ISLAMIA GROUP OF FUNDS
AND
INCOME ACHIEVERS, INC.
------------------------------
STANDARDS AND PROCEDURES
REGARDING
CONFLICTS OF INTEREST
------------------------------
CODE OF ETHICS
AND
REPORTING REQUIREMENTS
Conflicts of interest can arise when certain investment company or
investment adviser personnel (E.G., those who may have knowledge of impending
fund transactions) buy and sell securities for their personal accounts
("PERSONAL INVESTMENT ACTIVITIES"). These conflicts arise because such personnel
have the opportunity to profit from information about fund transactions, often
to the detriment of fund investors.
Section 17(j) of the Investment Company Act of 1940 (the "ACT") and
rule 17j-1 thereunder are intended to address the potential conflicts arising
from the personal investment activities of investment company personnel,
including the company's investment adviser. Rule 17j-1, among other things, (a)
prohibits fraudulent, deceptive or manipulative acts by fund affiliates and
certain other persons in connection with their personal transactions in
securities held or to be acquired by the investment company, (b) requires funds,
their investment advisers and principal underwriters to adopt codes of ethics
reasonably designed to prevent their "access persons" (generally, personnel that
are involved in the portfolio management process) from engaging in conduct
prohibited by the rule, (c) requires access persons to periodically report their
securities holdings and personal securities transactions, (d) requires the fund,
adviser and underwriter to use reasonable diligence and institute procedures
reasonably necessary to prevent violations of the code, and (e) requires the
fund, adviser, and principal underwriter to report annually to the board issues
arising under the code, including material violations and sanctions, and to
certify that they have adopted procedures reasonably necessary to prevent access
persons from violating the code. Accordingly, the Islamia Group of Funds (the
"FUND") and Income Achievers, Inc. ("INCOME ACHIEVERS"), as the investment
adviser and principal underwriter to the Fund, have each adopted this code of
ethics (the "CODE").
It should be noted that this Code is applicable to all employees of
Income Achievers, and the Fund and members of the Fund and Income Achievers'
board of trustees or directors (as applicable), unless otherwise indicated
below. The Code addresses personal transactions in securities within the context
of section 17(j) and rule 17j-1 of the Act. The Code does not encompass all
possible areas of potential liability under the federal securities laws,
including the Act. For instance, the federal securities laws preclude investors
from trading on the basis of material, nonpublic information or communicating
this information in breach of a fiduciary duty ("INSIDER TRADING" or "TIPPING").
Other provisions of the Act also address transactions involving investment
companies and their affiliated persons (such as the investment adviser) which
may involve fraud or raise other conflict issues. For example, section 17(a) of
<PAGE>
the Act generally prohibits sales or purchases of securities or other property
between a registered investment company and an affiliated person (or an
affiliated person of such person) and section 17(d) and rule 17d-1 thereunder
generally prohibits an affiliated person of a registered investment company (or
an affiliated person of such person) from participating in any joint enterprise,
arrangement, or profit sharing plan with the investment company absent an
exemptive order from the Securities and Exchange Commission. Accordingly,
persons covered by this Code are advised to seek advice before engaging in any
transactions other than the purchase or redemption of Fund shares or the regular
performance of their normal business duties if the transaction directly or
indirectly involves themselves and the Fund or other clients of Income
Achievers.
This Code of Ethics consists of six sections -- 1. Statement of General
Principles; 2. Definitions; 3. Exempted Transactions; 4. Prohibited Activities;
5. Compliance Procedures; and 6. Sanctions.
I. STATEMENT OF GENERAL PRINCIPLES
The Code is based upon the principle that the officers,
directors/trustees and employees of the Fund and Income Achievers owe a
fiduciary duty to, among others, the shareholders of the Fund, to conduct their
personal securities transactions in a manner which does not interfere with Fund
portfolio transactions or otherwise take unfair advantage of their relationship
to the Fund. In accordance with this general principle, all Access Persons (as
defined below) must: (1) place the interests of shareholders of the Fund first;
(2) execute personal securities transactions in compliance with the Code; (3)
avoid any actual or potential conflict of interest or any abuse of their
positions of trust and responsibility; and (4) not take inappropriate advantage
of their positions. Persons covered by this Code must adhere to its general
principles as well as comply with the Code's specific provisions. It bears
emphasis that technical compliance with the Code's procedures will not
automatically insulate from scrutiny trades which show a pattern of abuse of the
individual's fiduciary duties to the Fund or its shareholders. In addition, a
violation of the general principles of the Code may constitute a punishable
violation.
