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EXHIBIT (p)(1)
CODE OF ETHICS
OF
MEYERS INVESTMENT TRUST
AS AMENDED AND RESTATED JULY 14, 2000
1. APPLICABILITY.
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This Code of Ethics (the "Code") of Meyers Investment Trust (the "Trust"),
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a Delaware Business Trust, is adopted by the Board of Trustees of the Trust on
behalf of Meyers Pride Value Fund (the "Fund"), pursuant to Rule 17j-1 under
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the Investment Company Act of 1940, as amended (the "Act") to establish rules of
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conduct for "Access Persons" (as defined in this Code) of the Trust. For
purposes of this Code, Access Persons shall include: (i) any director, officer,
or general partner of a fund or of a fund's investment adviser, or any employee
of a fund or of a fund's investment adviser who, in connection with his or her
regular functions or duties, participates in the selection of a fund's portfolio
securities or who has access to information regarding a fund's future purchases
or sales of portfolio securities; or (ii) any director, officer, or general
partner of a principal underwriter who, in the ordinary course of business,
makes, participates in or obtains information regarding the purchase or sale of
securities for the fund for which the principal underwriter acts, or whose
functions or duties in the ordinary course of business relate to the making of
any recommendation to the fund regarding the purchase or sale of securities.
For purposes of this section, a person does not become an Access Person
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solely by reason of (i) normally assisting in the preparation of public reports
or receiving public reports, but not receiving information about current
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recommendations or trading; or (ii) a single instance of obtaining knowledge of
current recommendations or trading activity, or infrequently and inadvertently
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obtaining such knowledge.
2. PROHIBITIONS. - Personal Transactions in Securities
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A. Prohibited Conduct
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Advance clearance must be obtained for any personal transaction in a
security by an Access Person if such Access Person has, or as a result of the
transaction acquires, any direct or indirect beneficial ownership in the
security. For purposes of this section, a person generally is deemed to have a
beneficial ownership in securities if: (i) the person, directly or indirectly,
through any contract, arrangement, understanding, relationship, or otherwise,
has or shares (a) voting power, which includes the power to vote, or to direct
the voting of, the securities, and/or (b) investment power, which includes the
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power to dispose of, or to direct the disposition of, the securities; and (ii)
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the person, directly or indirectly, through any
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contract, arrangement, understanding, relationship or otherwise, has or shares a
direct or indirect pecuniary interest in the securities. A person is deemed to
have voting and/or investment power with respect to securities as interpreted by
reference to Rule 16a-1 under the Securities Exchange Act of 1934, as amended,
except that the determination of direct or indirect beneficial ownership for
purposes of the Code must be made with respect to all securities that an Access
Person has or acquires. Generally, a person is deemed to have beneficial
ownership if the person has the right to acquire beneficial ownership in the
security within sixty (60) days, including any right to acquire the security
through the exercise of any option, warrant or right; the conversion of a
security; pursuant to the power to revoke a trust, discretionary account or
similar arrangement; or pursuant to the automatic termination of a trust,
discretionary account or similar arrangement.
(1) Access Persons who are not Independent Trustees
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(a) No Access Person shall buy or sell any security for his own
account or for an account in which he has, or as a result of
the transaction acquires, any direct or indirect beneficial
ownership (referred to herein as a "personal transaction")
unless:
(i) preclearance of the transaction has been obtained; and
(ii) the transaction is reported in writing to the Trust in
accordance with the requirements of Section 4 below.
(b) No Access Person shall purchase or sell, directly or
indirectly, any security in which he has, or by reason of
such transaction acquires, any direct or indirect beneficial
ownership (as defined above) and which he knows or should
have known at the time of such purchase or sale;
(i) is being considered for purchase or sale by the Trust;
(for purposes of this subsection, a security is "being
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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 such person seriously considers
making such a recommendation); and
(ii) is being purchased or sold by the Trust.
(c) No Access Person shall recommend any securities transaction
by the Trust without having disclosed his interest, if any,
in such securities or the issuer of the securities,
including without limitation:
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(i) his direct or indirect beneficial ownership of any
securities of such issuer;
(ii) any contemplated transaction by such person in such
securities;
(iii) any position with such issuer or its affiliates; and
(iv) any present or proposed business relationships between
such issuer or its affiliates and such person or any
party in which such person has a significant interest.
