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

 

**PREAMBLE**	  We have a fiduciary duty to our clients. They deserve our undividedloyalty	  and effort, and their interests come first. We must avoid even theappearance	  of impropriety. Our personnel must not take inappropriate advantage of    their positions and the access to information that comes with theirpositions. 

	  Supervised persons must comply with applicable federal and statesecurities	  laws, as well as regulations and rules of the National Association ofSecurities  Dealers.                                     

	  The Board of Directors of Saturna Capital Corporation and the Board of	  Trustees of both Saturna Investment Trust and Amana Mutual Funds Trust	  adopted this Code of Ethics to assist in maintaining the highest standard	  of conduct.	  The Adviser and Fund encourage private investment activities, but such	  activities must be carried out within the letter and spirit of this Code.	  The Board of	  each Fund must approve any material change to this Code of Ethics within	  six months of the change. Questions should be brought to the attention	  of the	  Compliance Officer in advance of the execution of any trade. 	  By accepting employment with the Adviser or association with a Fund, you	  have agreed to be bound by this Code. This Code is a part of the Saturna	  Manual, which governs the operations of Saturna Capital and itsaffiliates.	  As part	  of the Saturna Manual, each employee annually certifies in writing his	  understanding of and intention to comply with this Code (including any  amendments).                                         

**SECTION 1 – DEFINITIONS**    (a) "Adviser" means Saturna Capital Corporation, including any    of its subsidiaries.	  (ii) “Fund” means any registered investment company adoptingthisCode of Ethics.(iii) “Compliance Officer” means the person so designated by theAdviser to act in that capacity.(iv) “Chief Compliance Officer” means the person designated by theAdviser and the Fund to act in that capacity under Rule 38a1 of the InvestmentCompany Act.Adviser does not include any consultant or sub-advisor whose only role is toadvise on general principles.(b) "Access person" means any director, officer, or advisory personof the Adviser or Fund.(c) "Advisory person" means:( i ) any employee of the Adviser or Fund who, in connection with his regularfunctions or duties, makes, participates in, or obtains information regardingthe purchase or sale of a security by the clients of the Adviser or the Fund,or whose functions relate to the making of any recommendations with respect tosuch purchases or sales; and(ii) any natural person in a control relationship to any client of the Adviseror Fund who obtains information concerning recommendations made to the clientconcerning the purchase or sale of a security.(d) A security is "being considered for purchase or sale" when arecommendationto purchase or sell a security has been made and communicated and, with respectto the person making the recommendation, when that person seriously considersmaking such a recommendation.(e) "Beneficial ownership" shall be interpreted in the same manneras it would be in determining whether a person is subject to the provisions ofSection 16 of the Securities Exchange Act of 1934 and the rules and regulationsthere under interpreted in a manner consistent with Rule 16a1(a)(2) under theExchange Act, except that the determination of direct or indirect beneficialownership shall apply to all securities that an access person has oracquires.(f) "Control" means the power to exercise a controlling influence overthe management or policies of a company, unless such power is solely the resultof an official position with such company. There is a presumption of controlon the part of any person who owns beneficially 25% of the voting securitiesof the company.(g) "Disinterested Trustee" means a trustee of a Fund who is not an"interestedperson" of the Fund. Only for purposes of this Code, it shall include atrustee of a Fund who, though an interested person of the Adviser by virtuebeingsolely a consultant to a Fund, is not an employee, officer or director of theAdviser.(h) "Interested person" of another person means, when used withrespectto a Fund:(i) any affiliated person of such company,(ii) any member of the immediate family of any natural person who is anaffiliatedperson of such company,(iii) any interested person of any investment adviser or principal underwriterfor such company,(iv) any person or partner or employee of any person who at any time since thebeginning of the last two fiscal years of such company has acted as legalcounselfor such company,(v) any broker or dealer registered under the Securities Exchange Act of 1934or any affiliated person of such a broker or dealer, and(vi) any natural person whom the Securities and Exchange Commission by ordershall have determined to be an interested person by reason of having had, atany time since the beginning of the last two fiscal years of such company, amaterial business or professional relationship with such company or with theprincipal executive officer of such company or with any other Investment Companyhaving the same Investment Adviser or principal underwriter or with theprincipalexecutive officer of such other Investment Company.*Provided*, That no person shall be deemed to be an interested person ofan InvestmentCompany solely because of (a) his being a member of its Board of Trustees oradvisory board or an owner of its securities, or (b) his membership in theimmediatefamily of any person speci-fied in clause (a) of this proviso.For the purposes of this paragraph (h), "member of the immediatefamily" meansany parent, spouse of a parent, child, spouse of a child, spouse, brother, orsister, and includes step and adoptive relation-ships.(i) "Purchase or sale of a security" includes, among other things,the writing of an option to purchase or sell a security.(j) "Security" means any note, stock, treasury stock, bond, debenture,mutual fund share, evi-dence of indebtedness, certificate of interest orparticipationin any profit—sharing agreement, collateral—trust certificate,preorganizationcertificate or subscription, transferable share, investment contract,voting—trustcertificate, certificate of deposit for a security, fractional undividedinterestin oil, gas, or other mineral rights, or any interest or instrument commonlyknown as a "security," or any certificate of interest or participationin, temporary or interim certificate for, receipt for, guarantee of, or warrantor right to subscribe to or purchase, any of the foregoing.“Security” does not include direct obligations of the Government of theUnited States (including short-term debt securities that are governmentsecuritieswithin the meaning of the Investment Company Act), bankers' acceptances, bankcertificates of deposit, commercial paper, repurchase agreements, otherhigh-qualityshort-term debt instruments, shares of registered open-end money-marketinvestmentcompanies, and securities based upon a recognized market index [includingderivatives(such as options or futures) based on a market index].(k) "Security held or to be acquired" by a client means any security(including any option on a security and any security that is convertible intoor exchangeable for) 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 the Adviser for purchaseby such client.(l) “Supervised person” means any employee of Saturna CapitalCorporationor its subsidiaries.

