**CODE OF ETHICS**of SATURNA CAPITAL CORPORATION under Rule 204a1 of the InvestmentAdvisers Act including its subsidiary SATURNA BROKERAGE SERVICES,INC. and SATURNA INVESTMENT TRUST AMANA MUTUAL FUNDSTRUST under Rule 17f1 of the Investment Companies Act**PREAMBLE**

We have a fiduciary duty to our clients. They deserve ourundivided loyalty and effort, and their interests come first. We must avoid eventhe appearance of impropriety. Our personnel must not take inappropriateadvantage of their positions and the access to information that comes with theirpositions. 

Supervised persons must comply withapplicable federal and state securities laws, as well as regulations and rulesof the National Association of Securities Dealers.

TheBoard of Directors of Saturna Capital Corporation and the Board of Trustees ofboth Saturna Investment Trust and Amana Mutual Funds Trust adopted this Code ofEthics to assist in maintaining the highest standard of conduct. The Adviser andFund encourage private investment activities, but such activities must becarried out within the letter and spirit of this Code. The Board of each Fundmust approve any material change to this Code of Ethics within six months of thechange. Questions should be brought to the attention of the Compliance Officerin advance of the execution of any trade. 

By acceptingemployment with the Adviser or association with a Fund, you have agreed to bebound by this Code. This Code is a part of the Saturna Manual, which governs theoperations of Saturna Capital and its affiliates. As part of the Saturna Manual,each employee annually certifies in writing his understanding of and intentionto comply with this Code (including any amendments).

**SECTION 1 – DEFINITIONS**
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(a) **"Adviser"** meansSaturna Capital Corporation, including any of its subsidiaries.

(i) **“Fund”**means any registeredinvestment company adopting this Code of Ethics.

(ii)**“Compliance Officer”** means the person so designatedby the Adviser to act in that capacity.

(iii)**“Chief Compliance Officer”** means the persondesignated by the Adviser and the Fund to act in that capacity under Rule 38a1of the Investment Company Act. Adviser does not include anyconsultant or sub-advisor whose only role is to advise on generalprinciples.

(b) **"Accessperson"** means any director, officer, or advisory person of theAdviser or Fund.

(c) **"Advisoryperson"** means:

(i) anyemployee of the Adviser or Fund who, in connection with his regular functions orduties, makes, participates in, or obtains information regarding the purchase orsale of a security by the clients of the Adviser or the Fund, or whose functionsrelate to the making of any recommendations with respect to such purchases orsales; and

(ii) any natural person in a controlrelationship to any client of the Adviser or Fund who obtains informationconcerning recommendations made to the client concerning the purchase or sale ofa security.

(d) A security is**"being considered for purchase or sale"** when arecommendation to purchase or sell a security has been made and communicatedand, with respect to the person making the recommendation, when that personseriously considers making such a recommendation.

(e)**"Beneficial ownership"** shall be interpreted in thesame manner as it would be in determining whether a person is subject to theprovisions of Section 16 of the Securities Exchange Act of 1934 and the rulesand regulations there under interpreted in a manner consistent with Rule16a-1(a)(2) under the Exchange Act, except that the determination of direct orindirect beneficial ownership shall apply to all securities that an accessperson has or acquires. “Direct or indirect beneficial ownership”means direct or indirect influence or control or ownership of any beneficialinterest.

(f) **"Control"** meansthe power to exercise a controlling influence over the management or policies ofa company, unless such power is solely the result of an official position withsuch company. There is a presumption of control on the part of any person whoowns beneficially 25% of the voting securities of the company.

(g) **"Disinterested Trustee"** means atrustee of a Fund who is not an "interested person" of the Fund. Onlyfor purposes of this Code, it shall include a trustee of a Fund who, though aninterested person of the Adviser by virtue being solely a consultant to a Fund,is not an employee, officer or director of the Adviser.

