**SARBANES-OXLEY**

**CODE OF ETHICS**

**Davis Funds**

**Selected Funds**

**Clipper Fund**

**(“Funds”)**

**December 2007**

 

| **I.** | **Covered Officers/Purpose of the Code** |
|--------|------------------------------------------|

 

This Sarbanes-Oxley Code of Ethics (“Code”) applies to each Fund’s Principal Executive Officer, Principal Financial Officer, Principal Accounting Officer, and Controller, or persons performing similar functions elected by the Funds (the “Covered Officers”) for the purposes of promoting: 

 

|   | **•** | honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships; |
|--------|------------|---------------------------------------------------------------------------------------------------------------------------------------------------------|

|   | **•** | full, fair, accurate, timely and understandable disclosure in reports and documents that a registrant files with, or submits to, the Securities and Exchange Commission (“SEC”) and in other public communications made by the Funds; |
|--------|------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|

|   | **•** | compliance with applicable laws and governmental rules and regulations; |
|--------|------------|-------------------------------------------------------------------------|

|   | **•** | the 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.** | **Covered Officers Should Handle Ethically 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 or her service to, the Funds.  For example, a conflict of interest would arise if a Covered Officer, or a member of the officer’s family, receives improper personal benefits as a result of a position with the Funds.

 

Certain conflicts of interest arise out of the relationships between Covered Officers and the Funds and already are subject to conflict of interest provisions in the Investment Company Act of 1940 (“Investment Company Act”) and the Investment Advisers Act of 1940 (“Investment Advisers Act”).  For example, Covered Officers may not individually engage in certain transactions (such as the purchase or sale of securities or other property) with the Funds because of their status as “affiliated persons” of the Funds.  The Funds’ and the 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, replace these 

 

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