**CODE OF ETHICS**(March 1, 2006)

**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 the appearance      of impropriety. Our personnel must not take inappropriate advantage of their      positions 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 of Securities  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 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.

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(i) “Fund” means              any registered investment company adopting this Code of Ethics.    (ii) “Compliance Officer” means the person so designated                  by the Adviser to act in that capacity.    (iii) “Chief Compliance Officer” means the person designated                by the Adviser and the Fund to act in that capacity under Rule    38a1 of the Investment                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:

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(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 and regulations there under interpreted in a manner consistent with      Rule 16a-1(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 or acquires. “Direct                      or indirect beneficial ownership” means direct or                      indirect influence or control or ownership of any beneficial                      interest.

(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                            with respect to a Fund:

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(i) any        affiliated person of such company,    (ii) any member of the immediate family of any                                  natural person who is an affiliated 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 Investment                                  Company                                  having the same Investment Adviser or principal                                  underwriter or with the principal executive officer                                  of such other                                  Investment Company.*Provided*, That no person shall be deemed to be                                  an interested person of an Investment 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 immediate family" 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, evidence    of indebtedness, certificate      of interest or participation                                  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 undivided interest in oil, gas,                                  or other mineral rights, or any interest or                                  instrument                                  commonly                                  known as a "security," or any certificate                                  of interest or participation in, temporary                                  or interim certificate for, receipt for,                                  guarantee of,                                  or warrant or right to subscribe to or purchase,  any of the foregoing.

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“Security” does not include direct obligations of the Government      of the United States (including short-term debt securities        that are government securities within the meaning of the Investment Company        Act), bankers' acceptances,                                  bank                                        certificates of deposit, commercial paper,        repurchase agreements, other high-quality short-term debt instruments, shares        of registered open-end money-market                                  investment                                        companies, and securities based upon a recognized        market index [including derivatives (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:

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(i) is        or has been held by such client, or    (ii) is being or has been considered by such                                          client or the Adviser for purchase by such                                          client.

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

**SECTION    2 – EXEMPTEDTRANSACTIONS**

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                                                  the access                                                  person has                                                  no direct                                                  or indirect                                                  influence or                                                  control.

(d) Automatic    Investment Plans. Purchases or sales made automatically                                                    in accordance                                                    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 the                                                      extent such rights were    ac-quired from such issuer, and sales                                                      of rights so                                                      acquired.

(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 the                                                          provisions of Sections                                                          3 and 5 only if the    Trustee/Officer, at                                                          the time                                                          of that                                                          transaction,                                                          knew or, in the ordinary                                                          course                                                          of fulfilling his official                                                          duties as a                                                          Trustee/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                                                          was                                                          purchased or sold by                                                          the Fund                                                          or was being                                                          considered for                                                          purchase by                                                          its Adviser.

(h) Insignificant                                                            Position. 

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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.

(j)      Mutual funds. Purchases                                                                    or                                                                    sales of    mutual fund shares.

Any action,                                                                      duty or    responsibility delegated                                                                      to the    Compliance Officer or                                                                      Chief                                                                      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 the    Adviser.

**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                                                        ownership                                                                          without                                                                          first                                                                          obtaining                                                                          the                                                                          permission                                                                          of                                                                          the                                                                          Compliance                                                                          Officer,                                                                          who                                                                          shall                                                                          make                                                                          reasonable                                                                          inquiry                                                                          as                                                                          to                                                                          the                                                                          trading                                                                          or                                                                          proposed                                                                          trading                                                                          or                                                                          pending                                                                          purchase                                                                          or                                                                          sale                                                                          orders                                                                          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                                                                            such                                                                            transaction                                                                            acquires,                                                                            any                                                                            direct                                                                            or                                                                            indirect                                                                            beneficial                                                                            ownership,                                                                            if                                                                            the                                                                            person                                                                            knows at                                                                            the                                                                            time                                                                            of                                                                            purchase                                                                            or                                                                            sale                                                                            that                                                                            the                                                                            security

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(1)     is being     considered, or     within five     days preceding     the proposed     transaction 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 best       execution and       no client       is favored.

(c)     *Blackout Period.*  No advisory     person shall     purchase or     sell a     security during     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 appropriate       cases 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 such       transaction 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     or indirectly,     any security     in which     he has     or because     of such     transaction acquires,    any      direct      or indirect      beneficial ownership,      if such      transaction is      not in      the open      market, 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 any     subsequent      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 by                                                                                  persons 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 and    grant of    permission with    the records    of the    Code.

**SECTION      4 – PROHIBITED       ACTIVITIES**

(a) *Giftsand Gratuities*

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*(1) Definitions: As used in this Section:*

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

**"Business Entertainment”** means ordinary and usual business entertainment                such as an occasional meal, ticket to a sporting event or theater, or comparable                entertainment, so long as it is neither so frequent nor so extensive as              to raise any question of propriety and the person providing the **Business          Entertainment*****must*** accompany the recipient to any such function

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

**“Enterprise Limit”** 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 **“Business          Entertainment”**.

A **“Restricted Person”** is any person                        (which includes both 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 similar capacities            are considered to be part of the **Restricted Person**.