(h) **"Interested person"** of anotherperson means, when used with respect to a Fund:

(i) any affiliated person of such company,

(ii) any member of the immediate family of any natural personwho is an affiliated person of such company,

(iii) anyinterested person of any investment adviser or principal underwriter for suchcompany,

(iv) any person or partner or employee of anyperson who at any time since the beginning of the last two fiscal years of suchcompany has acted as legal counsel for such company,

(v)any broker or dealer registered under the Securities Exchange Act of 1934 or anyaffiliated person of such a broker or dealer, and

(vi)any natural person whom the Securities and Exchange Commission by order shallhave determined to be an interested person by reason of having had, at any timesince the beginning of the last two fiscal years of such company, a materialbusiness or professional relationship with such company or with the principalexecutive officer of such company or with any other Investment Company havingthe same Investment Adviser or principal underwriter or with the principalexecutive officer of such other Investment Company.*Provided,* That no person shall be deemed to be an interested person ofan Investment Company solely because of (a) his being a member of its Board ofTrustees or advisory board or an owner of its securities, or (b) his membershipin the immediate family of any person speci-fied in clause (a) of thisproviso. For the purposes of this paragraph (h), "member ofthe immediate family" means any parent, spouse of a parent, child, spouseof a child, spouse, brother, or sister, and includes step and adoptiverelation-ships.

(i) **"Purchaseor sale of a security"** includes, among other things, the writingof an option to purchase or sell a security.

(j)**"Security"** means any note, stock, treasury stock,bond, debenture, mutual fund share, evidence of indebtedness, certificate ofinterest or participation in any profit-sharing agreement, collateral-trustcertificate, preorganization certificate or subscription, transferable share,investment contract, voting-trust certificate, certificate of deposit for asecurity, fractional undivided interest in oil, gas, or other mineral rights, orany interest or instrument commonly known as a "security," or anycertificate of interest or participation in, temporary or interim certificatefor, receipt for, guarantee of, or warrant or right to subscribe to or purchase,any of the foregoing.

**“Security”** does**not** include direct obligations of the Government of the UnitedStates (including short-term debt securities that are government securitieswithin the meaning of the Investment Company Act), bankers' acceptances, bankcertificates of deposit, commercial paper, repurchase agreements, otherhigh-quality short-term debt instruments, shares of registered open-endmoney-market investment companies, and securities based upon a recognized marketindex [including derivatives (such as options or futures) based on a marketindex].

(k) **"Security held orto be acquired"** by a client means any security (including anyoption on a security and any security that is convertible into or exchangeablefor) which, within the most recent fifteen (15) days:

(i) is or has been held by such client, or

(ii) is being or has been considered by such client or theAdviser for purchase by such client.

(l)**“Supervised person”** means any employee of SaturnaCapital Corporation or its subsidiaries.

**SECTION 2 – EXEMPTEDTRANSACTIONS**

The prohibitions of Section3 of this Code of Ethics shall not apply to:
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(a) ***Securities not Eligible forClients.*** Purchases or sales of securities that are not eligiblefor purchase or sale by any client.

(b)***Non-volitional Transactions.*** Purchases or sales thatare non-volitional by either the access person or any client (includingtransactions in fully discretionary portfolio management accounts managed byregistered investment advisers and with respect to which such access person hasno actual advance knowledge of a given trade).

(c)***No Control.*** Purchases or sales effected in any accountover which the access person has no direct or indirect influence or control.

(d) ***Automatic Investment Plans.***Purchases or sales made automatically in accordance with apredetermined schedule and allocation, such as dividend reinvestment plans.

(e) ***Rights Offerings.*** Purchaseseffected 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 wereacquired from such issuer, and sales of rights so acquired.

(f) ***Approved Transactions.*** Purchasesor sales that receive the prior approval of the Compliance Officer on the basisthat they do not present the types of conflicts of interest or potential harmintended to be covered by this Code of Ethics.

(g)***Disinterested Trustees.*** Transactions by aDisinterested Trustee and any Officer who is not an affiliated person of theAdviser are subject to the provisions of Sections 3 and 5 only if theTrustee/Officer, at the time of that transaction, knew or, in the ordinarycourse of fulfilling his official duties as a Trustee/Officer, should have knownthat, during the five day period immediately preceding or after the date of thetransaction by the Trustee/Officer, such security was purchased or sold by theFund or was being considered for purchase by its Adviser.