II. DEFINITIONS
As used herein:
A. "ACCESS PERSON" shall mean any director or trustee, officer or
Advisory Person of the Fund or Income Achievers. A list of persons deemed to be
Access Persons is attached as Exhibit A.
B. "ACT" means the Investment Company Act of 1940, as amended.
C. "ADVISORY PERSON" shall mean:
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1. Any employee of the Fund or Income Achievers (or of any
company in a control relationship to the Fund or Income Achievers) who,
in connection with his or her regular functions or duties, makes,
participates in, or obtains information regarding the purchase or sale
of Covered Securities by the Fund or whose functions relate to the
making of any recommendations with respect to such purchases or sales;
and
2. Any natural person in a control relationship to the Fund
or Income Achievers who obtains information concerning recommendations
made to such Fund with regard to the purchase or sale of Covered
Securities by the Fund.
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 such person
considers making such recommendation.
E. "BENEFICIAL OWNERSHIP" shall be interpreted in the same manner as
it would be under rule 16a-1(a)(2) of the Securities Exchange Act of 1934 (the
"EXCHANGE ACT") in determining whether a person has beneficial ownership of a
security for purposes of section 16 of the Exchange Act and the rules and
regulations thereunder. In this regard, beneficial ownership will be deemed to
exist if a person, directly or indirectly, through any contract, arrangement,
understanding, relationship or otherwise has a direct or indirect pecuniary
interest in the securities (i.e., an opportunity, directly or indirectly, to
profit or share in any profit derived from a transaction in the securities).
Under this definition, beneficial ownership by a person includes, but is not
limited to, securities held by members of a person's immediate family sharing
the same household, securities held in certain trusts, and a general partner's
proportionate interest in the portfolio securities held by a general or limited
partnership. A person will not be deemed to be the beneficial owner of
securities held in the portfolio of a registered investment company solely by
reason of his or her ownership of shares or units of such registered investment
company.
F. "COMPLIANCE OFFICER" shall be the President of Income Achievers and
the Fund or his/her designees. A list of the Compliance Officers is attached as
Exhibit B.
G. "CONTROL" shall have the same meaning as set forth in section
2(a)(9) of the Act.
H. "COVERED SECURITY" shall mean any stock, bond, debenture, evidence
of indebtedness or in general any other instrument defined to be a security in
section 2(a)(36) of the Act except that it shall not include shares of
registered open-end investment companies, direct obligations of the Government
of the United States, bankers' acceptances, bank certificates of deposit,
commercial paper and high quality short-term debt instruments, including
repurchase agreements.
I. "INCOME ACHIEVERS" means Income Achievers, Inc.
J. "INVESTMENT PERSONNEL" of the Fund or Income Achievers shall mean:
(1) any employee of the Fund or Income Achievers (or of any company in a control
relationship to the Fund or Income Achievers) who, in connection with his or her
regular functions or duties, makes or participates in making recommendations
regarding the purchase or sale of securities by the Fund, and (2) any natural
person who controls the Fund or Income Achievers and who obtains information
concerning recommendations made to the Fund regarding the purchase or sale of
securities by the Fund. A list of investment personnel is attached as Exhibit C.
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K. "PORTFOLIO MANAGER" shall mean any employee of the Fund or Income
Achievers who is entrusted with the direct responsibility and authority to make
investment decisions affecting the Fund. A list of portfolio managers is
attached as Exhibit D.
L. "PURCHASE OR SALE OF A COVERED SECURITY" includes, among other
things, the writing of an option to purchase or sell a Covered Security.
