THE ADVISORS' INNER CIRCLE FUND
                                 THE ARBOR FUND
                              THE EXPEDITION FUNDS
                                  THE MDL FUNDS

                                 CODE OF ETHICS
                            ADOPTED UNDER RULE 17J-1



The Advisors' Inner Circle Fund, The Arbor Fund, The Expedition Funds and The
MDL Funds (each a "Fund," and together, the "Funds") are confident that their
officers, Trustees and other persons involved with the Funds' business act with
integrity and good faith. The Funds recognize, however, that personal interests
may conflict with the Funds' interests where officers, Trustees and certain
other persons:

        o Know about the Funds' present or future portfolio transactions; or

        o Have the power to influence the Funds' portfolio transactions; and

        o Engage in securities transactions in their personal account(s).

In an effort to prevent conflicts of interest from arising, and in accordance
with Rule 17j-1 under the Investment Company Act of 1940 (the "1940 Act"), each
Fund has adopted this Code of Ethics (the "Code") to address transactions and
conduct that may create conflicts of interest, establish reporting requirements,
and create enforcement procedures. Definitions of UNDERLINED terms used
throughout the Code are included in Appendix I.

I.       ABOUT THIS CODE OF ETHICS

         A. WHO IS COVERED BY THE CODE?

            Each Fund's ACCESS PERSONS are covered under this Code. A Fund's
            ACCESS PERSONS generally are:

            o All Trustees of a Fund, both INTERESTED and INDEPENDENT;

            o All FUND OFFICERS; and

            o Natural persons in a CONTROL relationship to a Fund who obtain
              information concerning recommendations about the PURCHASE OR SALE
              of a security by a Fund ("Natural CONTROL Persons").





         B. WHAT RULES APPLY TO ME?

            o This Code sets forth specific prohibitions and restrictions. They
              apply to all ACCESS PERSONS of a Fund except where otherwise
              noted. The Code also sets out reporting requirements for ACCESS
              PERSONS. For the reporting requirements that apply to you, please
              refer to Parts A, B and C, as indicated below:

            o Independent Trustees                            Part A

            o Interested Trustees and Fund Officers           Part B

            o Natural CONTROL Persons                         Part C

II.      STATEMENT OF GENERAL PRINCIPLES

         In recognition of the trust and confidence placed in the Funds by
         shareholders, and because each Fund believes that its operations should
         benefit its shareholders, each Fund has adopted the following
         principles to be followed by its ACCESS PERSONS:

         A.   The interests of the Fund's shareholders are paramount. You must
              place shareholder interests before your own.

         B.   You must accomplish all personal securities transactions in a
              manner that avoids any conflict between your personal interests
              and the interests of the Fund or its shareholders.

         C.   You must avoid actions or activities that allow you or your family
              to benefit from your position with the Fund, or that bring into
              question your independence or judgment.

III.     GENERAL PROHIBITION AGAINST FRAUD, DECEIT AND MANIPULATION

         EACH FUND'S ACCESS PERSONS may not, in connection with the purchase or
         sale, directly or indirectly, of a SECURITY HELD OR TO BE ACQUIRED by
         the Fund:

         A.   Employ any device, scheme or artifice to defraud the Fund;

         B.   Make to the Fund any untrue statement of a material fact or omit
              to state to the Fund a material fact necessary in order to make
              the statements made, in light of the circumstances under which
              they are made, not misleading;

         C.   Engage in any act, practice or course of business that operates or
              would operate as a fraud or deceit upon the Fund; or

         D.   Engage in any manipulative practice with respect to the Fund.

                                          2



IV.      PROHIBITIONS AND RESTRICTIONS FOR ACCESS PERSONS
         (not applicable to INDEPENDENT TRUSTEES)

         A.   BLACKOUT PERIOD ON PERSONAL SECURITIES TRANSACTIONS.

              This restriction applies to: (i) ACCESS PERSONS who, in connection
              with their regular duties, make, participate in, or obtain
              information regarding the PURCHASE OR SALE OF SECURITIES by the
              Fund or whose functions relate to the making of any
              recommendations with respect to the PURCHASES OR SALES and
              (ii) Natural CONTROL Persons.

              These persons may not PURCHASE OR SELL, directly or indirectly,
              any SECURITY in which they have (or by reason of such transaction
              acquire) any BENEFICIAL OWNERSHIP ON THE SAME DAY as the same (or
              a related) SECURITY IS BEING PURCHASED OR SOLD by the Fund (or any
              series thereof).

         B.   PRE-APPROVAL FOR IPOS AND LIMITED OFFERINGS.

              This restriction applies to: (i) ACCESS PERSONS who, in connection
              with their duties, make or participate in making recommendations
              regarding THE PURCHASE OR SALE OF any securities by a Fund and
              (ii) Natural CONTROL Persons. These persons must obtain approval
              from the Review Officer (as defined in Section VI below) before
              directly or indirectly acquiring BENEFICIAL OWNERSHIP of any
              securities in an IPO or LIMITED OFFERING.

