UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
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FORM N-CSR
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CERTIFIED SHAREHOLDER REPORT OF REGISTERED MANAGEMENT
INVESTMENT COMPANIES
Investment Company Act file number 811-8689
The Nevis Fund, Inc.
(Exact name of registrant as specified in charter)
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1119 St. Paul Street
Baltimore, MD 21202
(Address of principal executive offices) (Zip code)
Forum Shareholder Services, LLC
P.O. Box 446
Portland, Maine 04112-0446
(Name and address of agent for service)
Registrant's telephone number, including area code: 1-877-44-NEVIS
Date of fiscal year end: May 31, 2004
Date of reporting period: November 30, 2003
Item 1. Reports to Stockholders.
[The Nevis Fund Logo Omitted]
SEMI-ANNUAL REPORT TO SHAREHOLDERS
NOVEMBER 30, 2003
(UNAUDITED)
TABLE OF CONTENTS
Letter to Shareholders....................................................... 1
Manager's Discussion and Analysis............................................ 2
Statement of Net Assets...................................................... 3
Statement of Operations...................................................... 5
Statements of Changes in Net Assets.......................................... 6
Financial Highlights......................................................... 7
Notes to Financial Statements................................................ 8
<page>
LETTER TO SHAREHOLDERS THE NEVIS FUND, INC.
December 30, 2003
Dear Fellow Shareholder:
The Nevis Fund's Net Asset Value ("NAV") increased from $9.85 per share on May
31, 2003 to $13.07 per share on November 30, 2003, a gain of 32.69%. This return
compares to an increase of 24.65% for the Russell 2000 Index, an increase of
23.14% for the NASDAQ Composite Index and an increase of 10.80% for the S&P 500
Index.
The U.S. economic recovery appears to be gaining momentum. Our field visits with
company managements confirm that business activity is accelerating, albeit at a
modest pace. Managements cite clear evidence that buyers have greater
authorization to purchase goods and services today than they did a year ago.
Indeed, on the whole our companies are experiencing a steady increase in
sequential revenues and a corresponding increase in backlogs. This is obviously
good news and bodes well for the future earnings streams of our portfolio
companies. Companies have spent much of the last three years streamlining their
expenses and cutting costs. We expect that our companies could possibly
experience disproportionately strong earnings growth relative to their revenue
growth because their expense structures contain varying degrees of operating
leverage.
We have seen firsthand the impact this recession has had on inventories. The
dramatic slowdown in capital equipment purchases over the last two years has
enabled purchasing managers to buy goods on a just-in-time basis. This works to
the advantage of the buyers as they are able to maximize their capital
utilization and cash flow. At the same time, however, inventories by definition
are minimized because demand does not exceed supply. This condition leads us to
speculate about one potential economic scenario that could materialize--that the
economy grows with artificial and perhaps unsustainable rapidity for a period of
time as manufacturing inventories get replenished. While we are not projecting
this outcome, we see signs that it could occur. And should it occur, we will try
to determine the real growth rates of our companies while at the same time,
watching closely the valuations accorded them.
We have seen some stocks perform extremely well this year over very short
periods of time. We expect to continue to see some sharp increases in value as
this market recovers from its 2002 lows. We will use these moves to maximize our
time-weighted returns and to re-invest in more attractively valued companies.
Our purchase and subsequent trimming of Avid Technologies this year is a good
example of this phenomenon. We purchased Avid in April for $24.52 per share.
Given our projected revenue and earnings growth rates, we had an initial price
target of $50 per share within 18 months of our purchase. The stock surpassed
our target within six months and we concluded that we should sell a portion of
our holding. Avid's two recent earnings reports have exceeded both Wall Street's
and our own expectations, so we are not altogether surprised by its strong stock
performance. However, we are mindful that Avid's share price is much more
expensive today by any conventional form of measurement and therefore, leaves
less margin for error in upcoming earnings reports. We are confident that Avid
will continue its strong growth, but we will likely also continue to use it as a
source of cash going forward to fund new ideas that in our opinion, contain more
attractive risk reward characteristics.