**SECTION 2 – EXEMPTED TRANSACTIONS**	  The prohibitions of Section 3 of this Code of Ethics shall not applyto:	  (a) Securities not Eligible for Clients. Purchases or sales of securities	  thatare not eligible for purchase or sale by any client.(b) Non-volitional Transactions. Purchases or sales that are non-volitional byeither the access person or any client (including transactions in fullydiscretionaryportfolio management accounts managed by registered investment advisers and withrespect to which such access person has no actual advance knowledge of a giventrade).(c) No Control. Purchases or sales effected in any account over which the accessperson has no direct or indirect influence or control.(d) Automatic Investment Plans. Purchases or sales made automatically inaccordancewith a predetermined schedule and allocation, such as dividend reinvestmentplans.(e) Rights Offerings. Purchases effected upon the exercise of rights issued byan issuer pro rata to all holders of a class of its securities, to the extentsuch rights were ac-quired from such issuer, and sales of rights soacquired.(f) Approved Transactions. Purchases or sales that receive the prior approvalof the Compliance Officer on the basis that they do not present the types ofconflicts of interest or potential harm intended to be covered by this Code ofEthics.(g) Disinterested Trustees. Transactions by a Disinterested Trustee and anyOfficerwho is not an affiliated person of the Adviser are subject to the provisionsof Sections 3 and 5 only if the Trustee/Officer, at the time of thattransaction,knew or, in the ordinary course of fulfilling his official duties as aTrustee/Officer,should have known that, during the five day period immediately preceding orafterthe date of the transaction by the Trustee/Officer, such security was purchasedor sold by the Fund 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 the average daily trading volume forthe last month.2) Purchases or sales that result in an open security position no larger than2,000 shares (or options thereon) for any stock in the Standard & Poor's500 Index, or 500 shares (or options thereon) for any stock in the Standard& Poor's400 Mid-Cap Index or Standard & Poor's 600 Small-Cap Index.(i) Section 28(e) transactions. Transactions executed by Saturna BrokerageServicesfor a Fund within the safe harbor of Section 28(e) of the 1934 Act will not bedeemed to violate the Section 17(e) general prohibitions.(j) Mutual funds. Purchases or sales of mutual fund shares.Any action, duty or responsibility delegated to the Compliance Officer or ChiefCompliance Officer under this Code of Ethics may, in his absence, and shall,with respect to actions involving the personal transactions of the ComplianceOfficer or Chief Compliance Officer, be performed by any director of theAdviser.

