OFFICIAL CODE OF ETHICS
                                       FOR
                         21ST CENTURY TECHNOLOGIES, INC.

         PURSUANT TO 247CFR WHICH REQUIRES REGISTERED INVESTMENT COMPANIES AND
THEIR INVESTMENT ADVISORS AND PRINCIPAL UNDERWRITERS TO ADOPT A CODE OF ETHICS
AND REPORTING REQUIREMENTS TO PREVENT FRAUDULENT, DECEPTIVE AND MANIPULATIVE
PRACTICES, THE FOLLOWING DOCUMENT SETS FORTH 21ST CENTURY TECHNOLOGIES, INC.'S
OFFICIAL CODE OF ETHICS AS ADOPTED BY THE CORPORATION'S BOARD OF DIRECTORS ON
AUGUST 27, 2003.

SECTION 1 - DEFINITIONS

         (1) "Fund" shall mean 21st Century Technologies, Inc.
         (2) "Access person" means any director, officer, general partner, or
             advisory person of the Fund.
         (3) "Advisory person" means any employee of the Fund, 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 Fund, 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 Fund
             who obtains information concerning recommendations made to the Fund
             with regard to the purchase or sale of a security.
         (4) "Purchase or sale of a security" includes, INTER ALIA, the writing
             of an option to purchase or sell a security.
         (5) "Control" shall have the same meaning as that set forth in Section
             2(a)(9) of the Investment Company Act.
         (6) "Security" shall have the meaning set forth in 2(a)(36) of the
             Investment Company Act, 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, bankers' acceptances, bank
             certificates of deposit, commercial paper, and such other money
             market instruments as designated by the board.
         (7) "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 there under, except that the
             determination of direct or indirect beneficial ownership shall
             apply to all securities which an access person has or acquires.
         (8) "Investment company" means a company registered as such under the
             Investment Company Act of 1940, as amended.
         (9) "Manipulation" means to alter by artful, insidious, or unfair means
             to serve one's purpose.

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         SECTION 2 - PROHIBITIONS

         No access person of 21st Century Technologies, Inc., or any of it's
         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:

         (a) is being considered for purchase or sale by the Fund; or
         (b) is being purchased or sold by the Fund; or
         (c) is being sold short by the Fund.

         SECTION 3 - EXEMPTED TRANSACTIONS

         The prohibitions of Section 2 of this Code shall not apply to:

         (a) Purchases or sales affected in any account over which the access
             person has no direct or indirect influence or control.
         (b) Purchases or sales of securities that are not eligible for purchase
             or sale by the Fund.
         (c) Purchases or sales that are non-volitional on the part of either
             the access person or the Fund.
         (d) Purchases, which are part of an automatic dividend reinvestment
             plan.
         (e) 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.
         (f) Purchases or sales that receive the prior approval of the Fund's
             Board because they are only remotely potentially harmful to the
             Fund, 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
             Fund.

         SECTION 4 - REPORTING

         (a) Every access person shall voluntarily report to the Fund, 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 amount over
             which such person does not have any direct or indirect influence.
         (b) A disinterested director of the Fund need only report a transaction
             in a security if such director, at the time of that transactions,
             knew or, in the ordinary course of fulfilling his or her official
             duties as a director of the Fund, 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 Fund or
             was being considered by the Fund or its investment advisor for the
             purchase or sale by the Fund.

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         (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:

             (i) The date of the transaction, the title and number of shares,
                 and the principal amount of each security involved.
             (ii) The nature of the transaction (i.e., purchase, sale or any
                 other type of acquisition or disposition).
             (iii) The price at which the transaction was effected.
             (iv) The name of the broker, dealer or bank with or through whom
                 the transaction was effected.

         It is the intent of the Fund to abide by Rule 17j-1, the Rule dictates
         the reporting requirement, and as the Role is amended, from time to
         time, to review the Rule to insure that the Fund diligently abides by
         all aspects of the reporting requirements under said Rule.

         SECTION 5 - SANCTIONS

                  Section (b)(1) of Rule 17j-1 requires Funds to "use reasonable
         diligence, and institute procedures reasonably necessary, to prevent
         violations" of its codes of ethics.

                  Upon discovering a violation of this Code of Ethics , the
         board of directors of the Fund 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.

                  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.

         SECTION 7 - SIGNATURES




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