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EXHIBIT P(I)
CODE OF ETHICS
OF
WT INVESTMENT TRUST I
WT MUTUAL FUND
RODNEY SQUARE MANAGEMENT CORPORATION
WILMINGTON TRUST COMPANY
PREAMBLE
This Code of Ethics has been adopted by
- the Board of Trustees of WT Investment Trust I (the "Trust") on behalf
of each series of the Trust listed on Schedule A hereto;
- the Board of Trustees of WT Mutual Fund (the "Fund") on behalf of each
series of the Fund listed on Schedule B hereto;
- the Board of Directors of Rodney Square Management Corporation
("Rodney Square"), insofar as Rodney Square serves as investment
adviser to certain series of the Trust and the Fund; and
- the Board of Directors of Wilmington Trust Company ("WTC"), insofar as
WTC serves as investment adviser to certain series of the Trust and
the Fund.
The Code has been adopted in accordance with the requirements of Rule 17j-1
(the "Rule") under the Investment Company Act of 1940 (the "Act"). The Rule
requires the Trust, the Fund, and Rodney Square and WTC (collectively, the
"Investment Advisers") to adopt written codes of ethics containing provisions
reasonably necessary to prevent persons from engaging in acts in violation of
the Act and the Rule, and to use reasonable diligence to prevent violations of
the code.
Violations of sub-paragraph (b) of the Rule may constitute grounds for the
imposition of significant administrative and civil injunctive, as well as
criminal, sanctions by the U.S. Securities and Exchange Commission or the
federal courts. In addition, the Trust or Fund may impose internal sanctions for
violations of this Code. All persons that are or that are about to become
covered by this Code are expected to be familiar with the proscriptions of this
Rule. To that end, a summary of Rule 17j-1(b) is included as Appendix A to this
Code.
Set forth below is the Code of Ethics adopted by the Trust, the Fund, and
the Investment Advisers in compliance with the Rule. This Code of Ethics is
based upon the principle that the trustees and officers of the Trust, the
trustees and officers of the Fund, and certain affiliated persons of the Trust,
the Fund, and the Investment Advisers owe a fiduciary duty to, among others,
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the shareholders of the Trust and/or the Fund to conduct their affairs,
including their personal securities transactions, in such manner to avoid (i)
serving their own personal interests ahead of shareholders; (ii) taking
inappropriate advantage of their position with the Trust or the Fund; and (iii)
any actual or potential conflicts of interest or any abuse of their position of
trust and responsibility.
(a) DEFINITIONS
(a) "ACCESS PERSON" means:
(i) Any director, trustee, officer, or ADVISORY PERSON of the Trust,
the Fund, or Rodney Square; and
(ii) With respect to WTC, means any director, officer, or Advisory
Person of WTC who, with respect to the Trust or the Fund, makes
any recommendation, participates in the determination of which
recommendation will be made, or whose principal function or
duties relate to the determination of which recommendation will
be made, or who, in connection with his or her duties, obtains
any information concerning recommendations on Covered Securities
being made by WTC to the Trust or the Fund.
(b) "ADVISORY PERSON" means
(i) any employee of the Trust, Fund, Rodney Square or WTC (or of any
company in a control relationship to the Trust, Fund, Rodney
Square or WTC) who, in connection with his regular functions or
duties, makes, participates in, or obtains current information
regarding the purchase or sale of a Covered Security by the Trust
or 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 the Trust, Fund,
Rodney Square or WTC, who obtains information concerning
recommendations made to the Trust or Fund with regard to the
purchase or sale of a Covered Security by the Trust or Fund.
(c) A security is "BEING CONSIDERED FOR PURCHASE OR SALE" or is "BEING
PURCHASED OR SOLD" when an instruction to purchase or sell the
security has been made and communicated to the trading desk, which
includes a pending "buy" or "sell" order with respect to a security
for the Trust or the Fund. In addition, as to any person, a security
is "BEING CONSIDERED FOR PURCHASE OR SALE" or is "BEING PURCHASED OR
SOLD" if such person is considering giving an instruction to purchase
or sell the security or is aware that any other person is considering
giving an instruction to purchase or sell the security for the Trust
or the Fund.