We note that through the first six months of this fiscal year we have purchased
ten new holdings and sold nine in their entirety. This is a higher level of
portfolio turnover than we have experienced in some past years and is a direct
result of our finding a greater number of what we believe to be exciting
investment opportunities. The Fund's turnover may rise in the short term if
valuations, in our opinion, warrant realizing gains.
Thank you for your patience and support.
Sincerely,
/s/ David R. Wilmerding, III /s/ Jon C. Baker
- ---------------------------- ----------------
David R. Wilmerding, III Jon C. Baker
1
<page>
MANAGER'S DISCUSSION AND ANALYSIS OF FUND PERFORMANCE
For the six months ended November 30, 2003
The Nevis Fund started fiscal year 2003 with 24 equity holdings and held 25 as
of the semi-annual period ended November 30, 2003. During the course of the six
months we made purchases of the following ten new holdings: Advanced Digital
Information, Alvarion, Aspect Communications, Aspen Technology, Bentley
Pharmaceuticals, Computer Network Technology, KVH Industries, Opsware,
Scientific Games, and Stellent. Additionally, we added to our positions in
ActivCard, Ditech Communications, and Imax.
During this six month period we sold the following nine holdings in their
entirety: Alvarion, Clarus, Clear Channel, Crown Holdings, Ditech
Communications, Microstrategy, Parametric Technology, Tibco and Trimble
Navigation. Additionally, we sold partial amounts from the positions in
companies that we either held in the fund during the six months or purchased
during the six months and continue to hold in the fund, including: American
Tower, Avid Technology, Connetics, Providian Financial, Tweeter Home
Entertainment Group and WebMD.
The Nevis Fund's Net Asset Value (NAV) increased from $9.85 per share on May
31, 2003 to $13.07 per share on November 30, 2003, an increase of 32.69%. This
return compares to an increase of 24.65% for the for the Russell 2000 Index, an
increase of 23.14% for the NASDAQ Composite Index and an increase of 10.80% for
the S&P 500 Index.
The Nevis Fund had a net realized and unrealized gain of approximately
$9,909,000 for the six month period from May 31, 2003 through November 30, 2003.
The largest single positive contribution to the Fund's performance, as measured
on the basis of realized and unrealized gains and losses over the six month
period from May 31, 2003 through November 30, 2003, came from Primus which
increased approximately $2,534,000 over this period. The top five companies
contributing positively to the Fund's performance over this six month period, as
measured on the basis of realized and unrealized gains, were Primus, Scientific
Games, Aspect Telecom, Dick's Sporting Goods and Armor Holdings. These five
holdings accounted for approximately $5,834,000 of the Fund's total realized and
unrealized gains. The largest single negative contribution to the Fund's
performance, as measured on the basis of realized and unrealized gains and
losses over the six month period from May 31, 2003 through November 30, 2003,
came from Bentley Pharmaceuticals, Inc., which represented approximately
$385,000 of the Fund's total realized and unrealized losses for the period. The
top five companies contributing negatively to the Fund's performance over this
six month period, as measured on the basis of realized and unrealized gains,
were Bentley Pharmaceuticals, Inc., Activcard, Aspen Technology, Opsware and
Clarus Corp. These five holdings accounted for approximately $932,000 of the
Fund's total realized and unrealized losses for the period.
THE FUND'S CONCENTRATED POSITIONS OFTEN TRANSLATE INTO HIGHER INDUSTRY
WEIGHTINGS THAN INDICES TYPICALLY HAVE, THEREBY RESULTING IN RETURNS THAT
DEVIATE FROM THE INDICES.
As of November 30, 2003, the Fund had $30,003 in unrealized losses (000) and
$72,579 in accumulated tax loss carry forwards (000).
2
<page>
STATEMENT OF NET ASSETS THE NEVIS FUND, INC.