**SECTION 3 – PROHIBITED PURCHASES AND SALES**	  (a) Pre-Clearance Required. No employee of the Adviser or any accessperson	  shall purchase or sell, directly or indirectly, any security in which hehas,	  or becauseof such transaction acquires, any direct or indirect beneficial ownershipwithoutfirst obtaining the permission of the Compliance Officer, who shall makereasonableinquiry as to the trading or proposed trading or pending purchase or sale ordersby clients of the Adviser in such security. The Adviser will maintain recordsof the approval of, and rationale supporting, the acquisition of investmentsin IPO’s and Private Placements for at least five years after the end ofthe fiscal year in which the approval is granted.(b) Conflicting Trades. No employee or access person shall purchase or sell,directly or indirectly, any security in which he has, or because of suchtransactionacquires, any direct or indirect beneficial ownership, if the person knows atthe time of purchase or sale that the security(1) is being considered, or within five days preceding the proposed transactionhas been considered, for purchase or sale by any client; or(2) is being purchased or sold by any client, or was purchased or sold by aclientwithin the five days preceding the access person's transactions; or (3) is designated by the Adviser as a "Recommended Security" forconsiderationof any client for purchase or sale.However, an employee or access person may participate as part of a"bunch" orderwith clients simultaneously purchasing or selling a security. The Adviser mustdetermine that, for each transaction, bundling is consistent with best executionand no client is favored.(c) Blackout Period. No advisory person shall purchase or sell a security duringa period of five days before and five days after the date on which a Fund orclient for which he or she is portfolio manager or co-manager, engages in anypurchase or sale in such security; provided, however, that in appropriate casesthe Compliance Officer may waive such prohibition in his discretion if allclienttrades have been cleared or executed.(d) Initial Public Offerings. No access person or other employee may purchase,directly or indirectly, any security in which he has or because of suchtransactionacquires, any direct or indirect beneficial ownership and which to his actualknowledge at the time of such purchase or sale, is the subject of an initialpublic offering.(e) Private Placements. No advisory person may purchase, directly or indirectly,any security in which he has or because of such transaction acquires, any director indirect beneficial ownership, if such transaction is not in the open market,or if such transaction is made pursuant to any exemption from the registrationprovisions of the federal securities laws unless such transaction has beenapprovedin advance by the Compliance Officer.Provided, that in determining whether to grant permission for such privateplacement,the Compliance Officer shall consider, among other things, whether such offeringshould be reserved for a Fund or other client of the Adviser, and whether suchtransaction is being offered to the person because of his or her position withthe Adviser.Provided further, that any such person who has received such permission shallbe required to disclose such an investment when participating in any subsequentconsideration of such security for purchase or sale by clients of the Adviser,and that the decision to purchase or sell such security should be made bypersonswith no personal direct or indirect interest in the security.(f) Principal Transactions. Neither the adviser nor any affiliate may effecta transaction as principal with a client.(g)`Short-swing trades. Securities may not be purchased and sold, or sold andrepurchased, within 14 calendar days. The Compliance Officer may, for good causeshown, permit a short-swing trade, but shall record the reasons and grant ofpermission with the records of the Code.

**SECTION 4 – PROHIBITED ACTIVITIES**	  (a) Gifts and Gratuities. No advisory person shall receive, solicit or	  accept any gift or other thing of more than $25 in value from any personor	  entity thattransacts business with the Adviser, or with any client or Fund managed by theAdviser at the direction of such person.(b) Directorships. No advisory person shall serve as director of any publiclytraded company without first obtaining approval of the Compliance Officer. Anysuch approval shall be based on a determination by the Compliance Officer ordirectors that such board service will be consistent with the interests of theclients of the Adviser, and that such person serving as a director will beisolatedfrom those making investment decisions with respect to such company byappropriateprocedures. At the direction of the Compliance Officer, in his sole discretion,such person may be required to resign from such directorship.(c) Brokerage accounts. (1) Employees and access persons desiring to trade securities for their ownaccountsare strongly encouraged, but not required, to open and maintain accounts withSaturna Brokerage Services, and to place all securities trades through SaturnaBrokerage. No employee or access person may open or maintain a securitiestradingaccount, of any type, in which he or she has any direct or indirect interestunless the Compliance Officer approves such account in advance. Any personmaintainingany such account shall instruct the broker with which such account is maintainedto send copies of confirmations of all personal securities transactions andcopiesof periodic statements with respect to such account directly to the ComplianceOfficer. (2) All access persons not maintaining a securities trading account with SaturnaBrokerage shall be responsible for maintaining on the NEPTUNE recordkeepingsystemof Saturna Brokerage an accurate inventory of all securities held by such personthat are required to be reported under this Code of Ethics. The name of thebroker,dealer or bank with which any account is established, and the date the accountis established, must be reported to the Compliance Officer.(d) Disclosure. No access person may recommend or attempt to cause anysecuritiestransactions by a client or participate in any investment decision withoutdisclosinghis interest in the securities.(e) Insider Trading. (1) Employees obtaining material nonpublic information should refrain fromdisclosingthat information to anyone. Additionally, employees should not trade in thesecuritiesto which the information relates.(2) Employees who are aware of the misuse of material nonpublic informationshouldreport such to the Compliance Officer.(f) Waivers. The Compliance Officer or Chief Compliance Officer, in unusualcircumstancesand for good cause shown, may recommend to an ad hoc committee consisting ofthe Compliance Officer plus one other director of Saturna, the waiver of anyof the prohibitions in Section 3 and Section 4 as to any particular set ofcircumstances,and such prohibition may be waived in such limited circumstances by such ad hoccommittee. A copy of the minutes of their deliberations shall be maintained withthe records regarding enforcement of this Code of Ethics.