M. "SECURITY HELD OR TO BE ACQUIRED" by the Fund means (a) any Covered
Security which, within the most recent fifteen days (i) is or has been held by
the Fund or (ii) is being or has been considered by the Fund or Income Achievers
for purchase by the Fund; and (b) any option to purchase or sell, and any
security convertible into or exchangeable for, a Covered Security described in
(a) of this item M.
III. EXEMPTED TRANSACTIONS
The prohibitions of Section IV(A) and IV(C) of this Code of Ethics
shall not apply to:
A. Purchases or sales effected in any account over which the
Access Person has no direct or indirect influence or control;
B. Purchases or sales of securities which are not eligible for
purchase or sale by the Fund;
C. Purchases or sales of securities of companies with a market
capitalization of $500 million or more;
D. Purchases or sales which are non-volitional on the part of
either the Access Person or the Fund (E.G., transactions in corporate
mergers, stock splits, tender offers);
E. Purchases which are part of an automatic dividend reinvestment
plan;
F. 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 such issuer, and sales of such
rights so acquired; and
G. Purchases or sales which receive the prior approval of the
Compliance Officer because they are only remotely potentially harmful
to the Fund or its shareholders, or because they clearly are not
related economically to the securities to be purchased, sold or held by
the Fund.
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IV. PROHIBITED ACTIVITIES
A. Access Persons shall not purchase or sell, directly or indirectly,
any Covered Security in which he or she has, or by reason of such transaction
acquires, any direct or indirect beneficial ownership and which to his or her
actual knowledge at the time of such purchase or sale (a) is being considered
for purchase or sale by the Fund or Income Achievers; or (b) is being purchased
or sold by the Fund.
Without limiting the generality of the foregoing (a) no Portfolio
manager may purchase or sell any Covered Security within fifteen calendar days
before and after any portfolio of the Fund which he or she manages trades in
that security, and (b) no Access Person shall purchase or sell any Covered
Security on the same day there is a pending buy or sell order in that security
by the Fund or Income Achievers. Any profits realized on trades within the
proscribed periods will be disgorged to a charitable organization.
B. Investment personnel shall not acquire directly or indirectly
beneficial ownership in securities pursuant to a private placement or initial
public offering without prior approval from the Compliance Officer described in
Section (V) below.
C. Investment personnel shall not profit in the purchase and sale, or
sale and purchase, of the same (or equivalent) security within sixty calendar
days. Trades made in violation of this prohibition shall be unwound or, if that
is impracticable, any profits must be disgorged to a charitable organization.
D. Investment personnel shall not receive any gift or other thing of
more than DE MINIMIS value from any person or entity that does business with or
on behalf of the Fund or any other client of Income Achievers.
E. Investment personnel shall not serve on the board of directors of a
publicly traded company, without prior authorization by the Compliance Officer.
Investment personnel may submit a request for authorization and such request
shall state the position sought, the reason service is desired and any possible
conflicts of interest known at the time of the request. No such position shall
be accepted without the prior clearance by the Compliance Officer. Service may
be cleared by the Compliance Officer only if such officer determines that
service in that capacity would be consistent with the interests of the Fund, any
shareholders affected, and any other clients of Income Achievers. In addition,
Investment personnel who receive authorization to serve in such a capacity must
be isolated through "Chinese Wall" procedures from making investment decisions
regarding securities issued by the entity involved.
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V. Compliance Procedures
A. PRE-CLEARANCE.
Investment personnel must receive prior approval of their personal
investment transactions in Covered Securities, as defined above, from the
Compliance Officer. A request for approval shall state the title and principal
amount of the security proposed to be purchased or sold, the nature of the
transaction, the price at which the transaction is proposed to be effected, and
the name of the broker, dealer or bank through whom the transaction is proposed
to be effected. Any approval shall be valid for three business days. In
determining whether approval should be granted, the Compliance Officer should
consider:
1. whether the investment opportunity should be reserved for the
Fund, its shareholders, or other clients of Income Achievers; and
2. whether the opportunity is being offered to an individual by
virtue of his/her position with the Fund or Income Achievers'
relationship with any other client.