November 30, 2003 (Unaudited)
Market
Value
Shares (000)
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COMMON STOCK 97.7%
AEROSPACE & DEFENSE 4.3%
Armor Holdings* 68,700 $ 1,666
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BIOLOGICAL PRODUCTS 4.9%
Connetics* 106,550 1,881
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COMMUNICATION SERVICES 3.5%
American Tower, Cl A* 118,978 1,354
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COMPUTERS & SERVICES 8.0%
ActivCard* 206,121 1,791
Advanced Digital Information* 84,948 1,289
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3,080
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DRUGS 2.7%
Bentley Pharmaceuticals* 85,368 1,046
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ELECTRONIC COMPONENTS 4.4%
Vicor* 147,975 1,702
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ENTERTAINMENT 10.2%
Avid Technology* 7,967 421
Imax* 170,000 1,346
Scientific Games, Cl A* 130,979 2,130
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3,897
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FINANCIAL SERVICES 3.0%
Providian Financial* 100,072 1,131
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MEASURING DEVICES 13.6%
Flir Systems* 50,424 1,738
Ionics* 62,526 2,010
KVH Industries* 47,350 1,493
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5,241
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RETAIL 8.2%
Dick's Sporting Goods* 36,022 1,894
Tweeter Home Entertainment Group* 150,000 1,254
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3,148
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SERVICES-BUSINESS SERVICES 6.4%
Opsware* 180,078 1,386
Wind River Systems* 163,248 1,063
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2,449
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SERVICES-COMPUTER INTEGRATED SYSTEMS DESIGN 2.6%
Computer Network Technology* 99,937 994
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SERVICES-COMPUTER PROCESSING & DATA PREPARATION 3.8%
WebMD* 158,996 1,455
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SERVICES-COMPUTER PROGRAMMING SERVICES 10.7%
Primus Knowledge Solutions* 704,000 3,133
Stellent* 100,000 987
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4,120
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The accompanying notes are an integral part of the financial statements.
3
<page>
STATEMENT OF NET ASSETS THE NEVIS FUND, INC.
November 30, 2003 (Concluded) (Unaudited)
Market
Value
Shares (000)
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SERVICES-PREPACKAGED SOFTWARE 7.6%
Aspect Communications* 131,425 $ 1,935
Aspen Technology* 128,467 988
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2,923
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WHOLESALE 3.8%
Central Garden & Pet* 55,528 1,472
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TOTAL COMMON STOCK
(Cost $67,562) 37,559
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CASH EQUIVALENT 2.1%
SEI Daily Income Trust 797,204 797
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TOTAL CASH EQUIVALENT
(Cost $797) 797
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TOTAL INVESTMENTS 99.8%
(Cost $68,359) 38,356
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OTHER ASSETS AND LIABILITIES:
Investment Advisory Fee Payable (45)
Other Assets and Liabilities, Net 136
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TOTAL OTHER ASSETS AND LIABILITIES 0.2% 91
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TOTAL NET ASSETS 100.0% $ 38,447
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NET ASSETS:
Paid in Capital (unlimited authorization-- no par value)
based on 2,941,149 outstanding shares of beneficial interest $ 165,879
Accumulated net investment loss (244)
Accumulated net realized loss on investments (97,185)
Net unrealized depreciation on investments (30,003)
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TOTAL NET ASSETS 100.0% $ 38,447
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Net Asset Value, Offering and Redemption Price Per Share $ 13.07
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* NON-INCOME PRODUCING SECURITY
CL-- CLASS
The accompanying notes are an integral part of the financial statements.
4
<page>
STATEMENT OF OPERATIONS (000) THE NEVIS FUND, INC.
For the six month period ended November 30, 2003 (Unaudited)
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INVESTMENT INCOME:
Interest Income $ 3
Dividend Income 2
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Total Investment Income 5
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EXPENSES:
Investment Advisory Fees (See Note 4) 254
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Total Expenses 254
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Net Investment Loss (249)
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Net Realized Loss on Investments (5,195)
Net Change in Unrealized Appreciation on Investments 15,104
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Net Realized and Unrealized Gain on Investments 9,909
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Net Increase in Net Assets Resulting from Operations $ 9,660
====================================================================================================================================
The accompanying notes are an integral part of the financial statements.