         C.   LIMITS ON ACCEPTING OR RECEIVING GIFTS.

              ACCESS PERSONS cannot accept or receive any gift of more than
              DE MINIMIS value from any person or entity in connection with the
              Fund's (or any series thereof) entry into a contract, development
              of an economic relationship, or other course of dealing by or on
              behalf of the Fund.

V.       REPORTING REQUIREMENTS

         ACCESS PERSONS of each Fund must comply with the reporting requirements
         set forth in Parts A-C (attached), with the exception of those ACCESS
         PERSONS reporting subject to Section VIII of this Code.

VI.      REVIEW AND ENFORCEMENT OF THE CODE

         A.   APPOINTMENT OF A REVIEW OFFICER.

              Each Fund's President shall appoint a review officer ("Review
              Officer") to perform the duties described below.

                                          3



         B.   THE REVIEW OFFICER'S DUTIES AND RESPONSIBILITIES.

              1.       The Review Officer shall notify each person who
                       becomes an ACCESS PERSON of the Fund and who is
                       required to report under this Code of Ethics of their
                       reporting requirements NO LATER THAN 10 days before
                       the first quarter in which such person is required to
                       begin reporting.

              2.       The Review Officer will, on a quarterly basis,
                       compare all reported personal securities transactions
                       with the Fund's completed portfolio transactions and
                       a list of SECURITIES that were BEING CONSIDERED FOR
                       PURCHASE OR SALE by the Fund's investment adviser(s)
                       during the period to determine whether a Code
                       violation may have occurred. Before determining that
                       a person has violated the Code, the Review Officer
                       must give the person a reasonable opportunity to
                       supply explanatory material.

              3.       If the Review Officer finds that a material Code
                       violation has occurred, or believes that a material
                       Code violation may have occurred, the Review Officer
                       must submit a written report regarding the possible
                       violation, together with the confidential report and
                       any explanatory material provided by the person, to
                       the President. The President will determine whether
                       the person violated the Code and may consult legal
                       counsel for the Fund in making this determination, as
                       necessary.

              4.       No person is required to participate in a
                       determination of whether he or she has committed a
                       Code violation or discuss the imposition of any
                       sanction against himself or herself.

              5.       The Review Officer will submit his or her own
                       reports, as may be required pursuant to Parts A-C
                       (attached), to an Alternate Review Officer who shall
                       fulfill the duties of the Review Officer with respect
                       to the Review Officer's reports.

              6.       The Review Officer will create a written report
                       detailing any approval(s) granted to ACCESS persons
                       for the acquisition of securities offered in
                       connection with an IPO or LIMITED OFFERING. The
                       report must include the rationale supporting any
                       decision to approve such an acquisition.

         C.   RESOLUTION; SANCTIONS.

              If the President determines that a person has violated the
              Code pursuant to paragraph B. (3) above, the President will
              impose upon the person a resolution of the situation and/or
              sanctions that the President deems appropriate. The President
              will submit the resolution, with a report of the violation, to
              the Board at the next regularly scheduled Board meeting
              unless, in the President's sole discretion, circumstances
              warrant an earlier report.

                                          4


VII.     ANNUAL WRITTEN REPORTS TO THE BOARD

         At least annually, the Review Officer, investment adviser(s) (including
         any sub-advisers), and principal underwriter(s) (if required) will
         provide WRITTEN reports to the Funds' Board of Trustees as follows:

         A.   ISSUES ARISING UNDER THE CODE. The reports must describe any
              issue(s) that arose during the previous year under the codes
              or procedures thereto, including any material code or
              procedural violations, and any resulting sanction(s). The
              Review Officer, President, investment adviser(s) (including
              any sub-advisers) and principal underwriter(s) may report to
              the Board more frequently as they deem necessary or appropriate
              and shall do so as requested by the Board.

         B.   The Review Officer, President, investment adviser(s) (including
              any sub-advisers) and principal underwriter(s) may report to the
              Board more frequently as they deem necessary or appropriate and
              shall do so as requested by the Board.

         C.   CERTIFICATION. Each report must be accompanied by a certification
              to the Board that each Fund, investment adviser(s) (including any
              sub-advisers) and principal underwriter(s) have adopted procedures
              reasonably necessary to revent their ACCESS PERSONS from violating
              their code of ethics.

VIII.    INTERRELATIONSHIP WITH OTHER CODES OF ETHICS

         A. GENERAL PRINCIPLE: OVERLAPPING RESPONSIBILITIES.

              A person who is both an ACCESS PERSON of a Fund and an ACCESS
              PERSON of an investment adviser to or principal underwriter
              for the Fund is only required to report under and otherwise
              comply with the investment adviser's or principal underwriter's
              code of ethics, provided such code has been adopted pursuant to
              and in compliance with Rule 17j-1. Such report will satisfy any
              reporting obligations under this Code. These ACCESS PERSONS,
              however, remain subject to the principles and prohibitions in
              Sections II and III hereof.

