WRIGHT EQUIFUND EQUITY TRUST
485BPOS, 2000-04-27
Previous: MORGAN STANLEY DEAN WITTER MUNICIPAL INCOME TRUST III, NSAR-A, 2000-04-27
Next: APPLEBEES INTERNATIONAL INC, 10-Q, 2000-04-27





     As filed with the Securities and Exchange Commission on April 27, 2000


                                                 1933 Act File No. 33-30085
                                                 1940 Act File No. 811-5866


                       SECURITIES AND EXCHANGE COMMISSION
                             WASHINGTON, D.C. 20549
                                    FORM N-1A

                             REGISTRATION STATEMENT
                                      UNDER
                           SECURITIES ACT OF 1933       [x]
                       POST-EFFECTIVE AMENDMENT NO. 18  [x]
                             REGISTRATION STATEMENT
                                      UNDER
                     THE INVESTMENT COMPANY ACT OF 1940 [x]
                              AMENDMENT NO. 21          [x]

                        The Wright EquiFund Equity Trust
               (Exact Name of Registrant as Specified in Charter)

                  255 State Street, Boston, Massachusetts 02109
                 -----------------------------------------------
                    (Address of Principal Executive Offices)

                                  617-482-8260
                         -------------------------------
                         (Registrant's Telephone Number)

                                 Alan R. Dynner
                  255 State Street, Boston, Massachusetts 02109
                 -------------------------------------------------
                     (Name and Address of Agent for Service)


It is  proposed  that this filing  will  become  effective  pursuant to Rule 485
(check appropriate box):

[ ]Immediately  upon filing  pursuant to paragraph(b)
[ ]On (date) pursuant to paragraph  (a)(1)
[x]On May 1, 2000  pursuant to paragraph (b)
[ ]75 days after filing  pursuant  to  paragraph  (a)(2)
[ ]60 days  after  filing  pursuant  to paragraph (a)(1)
[ ]On (date) pursuant to paragraph (a)(2)

If appropriate, check the following box:

[ ]  This  post-effective  amendment  designates a  new  effective  date  for a
previously filed post-effective amendment.


<PAGE>

THE WRIGHT EQUIFUND EQUITY TRUST





PROSPECTUS
May 1, 2000


   o Wright EquiFund -- Hong Kong/China
   o Wright EquiFund -- Japan
   o Wright EquiFund -- Mexico
   o Wright EquiFund -- Netherlands



As with all  mutual  funds,  the  Securities  and  Exchange  Commission  has not
approved or disapproved  these securities or determined  whether the information
in this  prospectus  is accurate or complete.  Anyone who tells you otherwise is
committing a crime.

An  investment  in a mutual  fund is not a bank  deposit  and is not  insured or
guaranteed by the Federal Deposit Insurance  Corporation or any other government
agency.

<PAGE>
Table of Contents
- ----------------------------------------------------------------------------



                                                                       Page
The Wright EquiFund Equity Trust --
    Overview of Principal Strategies and
     Information About the Funds.....................................    1


         Wright  EquiFund -- Hong Kong/China.........................    2
         Wright  EquiFund -- Japan...................................    4
         Wright  EquiFund -- Mexico..................................    6
         Wright  EquiFund -- Netherlands.............................    8

Information About Your Account ......................................   10
         How the Funds Value Their Shares............................   10
         Purchasing Shares...........................................   10
         Selling Shares..............................................   11
         Exchanging Shares...........................................   11

Dividends and Taxes    ..............................................   12

Managing the Funds ..................................................   13

Financial Highlights    .............................................   15
         Wright  EquiFund -- Hong Kong/China.........................   15
         Wright  EquiFund -- Japan...................................   16
         Wright  EquiFund -- Mexico..................................   17
         Wright  EquiFund -- Netherlands.............................   18

- --------------------------------------------------------------------------------
HOW TO USE THIS PROSPECTUS:

Reading this prospectus will help you decide if investing in the Wright funds is
right for you.  Please keep this  prospectus for future  reference.  Included in
this prospectus are descriptions telling you about each fund's:

(Graphic -- ship's wheel)
OBJECTIVE: what the fund seeks to achieve.