5
<page>
STATEMENTS OF CHANGES IN NET ASSETS (000) THE NEVIS FUND, INC.
For the six month period ended November 30, 2003 (Unaudited) and the year ended May 31, 2003
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6/1/03 6/1/02
to to
11/30/03 5/31/03
------------ ------------
INVESTMENT ACTIVITIES:
Net Investment Loss $ (249) $ (361)
Net Realized Loss on Investments (5,195) (43,396)
Net Change in Unrealized Appreciation/(Depreciation) on Investments 15,104 41,428
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Net Increase(Decrease) in Net Assets Resulting From Operations 9,660 (2,329)
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SHARE TRANSACTIONS:
Proceeds from Shares Issued 2,198 3,998
Redemption Fees (See Note 6) 12 7
Cost of Shares Repurchased (5,071) (6,660)
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Decrease in Net Assets from Capital Share Transactions (2,861) (2,655)
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TOTAL INCREASE (DECREASE) IN NET ASSETS 6,799 (4,984)
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NET ASSETS:
Beginning of Period 31,648 36,632
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NET ASSETS:
End of Period (including accumulated net investment loss/undistributed
net investment income of $(244) and $5, respectively) $38,447 $ 31,648
====================================================================================================================================
CAPITAL SHARE TRANSACTIONS:
Shares Issued 188 523
Shares Redeemed (458) (902)
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NET DECREASE IN SHARES FROM CAPITAL SHARE TRANSACTIONS (270) (379)
====================================================================================================================================
The accompanying notes are an integral part of the financial statements.
6
<page>
FINANCIAL HIGHLIGHTS THE NEVIS FUND, INC.
For a Share Outstanding for the six month period ended November 30, 2003
(Unaudited), and for the periods ended May 31,
Realized Ratio
Net and Net Net of Net
Asset Unrealized Distributions Asset Assets Ratio Investment
Value Net Gains (Losses) From Value End of Expenses Loss Portfolio
Beginning Investment on Capital End Total of Period to Average to Average Turnover
of Period Loss Securities Gains of Period Return+ (000) Net Assets Net Assets Rate
====================================================================================================================================
2003*++ $ 9.85 $(0.08) $ 3.30 $ -- $13.07 32.69% $ 38,447 1.50% (1.47)% 36.41%
2003 10.20 (0.11) (0.24) -- 9.85 (3.43) 31,648 1.50 (1.43) 51.24
2002 18.62 (0.32) (8.10) -- 10.20 (45.22) 36,632 1.50 (1.33) 26.20
2001 30.98 (0.31) (12.05) -- 18.62 (39.90) 80,011 1.50 (1.45) 21.86
2000 19.01 (0.19) 14.81(2) (2.65) 30.98 77.91*** 197,497 1.50 (1.24) 56.50
1999(1) 10.00 (0.01) 9.02 -- 19.01 90.10*** 9,975 1.50** (1.03)** 251.60
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AMOUNTS DESIGNATED AS "--" ARE EITHER $0 OR ROUND TO $0.
*FOR THE SIX MONTH PERIOD ENDED NOVEMBER 30, 2003. ALL RATIOS FOR THE PERIOD
HAVE BEEN ANNUALIZED.
**ANNUALIZED
***THE FUND BENEFITED SUBSTANTIALLY FROM FIRST-DAY REALIZED AND UNREALIZED
GAINS FROM INITIAL PUBLIC OFFERINGS DURING THESE PERIODS. THESE GAINS WERE
PARTICULARLY NOTEWORTHY GIVEN THE FUND'S RELATIVELY SMALL ASSET BASE DURING
PORTIONS OF THESE PERIODS. IT IS UNLIKELY THAT THE FUND WILL BENEFIT TO THE
SAME EXTENT FROM THESE TYPES OF GAINS IN THE FUTURE, ESPECIALLY IF FUND
ASSETS REMAIN AT CURRENT LEVELS OR IF THEY INCREASE.