         B.   OVERLAP WITH ADMINISTRATOR'S CODE OF ETHICS.

              ACCESS PERSONS of a Fund seeking to comply with the reporting
              and other requirements in an administrator's code of ethics in
              lieu of those in this Code must obtain prior approval from the
              Review Officer. If approval is granted, such report will satisfy
              any reporting obligations under this Code. However, such ACCESS
              PERSONS shall remain subject to the principles and prohibitions in
              Sections II and III, hereof; and the administrator must comply
              with this Section VIII, hereof and paragraph C, below.


                                          5



         C. PROCEDURES.

            Each such investment adviser, principal underwriter and
            administrator of the Fund must:

              1.       Submit to the Board of Trustees of the Fund a copy of
                       its code of ethics adopted pursuant to or in compliance
                       with Rule 17j-1;

              2.       Promptly furnish to the Fund, upon request, copies of
                       any reports made under its code of ethics by any
                       person who is also covered by the Fund's Code; and

              3.       Promptly report to the Fund in writing any material
                       amendments to its code of ethics, along with the
                       certification described under Section VII.C., above.

IX.      RECORDKEEPING

         Each Fund will maintain the following records in accordance with Rule
         31a-2 under the 1940 Act and the following requirements. They will be
         available for examination by representatives of the Securities and
         Exchange Commission and other regulatory agencies.

         A.   A copy of this Code and any other code adopted by the Fund,
              which is, or at any time within the past five years has been,
              in effect will be preserved in an easily accessible place.

         B.   A record of any material Code violation and of any sanctions
              taken will be preserved in an easily accessible place for a
              period of at least five years following the end of the fiscal
              year in which the violation occurred.

         C.   A copy of each Quarterly Transaction Report, Initial Holdings
              Report, and Annual Holdings Report submitted under this Code,
              including any information provided in lieu of any such reports
              made under the Code (SEE Parts A-C for more information about
              reporting), will be preserved for a period of at least five
              years from the end of the fiscal year in which it is made, for
              the first two years in an easily accessible place.

         D.   A record of all persons, currently or within the past five
              years, who are or were required to submit reports under this
              Code, or who are or were responsible for reviewing these
              reports, will be maintained in an easily accessible place.

         E.   A copy of each annual report required by Section VII of this
              Code must be maintained for at least five years from the end
              of the fiscal year in which it is made, for the first two
              years in any easily accessible place.

         F.   A record of any decision, and the reasons supporting the
              decision, to approve the acquisition of securities acquired in
              an IPO or LIMITED OFFERING.


                                          6



X.       MISCELLANEOUS

         A. CONFIDENTIALITY.

            All reports and other information submitted to the Fund pursuant
            to this Code will be treated as confidential to the maximum extent
            possible, provided that such reports and information may be
            produced to the Securities and Exchange Commission and other
            regulatory agencies and to persons who have a need to know for
            purposes of administering this Code.

         B. INTERPRETATION OF PROVISIONS.

            The Board of Trustees may from time to time adopt such
            interpretations of this Code as it deems appropriate.

         C. COMPLIANCE CERTIFICATION.

            Within 10 days of becoming an ACCESS PERSON of the Fund, and each
            year thereafter, each such person must complete the Compliance
            Certification, attached as Appendix V.


Adopted this 13th day of November, 1995.
Revised November 11, 1996.
Revised February 18, 1997.
Revised November 16, 1998.
Revised February 23, 2000.
Revised November 23, 2000.
Revised November 13, 2001.

                                          7



                         THE ADVISORS' INNER CIRCLE FUND
                                 THE ARBOR FUND
                              THE EXPEDITION FUNDS
                                  THE MDL FUNDS


PART A - INDEPENDENT TRUSTEES

I.       QUARTERLY TRANSACTION AND ACCOUNT REPORTS

         A. Subject to Section II. (B) below, each quarter, you must
            report all of your SECURITIES transactions effected, as well
            as any securities accounts you established, during the
            quarter. You must submit your report to the Review Officer no
            later than 10 days after the end of each calendar quarter. A
            Quarterly Personal Securities Transactions Report Form is
            included as Appendix II.

         B. If you had no reportable transactions and did not open any
            securities accounts during the quarter, you are still required
            to submit a report. Please note on your report that you had no
            reportable items during the quarter, and return it, signed and
            dated.

         C. You need not submit a quarterly report if the report would
            duplicate information in broker trade confirmations or account
            statements received by the Fund, provided that all required
            information is contained in the broker trade confirmations or
            account statements and is received by the Review Officer NO
            LATER THAN 10 days after the end of the calendar quarter.
            Please see the Review Officer for more information about this
            reporting mechanism.