(Graphic -- compass)
PRINCIPAL INVESTMENT STRATEGIES: how the fund intends to achieve its investment
objective and the strategies used by Wright Investors' Service, the fund's
investment adviser.

(Graphic -- life preserver)
PRINCIPAL RISKS: the risks associated with the fund's primary investments.
Who May Want to Invest: decide if the fund is a suitable investment for you.

(Graphic -- assorted nautical flags)
WHO MAY WANT TO INVEST: decide if the fund is a suitable investment for you.

(Graphic -- ship's log)
PAST PERFORMANCE: the total return on your investment, including income from
dividends and interest, and the increase or decrease in price over various
time periods.

(Graphic -- two crossed anchors with a $ in the center)
FEES AND EXPENSES: what overall costs you bear by investing in the fund.

<PAGE>

OVERVIEW OF PRINCIPAL STRATEGIES AND INFORMATION ABOUT THE FUNDS
- -------------------------------------------------------------------------------



Each fund seeks total investment return  (consisting of price  appreciation plus
income) by investing in a broadly based portfolio of equity securities  selected
from publicly  traded  companies in a Wright  Approved  Investment List for each
nation in which a fund invests.

THE WRIGHT APPROVED INVESTMENT LISTS
Each list  includes  all publicly  traded  companies in the nation that meet the
standards of a prudent  investor.  These standards  require that care, skill and
caution be used in  selecting  securities  for  investment.  To be  included,  a
company must generally:


    o have an  established  minimum in both book value and market value o have a
      significant portion of the company's shares are publicly owned

    o have positive  earnings for either the last fiscal,  calendar year or past
      12 months, or cumulatively for the past three years

    o not be a  closed-end  mutual  fund,  a real estate  investment  trust or a
      non-bank securities broker/dealer.


In selecting securities for inclusion in the list, Wright uses its Worldscope(R)
international database.

The lists are adjusted  quarterly  or as  necessary  to reflect any  significant
events. Wright deletes a company when it no longer meets the criteria for a list
and adds other companies when they meet the criteria.  A detailed explanation of
the criteria  used in selecting  companies for inclusion in the list is included
in the  statement  of  additional  information.


Using a bottom-up  fundamental approach,  Wright systematically  identifies
those  companies in the  Worldscope(R)  database that meet minimum  standards of
prudence and thus are suitable for investment by fiduciary investors.  Companies
meeting these  requirements  are considered by Wright to be "investment  grade."
All of these companies have established investment acceptance and active, liquid
markets.

- -----SIDE BAR TEXT-----
                             Fundamental Analysis and
                         "Bottom-Up" Approach to Investing

   Fundamental  analysis is the analysis of company  financial  statements  to
forecast future price movements using past records of assets,  earnings,  sales,
products,  management  and markets.  It differs from  technical  analysis  which
relies on price and volume  movements of stocks and does not concern itself with
financial statistics.

     Bottom-up   investing  is  the  analysis  of  company   information  before
considering  the impact of industry  and  economic  trends.  It differs from the
"top-down" approach which looks first at the economy, then the industry and last
the company.

- -----END SIDE BAR TEXT-----
<PAGE>

WRIGHT EQUIFUND -- HONG KONG/CHINA
- -------------------------------------------------------------------------------

CUSIP: 982332736                                     Ticker Symbol: WEHKX

(Graphic -- ship's wheel)
OBJECTIVE
     The fund seeks total  investment  return  consisting of price  appreciation
plus income.


(Graphic -- compass)
PRINCIPAL INVESTMENT STRATEGIES
     The fund invests in a broadly based portfolio of equity securities selected
by Wright from those companies listed on the Wright Approved Investment List for
Hong Kong and China. At least 65% of the fund's total assets are invested in the
equity securites of companies  located or doing business in Hong Kong and China.
For temporary defensive purposes, the fund may hold cash or invest without limit
in short-term debt securities. Although the fund would do this to reduce losses,
defensive investments may conflict with and  hurt the fund's efforts to achieve
its objective.