+RETURNS ARE FOR THE PERIOD INDICATED AND HAVE NOT BEEN ANNUALIZED. RETURNS
DO NOT REFLECT THE DEDUCTION OF TAXES THAT A SHAREHOLDER WOULD PAY ON FUND
DISTRIBUTIONS OR THE REDEMPTION OF FUND SHARES.
++PER SHARE DATA CALCULATED USING AVERAGE SHARES OUTSTANDING METHOD.
(1)THE NEVIS FUND, INC. COMMENCED OPERATIONS ON JUNE 29, 1998.
(2)THE AMOUNT SHOWN FOR THE YEAR ENDED MAY 31, 2000 FOR A SHARE OUTSTANDING
THROUGHOUT THE PERIOD DOES NOT ACCORD WITH THE AGGREGATE NET GAINS ON
INVESTMENTS FOR THAT PERIOD BECAUSE OF THE SALES AND REPURCHASES OF FUND
SHARES IN RELATION TO FLUCTUATING MARKET VALUE OF THE INVESTMENTS OF THE
FUND.
The accompanying notes are an integral part of the financial statements.
7
<page>
NOTES TO FINANCIAL STATEMENTS THE NEVIS FUND, INC.
November 30, 2003 (Unaudited)
1. ORGANIZATION:
THE NEVIS FUND, INC. (the "Fund") was incorporated in Maryland on February 20,
1998. The Fund is registered under the Investment Company Act of 1940, as
amended, as a non-diversified open-end management investment company. The Fund's
prospectus provides a description of the Fund's investment goals and strategies.
2. SIGNIFICANT ACCOUNTING POLICIES:
The following is a summary of the significant accounting policies followed by
the Fund.
USE OF ESTIMATES -- The preparation of financial statements in conformity
with accounting principles generally accepted in the United States, requires
management to make estimates and assumptions that affect the reported amount of
assets and liabilities and disclosure of contingent assets and liabilities at
the date of the financial statements and the reported amounts of revenues and
expenses during the reporting period. Actual results could differ from those
estimates.
SECURITY VALUATION -- Securities listed on a securities exchange, and for
which quotations are readily available, are valued at the last quoted sale price
on the principal exchange or market (foreign or domestic) on which they are
traded on valuation date, or, if there is no such reported sale on the valuation
date, at the most recent quoted bid price. Securities that are quoted on the
NASDAQ national market system are valued at the official closing price. Short
term investments that have remaining maturities of sixty days or less at time of
purchase may be valued at amortized cost, which approximates market value. The
value of other assets and securities for which no quotations are readily
available is determined in good faith at fair value following procedures
approved by the Board of Directors.
FEDERAL INCOME TAXES -- It is the Fund's intention to continue to qualify as
a regulated investment company. The Fund's policy is to comply with the
requirements of Subchapter M of the Internal Revenue Code and to distribute all
of its taxable income and net capital gains to its shareholders. Accordingly, no
provision for federal income taxes is required.
SECURITY TRANSACTIONS AND RELATED INCOME -- Security transactions are
accounted for on the date the security is purchased or sold (trade date). Costs
used in determining realized gains and losses on the sales of investment
securities are based on the specific identification method. Interest income is
recognized on the accrual basis. Dividend income is recorded on the ex-date.
DIVIDENDS AND DISTRIBUTIONS TO SHAREHOLDERS -- Dividends from net investment
income are declared and paid to shareholders annually. Any net realized capital
gains are distributed to shareholders at least annually.
3. TRANSACTIONS WITH AFFILIATES:
Certain officers of the Fund are also officers of SEI Investment Global Funds
Services (the "Administrator") and/or SEI Investments Distribution Co. (the
"Distributor"). Such officers are paid no fees by the Fund for serving as
officers of the Trust.