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

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

(2) *Limit      on Gifts and Business Entertainment*
**Note:The following table represents the limitations on Gifts and Business Entertainment,accepted from or given to, either directly or indirectly, a Restricted Person.**CLASSIFICATION OF PERSONSTOTAL COMBINED VALUE OF ALL GIFTS IN ANY 12-MONTH PERIODTOTAL COMBINED VALUE OF GIFTS AND BUSINESS ENTERTAINMENT      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 Advisory      Persons and Trustees giving or receiving Gifts or Business Entertainment      as permitted by Paragraph (b) within 10 working days following the giving        or receipt of any gift or business entertainment shall report to the Chief  Compliance Officer the following information:
- The name of the Restricted Person 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;
- The date              on which the Gifts and Business Entertainment were given or                      received, a description of the Gifts and Business 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 in connection with meetings held by an offeror or by        an NASD member, for the purpose of training or education of the Attendee        may be received,  provided that:
- The record keeping requirement in paragraph (c) is satisfied, including                              all compensation received, the name of the offeror or NASD            member, the amount of cash received,          and the nature and, if known, value of any non-cash compensation;
- The Attendee          obtains Saturna’s prior approval to attend the meeting; 
- The location              is appropriate to the purpose of the meeting, which shall mean an office              of the offeror or the NASD member, or              a facility located in the vicinity                                      of such office, or a regional location with respect            to regional meetings;
- The payment              or reimbursement is not applied to the expenses of guests                                        of the              Attendee; and
- The payment              or reimbursement by the offeror is not subject to any conditions.

(5)*Exception*

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

(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 by appropriate procedures.                                      At                                      the direction of the                                      Compliance                                      Officer, in his sole discretion,                                      such person may be required to resign from            such directorship.

(c) *Brokerage    accounts.*

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(1) All          employees and access persons who own or trade securities must maintain              a brokerage account                                                with Saturna Brokerage Services,                                                and hold all of their                                                securities in that account, and perform          all trading through that account.

(2)          Employees and access persons may not, directly or indirectly, have an                                                  interest                                                  in any brokerage                                                  or trading account outside                                                  of SBS. Employees having any such                                                  account shall arrange to transfer          all such accounts to SBS prior to September            1, 2006. 

(3) The        President may permit, in unusual circumstances and for good                                                    cause shown,                                                    an access person                                                    to maintain an account                                                    other                                                    than with                                                    SBS, if such account                                                    (i) is managed by a person not                                                    related to such access person,                                                    (ii) such manager                                                    is                                                    a registered                                                    investment adviser, (iii)                                                    such manager                                                    has acknowledged in                                                    writing to the President that        such adviser is aware that the access                                                    person is not                                                    permitted to have 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 access person permitted to maintain such an account not                                                        with SATURNA                                                        BROKERAGE                                                        SERVICES,                                                        shall instruct the manager                                                        or                                                        custodian                                                        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; and       (b) Such access person 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. 

(d) *Disclosure.*  No access person may recommend or attempt to                                                    cause any securities                                                    transactions                                                    by a client or participate                                                    in any investment                                                    decision without                                                    disclosing his interest in              the securities.

(e) *Insider      Trading*. 

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(1) Employees        obtaining material nonpublic information should                                                            refrain from disclosing                                                            that information                                                            to anyone. Additionally,                                                            employees                                                            should not trade                                                            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 limited                                                          circumstances 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(b) 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:

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(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        the        transaction        was        effected.

(c)        *Review        of        reports.*

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(1)     The     Chief     Compliance     Officer     shall     be     responsible     for     a     quarterly     review,     as     prepared     by     the     Adviser's     NEPTUNE     system,     which     compares     the     reported personal          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 of Ethics 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     municipal     principal     quarterly,     who will       compile       and       report       thereon       as       required       under       relevant       regulations.

(f)*Certification.*

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(1) Within        ten days of employment, all personnel shall meet with the Chief Compliance        Officer to discuss the reporting requirements           of this Section. At that time, the employee shall deliver to the CCO a        complete record of all of the employee’s securities holdings, and shall        provide the CCO with evidence that the employee has made provision with SBS        to open           account, to transfer all securities holdings to SBS, and close any previous           outside accounts.    (2) At the end of the employee’s first month of employment, the employee      shall meet with the CCO and demonstrate that the employee has completed    the process of closing all outside accounts and moving all holdings to SBS.           If the employee      has not done so, or is having difficulty doing so, the CCO will provide    appropriate      guidance and assistance to the employee to complete the process.    (3) In conjunction with the Adviser's annual employee compliance meeting (normally      held in August), and more frequently if instructed by the Compliance Officer,      all Adviser personnel 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.     (4) An employee’s willful non-compliance with completion of this process      shall be considered a violation of this Code of ethics.

(g)     *Fund     Disclosure.*  As     provided     under     Rule     17j1,     Funds     disclose     in     their     registration     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 Chief     Compliance Officer.     Such recommendation     shall be     based on, among     other things,     the severity 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:

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(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.

 

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**Copyright 2006 Saturna Capital Corporation**