(d) No Access Person shall, directly or indirectly in connection
with the purchase or sale of any securities held or to be
acquired by the Trust:
(i) employ any device, scheme or artifice to defraud the
Trust;
(ii) make to the Trust any untrue statement of a material
fact or omit to state to the Trust a material fact
necessary in order to make the statements made, in
light of the circumstances under which they are made,
not misleading; or
(iii) engage in any act, practice or course of business
which operates or would operate as a fraud or deceit
upon the Trust.
For purposes of this section, the term "security" shall have the meaning
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set forth in Section 2(a)(36) of the Act, except that it shall not include
securities issued by the Government of the United States, short term securities
which are "government securities" as defined in Section 2(a)(16) of the Act,
bankers' acceptances, bank certificates of deposit, commercial paper, shares of
registered open-end investment companies and such other money market
instruments, as designated by the Board of Trustees of the Trust.
(2) Access Persons who are Independent Trustees
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An Access Person, who is an independent trustee and not an "interested
person" as defined in the Act (an "Independent Trustee"), shall be required to
report a transaction on Attachment A attached hereto, only if such person, at
the time of that transaction, knew, or in the ordinary course of fulfilling
his/her official duties as trustee should have known, that during the 15-day
period immediately preceding or after the date of the transaction by such
person, the security such person purchased or sold is or was purchased, or sold
by such company or was being considered for purchase or sale by such company or
its investment adviser.
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B. Personal Securities Trading
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(1) Each Access Person of the Trust who engages in securities trades
on his or her own behalf is required to instruct his or her broker(s) to forward
copies of all confirmations and account statements to be received within ten
(10) days following the date of such purchase, to the Designated Supervisory
Person. Copies of all such letters to brokers must also be forwarded to the
Compliance Officer.
(2) Confirmations and statements are required for all accounts in
which the Access Persons may be deemed under law to be the "beneficial owner"
(as defined above) in Section 2.A of the securities being traded. Following is
a list of accounts which should be included:
. Any relative who shares your household, including but not limited to
your spouse and your children (including minor children);
. A trust in which you have a beneficial interest, unless you have no
direct or indirect control over the trust;
. A trust under which you are a trustee;
. A revocable trust as to which you are a settlor;
. A Corporation (excluding companies affiliated with the company) of which
you are an officer, director of 10% or greater stockholder; or
. A partnership of which you are a partner (including most investment
clubs) unless you have no direct or indirect control over the
partnership.
(3) In addition to your broker's providing information on trades as
set forth above, each Access Person must submit a report on the form attached
hereto as Attachment A to the Designated Supervisory Person within ten (10) days
after each calendar quarter end.
C. Restrictions and Limitations on Personal Securities Transactions
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The following restrictions and limitations govern investments and personal
securities transactions by Access Persons, except Independent Trustees. All
restrictions and limitations contained in this section 2C are applicable to all
Access Persons except Independent Trustees:
(1) Private placements of any kind may only be acquired with special
permission from the Designated Supervisory Person and Compliance Officer, and,
if approved, will be subject to continuous monitoring for possible future
conflict. Any Access Person wishing to request approval for private placements
must complete an Access Person Preclearance Request Form and submit the form to
the Designated Supervisory Person and Compliance Officer. A copy of this form,
which may be revised
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from time to time, is attached hereto as Attachment E. Where the Designated
Supervisory Person and Compliance Officer approves any acquisition of private
placements, its decision and reasons for supporting the decision will be
documented in a written report, which is to be kept for five years after the end
of the fiscal year in which the approval was granted.
(2) Access Persons may only acquire a security in an Initial Public
Offering (IPO) with special permission of the Designated Supervisory Person and
Compliance Officer, and if approved, will be subject to continuous monitoring
for possible future conflict. Any Access Person wishing to request approval for
an IPO must complete an Access Person Preclearance Request Form, as described
above, and submit the form to the Designated Supervisory Person and Compliance
Officer. Where the Designated Supervisory Person and Compliance Officer
approves any acquisition of IPOs, its decision and reasons for supporting the
decision will be documented in a written report, which is to be kept for five
years after the end of the fiscal year in which the approval was granted.