4. INVESTMENT MANAGEMENT ARRANGEMENTS:
The Fund and Nevis Capital Management LLC (the "Adviser") are parties to an
Investment Management Agreement under which the Adviser receives an annual fee
equal to 1.50% of the average daily net assets of the Fund. Pursuant to its
Investment Management Agreement with the Fund, the Adviser has agreed to bear
all ordinary expenses incurred by the Fund in the conduct of its operations. The
Fund will bear any extraordinary expenses incurred in the course of its
business.
5. ADMINISTRATION, TRANSFER AGENCY AND SERVICES, CUSTODIAN AND DISTRIBUTION
AGREEMENTS:
As discussed above, the Adviser has agreed to bear all ordinary expenses
incurred in the conduct of the Fund's operations. This includes the following
contractual relationships:
The Fund and the Administrator are parties to an Administration Agreement under
which the Administrator provides administrative services for an annual fee,
computed daily and paid monthly, at the annual rate of 0.12% of the first $100
million of the average daily net assets of the Fund, 0.10% of the next $100
million of such assets, and 0.08% of such assets in excess of $200 million
subject to a minimum annual fee of $120,000. For the six month period ended
November 30, 2003, the Administrator received $62,467.
Forum Shareholder Services, LLC (the "Transfer Agent") serves as the transfer
agent and dividend disbursing agent for the Fund under a Transfer Agency and
Services Agreement with the Fund.
The Fund and the Distributor are parties to a Distribution Agreement. For its
services, the Distributor received $92 for the six month period ended November
30, 2003. Wachovia Bank, N.A. serves as custodian (the "Custodian") for the
Fund.
8
<page>
NOTES TO FINANCIAL STATEMENTS (CONCLUDED) THE NEVIS FUND, INC.
November 30, 2003 (Unaudited)
6. REDEMPTION FEES:
The Fund imposes a redemption fee equal to 2% on shares redeemed within 180 days
of their purchase. The redemption fee is intended to limit short-term trading in
the Fund. Any proceeds from the fees will be credited to the assets of the Fund.
For the six month period ended November 30, 2003, redemption fees in the amount
of $12,083 were retained by the Fund.
7. INVESTMENT TRANSACTIONS:
The cost of security purchases and the proceeds from security sales, other than
short-term investments, for the six month period ended November 30, 2003 were as
follows (000):
Purchases
Other ................................. $12,083
Sales
Other ................................. $15,566
8. FEDERAL TAX INFORMATION:
Dividends from net investment income and distributions from net realized capital
gains are determined in accordance with U.S. Federal income tax regulations,
which may differ from those amounts determined under accounting principles
generally accepted in the United States of America. These book/tax differences
are either temporary or permanent in nature.
For Federal income tax purposes, capital loss carryforwards may be carried
forward and applied against future capital gains. As of May 31, 2003, the Fund
had the following capital loss carryforwards:
Expires Amount (000)
--------- --------------
2009 $15,922
2010 20,955
2011 35,702
At November 30, 2003, the total cost of securities and the net realized gains or
losses on securities sold for federal income tax purposes were not materially
different from amounts reported for financial reporting purposes. The aggregate
gross unrealized appreciation and depreciation for securities held by the Fund
at November 30, 2003, is as follows (000):
Federal Tax Cost......................... $ 68,359
=========
Aggregate gross unrealized
appreciation ......................... 8,646
Aggregate gross unrealized
depreciation ......................... (38,649)
---------
Net unrealized depreciation ............ $(30,003)
=========
9. CONCENTRATION/RISK:
The Fund is non-diversified, which means that it may invest in the securities of
relatively few companies. As a result, the Fund may be more susceptible to a
single adverse economic or regulatory occurrence affecting one or more of these
companies and may experience increased volatility due to its investments in
those securities.