(h) ***Insignificant Position.***

1) Purchases or sales that result in an open(long or short) security position (or options thereon) no larger than 1% of theaverage daily trading volume for the last month. 2) Purchases or salesthat result in an open security position no larger than 2,000 shares (or optionsthereon) for any stock in the Standard & Poor's 500 Index, or 500 shares (oroptions thereon) for any stock in the Standard & Poor's 400 Mid-Cap Index orStandard & Poor's 600 Small-Cap Index.

(i)***Section 28(e) transactions.***Transactions executed by Saturna Brokerage Services for a Fund within the safeharbor of Section 28(e) of the 1934 Act will not be deemed to violate theSection 17(e) general prohibitions.

(j)***Mutual funds.*** Purchases or sales of mutual fundshares.

 Any action, duty or responsibilitydelegated to the Compliance Officer or Chief Compliance Officer under this Codeof Ethics may, in his absence, and shall, with respect to actions involving thepersonal transactions of the Compliance Officer or Chief Compliance Officer, beperformed by any director of the Adviser.

**SECTION 3 – PROHIBITED PURCHASES AND SALES**
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(a) ***Pre-ClearanceRequired.*** No employee of the Adviser or any access person shallpurchase or sell, directly or indirectly, any security in which he has, orbecause of such transaction acquires, any direct or indirect beneficialownership without first obtaining the permission of the Compliance Officer, whoshall make reasonable inquiry as to the trading or proposed trading or pendingpurchase or sale orders by clients of the Adviser in such security. The Adviserwill maintain records of the approval of, and rationale supporting, theacquisition of investments in IPO’s and Private Placements for at leastfive years after the end of the fiscal year in which the approval isgranted.

(b) ***ConflictingTrades.*** No employee or access person shall purchase or sell,directly or indirectly, any security in which he has, or because of suchtransaction acquires, any direct or indirect beneficial ownership, if the personknows at the time of purchase or sale that the security

(1) is being considered, or within five days preceding theproposed transaction has been considered, for purchase or sale by any client;or

(2) is being purchased or sold by any client, or waspurchased or sold by a client within the five days preceding the access person'stransactions; or 

(3) is designated by the Adviser as a"Recommended Security" for consideration of any client for purchase orsale.

However, an employee or access personmay participate as part of a "bunch" order with clients simultaneouslypurchasing or selling a security. The Adviser must determine that, for eachtransaction, bundling is consistent with best execution and no client isfavored.

(c) ***Blackout Period.***No advisory person shall purchase or sell a security during a period of fivedays before and five days after the date on which a Fund or client for which heor she is portfolio manager or co-manager, engages in any purchase or sale insuch security; provided, however, that in appropriate cases the ComplianceOfficer may waive such prohibition in his discretion if all client trades havebeen cleared or executed.

(d) ***Initial PublicOfferings.*** No access person or other employee may purchase,directly or indirectly, any security in which he has or because of suchtransaction acquires, any direct or indirect beneficial ownership and which tohis actual knowledge at the time of such purchase or sale, is the subject of aninitial public offering.

(e)***PrivatePlacements.*** No advisory person may purchase, directly orindirectly, any security in which he has or because of such transactionacquires, any direct or indirect beneficial ownership, if such transaction isnot in the open market, or if such transaction is made pursuant to any exemptionfrom the registration provisions of the federal securities laws unless suchtransaction has been approved in advance by the Compliance Officer.

*Provided,* that in determining whether to grantpermission for such private placement, the Compliance Officer shall consider,among other things, whether such offering should be reserved for a Fund or otherclient of the Adviser, and whether such transaction is being offered to theperson because of his or her position with the Adviser.

*Provided further,* that any such person who has receivedsuch permission shall be required to disclose such an investment whenparticipating in any subsequent consideration of such security for purchase orsale by clients of the Adviser, and that the decision to purchase or sell suchsecurity should be made by persons with no personal direct or indirect interestin the security.