In the event approval is granted, the Access Person must disclose the
investment when he/she plays a role in any client's, including the Fund's,
subsequent investment decision regarding the same issuer. In such circumstances,
the decision to purchase or sell securities of the issuer will be subject to an
independent review by Investment personnel with no personal interest in the
issuer or another designee.
The pre-clearance requirement shall not apply to Exempted Transactions
listed in Section III. This exception does not eliminate or modify the
requirement that Investment personnel receive pre-approval before acquiring
securities in a private placement or initial public offering, as required under
Section IV(B) above.
B. REPORTING REQUIREMENTS.
Unless excepted by Subsection C of this Section V, every Access Person
of the Fund and of Income Achievers must report to the Compliance Officer the
following:
1. INITIAL HOLDINGS REPORTS. No later than ten days after the
person becomes an Access Person, the following information:
a. the title, number of shares and principal amount of each
Covered Security in which the Access Person had any direct or indirect
beneficial ownership when the person became an Access Person;
b. the name of any broker, dealer or bank with whom the Access
Person maintained an account in which any securities were held for the
direct or indirect benefit of the Access Person as of the date the
person became an Access Person; and
c. the date that the report is submitted by the Access Person.
2. QUARTERLY TRANSACTION REPORTS. No later than ten days after the end
of the calendar quarter, the following information:
a. With respect to any transaction during the quarter in a
Covered Security in which the Access Person had any direct or indirect
beneficial ownership:
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1. The date of the transaction, the title, the interest rate and
maturity date (if applicable), the number of shares and the principal
amount of each Covered Security involved;
2. The nature of the transaction (I.E., purchase, sale or any
other type of acquisition or disposition);
3. The price of the Covered Security at which the transaction was
effected;
4. The name of the broker, dealer or bank with or through which
the transaction was effected; and
5. The date that the report is submitted by the Access Person.
b. With respect to any account established by the Access
Person in which any securities were held during the quarter for the
direct or indirect benefit of the Access Person:
1. The name of the broker, dealer or bank with whom the Access
Person established the account;
2. The date the account was established; and
3. The date that the report is submitted by the Access Person.
In addition to the above, every Access Person other than trustees who
are not "interested persons" shall direct his or her broker or brokers to supply
to the Compliance Officer, on a timely basis, duplicate copies of confirmations
of all securities transactions and copies of periodic statements for all
securities accounts involving Covered Securities in which such Access Person
acquires or foregoes direct or indirect beneficial ownership. Such duplicate
confirmations and periodic statements received during the proscribed period
shall satisfy the reporting requirements set forth in this paragraph if all the
information required to be included in the Quarterly Report is contained in the
broker confirmations or account statements.
3. ANNUAL HOLDINGS REPORT. No later than ten days after the end of the
calendar year the following information (which information must be current as of
a date no more than thirty days before the report is submitted):
a. The title, number of shares and principal amount of each
Covered Security in which the Access Person had any direct or indirect
beneficial ownership;
b. The name of any broker, dealer or bank with whom the Access
Person maintains an account in which any securities are held for the
direct or indirect benefit of the Access Person; and
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c. The date that the report is submitted by the Access Person.
C. EXCEPTIONS TO REPORTING REQUIREMENTS.
1. A person need not make a report under Section V(B) of this Code
with respect to transactions effected for, and Covered Securities held in, any
account over which the person has no direct or indirect influence or control.
2. A trustee of the Fund who is not an "interested person" of the Fund
within the meaning of section 2(a)(19) of the Act, and who would be required to
make a report solely by reason of being a Fund trustee, need not make:
a. An initial holdings report under Section V(B)(1) of this Code
and an annual holdings report under Section V(B)(3) of this Code; and
b. A quarterly transaction report under Section V(B)(2) of this
Code, unless the trustee knew or, in the ordinary course of fulfilling
his or her official duties as a Fund trustee, should have known that
during the 15-day period immediately before or after the trustee's
transaction in a Covered Security, the Fund purchased or sold the
Covered Security, or the Fund or its investment adviser considered
purchasing or selling the Covered Security.