II.      WHAT MUST BE INCLUDED IN YOUR QUARTERLY REPORTS?

         A. You must report all transactions in SECURITIES that: (i) you
            directly or indirectly BENEFICIALLY OWN or (ii) because of the
            transaction, you acquire direct or indirect BENEFICIAL
            OWNERSHIP. In addition, you must also report any account you
            established during the quarter in which any securities were
            held for your direct or indirect benefit.

         B. Notwithstanding Section I above, reports of individual
            SECURITIES transactions are required only if you KNEW at the
            time of the transaction, or in the ordinary course of
            fulfilling your official duties as a Trustee SHOULD HAVE
            known, that during the 15-day period immediately preceding or
            following the date of your transaction, the same SECURITY was
            purchased or sold, or was BEING CONSIDERED FOR PURCHASE OR
            SALE, by the Fund (or any series thereof). Also
            notwithstanding Section I above, you are required to report
            the opening of a securities account only if the account holds
            or held securities that are the subject of a report required
            under this paragraph B.


                                          A-1



            The "SHOULD HAVE KNOWN" standard does not:

            o imply a duty of inquiry;

            o presume  you should  have  deduced  or  extrapolated  from
              discussions  or  memoranda  dealing  with the Fund's (or a series)
              investment strategies; or

            o impute knowledge from your awareness of the Fund's (or a series)
              portfolio holdings, market considerations, or investment policies,
              objectives and restrictions.

III.     WHAT MAY BE EXCLUDED FROM YOUR QUARTERLY REPORTS?

         You are not required to detail or list the following items on your
         quarterly report:

         A. Securities accounts, as well as purchases or sales effected
            for or SECURITIES held in any account, over which you have no
            direct or indirect influence or control;

         B. Purchases you made solely with the dividend proceeds received
            in a dividend reinvestment plan or that are part of an
            automatic payroll deduction plan, where you purchased a
            SECURITY issued by your employer;

         C. Purchases effected on the exercise of rights issued by an
            issuer PRO RATA to all holders of a class of its Securities,
            as long as you acquired these rights from the issuer, and
            sales of such rights;

         D. Purchases or sales which are non-volitional, including
            purchases or sales upon the exercise of written puts or calls
            and securities sold at a broker's discretion from a margin
            account pursuant to a BONA FIDE margin call; and

        (E) Purchases or sales of any of the following securities:

            o Direct obligations of the U.S. government;

            o Bankers' acceptances, bank certificates of deposit,
              commercial paper and HIGH QUALITY SHORT-TERM DEBT
              INSTRUMENTS, including repurchase agreements; and

            o Shares issued by registered, open-end investment companies.

You may include a statement in your report that the report shall not be
construed as your admission that you have any direct or indirect BENEFICIAL
OWNERSHIP in the SECURITY included in the report.

                                          A-2




                         THE ADVISORS' INNER CIRCLE FUND
                                 THE ARBOR FUND
                              THE EXPEDITION FUNDS
                                  THE MDL FUNDS

PART B  - INTERESTED TRUSTEES AND FUND OFFICERS

I.       REQUIRED REPORTS

         A. INITIAL HOLDINGS REPORT.

            You must submit a listing of all SECURITIES you BENEFICIALLY
            OWN, as well as all of your securities accounts, as of the
            date you first become subject to this Code's reporting
            requirements. You must submit this list to the Review Officer
            within 10 days of the date you first become subject to this
            Code's reporting requirements. An Initial Holdings Report Form
            is attached as Appendix III.

         B. ANNUAL HOLDINGS REPORT.

            Each year, you must submit to the Review Officer a listing of
            all SECURITIES you BENEFICIALLY OWN, as well as all of your
            securities accounts. Your list must be current as of a date no
            more than 30 days before you submit the report. An Annual
            Holdings Report Form is attached as Appendix IV.

         C. QUARTERLY TRANSACTION AND ACCOUNT REPORTS.

            1.       Each quarter, you must report all of your SECURITIES
                     transactions effected, as well as any securities
                     accounts you established, during the quarter. You
                     must submit your report to the Review Officer NO
                     LATER THAN 10 days after the end of each calendar
                     quarter. A Quarterly Personal Securities Transactions
                     Report Form is included as Appendix II.

            2.       If you had no reportable transactions and did not
                     open any securities accounts during the quarter, you
                     are still required to submit a report. Please note on
                     your report that you had no reportable items during
                     the quarter, and return it, signed and dated.

            3.       You need not submit a quarterly report if the report
                     would duplicate information contained in broker trade
                     confirmations or account statements received by the
                     Fund, provided that all required information is
                     contained in the broker trade confirmations or
                     account statements and is received by the Review
                     Officer NO LATER THAN 10 days after the end of the
                     calendar quarter. Please see the Review Officer for
                     more information about this reporting mechanism.

                                          B-1



II.      WHAT MUST BE INCLUDED IN YOUR REPORTS?

         You must report all transactions in SECURITIES that: (i) you directly
         or indirectly BENEFICIALLY OWN; or (ii) because of the transaction, you
         acquire direct or indirect BENEFICIAL OWNERSHIP. In addition, you must
         also report all of your accounts in which any securities were held for
         your direct or indirect benefit.