(3) Any Access Person who has a personal position in an issuer
through a private placement must affirmatively disclose that interest if such
Access Person is involved in consideration of any subsequent investment decision
regarding any security of that issuer or its affiliate. In such event, the
final investment decision shall be independently reviewed by the Compliance
Officer. Written records of any such circumstance shall be maintained and sent
to the Designated Supervisory Person.
D. Preclearance Requirement
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(1) Procedures
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The Designated Supervisory Person is designated by the Trust to monitor the
overall compliance with this Code. As of the date hereof, the Designated
Supervisory Person is Laila Poveda. The Compliance Officer is designated by the
Trust to provide final review and approval with respect to the compliance with
this Code. As of the date hereof, the Compliance Officer is Kathleen McGinnis.
The designations included herein made by the Trust may be amended from time to
time.
(a) From Whom Obtained
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Subject to the limitations and restrictions of Subsection 2.C. above,
advance preclearance of a personal transaction in a security must be obtained
from both the Designated Supervisory Person and Compliance Officer of the Trust.
Prior to obtaining the signature of the Compliance Officer, the form must
be approved by the Designated Supervisory Person.
The Compliance Officer will not sign unless the approval of the Designated
Supervisory Officer is indicated on the form. The Trust has implemented
procedures reasonably designed to monitor purchases and sales effected pursuant
to the aforementioned preclearance procedures.
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(b) Time of Preclearance
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All approved securities transactions must take place (prior to 4:00 p.m.
EST) within five business days from and including the date on which complete
advance preclearance is obtained. If the transaction is not completed on the
final day of preclearance, a new preclearance must be obtained, including one
for any uncompleted portion. Post-approval is not permitted under the Code of
Ethics. If it is determined that a trade was completed before approval, it will
be considered a violation of the Code of Ethics.
(c) Form
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Preclearance must be obtained by completing and signing the Access Person
Preclearance Request Form provided (as described above) for that purpose by the
Trust and obtaining signatures as indicated in sub-section 2.D.(1)(a) above.
(d) Filing
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After all required signatures are obtained, the Access Person Preclearance
Request Form must be filed with the Designated Supervisory Person by noon of the
day prior to execution of such trade, for filing in the respective individual's
Code of Ethics file and a copy forwarded to the Compliance Officer for final
review and approval, as described below. A copy is retained by the Access
Person for his or her records. (If a preclearance request is denied, a copy of
the form will be maintained with the Designated Supervisory Person.)
(2) Factors Considered in Preclearance of Personal Transactions
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In addition to the limitations and restrictions set forth in this Code, the
Compliance Officer, in keeping with the general principles and objectives of
this Code of Ethics, may refuse to grant preclearance of a personal transaction
in his/her sole discretion without being required to specify any reason for the
refusal. Generally, the Compliance Officer will consider the following factors
in determining whether or not to clear a proposed transaction:
(a) Whether the amount or the nature of the transaction or
person making it is likely to affect the price or market of
the security.
(b) Whether the individual making the proposed purchase or sale
is likely to benefit from purchases or sales being made or
considered on behalf of any of its clients.
(c) Whether the transaction is non-volitional on the part of the
individual.
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3. EXEMPT TRANSACTIONS.
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A. The Prohibitions Described In This Code, Shall Not Apply To:
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(i) purchases of sales effected in any account over which the
Access Person has no direct or indirect influence or
control;
(ii) purchases or sales of securities which are not eligible for
purchases or sale by the Trust;
(iii) purchases or sales that are non-volitional on the part of
the Access Person;
(iv) purchases that are part of an automatic dividend
reinvestment plan;
(v) 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 acquired from
the issuer, and sales of such rights so acquired;
(vi) any securities transaction, or series or related
transactions, involving 500 shares or less in the
aggregate, if the issuer has a market capitalization
(outstanding shares multiplied by the current price per
share) greater than $1 billion; or
(vii) purchases or sales for which the Access Person has received
prior approval from the Designated Supervisory Person.
Prior approval shall be granted only if a purchase or sale
of securities is consistent with the purposes of this Code,
Rule 17j-1 and Section 17(j) of the Act. To illustrate, a
purchase or sale shall be considered consistent with those
purposes if such purchase or sale is only remotely
potentially harmful to the Trust because such purchase or
sale would be unlikely to affect a highly institutional
market, or because such purchase or sale is clearly not
related economically to the securities held, purchased or
sold by the Trust.
