CALIFORNIA INVESTMENT TRUST
AND
CALIFORNIA INVESTMENT TRUST II
AND
CCM PARTNERS
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CODE OF ETHICS
(Revised March 2005)
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I. Legal Requirement
Rule 17j-1 under the Investment Company Act of 1940, as amended (the
"1940 Act"), requires every investment company (as well as its investment
advisor and principal underwriter) to have a written Code of Ethics, which
specifically deals with "insider trading" by "access persons." Access Persons
are defined to include officers of California Investment Trust and California
Investment Trust II (each, a "Trust" and collectively, the "Trusts"), directors
and officers of CCM Partners (the "Adviser"), advisory personnel of the Adviser
with substantial responsibility or with knowledge of the investments of the
Funds constituting series of the Trusts (each, a "Fund"), and each member of the
Boards of Trustees. The Rule also requires that reasonable diligence be used and
procedures instituted to prevent violations of this Code of Ethics.
The Code of Ethics is designed to provide a program for detecting
and preventing insider trading and other violations of fiduciary duties by
requiring Access Persons to report personal holdings and securities transactions
of securities of the types, which the Funds may purchase. The reason underlying
this reporting requirement is the potential for insiders who have knowledge of
what a Fund is doing to take advantage of this information to trade in advance
of a Fund. If the security involved is thinly traded or if the Fund buys or
sells in big enough blocks to move the market, this type of insider trading
could disadvantage the Fund or unfairly benefit the insider. The Code of Ethics
is also aimed at minimizing conflicts of interest and the appearance of such
conflicts.
Under the Code of Ethics, all Access Persons, except Independent
Trustees (who meet the exemptions in Sections VII), are required to file reports
of their personal holdings and securities transactions (excluding securities
issued or guaranteed by the United States Government, its agencies or
instrumentalities; bankers' acceptances; bank certificates of deposit;
commercial paper and high quality short-term debt instruments, repurchase
agreements, other money market instruments, and non-Reportable Funds) at least
quarterly within 30 days after the close of the applicable quarter. These
reports are then compared against the activities of the Funds and if a pattern
emerges that indicates abusive trading of Access Persons of the Trusts, the
matter is referred to the Board of Trustees who will review the pattern and
makes appropriate inquiries and decides what action, if any, is then necessary
and for Access Persons of the Advisor, the Advisor will review the matter and
make a report to the Board of Trustees upon the resolution of the matter.
Additionally, Access Persons are required to obtain prior written approval
before making any investment in an Initial Public Offering ("IPO") or private
placement offering. Before approval of any such investment, the transaction will
be carefully reviewed for any immediate or future potential conflicts of
interest.
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Independent Trustees who do not have day-to-day contact with the
Funds and who do not have specific knowledge of the Funds' intended investments
are not required to file any reports, and there is no restriction on their
personal securities trading activities (excepted as provided for in Section
VII).
This Code of Ethics is not intended to cover all possible areas of
potential liability under the 1940 Act or under the federal securities laws in
general. For example, other provisions of Section 17 of the 1940 Act prohibit
various transactions between a registered investment company and affiliated
persons, including the knowing sale or purchase of property to or from a
registered investment company on a principal basis, and joint transactions
(e.g., combining to achieve a substantial position in a security or commingling
of funds) between an investment company and an affiliated person. Persons
covered by this Code of Ethics are advised to seek advice before engaging in any
transactions involving securities held or under consideration for purchase or
sale by a Fund of the Trusts.
In addition, the Securities Exchange Act of 1934 may impose
fiduciary obligations and trading restrictions on Access Persons in certain
situations. It is expected that Access Persons will be sensitive to these areas
of potential conflict, even though this Code of Ethics does not address
specifically these other areas of fiduciary responsibility.