III. WHAT MAY BE EXCLUDED FROM YOUR REPORTS?

         You are not required to detail or list the following items on your
         reports:

         A. Securities accounts, as well as purchases or sales effected
            for or SECURITIES held in any account, over which you have no
            direct or indirect influence or control;

         B. Purchases you made solely with the dividend proceeds received
            in a dividend reinvestment plan or that are part of an
            automatic payroll deduction plan, where you purchased a
            SECURITY issued by your employer;

         C. Purchases effected on the exercise of rights issued by an
            issuer PRO RATA to all holders of a class of its Securities,
            as long as you acquired these rights from the issuer, and
            sales of such rights;

         D. Purchases or sales which are non-volitional, including
            purchases or sales upon the exercise of written puts or calls
            and securities sold at a broker's discretion from a margin
            account pursuant to a BONA FIDE margin call; and

         E. Purchases or sales of any of the following securities:

          o Direct obligations of the U.S. government;

          o Bankers' acceptances, bank certificates of deposit, commercial
            paper and HIGH QUALITY SHORT-TERM DEBT INSTRUMENTS, including
            repurchase agreements; and

          o Shares issued by registered, open-end investment companies.

         You may include a statement in your report that the report shall not be
         construed as your admission that you have any direct or indirect
         BENEFICIAL OWNERSHIP in the SECURITY included in the report.

                                          B-2



                         THE ADVISORS' INNER CIRCLE FUND
                                 THE ARBOR FUND
                              THE EXPEDITION FUNDS
                                  THE MDL FUNDS

PART C  - NATURAL CONTROL PERSONS

I.       REQUIRED REPORTS

         A. INITIAL HOLDINGS REPORT.

            You must submit a listing of all SECURITIES you BENEFICIALLY
            OWN, as well as all of your securities accounts, as of the
            date you first become subject to this Code's reporting
            requirements. You must submit this list to the Review Officer
            within 10 days of the date you first become subject to this
            Code's reporting requirements. An Initial Holdings Report Form
            is attached as Appendix III.

         B. ANNUAL HOLDINGS REPORT.

            Each year, you must submit to the Review Officer a listing of
            all SECURITIES you BENEFICIALLY OWN, as well as all of your
            securities accounts. Your list must be current as of a date no
            more than 30 days before you submit the report. An Annual
            Holdings Report Form is attached as Appendix IV.

         C. QUARTERLY TRANSACTION AND ACCOUNT REPORTS.

            1.       Each quarter, you must report all of your SECURITIES
                     transactions effected, as well as any securities
                     accounts you established, during the quarter. You
                     must submit your report to the Review Officer NO
                     LATER THAN 10 days after the end of each calendar
                     quarter. A Quarterly Personal Securities Transactions
                     Report Form is included as Appendix II.

            2.       If you had no reportable transactions and did not
                     open any securities accounts during the quarter, you
                     are still required to submit a report. Please note on
                     your report that you had no reportable items during
                     the quarter, and return it, signed and dated.

            3.       You need not submit a quarterly report if the report
                     would duplicate information contained in broker trade
                     confirmations or account statements received by the
                     Fund, provided that all required information is
                     contained in the broker trade confirmations or
                     account statements and is received by the Review
                     Officer NO LATER THAN 10 days after the end of the
                     calendar quarter. Please see the Review Officer for
                     more information about this reporting mechanism.

                                          C-1



II.      WHAT MUST BE INCLUDED IN YOUR REPORTS?

         You must report all transactions in SECURITIES that: (i) you directly
         or indirectly BENEFICIALLY OWN; or (ii) because of the transaction, you
         acquire direct or indirect BENEFICIAL OWNERSHIP. In addition, you must
         also report all of your accounts in which any securities were held for
         your direct or indirect benefit.

III.     WHAT MAY BE EXCLUDED FROM YOUR REPORTS?

         You are not required to detail or list the following items on your
         reports:

         A. Securities accounts, as well as purchases or sales effected
            for or SECURITIES held in any account, over which you have no
            direct or indirect influence or control;

         B. Purchases you made solely with the dividend proceeds received
            in a dividend reinvestment plan or that are part of an
            automatic payroll deduction plan, where you purchased a
            SECURITY issued by your employer;

         C. Purchases effected on the exercise of rights issued by an
            issuer PRO RATA to all holders of a class of its Securities,
            as long as you acquired these rights from the issuer, and
            sales of such rights;

         D. Purchases or sales which are non-volitional, including
            purchases or sales upon the exercise of written puts or calls
            and securities sold at a broker's discretion from a margin
            account pursuant to a BONA FIDE margin call; and

         E. Purchases or sales of any of the following securities:

          o Direct obligations of the U.S. government;

          o Bankers' acceptances, bank certificates of deposit,
            commercial paper and HIGH QUALITY SHORT-TERM DEBT
            INSTRUMENTS, including repurchase agreements; and

          o Shares issued by registered, open-end investment companies.