B. Exempt Securities
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(a) The securities listed below are exempt from the restrictions
of Section 2.C., the preclearance requirement of Section
2.D., and the quarterly and annual reporting requirements of
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Section 4. Therefore, it is not necessary to obtain
preclearance for personal transactions in any of the
following securities nor is it necessary to report such
securities in the
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quarterly transaction reports or annual securities holdings
list:
(i) U.S. Government Securities;
(ii) Bank Certificates of Deposit;
(iii) Bankers' Acceptances;
(iv) Commercial Paper;
(v) Open-end investment companies (mutual funds) (Closed-end
funds must be pre-approved).
C. Exemption from Preclearance Requirement
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Preclearance is not required for any account over which the Access Person
has no influence or control. In case of doubt, the Access Person may state on
the Transaction/New Account Report of Securities Transaction form that he or she
disclaims any beneficial ownership in the securities involved.
4. REPORTING.
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All Access Persons must submit the reports attached hereto and as set forth
below. Attached hereto as Attachment C, is an Access Person List, which provides
a list of Access Persons of the Trust. In addition, a Certification to the
Board of Trustees as described below must be submitted on Attachment D.
(a) Initial and Annual Holdings Reports (Attachment B)
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All Access Persons must file a completed Initial and Annual Holdings Report
(to be updated by filing a Transaction/New Account Report, in the form of
Attachment A hereto, within ten calendar days (10) of commencement of their
employment, or otherwise becoming subject to this Code, and thereafter on an
annual basis following the end of the calendar year in compliance with Rule 17j-
1. The information must be current as of a date not more than 30 days before
the report is submitted.
New employees will be required to provide a listing of all non-exempt
securities holdings, as of the date of commencement of employment, as well as a
listing of all outside brokerage accounts.
(b) Transaction/New Account Report (Attachment A)
---------------------------------------------
All Access Persons must file a completed Transaction/New Account Report, in
the form of Attachment A hereto, within ten (10) calendar days after (i) opening
an account with a broker, dealer or bank in which covered securities are held,
or (ii) entering into any personal securities transactions in which an Access
Person has any direct or indirect beneficial ownership.
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Access Persons must file a Report during the time frame described above,
even if such person made no purchases or sales of securities during the period
covered by the report. Any officer or trustee exempt from preclearance is
subject to the quarterly reporting requirements.
(c) Quarterly Transaction Reports (Attachment A)
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Rule 17j-1 requires Access Persons to report personal securities
transactions to the Designated Supervisory Person at least quarterly ("quarterly
transaction reports") by filing a completed Transaction/New Account Report.
Quarterly transaction reports are required to be submitted no later than ten
calendar (10) days after the end of the calendar quarter.
(d) Access Person Certification Form (Attachment D)
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In accordance with the Access Person Certification Form (the
"Certification"), attached hereto as Attachment D, all Access Persons and all
employees of the Trust must certify that they have read thoroughly, understand
and agree to abide by the conditions set forth in the Trust's Code of Ethics.
5. SANCTIONS.
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If a determination is made that an Access Person has committed a violation
of this Code, the officer or trustee of the Trust shall bring the matter to the
attention of the counsel to the Trust, who shall then report the matter to the
Board of Trustees of the Fund, who may impose such sanctions as it deems
appropriate, or other actions may be taken, including but not limited to, a
letter of caution or warning, suspension of personal trading rights, suspension
of employment (with or without compensation), fine, civil referral to the SEC,
criminal referral, and termination of the employment of the violator for cause.
An Access Person may also be required to reverse the trade(s) in question and
forfeit any profit or absorb any loss derived therefrom. The amount of profit
shall be calculated and shall be forwarded to a charitable organization. The
Board of Trustees, in its sole discretion, is authorized to determine the choice
of sanctions to be imposed in specific cases, including termination of
employment of any employee.
In addition to these penalties, violations by employees may lead to both
public embarrassment of the Trust and significant legal liability.
6. ADMINISTRATION OF CODE OF ETHICS
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On a quarterly basis, the Board of Trustees of the Fund shall be provided
with a written report by the Fund that describes any new issues arising under
the Code of Ethics, including information on material violations of the Code of
Ethics or procedures and sanctions imposed, and annually, the Fund must certify
that it has adopted procedures reasonably necessary to prevent Access Persons
from violating the Code of Ethics.