     Wright  considers  recent  valuations  and  price/earnings   momentum  when
deciding which companies on the index present the best value in terms of current
price and forecasted  earnings.  Selected companies may or may not currently pay
dividends on their shares.  Although the fund may acquire only those  securities
that are included in the list, the fund's portfolio is not expected to resemble
the index either in the number of securities  included or in the amount invested
in each security. A security is sold if it is deleted from the list.


The fund's objective may be changed by the trustees without shareholder
approval.

(Graphic -- life preserver)
PRINCIPAL RISKS
     Before you  invest in any mutual  fund,  you  should  understand  the risks
involved.  There are two basic risks  prevalent  in mutual  funds  investing  in
common stocks, such as the fund. They are:

              o Market risk:  When the price of stock falls, the value of the
                fund's investments may fall.
              o Management risk: Wright's strategy may not produce the expected
                results, causing losses.

     There are risks  associated with investing in foreign  countries  including
currency  risk  (changes in foreign  currency  rates  reducing  the value of the
fund's  assets),  the  collapse  of the Hong Kong or Chinese  economy,  seizure,
expropriation  or  nationalization  of a  company's  assets,  and the  impact of
political,  social or diplomatic events. The statement of additional information
includes a country summary. This summary contains other information about Hong
Kong, including political and economic considerations.

     The fund's  share  price may  fluctuate  more than the share price of funds
primarily invested in large companies. Small companies may pose greater risk due
to narrow product lines, limited financial  resources,  less depth in management
or a limited trading market for their stocks.

The fund cannot eliminate risk or assure  achievement of its objective and you
may lose money.

raphic --assorted nautical flags)
WHO MAY WANT TO INVEST
     The fund is not intended to be a complete  investment program by itself but
may provide a diversification opportunity for investors seeking participation in
the  economies  of Hong  Kong and  China.  The fund is  intended  for  long-term
investors.  To discourage short-term  investors,  there is a 1.0% redemption fee
for  shares  redeemed  within  six  months  of  purchase.  The  fund  may not be
appropriate if you are uncomfortable with the risks associated with investing in
foreign stocks.

(Graphic --ship's log)
PAST  PERFORMANCE
     The  information  on the next page  shows the  fund's  performance  for the
indicated  periods.  These  returns  include  reinvestment  of all dividends and
capital gain distributions, and reflect fund expenses. As with all mutual funds,
past performance does not guarantee future results.

<PAGE>

The bar chart  illustrates  the risks of  investing  in the fund by showing  how
volatile the fund's performance has been for each full year since its inception.
<TABLE>
<CAPTION>


Total Return as of December 31
<S>     <C>          <C>          <C>     <C>       <C>     <C>           <C>      <C>
   90%
- ------------------------------------------------------------------------------------------------------------
   80%                             84.32%
- -----------------------------------------------------------------------------------------------------------
   70%
- -----------------------------------------------------------------------------------------------------------
   60%
- -----------------------------------------------------------------------------------------------------------
   50%                                                                                              51.03%
- -----------------------------------------------------------------------------------------------------------
   40%
- -----------------------------------------------------------------------------------------------------------
   30%   34.34%
- -----------------------------------------------------------------------------------------------------------
   20%                                                           27.96%
- -----------------------------------------------------------------------------------------------------------
   10%                16.23%
- -----------------------------------------------------------------------------------------------------------
    0%                                               1.63%
- -----------------------------------------------------------------------------------------------------------
 (10)%                                                                                 -18.65%
- -----------------------------------------------------------------------------------------------------------
 (20)%                                                                       -27.26%
- -----------------------------------------------------------------------------------------------------------
 (30)%                                     -37.03%
- -----------------------------------------------------------------------------------------------------------
 (40)%
- -----------------------------------------------------------------------------------------------------------
            1991       1992       1993       1994       1995       1996       1997      1998         1999


 Best quarter:  41.38% (4th quarter 1993) Worst quarter:   -32.39% (4th quarter 1997)
</TABLE>

     The fund's average annual return is compared with the indices listed below.
While the fund does not seek to match the  returns of these  unmanaged  indices,
they are good  indicators of the  performance of the Hong Kong and Chinese stock
markets.  The Hang Seng Index is a better indicator of the Hong Kong Market than
the FT/S&P  Actuaries  which will not be included in the future.  These indices,
unlike the fund, do not incur fees or charges.