3. An Access Person to Income Achievers need not make a quarterly
transaction report to the Compliance Officer under Section V(B)(2) of this Code
if all the information in the report would duplicate information required to be
recorded under Rules 204-2(a)(12) or 204-2(a)(13) of the Investment Advisers Act
of 1940.
D. CERTIFICATION.
1. All Access Persons shall certify annually that:
a. They have read and understood the Code and recognize that they
are subject thereto; and
b. They have complied with the requirements of the Code and
disclosed or reported all personal securities transactions required to
be disclosed or reported pursuant to the Code.
E. DUTIES OF THE COMPLIANCE OFFICER.
1. REVIEW REPORTS. The Compliance Officer of the Fund and Income
Achievers shall review the reports submitted under Section V(B).
2. NOTIFICATION OF REPORTING OBLIGATION. The Compliance Officer shall
update Exhibits A, B, C and D as necessary to include new Access Persons,
Investment Personnel and portfolio managers and shall notify those persons of
their reporting obligations hereunder and to update the Compliance Officer or
designee responsible to review reports.
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3. REPORTING TO THE BOARD OF TRUSTEES. The Compliance Officer (with
the assistance of the Fund's legal counsel if necessary) shall prepare an annual
written report to the Fund's Board of Trustees which shall:
a. Summarize existing procedures concerning personal investing
and any changes in the procedures made during the past year;
b. Describe any issues arising under the Code or procedures since
the last report to the Board of Trustees, including, but not limited
to, information about material violations of the Code or procedures and
sanctions imposed in response to the material violations; and
c. Identify any recommended changes in existing restrictions or
procedures based upon the Fund's experience under its Code, evolving
industry practices, or developments in laws or regulations;
d. Certify that the Fund and Income Achievers have adopted
procedures reasonably necessary to prevent Access Persons from
violating the Code.
4. The Compliance Officer or his designee shall maintain all records
required under rule 17j-1 of the Act for the periods required under the Rule.
VI. SANCTIONS
Upon discovery of a violation of this Code, including either violations
of the enumerated provisions or the general principles provided, the Fund or
Income Achievers may impose such sanctions as it deems appropriate, including,
INTER ALIA, a letter of censure or suspension or termination of the employment
of the violator.
VII. AMENDMENT TO THIS CODE
The Fund's Board of Trustees must approve any material change to this
Code of Ethics no later than six months after the adoption of the material
change.
Dated: May 3, 2000
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EXHIBIT A
ACCESS PERSONS (AS OF _____ , 2000)
ACCESS PERSONS (FUND AND INCOME ACHIEVERS EMPLOYEES AND INTERESTED TRUSTEES)
ACCESS PERSONS (OUTSIDE DIRECTORS)
Trustees of Funds Managed by Income Achievers
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EXHIBIT B
COMPLIANCE OFFICER AND DESIGNEE (AS OF ______, 2000)
THE FOLLOWING IS THE COMPLIANCE OFFICER AND HIS/HER DESIGNEE
RESPONSIBLE FOR REVIEWING REPORTS SUBMITTED UNDER THE CODE OF ETHICS OF THE FUND
AND INCOME ACHIEVERS:
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EXHIBIT C
INVESTMENT PERSONNEL (AS OF_______, 2000)
INVESTMENT PERSONNEL
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EXHIBIT D
PORTFOLIO MANAGERS (AS OF _______________, 2000)
PORTFOLIO MANAGERS
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EXHIBIT E
ACKNOWLEDGMENT OF RECEIPT OF CODE OF ETHICS
I acknowledge that I have received the Code of Ethics dated
___________, 2000, and represent:
1. I have read and understood the Code of Ethics and recognize that I
am subject to its provisions;
2. In accordance with Section V of the Code of Ethics, I will report
all securities transactions in which I have a beneficial interest, except for
transactions exempt from reporting under Section V(C) of the Code of Ethics.