(d) "BENEFICIAL OWNERSHIP" shall be as defined in, and 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 thereunder which, generally
speaking, encompasses those situations where the beneficial owner has
the right to enjoy some
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economic benefit from the ownership of the security regardless of who
is the registered owner. This would include:
(i) securities which a person holds for his or her own benefit
either in bearer form, registered in his or her own name or
otherwise regardless of whether the securities are owned
individually or jointly;
(ii) securities held in the name of a member of his or her
immediate family (spouse, minor child and adults) sharing
the same household;
(iii) securities held by a trustee, executor, administrator,
custodian or broker;
(iv) securities owned by a general partnership of which the
person is a member or a limited partnership of which such
person is a general partner;
(v) securities held by a corporation which can be regarded as a
personal holding company of a person; and
(vi) securities recently purchased by a person and awaiting
transfer into his or her name.
(e) "COMPLIANCE OFFICER" means an officer or employee of the Trust or
Fund, as the case may be, who is authorized and appointed by the Trust
or Fund to perform, or procure the performance of, the various
responsibilities assigned to such Compliance Officer by this Code.
(f) "CONTROL" has the same meaning as that set forth in Section 2(a)(9) of
the Act.
(g) "Covered Security" means any Security other than
(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 registered open-end investment companies.
(h) "EQUIVALENT SECURITY" shall include any option to purchase or sell,
and any security convertible into or exchangeable for such Covered
Security.
(i) "INDEPENDENT DIRECTOR" means a Director of any of the Investment
Advisers who is not deemed to be an "interested person" within Section
2(a)(19)(B) of the Act and has no involvement with the day-to-day
operations of the Trust, the Fund or any of the Investment Advisers.
(j) "INDEPENDENT TRUSTEE" means a Trustee of the Trust or the Fund,
respectively, who is not an "interested person" of the Trust or Fund,
respectively, within the meaning of Section 2(a)(19)(A) of the Act.
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(k) "INITIAL PUBLIC OFFERING" ("IPO") means an offering of securities
registered under the Securities Act of 1933 ("Securities Act"), the
issuer of which, immediately before the registration, was not subject
to the reporting requirements of Sections 13 or 15(d) of the
Securities Exchange Act of 1934.
(k) "INVESTMENT PERSONNEL" means:
(i) any employee of the Trust, the Fund, Rodney Square or WTC (or of
any company in a control relationship to the Trust, the Fund,
Rodney Square or WTC), who, in connection with his regular
functions or duties, makes or participates in making
recommendations regarding the purchase or sale of securities by
the Trust or the Fund; and
(ii) any natural person who controls the Trust, the Fund, Rodney
Square or WTC who obtains information concerning recommendations
made to the Trust or Fund regarding the purchase or sale of
securities by the Trust or Fund.
(l) "LIMITED OFFERING" means an offering that is exempt from registration
under the Securities Act pursuant to Section 4(2) or Section 4(6) or
pursuant to Rule 504, Rule 505 or Rule 506 under the Securities Act.
(m) "PURCHASE OR SALE OF A COVERED SECURITY" includes the writing of an
option to purchase or sell a Covered Security.
(n) "SECURITY" as defined in Section 2(a)(36) of the Act means any note,
stock, treasury stock, bond, debenture, 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, any put,
call, straddle, option, or privilege on any security (including a
certificate of deposit) or on any group or index of securities
(including any interest therein or based on the value thereof), or any
put, call, straddle, option, or privilege entered into in a national
securities exchange relating to foreign currency, or, in general, 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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(b) PROHIBITED TRANSACTIONS
(i) No Access Person or Investment Personnel shall engage
in any act, practice or course of conduct, which would violate the
provisions of Rule 17j-1 set forth in Appendix A.