Average Annual Returns as of December 31, 1999
                                                            Life of Fund
                               1 Year          5 Year      (July 2, 1990)
- -------------------------------------------------------------------------------
EquiFund -- Hong Kong/China     51.03%           3.05%          6.03%
FT/S&P Actuaries - Hong Kong    57.30%          11.73%         18.39%
FT World ex US Index            31.83%          12.67%          8.96%
Hang Send Index                 74.33%          20.67%         23.83%

(Graphic -- two crossed anchors with a $ in the center)
FEES AND EXPENSES
The table describes the fees and expenses you may pay if you buy and hold shares
of the fund.

SHAREHOLDER FEES(1)
(paid directly from
 your invesment)                 Maximum redemption fee         1.00%
                              (% of redemption proceeds)


ANNUAL FUND OPERATING EXPENSES
(deducted directly from
 fund assets)                      Management fee               0.75%
                                   Distribution (12b-1) fee     0.25%
                                   Other expenses               2.12%
                                -----------------------------------------------
                                   Total Operating Expenses     3.12%
                                   Fee Waiver and Expense
                                    Reimbursement(3)           (0.79%)
                                -----------------------------------------------
                                    NET OPERATING EXPENSES(2)   2.38%


(1)A redemption fee applies if you redeem your shares within six months of
   purchase.
(2)Under an expense offset arrangement, custodian fees are reduced by credits
   based on the fund's average daily cash balance. Under SEC reporting
   requirements, these reductions are not reflected in the net operating ratio
   above. If reflected, the ratio would be:

NET OPERATING EXPENSES AFTER CUSTODIAN FEE REDUCTIONS           1.99%

(3)Under a written agreement, Wright waives a portion of its advisory fee and
   assumes operating expenses to the extent necessary to limit net operating
   expenses after any custodian fee reductions to 2.00%.


The following example will help you compare the cost of investing in the fund to
the cost of  investing  in other  mutual funds by showing what your costs may be
over  time.  It  uses  the  same  assumptions  that  other  funds  use in  their
prospectuses:  $10,000 initial  investment,  5% total return for each year, fund
operating expenses remain the same for each period, and redemption after the end
of each period.

     Your  actual  costs  may be  higher  or  lower,  so use  this  example  for
comparison only. Based on these assumptions your costs at the end of each period
would be:

Example Costs
                   One Year      Three Years     Five Years       Ten Years
- -------------------------------------------------------------------------------
                    $236           $727          $1,245           $2,666


- -----SIDE BAR TEXT-----
                             Understanding Expenses
Annual fund  operating  expenses are paid by the fund. As a result,  you pay for
them  indirectly  because they reduce the fund's return.  Fund expenses  include
management  fees,  12b-1  fees and  administrative  costs,  such as  shareholder
recordkeeping  and reports,  custodian and pricing  services,  and  registration
fees.

- -----END SIDE BAR TEXT-----

<PAGE>

WRIGHT EQUIFUND -- JAPAN
- -------------------------------------------------------------------------------
CUSIP:   982332728                             Ticker Symbol:       WEJPX


(Graphic -- ship's wheel)
OBJECTIVE
     The fund seeks to  enhance  total  investment  return  consisting  of price
appreciation  plus income.


(Graphic -- compass)
PRINCIPAL  INVESTMENT  STRATEGIES
     The fund invests in a broadly based portfolio of equity securities selected
by Wright from those companies listed on the Wright Approved Investment List for
Japan.  At least 65% of the  fund's  total  assets  are  invested  in the equity
securities  of  companies  located or doing  business  in Japan.  For  temporary
defensive purposes, the fund may hold cash or invest without limit in short-term
debt  securities.  Although the fund would do this to reduce  losses,  defensive
investments may conflict with and hurt the fund's efforts to achieve its
objective.