You may include a statement in your report that the report shall not be
construed as your admission that you have any direct or indirect BENEFICIAL
OWNERSHIP in the SECURITY included in the report.

                                          C-2




                                   APPENDIX I

                         THE ADVISORS' INNER CIRCLE FUND
                                 THE ARBOR FUND
                              THE EXPEDITION FUNDS
                                  THE MDL FUNDS


DEFINITIONS

                                  GENERAL NOTE

              THE DEFINITIONS AND TERMS USED IN THIS CODE OF ETHICS ARE
              INTENDED TO MEAN THE SAME AS THEY DO UNDER THE 1940 ACT AND
              THE OTHER FEDERAL SECURITIES LAWS. IF A DEFINITION
              HEREUNDER CONFLICTS WITH THE DEFINITION IN THE 1940 ACT OR
              OTHER FEDERAL SECURITIES LAWS, OR IF A TERM USED IN THIS
              CODE IS NOT DEFINED, YOU SHOULD FOLLOW THE DEFINITIONS AND
              MEANINGS IN THE 1940 ACT OR OTHER FEDERAL SECURITIES LAWS,
              AS APPLICABLE.

ACCESS PERSON means:

          o any Trustee or officer of a Fund;

          o any employee of a Fund (or of any company in a control
            relationship to a Fund) who, in connection with his or her regular
            functions or duties, makes, participates in, or obtains
            information regarding the PURCHASE OR SALE of SECURITIES by a Fund
            or whose functions relate to the making of any recommendations
            with respect to the purchases or sales; and

          o any natural person in a CONTROL relationship to a Fund who obtains
            information concerning recommendations made to a Fund with regard
            to the PURCHASE OR SALE of securities by a Fund.

         NOTE: Persons who are ACCESS PERSONS of a Fund because of their
         position with the Fund or with that Fund's adviser or sub-adviser, will
         generally not be considered ACCESS PERSONS of another Fund, unless they
         satisfy the criteria described above with respect to that particular
         Fund, E.G., an ACCESS PERSON of one Fund covered by this joint Code is
         not automatically considered an ACCESS PERSON of another Fund covered
         by this Code.

BENEFICIAL OWNERSHIP means the same as it does under Section 16 of the
Securities Exchange Act of 1934 and Rule 16a-1(a)(2) thereunder. You should
generally consider yourself the "beneficial owner" of any securities in which
you have a direct or indirect pecuniary interest. In addition, you should
consider yourself the beneficial owner of securities held by your spouse, your
minor children, a relative who shares your home, or other persons by reason of
any contract, arrangement,

                                          I-1



understanding or relationship that provides you with sole or shared voting or
investment power.

CONTROL means the same as it does under Section 2(a)(9) of the 1940 Act. Section
2(a)(9) provides that "control" means the power to exercise a controlling
influence over the management or policies of a company, unless such power is
solely the result of an official position with such company.

Ownership of more than 25% of a company's outstanding voting securities is
presumed to give the holder of such securities control over the company. The SEC
may determine, however, that the facts and circumstances of a given situation
that may counter this presumption.

FUND OFFICERS means any person lawfully elected by the Board of Trustees and
authorized to act on behalf of the Fund. Additional information regarding the
Funds' officers may be found in each Fund's Statement of Additional Information,
respectively.

HIGH QUALITY SHORT-TERM DEBT INSTRUMENT means any instrument that has a maturity
at issuance of less than 366 days and that is rated in one of the two highest
rating categories by a nationally recognized statistical rating organization
(E.G., Moody's Investors Service).

INDEPENDENT TRUSTEE means a Trustee of the Fund who is not an "interested
person" of the Fund within the meaning of Section 2(a)(19) of the 1940 Act. As
of November 13, 2001, the Fund's INDEPENDENT TRUSTEES are:

                                            John T. Cooney
                                            Robert A. Patterson
                                            Eugene B. Peters
                                            James M. Storey
                                            George J. Sullivan, Jr.

IPO (I.E., initial public offering) means an offering of securities registered
under the Securities Act of 1933, the issuer of which, immediately before
registration, was not subject to the reporting requirements of Section 13 or
Section 15(d) of the Securities Exchange Act of 1934.

INTERESTED TRUSTEE means a Trustee of the Fund who is an "interested person" of
the Fund within the meaning of Section 2(a)(19) of the 1940 Act. As of November
13, 2001, the Fund's interested Trustees are:
                                            William M. Doran
                                            Robert A. Nesher

LIMITED OFFERING means an offering that is exempt from registration under the
Securities Act of 1933 pursuant to Section 4(2), Section 4(6), Rule 504, Rule
505 or Rule 506 (E.G., private placements).

PURCHASE OR SALE of a SECURITY includes, among other things, the writing of an
option to purchase or sell a SECURITY.