(ii)
(iii) Except as otherwise provided, no Access Person shall:
(iv)
(1) purchase or sell, directly or indirectly, any Covered
Security (or any Equivalent Security) in which he or she has or
by reason of such transaction acquires, any direct or indirect
beneficial ownership and which at the time of such purchase or
sale:
(a) is being considered for purchase or sale by the Trust
or the Fund, as the case may be, or
(b) is being purchased or sold by the Trust or the Fund;
(2) disclose to other persons the securities activities
engaged in or contemplated for the various portfolios of the
Trust or Fund;
(3) buy or sell a Covered Security within at least seven (7)
calendar days after any series of the Trust or the Fund trades in
that security;
(4) seek or accept anything of value, either directly or
indirectly, from broker-dealers or other persons providing
services to the Trust or Fund because of such person's
association with the Trust or Fund. For the purposes of this
provision, the following gifts from broker-dealers or other
persons providing services to the Trust or Fund will not be
considered to be in violation of this section:
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(a) AN OCCASIONAL MEAL;
(b) AN OCCASIONAL TICKET TO A SPORTING EVENT, THE
THEATER OR COMPARABLE ENTERTAINMENT, FOR WHICH THE ACCESS
PERSON WILL REIMBURSE THE HOST;
(c) A HOLIDAY GIFT OF FRUIT OR OTHER FOODS; PROVIDED,
HOWEVER, THAT SUCH GIFT IS MADE AVAILABLE TO ALL MEMBERS OF
THE RECIPIENT'S DEPARTMENT.
(5) trade on or communicate material non-public information,
or "inside information" , of any sort, whether obtained in the
course of research activities, through a client relationship or
otherwise.
(v)
(vi) NO INVESTMENT PERSONNEL SHALL:
(vii)
(1) acquire directly or indirectly any beneficial ownership in
any securities in an IPO;
(2) purchase any securities in a Limited Offering without
prior approval of the Compliance Officer or other person
designated by the Trust's or the Fund's Board of Trustees, as the
case may be. Any person authorized to purchase securities in a
Limited Offering shall disclose that investment when involved in
the Trust's of Fund's subsequent consideration of an investment
in the issuer. In such circumstances, the Trust's or Fund's
decision to purchase securities of the issuer shall be subject to
independent review by the Trust's or Fund's officers, as the case
may be, with no personal interest in the issuer:
(3) profit in the purchase and sale, or sale and purchase, of
the same Covered Security (or any Equivalent Security) within
sixty (60) calendar days. Any profits realized on such short-term
trades shall be subject to disgorgement;
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(4) serve on the board of directors of any publicly traded
company without prior authorization of the Chairman and/or
President of the Trust or Fund, as the case may be. Any such
authorization shall be based upon a determination that the board
service would be consistent with the interests of the Trust or
the Fund and the shareholders of the Trust or Fund, as the case
may be;
(5) buy or sell a Covered Security within at least seven (7)
calendar days before and after any series of the Trust or the
Fund trades in that security. Any profits realized on trades
within the proscribed period are required to be disgorged.
(viii)
(c) EXEMPTED TRANSACTIONS
The prohibitions of Sections 2(b) and 2(c) of the Code shall not apply to:
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(i) purchases or sales effected in any account over which the
Access Person has no direct or indirect influence or control;
(ii) purchases or sales which are non-volitional on the part of
either the Access Person or the Trust or Fund;
(iii) purchases which are part of an automatic dividend
reinvestment plan;
(iv) 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;
(v) purchases or sales of shares of any series of the Trust or
Fund; and
(vi) purchases or sales of securities of any issuer with a
market capitalization of at least $5 billion, provided the amount
of the trade, when aggregated with all other like trades in the
same security, or any option to purchase or sell and any security
convertible into or exchangeable for such security, by or on
behalf of the same person during the previous thirty (30) days,
does not exceed a total of $25,000.
(vii)
(d) COMPLIANCE PROCEDURES
RESTRICTED SECURITIES LIST
(i) The Compliance Officer shall maintain a
current list of Covered Securities which are subject to the
provisions of Section 2 of this Code.
INITIAL AND ANNUAL HOLDINGS REPORTS
All Access Persons, except Independent Trustees and
Independent Directors, shall disclose to the Compliance
Officer within 10 days of becoming an Access Person, and
thereafter on an annual basis as
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of December 31, (i) the name, number of shares and principal
amount of each Covered Security in which the Access Person
has any direct or indirect beneficial ownership and (ii) the
name of any broker, dealer or bank with whom the Access
Person maintains a securities account. The initial and
annual holdings reports shall be made on the appropriate
forms attached under APPENDIX B.