     Wright  considers  recent  valuations  and  price/earnings   momentum  when
deciding which companies on the index present the best value in terms of current
price and forecasted  earnings.  Selected companies may or may not currently pay
dividends on their shares.  Although the fund may acquire only those  securities
that are included in the list, the fund's portfolio is not expected to resemble
the index either in the number of securities  included or in the amount invested
in each security. A security is sold if it is deleted from the list.


     The fund's  objective  may be changed by the trustees  without  shareholder
approval.

(Graphic -- life preserver)
PRINCIPAL RISKS
     Before you  invest in any mutual  fund,  you  should  understand  the risks
involved.  There are two basic risks  prevalent  in mutual  funds  investing  in
common stocks, such as the fund. They are:

              o market risk:  When the price of stock falls, the value of the
                fund's investments may fall.
              o management risk: Wright's strategy may not produce the expected
                results, causing losses.

     There are risks  associated with investing in foreign  countries  including
currency  risk  (changes in foreign  currency  rates  reducing  the value of the
fund's assets), the collapse of the Japanese economy, seizure,  expropriation or
nationalization  of a company's assets,  and the impact of political,  social or
diplomatic  events. The statement of additional  information  includes a country
summary. This summary contains other informationabout Japan, including political
and economic considerations.

     The fund's  share  price may  fluctuate  more than the share price of funds
primarily invested in large companies. Small companies may pose greater risk due
to narrow product lines, limited financial  resources,  less depth in management
or a limited trading market for their stocks.

The fund cannot eliminate risk or assure acheivement of its objective and you
may lose money.

(Graphic -- assorted nautical flags)
WHO MAY  WANT TO  INVEST
     The fund is not intended to be a complete  investment program by itself but
may provide a diversification opportunity for investors seeking participation in
the  Japanese  economy.  The  fund  is  intended  for  long-term  investors.  To
discourage  short-term  investors,  there is a 1.0%  redemption  fee for  shares
redeemed  within six months of purchase.  The fund may not be appropriate if you
are uncomfortable with the risks associated with investing in foreign stocks.

(Graphic -- ship's log)
PAST PERFORMANCE
     The  information  on the next page  shows the  fund's  performance  for the
indicated  periods.  These  returns  include  reinvestment  of all dividends and
capital gain distributions, and reflect fund expenses. As with all mutual funds,
past performance does not guarantee future results.
<PAGE>


     The bar chart illustrates the risks of investing in the fund by showing how
volatile the fund's performance has been for each full year since its inception.
Year-by-Year Total Return as of December 31
                                                                        102.91%
   20%
- -------------------------------------------------------------------------------
   10%
- -------------------------------------------------------------------------------
    0%                                                          5.41%
- -------------------------------------------------------------------------------
 (10)%        -9.10%         -9.10%
- -------------------------------------------------------------------------------
 (20)%                                         -14.20%
- -------------------------------------------------------------------------------
                1995          1996              1997             1998      1999


Best quarter:37.89%(4th quarter 1999)  Worst quarter:-18.18% (4th quarter 1997)

     The fund's average annual return is compared with those listed below. While
the fund does not seek to match the returns of these unmanaged indices, they are
good indicators of the performance of the Japanese stock market. The Tokyo SE
Index is a better indicator of the Japanese market than the FT/S&P Actuaries
which will not be included in the future. These indices, unlike the fund, do not
incur fees or charges.

Average Annual Returns as of December 31, 1999
                                                          Since Inception
                              1 Year        5 Years     (February 14, 1994)
- -------------------------------------------------------------------------------
EquiFund-- Japan             102.91%         8.66%             6.92%
FT/S&P Actuaries - Japan      72.21%         2.69%             3.15%
FT World ex US Index          31.83%        12.67%            10.60%
Tokyo SE Index                77.97%         2.67%             2.94%

(Graphic -- two crossed anchors with a $ in the center)
EXPENSES
The table describes the fees and expenses you may pay if you buy and hold shares
of the fund.