(f) ***PrincipalTransactions***. Neither the adviser nor any affiliate may effect atransaction as principal with a client.

(g)***Short-swing trades.*** Securities may not be purchasedand sold, or sold and repurchased, within 14 calendar days. The ComplianceOfficer may, for good cause shown, permit a short-swing trade, but shall recordthe reasons and grant of permission with the records of the Code.

**SECTION 4 –PROHIBITED ACTIVITIES**

(a) Gifts andGratuities 
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(1) ***Definitions: Asused in this Section:***

**"Advisory Person"** is defined inSection 1(c) of this Code. All employees, officers and directors of Saturna are**Advisory Persons**. The term **“AdvisoryPerson”** does not include a **Trustee**.

**"Business Entertainment”** meansordinary and usual business entertainment such as an occasional meal, ticket toa sporting event or theater, or comparable entertainment, so long as it isneither so frequent nor so extensive as to raise any question of propriety andthe person providing the **Business Entertainment*****must*** accompany the recipient to any such function

**“Director”** means a director of**Saturna**.

**“EnterpriseLimit”** means the total value of all **Gifts** and**Business Entertainment** that may be given to, or accepted from,a **Restricted Person**, by **Advisory Persons** and**Trustees**, taken as a group, in any 12-month period.

**"Gift"** includes anything of value,but does not include ordinary and usual **“BusinessEntertainment.”**

A**“Restricted Person”** is any person (which includesboth individuals and business entities) that transacts business with**Saturna** or any **Fund**. All of the**Restricted Person’s** employees, officers, directors,representatives, affiliates, controlled entities and other persons in similarcapacities are considered to be part of the **RestrictedPerson**.

**“Saturna”**means Saturna Capital Corporation, including its subsidiaries and controlledentities.

**“Trustee”** means a**Trustee** of a registered investment company managed by Saturna(a “Fund”).

(2)***Limit on Gifts and Business Entertainment***
**Note: The following table represents the limitations onGifts and Business Entertainment, accepted from or given to, either directly orindirectly, a Restricted Person.**CLASSIFICATION OF PERSONSTOTAL COMBINED VALUE OF ALL GIFTS IN ANY 12-MONTH PERIODTOTAL COMBINED VALUE OF GIFTS AND BUSINESSENTERTAINMENT WITHIN A 12-MONTH PERIODENTERPRISE LIMITAdvisory Persons who are not Directors or Trustees$100$250$500Directors and Trustees$100$1,000$2,500
(3)***Reporting***

All **AdvisoryPersons** and **Trustees** giving or receiving**Gifts** or **Business Entertainment** as permittedby Paragraph (b) within 10 working days following the giving or receipt of anygift or business entertainment shall report to the Chief Compliance Officer thefollowing information:
- The name of the  RestrictedPerson  giving or receiving the  Gifts  or Business Entertainment ;
- The name and employer of the Restricted Person  to or from which the  Gifts and  Business Entertainment  were given or received;
- Thedate on which the  Gifts  and  BusinessEntertainment  were given or received, a description of the Gifts andBusiness Entertainment; and
-  The estimated value of the Gifts  or  Business Entertainmnent . 

(4) ***Payment or Reimbursement of Expenses.***

Payments of an Advisory Person’s,Director’s or Trustee’s (“Attendee”) expenses inconnection with meetings held by an offeror or by an NASD member, for thepurpose of training or education of the Attendee may be received, *providedthat*:
- The record keeping requirement in paragraph (c) issatisfied, including all compensation received, the name of the offeror or NASDmember, the amount of cash received, and the nature and, if known, value of anynon-cash compensation;
-  The Attendee obtains Saturna’s priorapproval to attend the meeting;
-  The location is appropriate to thepurpose of the meeting, which shall mean an office of the offeror or the NASDmember, or a facility located in the vicinity of such office, or a regionallocation with respect to regional meetings;
-  The payment orreimbursement is not applied to the expenses of guests of the Attendee; and
-  The payment or reimbursement by the offeror is not subject to anyconditions.