3. I will comply with the Code of Ethics in all other respects.
------------------------------
Access Person Signature
------------------------------
Print Name
Dated: _____________________
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EXHIBIT F
ANNUAL CERTIFICATION OF COMPLIANCE WITH THE CODE OF ETHICS
I certify that during the past year:
1. I have read and understood the Code of Ethics and recognize that I
am subject to its provisions;
2. In accordance with Section V of the Code of Ethics, I have reported
all securities transactions in which I have a beneficial interest except for
transactions exempt from reporting under Section V(C) of the Code of Ethics and
except to the extent disclosed on an attached schedule.
2. I have complied with the Code of Ethics in all other respects.
------------------------------
Access Person Signature
------------------------------
Print Name
Dated: _____________________
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EXHIBIT G
ISLAMIA GROUP OF FUNDS
INCOME ACHIEVERS, INC.
INITIAL HOLDINGS REPORT
DATE OF BECOMING AN ACCESS PERSON: _______________
To: Compliance Officer
As of the date referred to above, I have direct or indirect beneficial
ownership in the following securities which are required to be reported pursuant
to the Code of Ethics of the Islamia Group of Funds/Income Achievers, Inc.
<TABLE>
<CAPTION>
------------------------------- ------------------- --------------------------- --------------------
Broker/
Dealer
Dollar or Bank
Security (Include Full Number of Amount of holding the
Name of Issuer) Shares Securities Securities:
------------------------------- ------------------- --------------------------- --------------------
<S> <C> <C> <C> <C> <C> <C>
------------------------------- ------------------- --------------------------- --------------------
------------------------------- ------------------- --------------------------- --------------------
------------------------------- ------------------- --------------------------- --------------------
------------------------------- ------------------- --------------------------- --------------------
------------------------------- ------------------- --------------------------- --------------------
------------------------------- ------------------- --------------------------- --------------------
------------------------------- ------------------- --------------------------- --------------------
------------------------------- ------------------- --------------------------- --------------------
------------------------------- ------------------- --------------------------- --------------------
------------------------------- ------------------- --------------------------- --------------------
------------------------------- ------------------- --------------------------- --------------------
</TABLE>
This report (i) excludes transactions effected for or securities held
in any account over which I had no direct or indirect influence or control, (ii)
excludes other transactions not required to be reported, and (iii) is not an
admission that I have or had any direct or indirect beneficial ownership in the
securities listed above.
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This report is to be signed, dated and returned within ten days of the
person becoming an Access Person, as defined in the Code of Ethics.
Signature:_________________________________
Printed name:______________________________
Date:______________________________________
Return by [_____________] to Compliance Officer. Questions regarding
this form may be directed to [_____________] at [_______________].
Date Submitted to Compliance Officer: __________________________.
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EXHIBIT H
ISLAMIA GROUP OF FUNDS
INCOME ACHIEVERS, INC.
SECURITIES TRANSACTION REPORT
FOR THE CALENDAR QUARTER ENDED [___________]
To: Compliance Officer
A._______During the quarter referred to above, the following
transactions were effected in securities of which I had, or by reason of such
transactions acquired, direct or indirect beneficial ownership, and which are
required to be reported pursuant to the Code of Ethics of the Islamia Group of
Funds/Income Achievers, Inc.