II. Implementation
In order to implement this Code of Ethics, a compliance officer and
two alternates should be designated. These individuals are:
Michael O'Callaghan, Compliance Officer
Steve Rogers, Alternate
Matt Clark, Alternate
The compliance officer shall create a list of advisory persons and
other Access Persons and update the list with reasonable frequency. The
compliance officer shall circulate a copy of this Code of Ethics to each Access
Person, together with an acknowledgment of receipt, which shall be signed and
returned to the compliance officer by each Access Person. The compliance officer
is charged with responsibility for insuring that the reporting requirements of
this Code of Ethics (see Section VI) are adhered to by all Access Persons. The
compliance officer shall be responsible for ensuring that the review
requirements of this Code of Ethics (see Section VIII) are performed in a prompt
manner. The compliance officer shall also be responsible for giving special
prior approval to transactions that would otherwise be prohibited pursuant to
Section IV of this Code of Ethics.
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III. Definitions
(a) "Access person" means any trustee, director or general partner,
officer or advisory person of a Fund or Trust or the Adviser.
(b) "Advisory person" means (i) any employee of (A) a Trust, (B) an
investment advisor to a Trust or (C) any company in control relationship to a
Trust, who, in connection with his regular functions or duties, makes,
participates in, or obtains information regarding, the purchase or sale of a
security by a Fund of the Trusts, or whose functions relate to the making of any
recommendations with respect to such purchases or sales; and (ii) any natural
person in a control relationship to a Trust or an investment adviser to a Trust
who obtains information concerning recommendations made to a Trust with regard
to the purchase or sale of a security.
(c) A security is "being considered for purchase or sale" when a
recommendation to purchase or sell a security has been made and communicated
and, with respect to the person making the recommendation, when such person
seriously considers making such a recommendation.
(d) "Beneficial ownership" shall be interpreted in the same manner
as it would be in determining whether a person is subject to the provisions of
Section 16 of the Securities Exchange Act of 1934, as amended, and the rules and
regulations thereunder, with the exception that the determination of direct or
indirect beneficial ownership shall apply to all securities which an Access
Person has or acquires.
(e) "Control" has the same meaning as in Section 2(a) (9) of the
1940 Act.
(f) "Investment Personnel" of a Trust or of the Adviser means (i)
any employee of a Trust or the Adviser (or of any company in a control
relationship to the Trust or the Adviser) who, in connection with his or her
regular functions or duties, makes or participates in making recommendations
regarding the purchase or sale of securities by a Fund; or (ii) any natural
person who controls the Trust or the Adviser and who obtains information
concerning recommendations made to a Fund regarding the purchase or sale of
securities by a Fund.
(g) "Purchase or sale of a security" includes the writing of an
option to purchase or sell a security.
(h) "Reportable Fund" means, for a particular Access Person, any
mutual fund for which the investment adviser with whom the Access Person is
associated, if any (the "Associated Adviser"), serves as investment adviser
(including any sub-adviser) or any mutual fund whose investment adviser or
principal underwriter controls the Associated Adviser, is controlled by the
Associated Adviser, or is under common control with the Associated Adviser.
(i) "Security" shall have the meaning set forth in Section 2(a) (36)
of the 1940 Act, except that it shall not include shares of mutual funds that
are not Reportable Funds, securities issued by the Government of the United
States (including Government agencies or instrumentalities), short term debt
securities which are "government securities" within the meaning of Section 2(a)
(16) of the 1940 Act, bankers' acceptances, bank certificates of deposit,
commercial paper and high quality short-term debt instruments, repurchase
agreements and other money market instruments.
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IV. Prohibited Purchases and Sales
No Access Person shall purchase or sell directly or indirectly, any
Security in which he or she has, or by reason of such transactions acquires, any
direct or indirect beneficial ownership, which Security to his or her actual
knowledge at the time of such purchase or sale:
(a) is being considered for purchase or sale by a Reportable
Fund (Index Funds excepted, where an "Index Fund" is a
Fund which seeks to match the performance of an Index);
(b) has been purchased or sold by a Reportable Fund within
the most recent 7 days if such person participated in
the recommendation to, or the decision by, the
Reportable Fund to purchase or sell such security (Index
Funds transactions excepted).
