that may be helpful to competitors, or otherwise
harmful to the Trust or its shareholders. The obligation to preserve
confidentiality of this information continues after association with the Trust
ends.

Fair Dealing

Officers and Trustees should endeavor to deal fairly with the Trust's
shareholders, service providers and competitors, and shall not seek unfair
advantage through improper concealment, abuse of improperly acquired
confidential information, misrepresentation of material facts when the other
party is known by the officer or Trustee to rely justifiably on the individual
to disclose those facts truthfully, or improper and unfair dealing.

Business Gifts and Entertainment

The purpose of business entertainment and gifts in a commercial setting is to
create goodwill and sound working relationships, not to gain unfair advantage.
No gift or entertainment should ever be offered, given, provided or accepted by
any officer or Trustee in connection with the Trust's business unless it (1) is
not a cash gift, (2) is consistent with customary business practices, (3) is not
excessive in value, (4) cannot be construed as a bribe, payoff or kickback and
(5) does not violate any laws or regulations.

Protection and Proper Use of Trust Assets

All officers and Trustees should endeavor to protect the Trust's assets and
pursue their efficient investment in accordance with the Trust's business
purposes and declaration of trust. Any suspected incident of fraud or theft
should be immediately reported for investigation as hereinafter described under
the caption "Reporting Illegal or Unethical Behavior."

The obligation of officers and Trustees to protect the Trust's assets includes
its proprietary information. Proprietary information includes intellectual
property such as trademarks and copyrights, as well as business, marketing and
service plans, databases, records, salary information and any unpublished
financial data and reports. Unauthorized use or distribution of this information
violates this Code.

Insider Trading

All officers and Trustees should pay particular attention to potential
violations of insider trading laws. Insider trading is both unethical and
illegal and will be dealt with decisively if it occurs. Officers and Trustees
are expected to familiarize themselves with the Policy Statement on Insider
Trading, adopted by the Trust's investment adviser. If they have questions about
these guidelines, they should consult with the Trust's president, the investment
adviser's compliance office, or the Trust's legal counsel.

Reporting Illegal or Unethical Behavior

The Trustees encourage each officer to talk to senior officers, the investment
adviser's compliance officers, or the Trustees about observed illegal or
unethical behavior, or when the officer is in doubt about the best course of
action in a particular situation. Officers should report actual and suspected
violations of laws, rules, regulations or this Code to appropriate personnel. If
an individual does not believe it appropriate or is not comfortable approaching
senior officers or the investment adviser's compliance officers about their
concerns, then the individual may contact any member of the Trust's audit
committee. If the individual's concerns require confidentiality, then this
confidentiality will be protected, subject to applicable law, regulation or
legal proceedings. The Trust will not permit retaliation of any kind by or on
behalf of the Trust or its officers and Trustees against good faith reports or
complaints of violations of this Code or other illegal or unethical conduct.

Reporting and Disclosure

As a registered investment company, it is of critical importance that the
Trust's filings with the Securities and Exchange Commission, including
specifically shareholder reports, contain full, fair, accurate, timely and
understandable disclosure. Each officer and Trustee should become familiar with
the disclosure laws and regulations applicable to the Trust, consistent with the
individual's authority and duties. Depending on the Trust, each officer and
Trustee may be called upon to provide necessary information to ensure that the
Trust's public reports are complete, fair and understandable. The Trustees
expect officers and Trustees to take this responsibility very seriously and to
provide prompt and accurate answers to inquiries related to the Trust's public
disclosure requirements. Officers may be asked to certify as to the accuracy of
all responses and information provided for inclusion in the Trust's public
reports and filings.



Recordkeeping

The Trust requires accurate recording and reporting of information in order to
make responsible business decisions. The Trustees expect each of the Trust's
officers, consistent with the officer's individual authority and duties, to
maintain the Trust's books, records, accounts and financial statements in
reasonable detail, and to appropriately reflect the Trust's transactions in
conformity with applicable legal requirements and the Trust's system of internal
controls.

Accounting and Financial Reporting Concerns

The Trust seeks to comply with all applicable financial reporting and accounting
regulations applicable to the Trust. Officers who have concerns or complaints
regarding questionable accounting or auditing matters or procedures involving
the Trust are encouraged to submit those concerns or complaints to the Trust's
audit committee which will, subject to its duties arising under applicable law,
regulations and legal proceedings, treat such submissions confidentially. These
submissions may be directed to the attention of the audit committee chairman, or
any Trustee who is a member of the audit committee, at the principal executive
offices of the Trust or at the Trustee's residence address.

Waivers of the Code of Business Conduct and Ethics

Any waiver of this Code for any Covered Officer or Trustee may be made only by
the Trustees or the Trust's audit committee and will be promptly disclosed as
required by law or by Securities and Exchange Commission regulations. Waivers of
this Code for any other individual may be made by the president only upon the
individual's making full disclosure in advance of the transaction in question.
This Code may be amended or modified at any time by the Trustees.


Adopted by Trustees September 10, 2003