<TABLE>
<CAPTION>
--------------------- --------------- -------------- ------------- ---------------- -------------- --------- -------------
SECURITY (INCLUDE DATE OF INTEREST NUMBER OF DOLLAR NATURE OF BROKER/
RATE AND DEALER
MATURITY OR BANK
DATE (IF AMOUNT OF TRANSACTION: EFFECTED
FULL NAME OF ISSUER) TRANSACTION APPLICABLE) SHARES TRANSACTION (BUY/SELL) PRICE THROUGH:
--------------------- --------------- -------------- ------------- ---------------- -------------- --------- -------------
<S> <C> <C> <C> <C> <C> <C>
--------------------- --------------- -------------- ------------- ---------------- -------------- --------- -------------
--------------------- --------------- -------------- ------------- ---------------- -------------- --------- -------------
--------------------- --------------- -------------- ------------- ---------------- -------------- --------- -------------
--------------------- --------------- -------------- ------------- ---------------- -------------- --------- -------------
--------------------- --------------- -------------- ------------- ---------------- -------------- --------- -------------
--------------------- --------------- -------------- ------------- ---------------- -------------- --------- -------------
--------------------- --------------- -------------- ------------- ---------------- -------------- --------- -------------
--------------------- --------------- -------------- ------------- ---------------- -------------- --------- -------------
--------------------- --------------- -------------- ------------- ---------------- -------------- --------- -------------
--------------------- --------------- -------------- ------------- ---------------- -------------- --------- -------------
--------------------- --------------- -------------- ------------- ---------------- -------------- --------- -------------
--------------------- --------------- -------------- ------------- ---------------- -------------- --------- -------------
</TABLE>
B._______During the quarter referred to above, I established the
following accounts in which securities were held during the quarter for my
direct or indirect benefit:
------------------------------------------- ----------------
Date Account
was established
Name of Broker/Dealer or Bank with the
Account
------------------------------------------- ----------------
------------------------------------------- ----------------
------------------------------------------- ----------------
------------------------------------------- ----------------
------------------------------------------- ----------------
C._______In lieu of the information required under A and B above, I
represent that the trade confirmations and/or brokerage account statements
attached hereto represent all transactions which must be reported pursuant to
the Code of Ethics.
or
No reportable transactions.
This report (i) excludes transactions effected for or securities held
in any account over which I had no direct or indirect influence or control, (ii)
excludes other transactions not required to be reported, and (iii) is not an
admission that I have or had any direct or indirect beneficial ownership in the
securities listed above.
This report is to be signed, dated and returned within ten days of the
end of the calendar quarter.
Signature:________________________________________
Printed name:_____________________________________
Date:_____________________________________________
Return by [_____________] to Compliance Officer. Questions regarding
this form may be directed to [_____________] at [______________].
Date Submitted to Compliance Officer: ____________________________.
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EXHIBIT I
ISLAMIA GROUP OF FUNDS
INCOME ACHIEVERS, INC.
ANNUAL HOLDINGS REPORT
FOR THE CALENDAR YEAR ENDED [___________]
To: Compliance Officer
As of _____________, which date shall be within 30 days of the date of
submitting this report, I have direct or indirect beneficial ownership in the
following securities which are required to be reported pursuant to the Code of
Ethics of the Islamia Group of Funds/Income Achievers, Inc.
<TABLE>
<CAPTION>
------------------------------- ---------------------------- ---------------------------- ----------------------------
DOLLAR BROKER/DEALER OR
SECURITY (INCLUDE FULL AMOUNT OF BANK WHO MAINTAINS
NAME OF ISSUER) NUMBER OF SHARES SECURITIES THESE SECURITIES
------------------------------- ---------------------------- ---------------------------- ----------------------------
<S> <C> <C> <C> <C> <C> <C>
------------------------------- ---------------------------- ---------------------------- ----------------------------
------------------------------- ---------------------------- ---------------------------- ----------------------------
------------------------------- ---------------------------- ---------------------------- ----------------------------
------------------------------- ---------------------------- ---------------------------- ----------------------------
------------------------------- ---------------------------- ---------------------------- ----------------------------
------------------------------- ---------------------------- ---------------------------- ----------------------------
------------------------------- ---------------------------- ---------------------------- ----------------------------
------------------------------- ---------------------------- ---------------------------- ----------------------------
</TABLE>
This report (i) excludes transactions effected for or securities held
in any account over which I had no direct or indirect influence or control, (ii)
excludes other transactions not required to be reported, and (iii) is not an
admission that I have or had any direct or indirect beneficial ownership in the
securities listed above.
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This report is to be signed, dated and returned within ten days of the
end of the calendar year.
Signature:_______________________________________
Printed name:____________________________________
Date:____________________________________________
Return by [_____________] to Compliance Officer. Questions regarding
this form may be directed to [_____________] at [______________].
Date Submitted to Compliance Officer: __________________________.
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