These restrictions shall continue to apply until the recommendation
has been rejected or any trade instruction to buy or sell has been completed or
canceled. Knowledge of any such consideration, intention, recommendation or
purchase or sale is always a matter of strictest confidence.
Investment Personnel must obtain prior written approval from the
Adviser's compliance officer before making an investment in an IPO or private
placement.
Exceptions to Prior Approval. These restrictions shall not apply to
purchases or sales which receive the prior approval of the compliance officer
because they are only remotely potentially harmful to a Fund, or because they
would be very unlikely to affect a highly institutional market, or because they
clearly are not related economically to the securities to be purchased, sold or
held by a Fund.
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V. Exempted Transactions/Securities
The prohibitions of Section IV of this Code shall not apply to:
(a) Purchases or sales effected in any account over which the
Access Person has no direct or indirect influence or control.
(b) Purchases or sales, which fall below either 1,000 shares or
$50,000, whichever is greater (except IPOs and private
placements).
(c) Purchases or sales of securities, which are not eligible for
purchase, or sale by any Fund (except IPOs and private
placements).
(d) Purchases or sales, which are non-volitional on the part of
either the Access Person or a Trust (except IPOs and private
placements) (e.g., receipt of gifts).
(e) Purchases, which are part of an automatic dividend
reinvestment, plan.
(f) Purchases effected upon the exercise of rights issued by an
issuer pro rata to all holders of a class of its securities,
to the extent such rights were acquired from such issuer, and
sales of such rights so acquired.
(g) Purchases and sales, which have received the prior approval of
the compliance officer.
(h) Purchases and sales or securities, which are not, included in
the definition of "Security" in Part III.g - i.e.,
non-Reportable Fund shares, government securities and money
market instruments.
(i) Purchases and sales of securities, which are in an Index Fund.
VI. Reporting
(a) Subject to the exceptions set forth below, all Access Persons,
with the exception of the Independent Trustees who meet the requirements of
Section VII(a), shall report to the Trusts or the Adviser the information
described in this Section VI(b) with respect to transactions in any security in
which such Access Person has, or by reason of such transaction acquires, any
direct or indirect beneficial ownership in the security.
(b) Every report shall be made not later than thirty (30) days after
the end of each calendar quarter and shall contain the following information:
(1) The date of the transaction, the title and the number of
shares, the interest rate and maturity date (if
applicable), and the principal amount of each security
involved;
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(2) The nature of the transaction (i.e., purchase, sale, or
any other type of acquisition of disposition);
(3) The price at which the transaction was effected;
(4) The name of the broker, dealer, or bank with or through
whom the transaction was effected; and
(5) The date that the report is being submitted.
(c) For periods in which no reportable transactions were effected,
the report shall contain a representation that no transactions subject to the
reporting requirements were effected during the relevant time period.
(d) Any such report may contain a statement that the report shall
not be construed as an admission by the person making such report that he has
any director indirect beneficial ownership in the security to which the report
relates.
(e) Copies of statements or confirmations containing the information
specified in paragraph (b) above may be submitted in lieu of listing the
transactions.
(f) Each Access Person (with the exception of the Independent
Trustees) must make an Initial Holdings Report within 10 days of becoming an
Access Person and an Annual Holdings Report, which must contain information,
current within 30 days before the report is submitted. Each of these reports
must contain the following information:
(1) the title, number of shares and principal amount of each
security in which the Access Person had any direct or
indirect beneficial ownership;
(2) the name of any broker, dealer or bank with whom the
Access Person maintained an account where such security
was held; and
(3) the date that the report is being submitted.
VII. Exceptions to Reporting Requirements
(a) An independent Trustee, i.e., a Trustee of a Trust who is not an
"interested person" (as defined in Section 2(a) (19) of the 1940 Act) of a
Trust, is not required to file a report on a transaction in a security;
provided, however, that such Trustee neither knew nor, in the ordinary course of
fulfilling his or her official duties as a trustee of a Trust, should have known
that, during the 15-day period immediately preceding or after the date of the
transaction by the Trustee, such security is or was purchased or sold by a Trust
or is or was being considered for purchase by its investment adviser.
