**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 undivided loyalty    and effort, and their interests come first. We must avoid even theappearance    of  impropriety. Our personnel must not take inappropriate advantage of theirpositions  and the access to information that comes with their positions.   Supervised persons must comply with applicable federal and state securities  laws, as well as regulations and rules of the National Association ofSecurities  Dealers.  The Board of Directors of Saturna Capital Corporation and the Board ofTrustees  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 its affiliates. 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 adopting this  Code of Ethics.  (iii) “Compliance Officer” means the person so designated by the  Adviser to act in that capacity.  (iv) “Chief Compliance Officer” means the person designated by  the Adviser and the Fund to act in that capacity under Rule 38a1 of theInvestment  Company Act.  Adviser does not include any consultant or sub-advisor whose only role is to  advise on general principles.  (b) "Access person" means any director, officer, or advisory person  of the Adviser or Fund.  (c) "Advisory person" means:  ( i ) any employee of the Adviser or Fund who, in connection with his regular  functions or duties, makes, participates in, or obtains information regarding  the 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  to such purchases or sales; and  (ii) any natural person in a control relationship to any client of the Adviser  or Fund who obtains information concerning recommendations made to the client  concerning the purchase or sale of a security.  (d) A security is "being considered for purchase or sale" when a  recommendation to purchase or sell a security has been made and communicated  and, with respect  to the person making the recommendation, when that person seriously considers  making such a recommendation.  (e) "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 andregulations  there under interpreted in a manner consistent with Rule 16a1(a)(2) under the  Exchange Act, except that the determination of direct or indirect beneficial  ownership shall apply to all securities that an access person has oracquires.  (f) "Control" means the power to exercise a controlling influence  over the management or policies of a company, unless such power is solely the  result  of an official position with such company. There is a presumption of control  on the part of any person who owns beneficially 25% of the voting securities  of the company.  (g) "Disinterested Trustee" means a trustee of a Fund who is not an"interested  person" of the Fund. Only for purposes of this Code, it shall include  a trustee of a Fund who, though an interested 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 another person means, when used withrespect  to a Fund:  (i) any affiliated person of such company,  (ii) any member of the immediate family of any natural person who is anaffiliated  person of such company,  (iii) any interested person of any investment adviser or principal underwriter  for such company,  (iv) any person or partner or employee of any person who at any time since  the beginning of the last two fiscal years of such company has acted as legal  counsel  for such company,  (v) any broker or dealer registered under the Securities Exchange Act of 1934  or any affiliated person of such a broker or dealer, and  (vi) any natural person whom the Securities and Exchange Commission by order  shall have determined to be an interested person by reason of having had, at  any time since the beginning of the last two fiscal years of such company,  a material business or professional relationship with such company or with  the  principal executive officer of such company or with any other InvestmentCompany  having the same Investment Adviser or principal underwriter or with theprincipal  executive officer of such other Investment Company.  Provided, That no person shall be deemed to be an interested person of anInvestment  Company solely because of (a) his being a member of its Board of Trustees or  advisory board or an owner of its securities, or (b) his membership in the  immediate family of any person speci-fied in clause (a) of this proviso.  For the purposes of this paragraph (h), "member of the immediatefamily" means  any parent, spouse of a parent, child, spouse of a child, spouse, brother,  or sister, 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 orparticipation  in any profit—sharing agreement, collateral—trust certificate,preorganization  certificate or subscription, transferable share, investment contract,voting—trust  certificate, certificate of deposit for a security, fractional undividedinterest  in oil, gas, or other mineral rights, or any interest or instrument commonly  known as a "security," or any certificate of interest orparticipation  in, temporary or interim certificate for, receipt for, guarantee of, orwarrant  or right to subscribe to or purchase, any of the foregoing.“  Security” does not include direct obligations of the Government of the  United States (including short-term debt securities that are governmentsecurities  within the meaning of the Investment Company Act), bankers' acceptances, bank  certificates of deposit, commercial paper, repurchase agreements, otherhigh-quality  short-term debt instruments, shares of registered open-end money-marketinvestment  companies, 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 into  or 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 forpurchase  by such client.  (l) “Supervised person” means any employee of Saturna CapitalCorporation  or its subsidiaries.**SECTION 2 – EXEMPTED TRANSACTIONS**  The prohibitions of Section 3 of this Code of Ethics shall not apply to:  (a) Securities not Eligible for Clients. Purchases or sales of securities that  are not eligible for purchase or sale by any client.  (b) Non-volitional Transactions. Purchases or sales that are non-volitional  by either the access person or any client (including transactions in fully  discretionary  portfolio management accounts managed by registered investment advisers and  with respect to which such access person has no actual advance knowledge of  a given  trade).  (c) No Control. Purchases or sales effected in any account over which theaccess  person has no direct or indirect influence or control.  (d) Automatic Investment Plans. Purchases or sales made automatically inaccordance  with a predetermined schedule and allocation, such as dividend reinvestment  plans.  (e) Rights Offerings. Purchases effected upon the exercise of rights issued  by an issuer pro rata to all holders of a class of its securities, to theextent  such rights were ac-quired from such issuer, and sales of rights soacquired.  (f) Approved Transactions. Purchases or sales that receive the prior approval  of the Compliance Officer on the basis that they do not present the types of  conflicts of interest or potential harm intended to be covered by this Code  of Ethics.  (g) Disinterested Trustees. Transactions by a Disinterested Trustee and any  Officer who is not an affiliated person of the Adviser are subject to theprovisions  of 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 or  after  the date of the transaction by the Trustee/Officer, such security waspurchased  or 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  for the last month.  2) Purchases or sales that result in an open security position no larger than  2,000 shares (or options thereon) for any stock in the Standard & Poor's  500 Index, or 500 shares (or options thereon) for any stock in the Standard& Poor's  400 Mid-Cap Index or Standard & Poor's 600 Small-Cap Index.  (i) Section 28(e) transactions. Transactions executed by Saturna Brokerage  Services for a Fund within the safe harbor of Section 28(e) of the 1934 Act  will not be  deemed to violate the Section 17(e) general prohibitions.  Any action, duty or responsibility delegated to the Compliance Officer orChief  Compliance Officer under this Code of Ethics may, in his absence, and shall,  with respect to actions involving the personal transactions of the Compliance  Officer 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 access person  shall purchase or sell, directly or indirectly, any security in which he has,  or because  of such transaction acquires, any direct or indirect beneficial ownershipwithout  first obtaining the permission of the Compliance Officer, who shall makereasonable  inquiry as to the trading or proposed trading or pending purchase or saleorders  by clients of the Adviser in such security. The Adviser will maintain records  of the approval of, and rationale supporting, the acquisition of investments  in IPO’s and Private Placements for at least five years after the end  of the 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 suchtransaction  acquires, any direct or indirect beneficial ownership, if the person knows  at the time of purchase or sale that the security  (1) is being considered, or within five days preceding the proposedtransaction  has 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 a  client within the five days preceding the access person's transactions; or  (3) is designated by the Adviser as a "Recommended Security" for  consideration of any client for purchase or sale.  However, an employee or access person may participate as part of a"bunch" order  with clients simultaneously purchasing or selling a security. The Adviser must  determine that, for each transaction, bundling is consistent with bestexecution  and no client is favored.  (c) Blackout Period. No advisory person shall purchase or sell a securityduring  a period of five days before and five days after the date on which a Fund or  client for which he or she is portfolio manager or co-manager, engages in any  purchase or sale in such security; provided, however, that in appropriatecases  the Compliance Officer may waive such prohibition in his discretion if all  client trades 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 suchtransaction  acquires, any direct or indirect beneficial ownership and which to his actual  knowledge at the time of such purchase or sale, is the subject of an initial  public offering.  (e) Private Placements. No advisory person may purchase, directly orindirectly,  any security in which he has or because of such transaction acquires, anydirect  or indirect beneficial ownership, if such transaction is not in the openmarket,  or if such transaction is made pursuant to any exemption from the registration  provisions of the federal securities laws unless such transaction has been  approved in advance by the Compliance Officer.  Provided, that in determining whether to grant permission for such private  placement, the Compliance Officer shall consider, among other things, whether  such offering  should be reserved for a Fund or other client of the Adviser, and whether such  transaction is being offered to the person because of his or her position with  the Adviser.  Provided further, that any such person who has received such permission shall  be required to disclose such an investment when participating in anysubsequent  consideration 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 bypersons  with no personal direct or indirect interest in the security.  (f) Principal Transactions. Neither the adviser nor any affiliate may effect  a transaction as principal with a client.  (g)`Short-swing trades. Securities may not be purchased and sold, or sold and  repurchased, within 14 calendar days. The Compliance Officer may, for good  cause shown, permit a short-swing trade, but shall record the reasons andgrant  of  permission 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 person or entity  that transacts business with the Adviser, or with any client or Fund managed  by the  Adviser at the direction of such person.  (b) Directorships. No advisory person shall serve as director of any publicly  traded company without first obtaining approval of the Compliance Officer.  Any such approval shall be based on a determination by the Compliance Officer  or  directors that such board service will be consistent with the interests of  the clients of the Adviser, and that such person serving as a director will  be isolated  from those making investment decisions with respect to such company byappropriate  procedures. At the direction of the Compliance Officer, in his solediscretion,  such person may be required to resign from such directorship.  (c) Brokerage accounts.   (1) Employees and access persons desiring to trade securities for their own  accounts are strongly encouraged, but not required, to open and maintainaccounts  with  Saturna Brokerage Services, and to place all securities trades through Saturna  Brokerage. No employee or access person may open or maintain a securitiestrading  account, of any type, in which he or she has any direct or indirect interest  unless the Compliance Officer approves such account in advance. Any person  maintaining any such account shall instruct the broker with which such account  is maintained  to send copies of confirmations of all personal securities transactions and  copies of periodic statements with respect to such account directly to the  Compliance  Officer.   (2) All access persons not maintaining a securities trading account withSaturna  Brokerage shall be responsible for maintaining on the NEPTUNE recordkeeping  system of Saturna Brokerage an accurate inventory of all securities held by  such person  that are required to be reported under this Code of Ethics. The name of the  broker, dealer or bank with which any account is established, and the date  the account  is established, must be reported to the Compliance Officer.  (d) Disclosure. No access person may recommend or attempt to cause anysecurities  transactions by a client or participate in any investment decision without  disclosing his interest in the securities.  (e) Insider Trading.   (1) Employees obtaining material nonpublic information should refrain from  disclosing that information to anyone. Additionally, employees should nottrade  in the securities  to which the information relates.  (2) Employees who are aware of the misuse of material nonpublic information  should report such to the Compliance Officer.  (f) Waivers. The Compliance Officer or Chief Compliance Officer, in unusual  circumstances and for good cause shown, may recommend to an ad hoc committee  consisting of  the Compliance Officer plus one other director of Saturna, the waiver of any  of the prohibitions in Section 3 and Section 4 as to any particular set of  circumstances, and such prohibition may be waived in such limitedcircumstances  by such ad hoc  committee. A copy of the minutes of their deliberations shall be maintained  with the 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 this Code of  Ethics with  respect to transactions in any 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 report shall be made not later than ten (10)  days after the end of the execution of the transaction, and shall contain the  following information:  (1) The date of the transaction, the title and the 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; and,  (4) The name of the broker, dealer or bank with or through whom thetransaction  was 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 reportedpersonal  securities transactions of employees with completed portfolio transactions  of clients to determine whether a violation of this Code of Ethics may have  occurred.  The Chief Compliance Officer shall also review any initial and annual holdings  reports. The Adviser will maintain the names of the persons reviewing these  reports.   (2) At their first regular meeting in each calendar year, the Fund boards must  be provided and review an annual report from the Adviser on compliance for  the previous year. The Boards must receive a certification that the Fund and  the  Adviser "have adopted procedures reasonably necessary to prevent Access  Persons from violating" their codes (a) before approving this Code ofEthics  and (b) "not less frequently than annually" thereafter. The annual  report to the Fund boards must describe any issues and material violations  arising under this Code since the last report.  (d) Not considered admission. Any such report may contain a statement that  the report shall not be construed as an admission by the person making such  report  that he has any direct or indirect beneficial ownership in the security to  which the report relates.  (e) Political Contributions. Any employee making political contributions, in  cash or services, must report each such contribution to the municipalprincipal  quarterly, who will compile and report thereon as required under relevantregulations.  (f) Certification. Within ten days of employment, access persons are required  to provide initial reports of their securities holdings. In conjunction with  the Adviser's annual employee compliance meeting (normally held in August),  and more frequently if instructed by the Compliance Officer, all Adviserpersonnel  shall certify the accuracy of the inventory of their securities holdings on  the  NEPTUNE recordkeeping system, and to their knowledge of and compliance with  this Code of Ethics.   (g) Fund Disclosure. As provided under Rule 17j1, Funds disclose in theirregistration  statements (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 own  accounts, 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 statements and  is available online at Saturna Capital’s website.**SECTION 6 – SANCTIONS**  Any violations discovered by or reported to the Compliance Officer or Chief  Compliance 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 of  Ethics.  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 regulatory authorities.