AMERICAN DEVELOPMENT & INVESTMENT FUND, INC.
                              CODE OF ETHICS
                      RELATING TO INVESTMENTS, CONFLICTS
                                  AND
                APPEARANCES OF IMPROPRIETY REGARDING INVESTMENTS

WHEREAS, investment companies are required to adopt a code of ethics and
reporting requirements to prevent fraudulent, deceptive and manipulative
practices, the following code of ethics relating to investments by the
Corporation is adopted by the Corporation Board of Directors.

I.	DEFINITIONS

A.	Corporation shall mean American Development & Investment Fund, Inc.
B.	Access Person means any director, officer, general partner, or
Advisory Person of the Corporation.
C.	Advisory Person means any employee of the Corporation, who, in
connection with his or her regular functions or duties, makes, participates in,
or obtains information regarding the purchase or sales of a security by the
Corporation, or whose functions relate to the making of any recommendations
with respect to such purchases or sales; and any natural person in a control
relationship to the Corporation who obtains information concerning
recommendations made to the Corporation with regard to the purchase or sale of
a security.
D.	Purchase or sale of a security includes, inter alia, the writing of an
option to purchase or sell a security.
E.	Control shall have the same meaning as that set forth in Section 2(a)(9)
of the Investment Company Act of 1940.
F.	Security shall have the meaning set forth in 2(a)(36) of the Investment
Company Act of 1940, except that it shall not include shares of registered
open-end investment companies, securities issued by the Government of the
United States, short term debt securities which are government securities
within the meaning of Section 2(a)(16) of the Investment Company Act of 1940,
bankers acceptances, bank certificates of deposit, commercial paper, and such
other money market instruments as designated by the board.
G.	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 and the rules and regulations
thereunder, except that the determination of direct or indirect beneficial
ownership shall apply to all securities which an Access Person has or acquires.
H. Investment company means a company registered as such under the
I. Investment
Company Act of 1940, as amended.
J. Manipulation means to alter by artful, insidious, or unfair means to
K. serve ones purpose.

II.	PROHIBITIONS

A. No Access Person of the Corporation, or any of its subsidiaries, shall
purchase or sell, directly or indirectly, any security in which he or she has,
or by reason of such transaction acquires, any direct or indirect beneficial
ownership and which he or she knows or should have known at the time of such
purchase or sale:

1.	is being considered for purchase or sale by the Corporation; or
2.	is being purchased or sold by the Corporation; or
3.	is being sold short by the Corporation.

III.	EXEMPTED TRANSACTIONS

A.	The prohibitions of Section 2 of this Code shall not apply to:
1.	Purchases or sales affected in any account over which the Access Person
has no direct or indirect influence or control.
2. Purchases or sales of securities that are not eligible for
purchase or sale by the Corporation.
3. Purchases or sales that are not voluntary or purposefully made
on the part of either the Access Person or the Corporation.
4.	Purchases, which are part of an automatic dividend reinvestment plan.
5.	Purchases effected upon the exercise of rights issued by an issuer
pro-rata to all holders of a class of securities, to the extent such rights
were acquired from the issuer, and sales of such rights so acquired.
6. Purchases or sales that receive the prior approval of the Corporation
Board because they are only remotely potentially harmful to the Corporation,
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 the Corporation.

IV.	REPORTING

A. Every Access Person shall voluntarily report to the Corporation, on a
timely basis, the information described in Section 4(c) of this Code 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; provided, however, that an Access Person shall not
be required to make a report with respect to transactions effected for any
account over which such person does not have any direct or indirect influence.
B. An employee of the Corporation who is not an Access Person need only
report a transaction in a security if such person, at the time of that
transaction, knew or, in the ordinary course of fulfilling his or her official
duties as an employee of the Corporation, should have known that, during the
15-day period immediately preceding the date of the transaction by the director
such security was purchased or sold by the Corporation or was being considered
by the Corporation or its investment advisor for the purchase or sale by the
Corporation.
C. Every report shall be made not later than 10 days after the end of the
calendar quarter in which the transaction to which the report relates was
effected, and shall contain the following information:
1. The date of the transaction, the title and number of shares, and the
principal amount of each security involved.
2. The nature of the transaction (i.e., purchase, sale or any other type
Of acquisition or 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.
D. It is the intent of the Corporation to abide by Rule 17j-1, dictating
the reporting requirement, and as the Rule is amended, from time to time, to
review the Rule to insure that the Corporation diligently abides by all aspects
of the reporting requirements under said Rule.

V.	SANCTIONS

A. Section (b)(1) of Rule 17j-1 requires Corporations to ?use reasonable
diligence, and institute procedures reasonably necessary, to prevent violations
 of its codes of ethics.
B. Upon discovering a violation of this Code of Ethics, the board of
directors of the Corporation may impose such sanctions as it deems appropriate,
including, inter alia, a letter of censure or suspension or termination of the
employment of the violator. Such a violation might include, but are not limited
to, filing incomplete, untimely, or false reports and engaging in any
manipulative practice or course of business that operates as a fraud
upon such registered investment company.
C. Rule 17j-1 does not supplant any obligation or prohibition to which an
Access Person may be subject under the Investment Advisors Act of 1940 or any
other federal securities laws.