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Exhibit (a)(1)
HARRIS ASSOCIATES INVESTMENT TRUST
CODE OF ETHICS FOR PRINCIPAL EXECUTIVE OFFICER
AND SENIOR FINANCIAL OFFICERS
I. COVERED OFFICERS/PURPOSE OF THE CODE
This code of ethics (the "Code") for Harris Associates Investment Trust
(the "Trust") applies to the Trust's Chief Executive Officer, Chief Financial
Officer and Chief Accounting Officer (the "Covered Officers") for the purpose of
promoting:
- honest and ethical conduct, including the ethical handling of actual
or apparent conflicts of interest between their personal relationships
and their professional relationships;
- full, fair, accurate, timely and understandable disclosure in reports
and documents that the Trust files with, or submits to, the Securities
and Exchange Commission ("SEC"), and in other public communications
made by the Trust;
- compliance with applicable laws and governmental rules and
regulations;
- prompt internal reporting of violations of the Code to an appropriate
person or persons identified in the Code; and
- accountability for adherence to the Code.
Each Covered Officer should adhere to a high standard of business ethics
and should be sensitive to situations that may give rise to actual as well as
apparent conflicts of interest.
II. ADMINISTRATION OF THE CODE
The Code shall be administered by the chief legal officer of the Trust (the
"Chief Legal Officer"), or in the absence of the Chief Legal Officer, his or her
designee, but only on a temporary basis.
The Trust has designated its Chief Legal Officer for purposes of the
Sarbanes-Oxley Act of 2002 and the rules promulgated thereunder. The Chief Legal
Officer is responsible for applying this Code to specific situations in which
questions are presented under it (in consultation with Trust counsel, where
appropriate) and has the authority to interpret this Code in any particular
situation. However, any waiver sought by a Covered Officer must be approved by
the Audit Committee of the Trust (the "Audit Committee").
III. ACTUAL AND APPARENT CONFLICTS OF INTEREST
OVERVIEW. A "conflict of interest" occurs when a Covered Officer's private
interest interferes with the interests of, or his/her service to, the Trust. For
example, a conflict of interest would arise if a Covered Officer, or a family
member, receives improper personal benefits as a result of the Covered Officer's
position with the Trust.
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Certain conflicts of interest arise out of the relationships between
Covered Officers and the Trust and already are subject to conflict of interest
provisions in the Investment Company Act of 1940 (the "Company Act") and the
Investment Advisers Act of 1940 (the "Advisers Act"). For example, Covered
Officers generally may not individually engage in certain transactions (such as
the purchase or sale of securities or other property) with the Trust because of
their status as "affiliated persons" of the Trust. The Trust's and its
investment adviser's compliance programs and procedures are designed to prevent,
or identify and correct, violations of these provisions. This Code does not, and
is not intended to, repeat or replace these programs and procedures, and such
conflicts fall outside of the parameters of this Code.
Although typically not presenting an opportunity for improper personal
benefit, conflicts arise from, or as a result of, the contractual relationship
between the Trust and its investment adviser of which the Covered Officers are
also officers or employees. As a result, this Code recognizes that the Covered
Officers will, in the normal course of their duties (whether formally for the
Trust or for the adviser, or for both), be involved in establishing policies and
implementing decisions that will have different effects on the adviser and the
Trust. The participation of the Covered Officers in such activities is inherent
in the contractual relationship between the Fund and the adviser and is
consistent with the performance by the Covered Officers of their duties as
officers of the Trust. Thus, if performed in conformity with the provisions of
the Company Act and the Advisers Act, such activities will be deemed to have
been handled ethically. In addition, it is recognized by the Trust's Board of
Trustees (the "Board") that the Covered Officers may also be officers or
employees of one or more other investment companies covered by this or other
codes.
Other conflicts of interest are covered by the Code, even if such conflicts
of interest are not subject to provisions of the Company Act and the Advisers
Act. The following list provides examples of conflicts of interest under the
Code, but Covered Officers should keep in mind that these examples are not
exhaustive. The overarching principle is that the personal interest of a Covered
Officer should not be placed improperly before the interest of the Trust.