(5)***Exception***

The limits of this Paragraph (a)shall not apply to any expenses incurred by any Fund or Trustee which are paidby the Adviser in connection with any meeting, conference, education or otheractivity of any kind related to business of a Fund.

(b) ***Directorships.*** No advisory personshall serve as director of any publicly traded company without first obtainingapproval of the Compliance Officer. Any such approval shall be based on adetermination by the Compliance Officer or directors that such board servicewill be consistent with the interests of the clients of the Adviser, and thatsuch person serving as a director will be isolated from those making investmentdecisions with respect to such company by appropriate procedures. At thedirection of the Compliance Officer, in his sole discretion, such person may berequired to resign from such directorship.

(c)***Brokerage accounts.***
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(1) All employees and access persons who own ortrade securities must maintain a brokerage account with Saturna BrokerageServices, and hold all of their securities in that account, and perform alltrading through that account; provided, however, that such person is notrequired to purchase no-load mutual funds through Saturna Brokerage Services ifand only if the purchase is made directly from the no-load fund and suchtransactions are entered into the person’s account maintained on NEPTUNEfor reporting purposes.

(2) Employees and access personsmay not, directly or indirectly, have an interest in any brokerage or tradingaccount outside of SBS. Employees having any such account shall arrange totransfer all such accounts to SBS. 

(3) The President maypermit, in unusual circumstances and for good cause shown, an access person tomaintain an account other than with SBS, if such account (i) is managed by aperson not related to such access person, (ii) such manager is a registeredinvestment adviser, (iii) such manager has acknowledged in writing to thePresident that such adviser is aware that the access person is not permitted tohave advance knowledge of the specifics of any transaction in the account; and(iv) such access person in fact has no advance knowledge of any transaction.And, provided further that

(a) Any accessperson permitted to maintain such an account not with SATURNA BROKERAGESERVICES, shall instruct the manager or custodian with which such account ismaintained to send copies of confirmations of all personal securitiestransactions and copies of periodic statements with respect to such accountdirectly to the Compliance Officer; and 

(b) Such accessperson shall be responsible for maintaining on the NEPTUNE recordkeeping systemof Saturna Brokerage an accurate inventory of all securities held by such personthat are required to be reported under this Code of Ethics. 

(d) ***Disclosure.*** Noaccess person may recommend or attempt to cause any securities transactions by aclient or participate in any investment decision without disclosing his interestin the securities.

(e) ***Insider Trading.***
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(1) Employees obtainingmaterial nonpublic information should refrain from disclosing that informationto anyone. Additionally, employees should not trade in the securities to whichthe information relates.

(2) Employees who are aware ofthe misuse of material nonpublic information should report such to theCompliance Officer.

(f) ***ShortSales and Options.***
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(1) AccessPersons may not sell short any security on the Adviser’s Recommended List.Portfolio managers may not conduct short sales of any security.

(2) Access Persons may not purchase any option or other securityin combination with any other options or securities from which the Access Personwould, directly or indirectly, benefit from a price decline in any stock on theRecommended List.

(g)***Waivers.*** The Compliance Officer or Chief ComplianceOfficer, in unusual circumstances and for good cause shown, may recommend to an*ad hoc*committee consisting of the Compliance Officer plus one otherdirector of Saturna, the waiver of any of the prohibitions in Section 3 andSection 4 as to any particular set of circumstances, and such prohibition may bewaived in such limited circumstances by such *ad hoc* committee. A copyof the minutes of their deliberations shall be maintained with the recordsregarding enforcement of this Code of Ethics.

**SECTION 5 – REPORTING**

(a) ***Trade Executions.*** Every accessperson and employee shall report to the Compliance Officer the informationdescribed in Section 5(b) of this Code of Ethics with respect to transactions inany security in which such person has, or because of such transaction acquires,any direct or indirect beneficial ownership in the security. 