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7. CONFIDENTIALITY.
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All information obtained from any Access Person hereunder shall be kept in
strict confidence, except that reports of securities transactions hereunder will
be made available to the SEC or any other regulatory or self-regulatory
organization to the extent required by law or regulation.
8. OTHER LAWS, RULES AND STATEMENTS OF POLICY.
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Nothing contained in this Code shall be interpreted as relieving any Access
Person from acting in accordance with the provision of any applicable law, rule
or regulation or any other statement of policy or procedure governing the
conduct of such person adopted by the Trust.
9. FURTHER INFORMATION.
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If any person has any question with regard to the applicability of the
provisions of this Code, generally or with regard to any securities transaction
or transactions, he should consult the Designated Supervisory Person, or in the
absence of the Designated Supervisory Person, the Compliance Officer of the
Trust.
10. EFFECTIVE DATE.
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All employees, officers and trustees of the Trust (whether or not Access
Persons) are required to sign a copy of this Code indicating their agreement to
abide by the terms of this Code.
In addition, all employees, officers and trustees of the Trust will be
required to certify annually that (i) they have read and understand the terms of
this Code of Ethics and recognize the responsibilities and obligations incurred
by their being subject to this Code, and (ii) they are in compliance with the
requirements of this Code of Ethics, including but not limited to the reporting
of all brokerage accounts, the preclearance for Access Persons and all non-
exempt personal securities transactions in accordance with this Code.
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Attachment A
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MEYERS PRIDE VALUE FUND
Transaction/New Account Report
of Securities Transactions
for Quarter Ending ________________, 2000
To: Kathy McGinnis
During the quarter referred to above, the following transactions were effected
in securities which are required to be reported by the Trust's Code of Ethics,
on behalf of the Fund, and Rule 17j-1 under the Investment Company Act of 1940,
as amended, where I had, or by reason of such transactions acquired, direct or
indirect beneficial ownership.
Note: In lieu of entering the information requested below, you may attach a copy
of each confirmation statement or monthly account statements from the broker,
dealer, or bank maintaining your securities account(s).
<TABLE>
<CAPTION>
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NAME OF DATE ACCOUNT TRADE DATE PURCHASE OR NO. OF SHARES OR PURCHASE/SALE BROKER, DEALER
SECURITY/CUSIP ESTABLISHED SALE PRINCIPAL AMOUNT PRICE OR BANK
NUMBER OF SECURITY
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<S> <C> <C> <C> <C> <C> <C>
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</TABLE>
Fill out all trade details completely. The date should include the month, day
and year. If no reportable transactions have occurred, please answer NONE.
This report excludes (1) transactions of which I had no direct or indirect
influence or control, (2) other transactions not required to be reported (i.e.,
U.S. Government securities, commercial paper, bank obligations and shares in
open end investment companies), and (3) is not an admission that I have or had
any direct beneficial ownership of the securities listed above.
______________________ _______________________
Date Filed Signature
______________________ _______________________
Reason for Approval Print Name
______________________ _______________________
Approval Date Title
Permission Denied_____________________
Denial Date___________________________
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Attachment B
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MEYERS INVESTMENT TRUST
Code of Ethics
INITIAL AND ANNUAL HOLDINGS REPORT
Name/Address
of Broker- Account Account Security Date Account Number of
Dealer or Bank Name Number Description Established Securities Held
-------------- ---- ------ ----------- ----------- ---------------
Attached are the Covered Securities/1/ beneficially owned by me as of the
date of this Initial and Annual Holdings Report.
_____________________
Print or Type Name
_____________________
Signature
_____________________
Date
________________________
/1/ Covered Security means a security as defined in section 2(a)(36) of the Act
[15 U.S.C.80a-2(a)(36)], except that it does not include:
(i) Direct obligations of the Government of the United States;
(ii) Bankers' acceptances, bank certificates of deposit, commercial
paper and high quality short-term debt instruments, including
repurchase agreements; and
(iii) Shares issued by open-end funds.