                                          I-2



SECURITY means the same as it does under Section 2(a)(36) of the 1940 Act,
except that it does not include direct obligations of the U.S. government,
bankers' acceptances, bank certificates of deposit, commercial paper, HIGH
QUALITY SHORT-TERM DEBT INSTRUMENTS, including repurchase agreements, or shares
issued by registered, open-end investment companies.

A SECURITY HELD OR TO BE ACQUIRED by the Fund means: (A) any SECURITY that
within the most recent 15 days (i) is or has been held by the Fund; or (ii) is
BEING OR HAS BEEN CONSIDERED by the Fund's adviser for purchase by the Fund; and
(B) any option to purchase or sell, and any security convertible into or
exchangeable for, any SECURITY described in (A) of this definition.

A SECURITY is BEING PURCHASED OR SOLD by the Fund from the time a purchase or
sale program has been communicated to the person who places buy and sell orders
for the Fund until the program has been fully completed or terminated.

A SECURITY is BEING CONSIDERED FOR PURCHASE by the Fund when a SECURITY is
identified as such by the investment adviser to the Fund.

                                          I-3



                                   APPENDIX II

                         THE ADVISORS' INNER CIRCLE FUND
                                 THE ARBOR FUND
                              THE EXPEDITION FUNDS
                                  THE MDL FUNDS

                QUARTERLY PERSONAL SECURITIES TRANSACTIONS REPORT

Name of Reporting Person:  ___________________________
Calendar Quarter Ended:    ___________________________
Date Report Due:           ____________________10, ___
Date Report Submitted:     ___________________________



SECURITIES TRANSACTIONS
- --------------------------------------------------------------------------------------------------------------
                                                     Principal
                  Name of Issuer      No. of     Amount, Maturity                              Name of Broker,
                       and            Shares         Date and                                   Dealer or Bank
    Date of          Title of          (if         Interest Rate       Type of                    Effecting
  Transaction        Security      applicable)    (if applicable)    Transaction     Price       Transaction
                                                                              

- --------------------------------------------------------------------------------------------------------------




- --------------------------------------------------------------------------------------------------------------




- --------------------------------------------------------------------------------------------------------------




- --------------------------------------------------------------------------------------------------------------


If you have no securities transactions to report for the quarter, please check
here. |_|

If you do not want this report to be construed as an admission that you have
beneficial  ownership of one or more securities reported above, please describe
below and indicate which securities are at issue.
- --------------------------------------------------------------------------------


SECURITIES ACCOUNTS

If you established a securities account during the quarter, please provide the
following information:



- --------------------------------------------------------------------------------------------------------------

       Name of Broker, Dealer or Bank          Date Account was Established    Name(s) on and Type of Account
                                                                         

- --------------------------------------------------------------------------------------------------------------



- --------------------------------------------------------------------------------------------------------------



- --------------------------------------------------------------------------------------------------------------



- --------------------------------------------------------------------------------------------------------------


If you did not establish a securities account during the quarter, please check
here. |_|



I CERTIFY THAT I HAVE INCLUDED ON THIS REPORT ALL SECURITIES TRANSACTIONS AND
ACCOUNTS REQUIRED TO BE REPORTED PURSUANT TO THE CODE OF ETHICS.

                                          II-1


___________________________         _____________________

Signature                                   Date

                                          II-2



                                  APPENDIX III

                         THE ADVISORS' INNER CIRCLE FUND
                                 THE ARBOR FUND
                              THE EXPEDITION FUNDS
                                  THE MDL FUNDS

                             INITIAL HOLDINGS REPORT

Name of Reporting Person:           ____________________________
Date Person Became Subject to the
Code's Reporting Requirements:      ____________________________
Information in Report Dated as of:  ____________________________ [NOTE: Date
                                                                  person became
                                                                  subject and as
                                                                  of date should
                                                                  be the same.]
Date Report Due:                    ____________________________
Date Report Submitted:              ____________________________





SECURITIES HOLDINGS
- --------------------------------------------------------------------------------------------------------------
     Name of Issuer and           No. of Shares                Principal Amount, Maturity Date and
      Title of Security          (if applicable)                  Interest Rate (if applicable)
                                                          
- --------------------------------------------------------------------------------------------------------------



- --------------------------------------------------------------------------------------------------------------



- --------------------------------------------------------------------------------------------------------------



- --------------------------------------------------------------------------------------------------------------

If you have no securities holdings to report, please check here. |_|

If you do not want this report to be construed as an admission that you have
beneficial  ownership of one or more securities reported above, please describe
below and indicate which securities are at issue.

- --------------------------------------------------------------------------------



SECURITIES ACCOUNTS



If you established a securities account during the quarter, please provide the
following information:
- --------------------------------------------------------------------------------------------------------------

           Name of Broker, Dealer or Bank                         Name(s) on and Type of Account
                                                               
- --------------------------------------------------------------------------------------------------------------



- --------------------------------------------------------------------------------------------------------------



- --------------------------------------------------------------------------------------------------------------



- --------------------------------------------------------------------------------------------------------------

If you have no securities accounts to report, please check here. |_|




I CERTIFY THAT I HAVE INCLUDED ON THIS REPORT ALL SECURITIES HOLDINGS AND
ACCOUNTS REQUIRED TO BE REPORTED PURSUANT TO THE CODE OF ETHICS.