(b) ***Required Information.*** Every reportshall be made not later than ten (10) days after the end of the execution of thetransaction, and shall contain the following information:
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(1) The date of the transaction, the title and the number ofshares, and the principal amount of each security involved;

(2) The nature of the transaction (i.e., purchase, sale or anyother type of acquisition or disposition);

(3) The priceat which the transaction was effected; and,

(4) The nameof the broker, dealer or bank with or through whom the transaction waseffected.

(c) ***Review ofreports.***
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(1) The ChiefCompliance Officer shall be responsible for a quarterly review, as prepared bythe Adviser's NEPTUNE system, which compares the reported personal securitiestransactions of employees with completed portfolio transactions of clients todetermine whether a violation of this Code of Ethics may have occurred. TheChief Compliance Officer shall also review any initial and annual holdingsreports. The Adviser will maintain the names of the persons reviewing thesereports. 

(2) At their first regular meeting in eachcalendar year, the Fund boards must be provided and review an annual report fromthe Adviser on compliance for the previous year. The Boards must receive acertification that the Fund and the Adviser "have adopted proceduresreasonably necessary to prevent Access Persons from violating" their codes(a) before approving this Code of Ethics and (b) "not less frequently thanannually" thereafter. The annual report to the Fund boards must describeany issues and material violations arising under this Code since the lastreport.

(d) ***Not consideredadmission.*** Any such report may contain a statement that the reportshall not be construed as an admission by the person making such report that hehas any direct or indirect beneficial ownership in the security to which thereport relates.

(e) ***PoliticalContributions.*** Any employee making political contributions, incash or services, must report each such contribution to the municipal principalquarterly, who will compile and report thereon as required under relevantregulations.

(f) ***Certification.***
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(1) Within ten days of employment, allpersonnel shall meet with the Chief Compliance Officer to discuss the reportingrequirements of this Section. At that time, the employee shall deliver to theCCO a complete record of all securities holdings in which the employee has adirect or indirect beneficial interest, and shall provide the CCO with evidencethat the employee has made provision with SBS to open an account with SBS, andas soon as practicable, arrange to transfer all securities holdings to SBS andclose any previous outside accounts.

(2) At the end ofthe employee’s first month of employment, the employee shall meet with theCCO and demonstrate that the employee has completed the process of closing alloutside accounts and moving all holdings to SBS. If the employee has not doneso, or is having difficulty doing so, the CCO will provide appropriate guidanceand assistance to the employee to complete the process.

(3) In conjunction with the Adviser's annual employee compliancemeeting (normally held in August), and more frequently if instructed by theCompliance Officer, all Adviser personnel shall certify the accuracy of theinventory of their securities holdings on the NEPTUNE recordkeeping system, andto their knowledge of and compliance with this Code of Ethics. 

(4) An employee’s willful non-compliance with completionof this process shall be considered a violation of this Code of ethics.

(g) ***Fund Disclosure.***As provided under Rule 17j1, Funds disclose in their registrationstatements (1) that the Fund and its Adviser have adopted this Code of Ethics,(2) that this Code permits personnel to invest in securities for their ownaccounts, and (3) that this Code is on public file, and available from, the SEC.This Code of Ethics is filed as an exhibit to the Funds' registration statementsand is available online at Saturna Capital’s website.

**SECTION 6 –SANCTIONS**

Any violations discovered by orreported to the Compliance Officer or Chief Compliance Officer shall be reviewedand investigated promptly, and reported through the Chief Compliance Officer tothe Board of Directors of the Adviser, with copies to Fund boards. Such reportshall include the corrective action taken and any recommendation fordisciplinary action deemed appropriate by the Chief Compliance Officer. Suchrecommendation shall be based on, among other things, the severity of theinfraction, whether it is a first or repeat offense, and whether it is part of apattern of disregard for the letter and intent of this Code of Ethics. Uponrecommendation of the Chief Compliance Officer, the Board of Directors of theAdviser may impose such sanctions for violation of this Code of Ethics as itdeems appropriate, including, but not limited to:
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(a) letter of censure;

(b) suspension ortermination of the employment; 

(c) reversal of asecurities trade at the violator’s expense and risk, includingdisgorgement of any profit; and 

(d) in serious cases,referral to law enforcement or regulatory authorities.