(ii) QUARTERLY REPORTS
(1) Every Access Person shall report to the
Compliance Officer the information described below
with respect to transactions in any Covered Security
in which such person has, or by reason of such
transaction acquires, any direct or indirect
beneficial ownership in the security; provided,
however, that an Access Person shall not be required
to make a report with respect to transactions
effected for any account over which such person has no
direct or indirect influence or control.
(2) Each Independent Trustee and Independent
Director, need only report a transaction in a security
if such Trustee or Director, at the time of that
transaction knew, or, in the ordinary course of
fulfilling his official duties as a Trustee or
Director, should have known that, during the 15-day
period immediately preceding or after the date of the
transaction by the Trustee or Director, such security
was purchased or sold by the Trust or the Fund, as the
case may be, or was being considered for purchase by
the Trust or the Fund or by any of the Investment
Advisers on behalf of the Trust or Fund.
(3) Reports required to be made under this
Paragraph (c) shall be made not later than 10 days
after the end of the calendar quarter. Every Access
Person shall be required to submit a report for all
periods, including those periods in which no
securities transactions were effected. A report shall
be made on the Securities Transaction Report form
attached hereto under APPENDIX B or on any other form
containing the following information:
With respect to any transaction during the quarter in a
Covered Security in which the Access Person had any direct
or indirect beneficial ownership:
(a) THE DATE OF THE TRANSACTION, THE NAME, THE
INTEREST RATE AND MATURITY DATE (IF APPLICABLE),
THE NUMBER OF SHARES, AND THE PRINCIPAL AMOUNT OF
EACH
<PAGE>
COVERED SECURITY INVOLVED;
(b) THE NATURE OF THE TRANSACTION (I.E.,
PURCHASE, SALE OR ANY OTHER TYPE OF ACQUISITION
OR DISPOSITION);
(c) THE PRICE AT WHICH THE TRANSACTION IN THE
COVERED SECURITY WAS EFFECTED;
(d) THE NAME OF THE BROKER, DEALER OR BANK WITH
OR THROUGH WHICH THE TRANSACTION WAS EFFECTED;
AND
(e) THE DATE THAT THE REPORT IS SUBMITTED BY THE
ACCESS PERSON.
With respect to any securities account established at a
broker, dealer or bank during the quarter for the direct or
indirect benefit of the Access Person:
(A) THE NAME OF THE BROKER, DEALER OR BANK
WITH WHOM THE ACCESS PERSON ESTABLISHED THE ACCOUNT;
(B) THE DATE THE ACCOUNT WAS ESTABLISHED;
AND
(C) THE DATE THAT THE REPORT IS SUBMITTED
BY THE ACCESS PERSON.
(4) 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 or she has any
direct or indirect beneficial ownership in the security
to which the report relates.
(iii) BROKER CONFIRMATIONS
With the exception of the Independent Trustees, every Access
Person shall direct his or her brokers to supply to the
Compliance Officer, on a timely basis, duplicate copies of
the confirmation of all personal securities transactions and
copies of all periodic statements for all securities
accounts.
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If copies of the confirmation of personal securities
transactions and copies of periodic statements are not
received within 30 days of the end of the reporting period,
the Access Person shall provide a written authorization to
the Compliance Officer to obtain such statements directly
from the Access Person's broker/dealer.
NOTIFICATION OF REPORTING OBLIGATION
The Compliance Officer shall notify each Access Person that
he or she is subject to these reporting requirements, and
shall deliver a copy of this Code of Ethics to each such
person upon request.
(iv) CERTIFICATION OF COMPLIANCE WITH CODE OF
ETHICS
(v)
With the exception of the Independent Trustees, Access
Persons shall certify annually that:
(i) THEY HAVE READ AND UNDERSTAND THE CODE OF ETHICS AND
RECOGNIZE THAT THEY ARE SUBJECT THERETO;
(ii) THEY HAVE COMPLIED WITH THE REQUIREMENTS OF THE CODE OF
ETHICS; AND
(iii) THEY HAVE REPORTED ALL PERSONAL SECURITIES
TRANSACTIONS REQUIRED TO BE REPORTED PURSUANT TO THE
REQUIREMENTS OF THE CODE OF ETHICS.
