EX.1

                                  BUFFALO FUNDS

                                 CODE OF ETHICS
          FOR PRINCIPAL EXECUTIVE OFFICER & PRINCIPAL FINANCIAL OFFICER

      The various Buffalo Funds (the "Funds") require 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 Funds. 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 Funds to the Audit
      Committee, the full Board of Trustees of the Funds, 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 Funds' needs; shall proactively promote ethical
      behavior of the Funds' 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 Funds 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 Boards of
      Directors/Trustees of the Funds 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 Boards of Directors/Trustees of the Funds.

5.    AMENDMENT AND WAIVER

      This Code of Ethics may only be amended or modified by approval of the
      Boards of Directors/Trustees. 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.

        ADOPTED BY THE BOARDS OF DIRECTORS/TRUSTEES ON NOVEMBER 21, 2003