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(b) While an independent Trustee is exempt from the reporting
requirements of Section VI(b) of this Code pursuant to Section VII(a), such
Trustee may voluntarily file a report representing that he or she did not engage
in any securities transactions which, to his or her knowledge, involved
securities that were being purchased or sold or considered for purchase by any
Fund during the 15-day period preceding or after the date(s) of any
transaction(s) by such Trustee. Any failure to regularly file such a report,
however, shall not be considered a violation of this Code of Ethics.
(c) Access Persons also need not make a report with respect to an
exempted transaction security as described in Section V of this Code (e.g.,
non-Reportable Fund shares).
VIII. Review
The compliance officer (or the alternate, as appropriate) shall
compare all reports of personal securities transactions with completed and
contemplated portfolio transactions of each Fund to determine whether a
violation of the Code of Ethics may have occurred. No person shall review his or
her own report. Before making any determination that a violation has been
committed by any person, the compliance officer shall give such person an
opportunity to supply additional explanatory material. If a securities
transaction of the compliance officer is under consideration, the Chairman shall
act in all respects in the manner prescribed herein for the compliance officer.
If the compliance officer determines that a violation of the Code of
Ethics has or may have occurred, he or she shall, following consultation with
counsel to the Trusts, submit his or her written determination, together with
the transaction report, if any, and any additional explanatory material provided
by the individual, to the President or, if the President shall be the compliance
officer, the Treasurer, who shall make an independent determination of whether a
violation has occurred.
The compliance officer shall be responsible for maintaining a
current list of all Access Persons (including all Trustees) and for identifying
all reporting Access Persons on such list, and shall take steps to ensure that
all reporting Access Persons have submitted reports in a timely manner. Failure
to submit timely reports will be communicated to the Board of Trustees.
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IX. Board Oversight
The Board of Trustees must initially approve the Code of Ethics for
the Trusts and the Adviser, and the Board of Trustees must approve any material
changes to the Code of Ethics within six (6) months of such change. The
compliance officer shall (i) promptly notify the Board of any material violation
of the Code; (ii) provide to the Board a written report summarizing any and all
material issues that arose during the previous year, and (iii) annually certify
that the Adviser has adopted procedures in compliance with the Code of Ethics
and Rule 17j-1 under the 1940 Act.
X. Sanctions
If a material violation of this Code occurs or a preliminary
determination is made that a violation may have occurred, a report of the
alleged violation shall be made to the Board of Trustees. The Board of Trustees
or the Adviser may impose such sanctions as it deems appropriate, including, a
letter of censure, suspension, or termination of the employment of the violator,
and/or a disgorging of any profits made by the violator.
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CALIFORNIA INVESTMEST TRUST
CALIFORNIA INVESTMENT TRUST II
SUPPLEMENTAL CODE OF ETHICS FOR
PRINCIPAL OFFICERS AND SENIOR FINANCIAL OFFICERS
The Board of Trustees (the "Board") of each of California Investment Trust and
California Investment Trust II (each a "Trust" and collectively, the "Trusts")
has adopted this Supplemental Code of Ethics (the "Code") for the Trusts'
Principal Officers and Senior Financial Officers (collectively, the "Officers")
to guide and remind the Officers of their responsibilities to the Trusts, other
officers, shareholders of the series of the Trusts (the "Funds"), and
governmental authorities. Officers are expected to act in accordance with the
guidance and standards set forth in this Code.
For the purposes of this Code, the Trusts' Principal Officers and Senior
Financial Officers shall include: the Principal Executive Officer; the Principal
Financial Officer; the Principal Accounting Officer; the Controller; and any
persons performing similar functions on behalf of the Trusts, regardless of
whether such persons are employed by the Trusts or a third party.
