Exhibit 99.CODE of ETHICS
ONE GROUP(R) MUTUAL FUNDS
ONE GROUP(R) INVESTMENT TRUST
CODE OF ETHICS FOR
PRESIDENT AND TREASURER
This Code of Ethics applies to the President and Treasurer ("Senior
Financial Officers") of One Group Mutual Funds and One Group Investment Trust
(collectively, the "Trust"). Its purpose is to promote honest and ethical
conduct and compliance with all applicable laws, rules and regulations,
particularly as related to the maintenance of the Trust's financial records and
the preparation of financial statements filed with the Securities and Exchange
Commission.
1. Each Senior Financial Officer shall carry out his or her responsibilities
honestly and with integrity, maintaining and promoting high standards of
ethical conduct, while exercising at all times his or her independent
judgement.
2. Senior Financial Officers are responsible for full, fair, accurate, timely
and understandable disclosure in the periodic reports required to be filed
by the Trust with the Securities and Exchange Commission and in other
public communications made by the Trust. Accordingly, it is the
responsibility of each Senior Financial Officer promptly to bring to the
attention of the Chief Legal Officer any material information of which he
or she may become aware that affects the disclosures made by the Trust in
its public filings or otherwise assist the appropriate personnel in
fulfilling their responsibilities as specified in the Trust's policies
related to financial reporting and disclosure, and internal controls.
3. Each Senior Financial Officer must at all times seek to provide information
to the Trust's service providers (e.g., investment adviser, administrator,
outside auditor, independent counsel, and custodian) that is accurate,
complete, objective, relevant, timely and understandable.
4. Each Senior Financial Officer shall promptly bring to the attention of the
Chief Legal Officer any information he or she may have concerning (a)
significant deficiencies in the design or operation of internal controls
which could adversely affect the Trust's ability to record, process,
summarize and report financial data or (b) any fraud, whether or not
material, that involves personnel who have a significant role in the
Trust's financial reporting, disclosures or internal controls.
5. Each Senior Financial Officer shall promptly bring to the attention of the
Chief Legal Officer any information he or she may have concerning any
actual or apparent conflicts of interest between personal and professional
relationships, involving the Senior Financial Officers or other personnel
who have a significant role in the Trust's financial reporting, disclosures
or internal controls.
6. Each Senior Financial Officer must comply with the securities or other
laws, rules or regulations applicable to the Trust and the operation of its
business. Each Senior Financial Officer shall promptly bring to the
attention of the Chief Legal Officer any information concerning evidence of
a material violation of an applicable United States federal or state
securities laws or a material breach of fiduciary duty arising under United
States or state law, or a similar material violation of any United States
or state law by the Trust (or any officer, director, employee, or agent of
the Trust ("Material Violation").
7. Each Senior Financial Officer must at all times act in good faith and with
due care, competence and diligence, without misrepresenting material facts
or allowing his or her independent judgment to be subordinated. Each Senior
Financial Officer must conduct the affairs of the Trust in a responsible
manner, consistent with this Code of Ethics. Each Senior Financial Officer
shall promptly report to the Chief Legal Officer any violation or suspected
violation of this Code.
8. Each Senior Financial Officer must respect and protect the confidentiality
of information acquired in the course of his or her professional duties,
except when authorized by the Trust to disclose such information or where
such disclosure is otherwise legally mandated. Each Senior Financial
Officer may not use confidential information acquired in the course of
their work for personal advantage.
9. The Trust's Chief Legal Officer and Qualified Legal Compliance Committee
(the "QLCC") shall interpret and apply this Code of Ethics. The Chief Legal
Officer shall investigate all reports made under this Code of Ethics and
determine what, if any, actions are appropriate. The Chief Legal Officer
shall report all reports made under this Code of Ethics to the QLCC on a
quarterly basis that are not required to be promptly reported to the QLCC
pursuant to the next sentence. In addition, following appropriate
investigation and analysis by the Chief Legal Officer, the Chief Legal
Officer shall promptly report the following to the QLCC: (a) any violations
of this Code of Ethics or (b) any Material Violations. Requests for legal
advice from a Senior Financial Officer to the Chief Legal Officer shall not
be considered a report under this Code of Ethics unless the Senior
Financial Officer has indicated to the Chief Legal Officer that he is
making a report under this Code of Ethics. The reporting obligation of the
Chief Legal Officer under this Code of Ethics is independent of any
separate reporting obligation that the Chief Legal Officer may have under
the Procedures of the QLCC.
The QLCC shall make such investigations and take such other actions in
accordance with the Procedures of the QLCC. If, in accordance with the
Procedures of the QLCC, the QLCC concurs that a material Code of Ethics
violation has occurred, it will inform and make a recommendation to the
Trust's Board of Trustees, which will consider appropriate action, which
may include review of, and appropriate modifications to, applicable
policies and procedures; notification to appropriate personnel of the
Trust's investment adviser, principal underwriter, administrator, transfer
agent, custodian or
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accountant or their boards; or removal of the applicable Senior Financial
Officer as an Officer of the Trust.
As adopted: November 13, 2003
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