**SECTION 5 – REPORTING**	  (a) Trade Executions. Every access person and employee shall report to	  the Compliance Officer the information described in Section 5(c) of thisCode	  of Ethics withrespect to transactions in any security in which such person has, or becauseof such transaction acquires, any direct or indirect beneficial ownership inthe security. (b) Required Information. Every report shall be made not later than ten (10)days after the end of the execution of the transaction, and shall contain thefollowing information:(1) The date of the transaction, the title and the number of shares, and theprincipal amount of each security involved;(2) The nature of the transaction (i.e., purchase, sale or any other type ofacquisition or disposition);(3) The price at which the transaction was effected; and,(4) The name of the broker, dealer or bank with or through whom the transactionwas effected.(c) Review of reports. (1) The Chief Compliance Officer shall be responsible for a quarterly review,as prepared by the Adviser's NEPTUNE system, which compares the reportedpersonalsecurities transactions of employees with completed portfolio transactions ofclients to determine whether a violation of this Code of Ethics may haveoccurred.The Chief 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 each calendar year, the Fund boards mustbe provided and review an annual report from the Adviser on compliance for theprevious year. The Boards must receive a certification that the Fund and theAdviser "have adopted procedures reasonably necessary to prevent AccessPersons from violating" their codes (a) before approving this Code ofEthicsand (b) "not less frequently than annually" thereafter. The annualreport to the Fund boards must describe any issues and material violationsarisingunder this Code since the last report.(d) Not considered admission. Any such report may contain a statement that thereport shall not be construed as an admission by the person making such reportthat he has any direct or indirect beneficial ownership in the security to whichthe report relates.(e) Political Contributions. 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. Within ten days of employment, access persons are requiredto provide initial reports of their securities holdings. In conjunction withthe Adviser's annual employee compliance meeting (normally held in August), andmore frequently if instructed by the Compliance Officer, all Adviser personnelshall certify the accuracy of the inventory of their securities holdings on theNEPTUNE recordkeeping system, and to their knowledge of and compliance with thisCode of Ethics. (g) Fund Disclosure. As provided under Rule 17j1, Funds disclose in theirregistrationstatements (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 Codeof Ethics is filed as an exhibit to the Funds' registration statements and isavailable online at Saturna Capital’s website.

**SECTION 6 – SANCTIONS**  Any violations discovered by or reported to the Compliance Officer or ChiefCompliance  Officer shall be reviewed and investigated promptly, and reported through the  Chief Compliance Officer to the Board of Directors of the Adviser, with copies  to Fund boards. Such report shall include the corrective action taken and any  recommendation for disciplinary action deemed appropriate by the ChiefCompliance  Officer. Such recommendation shall be based on, among other things, theseverity  of the infraction, whether it is a first or repeat offense, and whether it is  part of a pattern of disregard for the letter and intent of this Code ofEthics.  Upon recommendation of the Chief Compliance Officer, the Board of Directors of  the Adviser may impose such sanctions for violation of this Code of Ethics as  it deems appropriate, including, but not limited to:  (a) letter of censure;  (b) suspension or termination of the employment;   (c) reversal of a securities trade at the violator’s expense and risk,  including disgorgement of any profit; and   (d) in serious cases, referral to law enforcement or regulatoryauthorities.