                                          III-1


- -----------------------------               -----------------------
Signature                                            Date
                                          III-2




                                   APPENDIX IV

                         THE ADVISORS' INNER CIRCLE FUND
                                 THE ARBOR FUND
                              THE EXPEDITION FUNDS
                                  THE MDL FUNDS

                             ANNUAL HOLDINGS REPORT

Name of Reporting Person:           ________________________
Information in Report Dated as of:  ________________________  [NOTE: Information
                                                              should be dated no
                                                              more than 30 days
                                                              before report is
                                                              submitted.]
Date Report Due:                    ________________________
Date Report Submitted:              ________________________
Calendar Year Ended: December 31, ____





SECURITIES HOLDINGS
- --------------------------------------------------------------------------------------------------------------
     Name of Issuer and           No. of Shares                Principal Amount, Maturity Date and
      Title of Security          (if applicable)                  Interest Rate (if applicable)
                                                         
- --------------------------------------------------------------------------------------------------------------



- --------------------------------------------------------------------------------------------------------------



- --------------------------------------------------------------------------------------------------------------



- --------------------------------------------------------------------------------------------------------------

If you have no securities holdings to report, please check here. |_|

If you do not want this report to be construed as an admission that you have
beneficial ownership of one or more  securities reported above, please describe
below and indicate which securities are at issue.
- --------------------------------------------------------------------------------



SECURITIES ACCOUNTS



If you established a securities account during the quarter, please provide the
following information:
- ------------------------------------------------------------------------------------------------------

           Name of Broker, Dealer or Bank                         Name(s) on and Type of Account
                                                               
- ------------------------------------------------------------------------------------------------------



- ------------------------------------------------------------------------------------------------------



- ------------------------------------------------------------------------------------------------------



- ------------------------------------------------------------------------------------------------------


If you have no securities accounts to report, please check here. |_|




I CERTIFY THAT I HAVE INCLUDED ON THIS REPORT ALL SECURITIES HOLDINGS AND
ACCOUNTS REQUIRED TO BE REPORTED PURSUANT TO THE CODE OF ETHICS.

                                          IV-1


- ----------------------------                -----------------------
Signature                                            Date

                                          IV-2




                                   APPENDIX V

                         THE ADVISORS' INNER CIRCLE FUND
                                 THE ARBOR FUND
                              THE EXPEDITION FUNDS
                                  THE MDL FUNDS

                            COMPLIANCE CERTIFICATION
- ------------------------------------------------------------------------

                              INITIAL CERTIFICATION

I CERTIFY THAT I:         (I)   HAVE RECEIVED, READ AND REVIEWED THE FUND'S CODE
                                OF ETHICS;
                          (II)  UNDERSTAND THE POLICIES AND PROCEDURES IN
                                THE CODE;
                          (III) RECOGNIZE THAT I AM SUBJECT TO SUCH POLICIES
                                AND PROCEDURES;
                          (IV)  UNDERSTAND THE PENALTIES FOR NON-COMPLIANCE;
                          (V)   WILL FULLY COMPLY WITH THE FUND'S CODE OF
                                ETHICS; AND
                          (VI)  HAVE FULLY AND ACCURATELY COMPLETED THIS
                                 CERTIFICATE.

Signature:
Name:
                          _______________________________________(Please print)
Date Submitted:
Date Due:                 _______________________________________
- --------------------------------------------------------------------------------

                              ANNUAL CERTIFICATION

I CERTIFY THAT I:         (I)   HAVE RECEIVED, READ AND REVIEWED THE FUND'S CODE
                                OF ETHICS;
                          (II)  UNDERSTAND THE POLICIES AND PROCEDURES IN THE
                                CODE;
                          (III) RECOGNIZE THAT I AM SUBJECT TO SUCH POLICIES
                                AND PROCEDURES;
                          (IV)  UNDERSTAND THE PENALTIES FOR NON-COMPLIANCE;
                          (V)   HAVE COMPLIED WITH THE FUND'S CODE OF ETHICS
                                AND ANY APPLICABLE REPORTING REQUIREMENTS
                                DURING THIS PAST YEAR;
                          (VI)  HAVE FULLY DISCLOSED ANY EXCEPTIONS TO MY
                                COMPLIANCE WITH THE CODE BELOW;
                          (VII) WILL FULLY COMPLY WITH THE FUND'S CODE OF
                                ETHICS; AND
                          (VI)  HAVE FULLY AND ACCURATELY COMPLETED THIS
                                 CERTIFICATE.

EXCEPTION(S):


Signature:
Name:                      _______________________________________
Date Submitted:
Date Due:                  _______________________________________


                                          V-1