(vi) CONFLICT OF INTEREST
Every Access Person shall notify the Compliance Officer of
any personal conflict of interest relationship which may
involve the Trust or the Fund, such as the existence of any
economic relationship between their transactions and
securities held or to be acquired by any series of the Trust
or the Fund.
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(vii) REVIEW OF REPORTS
The Compliance Officer or a designate immediately shall review
all holdings reports submitted by each Access Person,
including confirmations of personal securities transactions,
to ensure that no trading has taken place in violation of the
Rule or this Code of Ethics. Any violations of this Code shall
be reported to the Board of Trustees of the Trust or Fund, as
the case may be, in accordance with Section 5 of this Code.
The Compliance Officer shall maintain a list of the persons
responsible for reviewing the transactions and holdings
reports.
(e) REPORTING OF VIOLATIONS
(i) The Compliance Officer shall promptly report to the
appropriate Board of Trustees:
(1) all apparent violations of this Code of Ethics and
the reporting requirements thereunder; and
(2) any reported personal securities transaction in a
Covered Security which was purchased or sold by the Trust or
Fund within fifteen (15) days before or after the date of
the reported transactions.
(ii) When the Compliance Officer finds that a transaction
otherwise reportable to the Board of Trustees under Paragraph (a)
of this Section could not reasonably be found to have resulted in
a fraud, deceit or manipulative practice in violation of Rule
17j-l(b), it may, in its discretion, lodge a written memorandum
of such finding and the reasons therefor with the reports made
pursuant to this Code of Ethics, in lieu of reporting the
transaction to the Board.
(iii) The Board of Trustees, or a Committee created by a
Board for that purpose, shall consider reports made to the Board
hereunder and shall determine whether or not this Code of Ethics
has been violated and what sanctions, if any, should be imposed.
(f) ANNUAL REPORTING
(i) The Compliance Officer and each Investment Adviser,
shall furnish to the Boards of Trustees of the Trust and the Fund, and
the Boards of Trustees shall consider, an annual report relating to
this
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Code of Ethics. Such annual report shall:
(ii) describe any issues arising under the Code of Ethics or
procedures during the past year;
(iii) identify any material violations of this Code or
procedures, including sanctions imposed in response to such
violations, during the past year;
(iv) identify any recommended changes in the existing
restrictions or procedures based upon the Trust's or Fund's
experience under its Code of Ethics, evolving industry practices
or developments in applicable laws or regulations; and
(v) certify that the Trust, the Fund, and each Investment
Adviser have adopted procedures reasonably necessary to prevent
Access Persons from violating the Code of Ethics.
(g) SANCTIONS
Upon discovering a violation of this Code, the appropriate Board of
Trustees, may impose such sanctions as they deem appropriate,
including, among other things, a letter of censure or suspension or
termination of the employment of the violator.
Notwithstanding receipt of approval pursuant to Section 4(a), any
securities trade executed in violation of Sections 2(b)(vii) or (viii)
shall be unwound or, in the alternative, all profits disgorged to the
affected series of the Trust or the Fund. Furthermore, any profits
realized on any other securities trades or activities in violation of
this Code, shall be disgorged to the affected series of the Trust or
the Fund.
(h) RETENTION OF RECORDS
This Code of Ethics, a list of all persons required to make reports
hereunder from time to time, a copy of each report made by an Access
Person hereunder, a list of all persons responsible for reviewing the
reports required hereunder, a record of any decision, and the reasons
supporting the decision, to approve the acquisition by Access Persons
or Investment Personnel of securities in a Limited Offering, each
memorandum made by the Compliance Officer hereunder and a record of
any violation hereof and any action taken as a result of such
violation, shall be maintained by the Trust and the Fund as required
under Rule 17j-l.
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(i) ADOPTION AND APPROVAL
The Boards of Trustees of the Trust and the Fund, including a majority
of the Independent Trustees of each Board, shall approve this Code of
Ethics of the Trust, the Fund, and the Investment Advisers, and any
material changes to this Code. Each Board shall approve any material
change to the Code no later than six (6) months after the adoption of
the material change.
