EX-99.CODE

                                 CODE OF ETHICS
                                       FOR
                             PRESIDENT AND TREASURER
                                       OF
          OHIO NATIONAL FUND, INC. AND THE DOW TARGET VARIABLE FUND LLC



     This Code of Ethics applies to the President (the principal executive
officer) and the Treasurer (the principal financial and accounting officer)
(collectively, the "Covered Officers") of Ohio National Fund, Inc. and The Dow
Target Variable Fund LLC (the "Funds").

     In order to maintain the Funds' high ethical standards, each Covered
Officer shall, to the best of his ability and knowledge:

     1.   endeavor to comply with all applicable rules and regulations of
          federal, state and local governments and regulatory agencies;

     2.   make every effort to assure that there is full, fair, accurate, timely
          and understandable disclosure in reports and documents which are
          provided by Funds to, or for the benefit of, the public;

     3.   provide regulators, independent auditors and shareholders with
          relevant, material, accurate and appropriate information reasonably
          needed or requested by them;

     4.   cooperate with any audit or investigation by, or on behalf of, any
          governmental or regulatory authority, including preserving all
          relevant and material records reasonably needed for such audit or
          investigation;

     5.   comply with the Conflicts of Interest policy applicable to Ohio
          National Financial Services, Inc., and its affiliates ("Ohio
          National");

     6.   respect the confidentiality of Fund or shareholder information and not
          disclose such information unless such disclosure is reasonably
          necessary: (1) to perform your duties; (2) to prevent a fraud, a
          criminal act, or serious physical or financial harm; or (3) to comply
          with a reasonable request for information (a) from a governmental or
          regulatory agency, or (b) in conjunction with pending or threatened
          litigation;

     7.   use and control Fund assets and resources responsibly; and

     8.   promptly report any suspected violation of this Code of Ethics in
          accordance with the reporting procedures published by the Funds.