ONE GROUP(R)
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 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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