Before approving this Code or any amendment to this Code, the Boards
shall have received a certification from the Trust, the Fund, and each
Investment Adviser that it has adopted procedures reasonably necessary
to prevent Access Persons from violating this Code.
Dated: August ___, 2000
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SCHEDULE A
SERIES OF WT INVESTMENT TRUST I
Intermediate Bond Series
International Multi-Manager Series
Large Cap Core Series
Large Cap Growth Series
Large Cap Value Series
Mid Cap Series
Mid Cap Value Series
Municipal Bond Series
Premier Money Market Series
Prime Money Market Series
Science & Technology Series
Short/Intermediate Bond Series
Socially Responsible Series
Small Cap Core Series
Small Cap Value Series
Tax-Exempt Series
U.S. Government Series
WT Large Cap Growth Series
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SCHEDULE B
SERIES OF WT MUTUAL FUND
CRM Intermediate Bond Fund
CRM Large Cap Value Fund
CRM Mid Cap Value Fund
CRM Municipal Bond Fund
CRM Prime Money market Fund
CRM Small Cap Value Fund
CRM Tax-Exempt Fund
Roxbury Large Cap Growth Portfolio
Roxbury Mid Cap Portfolio
Roxbury Science & Technology Portfolio
Roxbury Socially Responsible Portfolio
Wilmington Intermediate Bond Portfolio
Wilmington International Multi-Manager Portfolio
Wilmington Large Cap Core Portfolio
Wilmington Large Cap Growth Portfolio
Wilmington Large Cap Value Portfolio
Wilmington Mid Cap Value Portfolio
Wilmington Municipal Bond Portfolio
Wilmington Premier Money Market Portfolio
Wilmington Prime Money Market Portfolio
Wilmington Short/Intermediate Bond Portfolio
Wilmington Small Cap Core Portfolio
Wilmington Small Cap Value Portfolio
Wilmington Tax-Exempt Portfolio
Wilmington U.S. Government Portfolio
<PAGE>
APPENDIX A
SUMMARY OF RULE 17j-1(b)
It shall be unlawful for
- any affiliated person of, or principal underwriter for, a registered
investment company, or
- any affiliated person of an investment adviser of, or principal
underwriter for, a registered investment company
in connection with the purchase or sale, directly or indirectly, by such person
of a security held or to be acquired [SEE NOTE BELOW] . . . by such
registered investment company:
(1) to employ any device, scheme or artifice to defraud such registered
investment company;
(2) to make to such registered investment company any untrue statement of
a material fact or omit to state to such registered investment company
a material fact necessary in order to make the statements made, in
light of the circumstances under which they are made, not misleading;
(3) to engage in any act, practice, or course of business which operates
or would operate as a fraud or deceit upon such registered investment
company; or
(4) to engage in any manipulative practice with respect to such registered
investment company.
NOTE:
For purposes of Rule 17j-1, a "security held or to be acquired" by a registered
investment company means:
(i) any Covered Security within the meaning of the Rule (see the
definition of the term "Covered Security" in this Code) which,
within the most recent fifteen (15) calendar days:
- is or has been held by the investment company; or
- is being or has been considered by such company, or its
investment adviser, for purchase by the company
(ii) any option to purchase or sell, and any security convertible into
or exchangeable for, a Covered Security described above.
<PAGE>
APPENDIX B
WT INVESTMENT TRUST I/WT MUTUAL FUND
CODE OF ETHICS
INITIAL HOLDINGS REPORT
To the Compliance Officer:
1. I hereby acknowledge receipt of a copy of the Code of Ethics for
WT Investment Trust I (the "Trust") and WT Mutual Fund (the
"Fund").
2. I have read and understand the Code and recognize that I am
subject thereto in the capacity of an "Access Person."
3. Except as noted below, I hereby certify that I have no knowledge
of the existence of any personal conflict of interest
relationship which may involve the Trust or the Fund, such as any
economic relationship between my transactions and securities held
or to be acquired by the Trust, the Fund or any of their series.