Each Covered Officer must:
- not use personal influence or personal relationships improperly to
influence investment decisions or financial reporting by the Trust
whereby the Covered Officer or a family member would benefit
personally to the detriment of the Trust;
- not cause the Trust to take action, or fail to take action, for the
individual personal benefit of the Covered Officer or a family member
rather than the benefit of the Trust; and
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- not use material non-public knowledge of portfolio transactions made
or contemplated for the Trust to trade personally or cause others to
trade personally in contemplation of the market effect of such
transactions.(1)
There are some conflict of interest situations that must be approved by the
Chief Legal Officer. Those situations include, but are not limited to,:
- service as director on the board of any public or private company;
- receipt of any gifts from any person with whom the Trust has current
or prospective business dealings having an aggregate value in excess
of $250 from a third party during any 12-month period;
- receipt of any entertainment from any company with which the Trust has
current or prospective business dealings, unless such entertainment is
business-related, reasonable in cost, appropriate as to time and
place, and not so frequent as to raise any question of impropriety;
- any ownership interest in, or any consulting or employment
relationship with, any service provider to the Trust, other than its
investment adviser, principal underwriter, administrator or any
affiliated person thereof;
- a direct or indirect financial interest in commissions, transaction
charges or spreads paid by the Trust for effecting portfolio
transactions or for selling or redeeming shares other than an interest
arising from the Covered Officer's employment, such as compensation or
equity ownership.
IV. DISCLOSURE AND COMPLIANCE
Each Covered Officer should:
- be familiar with the disclosure requirements generally applicable to
the Trust;
- not knowingly misrepresent, or cause others to misrepresent, facts
about the Trust to others, whether within or outside the Trust,
including to the Board and auditors, and to governmental regulators
and self-regulatory organizations;
- to the extent appropriate within his/her area of responsibility,
consult with other officers and employees of the Trust and the adviser
with the goal of promoting full, fair, accurate, timely and
understandable disclosure in the reports and documents the Trust files
with, or submits to, the SEC and in other public communications made
by the Trust; and
- promote compliance with the standards and restrictions imposed by
applicable laws, rules and regulations.
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(1) For purposes of this Code, personal trading activity of the Covered
Officers shall be monitored in accordance with the advisers' code. Each
Covered Officer shall be considered an "Access Person" under such code.
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V. REPORTING AND ACCOUNTABILITY
Each Covered Officer must:
- upon adoption of the Code (or after becoming a Covered Officer),
affirm in writing to the Board that he/she has received, read and
understands the Code;
- annually thereafter affirm to the Board compliance with the
requirements of the Code;
- not retaliate against any other Covered Officer or any employee of the
Trust or their affiliated persons for reports of potential violations
that are made in good faith;
- notify the Chief Legal Officer promptly if he/she knows of any
violation of this Code; and
- respond to the trustee and officer questionnaires circulated
periodically in connection with the preparation of disclosure
documents for the Trust.
The Chief Legal Officer shall maintain records of all activities related to
this Code.
The Trust will follow these procedures in investigating and enforcing
this Code:
- The Chief Legal Officer will take all appropriate action to
investigate any potential violations reported to him/her;
- If, after such investigation, the Chief Legal Officer believes that no
violation has occurred, no further action is required;
- Any matter that the Chief Legal Officer believes is a violation will
be reported to the Audit Committee;
- If the Audit Committee concurs that a violation has occurred, it will
inform and make a recommendation to the Board, which will consider
appropriate action, which may include review of, and appropriate
modifications to, applicable policies and procedures; notification to
the Chief Executive Officer of the Trust; or a recommendation to
dismiss the Covered Officer;
- The Audit Committee will be responsible for granting waivers in its
sole discretion; and
- Any changes to or waivers of this Code will, to the extent required,
be disclosed as provided by SEC rules.
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VI. OTHER POLICIES AND PROCEDURES
This Code shall be the sole code of ethics adopted by the Trust for the
purposes of Section 406 of the Sarbanes-Oxley Act and the rules and forms
applicable to registered investment companies thereunder. Insofar as other
polices or procedures of the Trust, the Trust's advisers, principal underwriter
or other service providers govern or purport to govern the behavior or
activities of the Covered Officers who are subject to this Code, they are
superseded by this Code to the extent that they overlap or conflict with the
provisions of this Code. The code(s) of ethics of the Trust and its investment
adviser and principal underwriter under Rule 17j-1 under the Company Act and the
advisers' more detailed policies and procedures are separate requirements
applying to the Covered Officers and others and are not part of this Code.
VII. AMENDMENTS
Any amendment to this Code must be approved or ratified by the Board,
including a majority of independent Board members.
VIII. CONFIDENTIALITY
All reports and records prepared or maintained pursuant to this Code will
be considered confidential and shall be maintained and protected accordingly.
Except as otherwise required by law or this Code, such matters shall not be
disclosed to anyone other than the Board, the Covered Officers, the Chief Legal
Officer, outside audit firms and legal counsel to the Trust and the adviser, and
senior management of the adviser.
IX. INTERNAL USE
The Code is intended solely for the internal use by the Trust and does not
constitute an admission, by or on behalf of the Trust, as to any fact,
circumstance, or legal conclusion.
Adopted July 16, 2003
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