This Code is intended to serve as the code of ethics described in Section 406 of
The Sarbanes-Oxley Act of 2002 and Form N-CSR. To the extent that an Officer is
subject to the Trusts' code of ethics adopted pursuant to Rule 17j-1 of the
Investment Company Act of 1940, as amended (the "Rule 17j-1 Code"), this Code is
intended to supplement and be interpreted in the context of the Rule 17j-1 Code.
This Code also should be interpreted in the context of all applicable laws,
regulations, each Trust's Agreement and Declaration of Trust and Bylaws, as
amended, and all other governance and disclosure policies and documents adopted
by the Board. All Officers must become familiar and fully comply with this Code.
Because this Code cannot and does not cover every applicable law or provide
answers to all questions that might arise, all Officers are expected to use
common sense about what is right and wrong, including a sense of when it is
proper to seek guidance from others on the appropriate course of conduct.
The purpose of this Code is to set standards for the Officers that are
reasonably designed to deter wrongdoing and are necessary to promote:
o honest and ethical conduct, including the ethical handling of actual
or apparent conflicts of interest between personal and professional
relationships;
o full, fair, accurate, timely, and understandable disclosure in
reports and documents that the Trusts file with, or submit to, the
Securities and Exchange Commission (the "SEC") and in any other
public communications by the Trusts;
o compliance with applicable governmental laws, rules and regulations;
o the prompt internal reporting of violations of the Code to the
appropriate persons as set forth in the Code; and
o accountability for adherence to the Code.
1. HONEST AND ETHICAL CONDUCT
a. Honesty, Diligence and Professional Responsibility
Officers are expected to observe both the form and the spirit of the ethical
principles contained in this Code. Officers must perform their duties and
responsibilities for the Trusts:
o with honesty, diligence, and a commitment to professional and
ethical responsibility;
o carefully, thoroughly and in a timely manner; and
o in conformity with applicable professional and technical standards.
Officers who are certified public accountants are expected carry out their
duties and responsibilities in a manner consistent with the principles governing
the accounting profession, including any guidelines or principles issued by the
Public Company Accounting Oversight Board or the American Institute of Certified
Public Accountants from time to time.
b. Objectivity / Avoidance of Undisclosed Conflicts of Interest
Officers are expected to maintain objectivity and avoid undisclosed conflicts of
interest. In the performance of their duties and responsibilities for the
Trusts, Officers must not subordinate their judgment to personal gain and
advantage, or be unduly influenced by their own interests or by the interests of
others. Officers must avoid participation in any activity or relationship that
constitutes a conflict of interest unless that conflict has been completely
disclosed to affected parties. Further, Officers should avoid participation in
any activity or relationship that could create the appearance of a conflict of
interest.
A conflict of interest would generally arise if an Officer directly or
indirectly participated in any investment, interest, association, activity or
relationship that may impair or appear to impair the Officer's objectivity.
Any Officer who may be involved in a situation or activity that might be a
conflict of interest or give the appearance of a conflict of interest should
consider reporting such situation or activity using the reporting procedures set
forth in Section 4 (Reporting of Illegal or Unethical Behavior) of this Code.
The Audit Committee of the Trusts (the "Audit Committee") will not be
responsible for monitoring or enforcing this conflict of interest policy, but
rather each Officer is responsible for self-compliance with this conflict of
interest policy.
c. Preparation of Financial Statements
Officers must not knowingly make any misrepresentations regarding the Funds'
financial statements or any facts in the preparation of the Funds' financial
statements, and must comply with all applicable laws, standards, principles,
guidelines, rules and regulations in the preparation of the Fund's financial
statements. This section is intended to prohibit:
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o making, or permitting or directing another to make, materially false
or misleading entries in the Funds' financial statements or records;
o failing to correct the Funds' financial statements or records that
are materially false or misleading when he or she has the authority
to record an entry; and
o signing, or permitting or directing another to sign, a document
containing materially false or misleading financial information.
Officers must be scrupulous in their application of generally accepted
accounting principles. No Officer may (i) express an opinion or state
affirmatively that the financial statements or other financial data of the
Trusts are presented in conformity with generally accepted accounting
principles, or (ii) state that he or she is not aware of any material
modifications that should be made to such statements or data in order for them
to be in conformity with generally accepted accounting principles, if such
statements or data contain any departure from generally accepted accounting
principles then in effect in the United States.