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Attachment C
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MEYERS INVESTMENT TRUST
ACCESS PERSON LIST
Below is a list of Access Persons, as defined in Rule 17j-1 of the
Investment Company Act of 1940, as amended, under the Meyers Investment Trust
Code of Ethics.
ACCESS PERSONS INCLUDE: ANY DIRECTOR, OFFICER, OR GENERAL PARTNER OF THE
FUND OR OF THE FUND'S INVESTMENT ADVISER, OR ANY EMPLOYEE OF THE FUND OR OF
THE FUND'S INVESTMENT ADVISER OR ANY DIRECTOR, OFFICER, OR GENERAL PARTNER
OF THE PRINCIPAL UNDERWRITER OF THE FUND/1/
Dated: _________________, 2000.
___________________
/1/ The actual names of the Access Persons will be provided supplementally. A
list of such names will be kept with the Board of Trustees of the Trust,
and may be amended from to time, as required.
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Attachment D
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MEYERS INVESTMENT TRUST
Code of Ethics
INITIAL AND ANNUAL CERTIFICATION BY ACCESS PERSONS
AND
CERTIFICATION TO MEYERS PRIDE VALUE FUND BOARD
Meyers Investment Trust (the Trust) requires that all trustees, officers
and employees of the Trust (Access Persons) certify that they have read
thoroughly, understand and agree to abide by the conditions set forth in the
Trust's Code of Ethics (the Code). If such employees are deemed to be Access
Persons under the Code, they are required to submit Initial and Annual Holdings
Reports, as well as Transaction/New Account Reports to the Designated
Supervisory Person, listing all personal securities transactions in Covered
Securities/1/ for all such accounts in which the Access Person has any direct or
indirect beneficial interest within ten (10) days of entering into any such
transactions. Access Persons must direct their broker, dealer or bank(s) to
send duplicate trade confirmations and statements of all such personal
securities transactions to be received within ten (10) days following the date
of such purchase, directly to the Designated Supervisory Person, with copies of
same to the Compliance Officer, who compares them to the required
Transaction/New Account Reports. Additionally, the Designated Supervisory
Person undertakes a quarterly review of all Access Person's personal securities
transactions.
I have read and understand the Code of Ethics. I hereby agree to certify
on an annual basis that I have complied with the requirements of the Code and
that I have disclosed or reported all personal securities transactions required
to be disclosed or reported pursuant to the requirements of the Code.
______________________________ ____________
Type or Print Name Date
______________________________
Signature of Access Person
The undersigned hereby certifies that the Trust has adopted Procedures designed
to be reasonably necessary to prevent Access Persons from violating the Trust's
Code and the required provisions of Rule 17j-1 under the Investment Company Act
of 1940, as amended.
_______________________ ___________,2000
Designated Supervisory Person/Meyers Investment Trust Date
___________________
/1/ Covered Security means a security as defined in section 2(a)(36) of the
Act [15 U.S.C.80a-2(a)(36)], except that it does not include:
(i) Direct obligations of the Government of the United States;
(ii) Bankers' acceptances, bank certificates of deposit, commercial
paper and high quality short-term debt instruments, including
repurchase agreements; and
(iii) Shares issued by open-end funds.
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Attachment E
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ACCESS PERSON PRECLEARANCE REQUEST FORM
---------------------------------------
Designated Supervisory Person:
On each of the dates proposed below, I hereby request permission to effect
a transaction in the securities indicated below on behalf of myself and my
immediate family sharing the same household, adopted pursuant to Rule 17j-1
under the Investment Company Act of 1940, as amended, trusts of which I am
trustee or another account in which I have a beneficial ownership or legal
title, and which are required to be pre-approved pursuant to the Code of Ethics
of Meyers Investment Trust.
(Use approximate dates and amounts of proposed transactions.)
<TABLE>
<CAPTION>
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Name of Proposed No. of Dollar Nature of Broker/ Price
Security Date of Shares or Amount of Transaction Dealer or
Transaction Principal Transaction (Purchase, Bank
Amount Sale, Other)
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<S> <C> <C> <C> <C> <C> <C>
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</TABLE>
Print
Name:_____________________________
Title:____________________________
Date
Filed: ____________________________ Signature:________________________
Reason Permission Permission Denied:________________
Granted:__________________________
Approval Denial
Date:_____________________________ Date:_____________________________