9
<page>
INVESTMENT ADVISER
Nevis Capital Management LLC
1119 St. Paul Street
Baltimore, MD 21202
ADMINISTRATOR
SEI Investments Global Funds Services
One Freedom Valley Drive
Oaks, PA 19456
DIRECTORS
Joseph Hardiman
Bailey Morris-Eck
Charles Noell
Jon Baker
David Wilmerding, III
DISTRIBUTOR
SEI Investments Distribution Co.
One Freedom Valley Drive
Oaks, PA 19456
LEGAL COUNSEL
Morgan, Lewis & Bockius LLP
1701 Market Street
Philadelphia, PA 19103
INDEPENDENT PUBLIC ACCOUNTANTS
KPMG LLP
1601 Market Street
Philadelphia, PA 19103-2499
NEV-SA-001-0300
Item 2. Code of Ethics.
The registrant has adopted a code of ethics that applies to the registrant's
principal executive officer, the principal financial officer, controller or
principal accounting officer, and any person who performs a similar function.
Item 3. Audit Committee Financial Expert.
(a)(1) The registrant's board of trustees has determined that the registrant has
at least one audit committee financial expert serving on the audit committee.
(a)(2) The audit committee has not selected a financial expert as defined in
Form N-CSR Item 3(a)(2).
Item 4. Principal Accountant Fees and Services.
Not applicable - only effective for annual reports for periods ending on or
after December 15, 2003.
Item 5. Audit Committee of Listed Registrants.
Not applicable.
Item 6. (Reserved)
Item 7. Disclosure of Proxy Voting Policies and Procedures for Closed-End
Management Investment Companies.
Not applicable.
Item 8. Purchasers of Equity Securities byClosed-End Management Company and
Affiliated Purchasers.
Not applicable.
Item 9. Controls and Procedures.
(a) The certifying officers, whose certifications are included herewith, have
evaluated the registrant's disclosure controls and procedures within 90 days of
the filing date of this report. In their opinion, based on their evaluation, the
registrant's disclosure controls and procedures are adequately designed, and are
operating effectively to ensure, that information required to be disclosed by
the registrant in the reports it files or submits under the Securities Exchange
Act of 1934 is recorded, processed, summarized and reported within the time
periods specified in the Securities and Exchange Commission's rules and forms.
(b) There were no significant changes in the registrant's internal control over
financial reporting that occurred during the registrant's last fiscal half-year
that has materially affected, or is reasonably likely to materially affect, the
registrants internal control over financial reporting.
Items 10. Exhibits.
(a)(1) Code of Ethics attached hereto.
(a)(2) A separate certification for the principal executive officer and the
principal financial officer of the registrant as required by Rule 30a-2(a) under
the Investment Company Act of 1940, as amended (17 CFR 270.30a-2(a)), are filed
herewith.
(b) Officer certifications as required by Rule 30a-2(b) under the Investment
Company Act of 1940, as amended (17 CFR 270.30a-2(b)) also accompany this filing
as an Exhibit.
- --------------------------------------------------------------------------------
SIGNATURES
Pursuant to the requirements of the securities Exchange Act of 1934 and the
Investment Company Act of 1940, the registrant has duly caused this report to be
signed on its behalf by the undersigned, thereunto duly authorized.
(Registrant) The Nevis Fund, Inc.
By (Signature and Title)* /s/ David R. Wilmerding, III
----------------------------
David R. Wilmerding, III
Chief Executive Officer
Date: February 4, 2004
Pursuant to the requirements of the Securities Exchange Act of 1934 and the
Investment Company Act of 1940, this report has been signed below by the
following persons on behalf of the registrant and in the capacities and on the
dates indicated.
By (Signature and Title)* /s/ David R. Wilmerding, III
-----------------------------
David R. Wilmerding, III
Chief Executive Officer
Date: February 4, 2004
By (Signature and Title)* /s/ Peter Golden
----------------------
Peter Golden
Chief Financial Officer
Date: February 4, 2004
* Print the name and title of each signing officer under his or her signature.