Officers must follow the laws, standards, principles, guidelines, rules and
regulations established by all applicable governmental bodies, commissions or
other regulatory agencies in the preparation of financial statements, records
and related information. If an Officer prepares financial statements, records or
related information for purposes of reporting to such bodies, commissions or
regulatory agencies, the Officer must follow the requirements of such
organizations in addition to generally accepted accounting principles.
If an Officer and his or her supervisor have a disagreement or dispute relating
to the preparation of financial statements or the recording of transactions, the
Officer should take the following steps to ensure that the situation does not
constitute an impermissible subordination of judgment:
o The Officer should consider whether (i) the entry or the failure to
record a transaction in the records, or (ii) the financial statement
presentation or the nature or omission of disclosure in the
financial statements, as proposed by the supervisor, represents the
use of an acceptable alternative and does not materially
misrepresent the facts or result in an omission of a material fact.
If, after appropriate research or consultation, the Officer
concludes that the matter has authoritative support and/or does not
result in a material misrepresentation, the Officer need do nothing
further.
o If the Officer concludes that the financial statements or records
could be materially misstated as a result of the supervisor's
determination, the Officer should follow the reporting procedures
set forth in Section 4 (Reporting of Illegal or Unethical Behavior)
of this Code.
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d. Obligations to the Independent Auditor of the Fund
In dealing with the Funds' independent auditor, Officers must be candid and not
knowingly misrepresent facts or knowingly fail to disclose material facts, and
must respond to specific inquiries and requests by the Funds' independent
auditor.
Officers must not take any action, or direct any person to take any action, to
fraudulently influence, coerce, manipulate or mislead the Funds' independent
auditor in the performance of an audit of the Funds' financial statements for
the purpose of rendering such financial statements materially misleading.
2. FULL, FAIR, ACCURATE, TIMELY AND UNDERSTANDABLE DISCLOSURE
It is the Trusts' policy to provide full, fair, accurate, timely, and
understandable disclosure in reports and documents that the Trusts file with, or
submit to, the SEC and in any other public communications by the Trusts. The
Trusts have designed and implemented Disclosure Controls and Procedures to carry
out this policy.
Officers are expected to use their best efforts to promote, facilitate, and
prepare full, fair, accurate, timely, and understandable disclosure in all
reports and documents that the Trusts file with, or submit to, the SEC and in
any other public communications by the Trusts.
Officers must review the Trusts' Disclosure Controls and Procedures to ensure
they are aware of and carry out their duties and responsibilities in accordance
with the Disclosure Controls and Procedures and the public reporting obligations
of the Trusts. Officers are responsible for monitoring the integrity and
effectiveness of the Trusts' Disclosure Controls and Procedures.
3. COMPLIANCE WITH APPLICABLE LAWS, RULES AND REGULATIONS
Officers are expected to know, respect and comply with all laws, rules and
regulations applicable to the conduct of the Trusts' business. If an Officer is
in doubt about the legality or propriety of an action, business practice or
policy, the Officer should seek advice from the Officer's supervisor or the
Trusts' legal counsel.
In the performance of their work, Officers must not knowingly be a party to any
illegal activity or engage in acts that are discreditable to the Trusts.
Officers are expected to promote the Trusts' compliance with applicable laws,
rules and regulations. To promote such compliance, Officers may establish and
maintain mechanisms to educate employees carrying out the finance and compliance
functions of the Trusts about any applicable laws, rules or regulations that
affect the operation of the finance and compliance functions and the Trusts
generally.