4. As of the date below I had a direct or indirect beneficial ownership
interest in the following securities:
Name of Securities Number of Shares Type of Interest
------------------ ---------------- (Direct or Indirect)
--------------------
5. As of the date below, the following is a list of all brokers, dealers or
banks with whom I maintain an account in which securities are held for my
direct or indirect benefit:
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Firm Account Type of Interest
---- ------- (Direct or Indirect)
--------------------
Date: Signature:
-------------------------- ---------------------------
Print Name:
--------------------------
Title:
--------------------------------------
Employer's Name:
---------------------
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WT INVESTMENT TRUST I/WT MUTUAL FUND
CODE OF ETHICS
ANNUAL HOLDINGS REPORT
To the Compliance Officer:
1. I have read and understand the Code of Ethics of WT Investment
Trust I (the "Trust") and WT Mutual Fund (the "Fund") and recognize that I
am subject thereto in the capacity of an "Access Person."
2. I hereby certify that, during the year ended December 31, ___,
I have complied with the requirements of the Code and I have reported all
securities transactions required to be reported pursuant to the Code.
3. Except as noted below, I hereby certify that I have no
knowledge of the existence of any personal conflict of interest
relationship which may involve the Trust or the Fund, such as any economic
relationship between my transactions and securities held or to be acquired
by the Trust, the Fund or any of their series.
4. As of December 31, _____, I had a direct or indirect beneficial ownership
interest in the following securities:
Name of Securities Number of Shares Type of Interest
------------------ ---------------- (Direct or Indirect)
--------------------
5. As of December 31, ___, the following is a list of all brokers, dealers, or
banks with whom I maintain an account in which securities are held for my
direct or indirect benefit:
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Firm Account Type of Interest
---- ------- (Direct or Indirect)
--------------------
Date: Signature:
------------------------ -------------------------
Print Name:
------------------------
Title:
------------------------------------
Employer's Name:
--------------------
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WT INVESTMENT TRUST I/WT MUTUAL FUND
SECURITIES TRANSACTIONS REPORT
For the Calendar Quarter Ended:______________
To the Compliance Officer:
During the quarter referred to above, the following transactions were
effected in securities of which I had, or by reason of such transaction
acquired, direct or indirect beneficial ownership, and which are required to be
reported pursuant to the Code of Ethics adopted by WT Investment Trust I ("the
Trust") and WT Mutual Fund (the "Fund").
<TABLE>
<CAPTION>
======================================================================================================================
NAME OF SECURITY DATE OF NUMBER DOLLAR AMOUNT NATURE OF PRICE BROKER/DEALER OR BANK
(INCLUDING INTEREST RATE TRANSACTION OF SHARES OF TRANSACTION THROUGH WHOM EFFECTED
AND MATURITY DATE, IF TRANSACTION (PURCHASE,
APPLICABLE) SALE, OTHER)
PLEASE DO NOT INCLUDE
TICKER SYMBOLS
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======================================================================================================================
</TABLE>
During the quarter referred to above, the following accounts were
established by me in which securities were held for my direct or indirect
benefit:
<TABLE>
<CAPTION>
======================================================================================================================
FIRM NAME DATE ACCOUNT WAS ACCOUNT NUMBER
(broker, dealer or bank) ESTABLISHED
----------------------------------------------------------------------------------------------------------------------
<S> <C> <C>
----------------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------------
======================================================================================================================
</TABLE>
<PAGE>
This report (i) excludes transactions with respect to 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.
Except as noted on the reverse side of this report, I hereby certify that I
have no knowledge of the existence of any personal conflict of interest
relationship which may involve the Trust or the Fund, such as the existence of
any economic relationship between my transactions and securities held or to be
acquired by the Trust, the Fund or any of their series.
I hereby agree that if you have not received copies of the confirmations
listed herein or a periodic statement for the accounts listed herein, you are
authorized to obtain such documents directly from the broker, dealer or bank
listed herein and such broker, dealer or bank is hereby authorized to release
such documents to the Compliance Officer of the Trust and the Fund.
Date: Signature:
--------------------------- --------------------------
Print Name:
-------------------------
Title:
---------------------------------------
Employer's Name:
--------------------