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4. REPORTING OF ILLEGAL OR UNETHICAL BEHAVIOR
Officers should promptly report any conduct or actions by an Officer that do not
comply with the law or with this Code. Officers and the Trusts shall adhere to
the following reporting procedures:
o Any Officer who questions whether a situation, activity or practice
is acceptable must immediately report such practice to the Principal
Executive Officer of the Trusts (or to an Officer who is the
functional equivalent of this position) or to the Trusts' legal
counsel. The person receiving the report shall consider the matter
and respond to the Officer within a reasonable amount of time.
o If the Officer is not satisfied with the response of the Principal
Executive Officer or counsel, the Officer must report the matter to
the Chairman of the Audit Committee. If the Chairman is unavailable,
the Officer may report the matter to any other member of the Audit
Committee. The person receiving the report shall consider the
matter, refer it to the full Audit Committee if he or she deems
appropriate, and respond to the Officer within a reasonable amount
of time.
o If, after receiving a response, the Officer concludes that
appropriate action was not taken, he or she should consider any
responsibility that may exist to communicate to third parties, such
as regulatory authorities or the Fund's independent auditor. In this
matter, the Officer may wish to consult with his or her own legal
counsel.
o The Audit Committee and the Trusts will not be responsible for
monitoring or enforcing this reporting of violations policy, but
rather each Officer is responsible for self-compliance with this
reporting of violations policy.
o To the extent possible and as allowed by law, reports will be
treated as confidential.
o If the Audit Committee determines that an Officer violated this
Code, failed to report a known or suspected violation of this Code,
or provided intentionally false or malicious information in
connection with an alleged violation of this Code, the Trusts may
take disciplinary action against any such Officer to the extent the
Audit Committee deems appropriate. No Officer will be disciplined
for reporting a concern in good faith.
o The Trusts and the Audit Committee may report violations of the law
to the appropriate authorities.
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5. ACCOUNTABILITY AND APPLICABILITY
All Officers will be held accountable for adherence to this Code. On an annual
basis, within 30 days of the beginning of each calendar year, each Officer shall
certify in writing his or her receipt, familiarity and commitment to compliance
with this Code, by signing the Acknowledgment Form (Appendix A to this Code).
This Code is applicable to all Officers, regardless of whether such persons are
employed by the Trusts or a third party. If an Officer is aware of a person
("Potential Officer") who may be considered an Officer as defined by this Code,
the Officer should inform legal counsel to the Trusts of such Potential Officer
so that a determination can be made regarding whether such Potential Officer has
completed or should complete an Acknowledgment Form. However, the absence of
such a determination will not be deemed to relieve any person of his or her
duties under this Code.
6. DISCLOSURE OF THIS CODE
This Code shall be disclosed by at least one of the following methods in the
manner prescribed by the SEC, unless otherwise required by law:
o by filing a copy of the Code with the SEC;
o by posting the text of the Code on the Trusts' website; or
o by providing, without charge, a copy of the Code to any person upon
request.
7. WAIVERS
Any waiver of this Code, including an implicit waiver, that has been granted to
an Officer, may be made only by the Board or a committee of the Board to which
such responsibility has been delegated, and must be disclosed by the Trusts in
the manner prescribed by law and as set forth above in Section 6 (Disclosure of
this Code).
8. AMENDMENTS
This Code may be amended by the affirmative vote of a majority of the Board. Any
amendment of this Code, must be disclosed by the Trusts in the manner prescribed
by law and as set forth above in Section 6 (Disclosure of this Code), unless
such amendment is deemed to be technical, administrative, or otherwise
non-substantive. Any amendments to this Code will be provided to the Officers.
Approved by the Board of Trustees on May 13, 2003.
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Appendix A
California Investment Trust
California Investment Trust II
Certification and Acknowledgment of Receipt of Supplemental Code of Ethics for
Principal Officers and Senior Financial Officers
I acknowledge and certify that I have received a copy of the Supplemental Code
of Ethics for Principal Officers and Senior Financial Officers for California
Investment Trust and California Investment Trust II (the "Code"). I understand
and agree that it is my responsibility to read and familiarize myself with the
policies and procedures contained in the Code and to abide by those policies and
procedures.
I acknowledge my commitment to comply with the Code.
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Officer Name (Please Print) Officer Signature
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Date