SHAREHOLDER FEES(1)
(paid directly from
 your invesment)                 Maximum redemption fee         1.00%
                              (% of redemption proceeds)


ANNUAL FUND OPERATING EXPENSES
(deducted directly from
 fund assets)                      Management fee               0.75%
                                   Distribution (12b-1) fee     0.25%
                                   Other expenses               2.30%
                                -----------------------------------------------
                                   Total Operating Expenses     3.30%
                                   Fee Waiver and Expense
                                    Reimbursement(3)           (1.14%)
                                -----------------------------------------------
                                    NET OPERATING EXPENSES(2)   2.16%


(1)A redemption fee applies if you redeem your shares within six months of
   purchase.
(2)Under an expense offset arrangement, custodian fees are reduced by credits
   based on the fund's average daily cash balance. Under SEC reporting
   requirements, these reductions are not reflected in the net operating ratio
   above. If reflected, the ratio would be:

NET OPERATING EXPENSES AFTER CUSTODIAN FEE REDUCTIONS           2.02%

(3)Under a written agreement, Wright waives a portion of its advisory fee and
   assumes operating expenses to the extent necessary to limit net operating
   expenses after any custodian fee reductions to 2.00%.

    The  following  example  will help you compare the cost of investing in the
fund to the cost of  investing  in other mutual funds by showing what your costs
may be over time.  It uses the same  assumptions  that other  funds use in their
prospectuses:  $10,000 initial  investment,  5% total return for each year, fund
operating expenses remain the same for each period, and redemption after the end
of each period.

     Your  actual  costs  may be  higher  or  lower,  so use  this  example  for
comparison only. Based on these assumptions your costs at the end of each period
would be:

Example Costs
                One Year        Three Years       Five Years        Ten Years
- -------------------------------------------------------------------------------
                 $ 219            $676              $1,159           $2,493

- -----SIDE BAR TEXT-----
                             Understanding Expenses

Annual fund  operating  expenses are paid by the fund. As a result,  you pay for
them  indirectly  because they reduce the fund's return.  Fund expenses  include
management  fees,  12b-1  fees and  administrative  costs,  such as  shareholder
recordkeeping  and reports,  custodian and pricing  services,  and  registration
fees.
- -----END SIDE BAR TEXT-----

<PAGE>

WRIGHT EQUIFUND -- MEXICO
- -------------------------------------------------------------------------------
CUSIP:  982332843                                    Ticker Symbol:    WEMEX

(Graphic -- ship's wheel)
OBJECTIVE
     The fund seeks to  enhance  total  investment  return  consisting  of price
appreciation  plus income.


(Graphic -- compass)
PRINCIPAL  INVESTMENT  STRATEGIES
     The fund invests in a broadly based portfolio of equity securities selected
by Wright from those companies listed on the Wright Approved Investment List for
Mexico.  At least 65% of the  fund's  total  assets are  invested  in the equity
securites  of  companies  located or doing  business  in Mexico.  For  temporary
defensive purposes, the fund may hold cash or invest without limit in short-term
debt  securities.  Although the fund would do this to reduce  losses,  defensive
investments may conflict with and hurt the fund's efforts to achieve its
objective.

     Wright  considers  recent  valuations  and  price/earnings   momentum  when
deciding which companies on the index present the best value in terms of current
price and forecasted  earnings.  Selected companies may or may not currently pay
dividends on their shares.  Although the fund may acquire only those  securities
that are included in the index, the fund's portfolio is not expected to resemble
the index either in the number of securities  included or in the amount invested
in each security. A security is sold if it is deleted from the index.


     The fund's  objective  may be changed by the trustees  without  shareholder
approval.

(Graphic --life preserver)
 PRINCIPAL RISKS

     Before you  invest in any mutual  fund,  you  should  understand  the risks
involved.  There are two basic risks  prevalent  in mutual  funds  investing  in
common stocks, such as the fund. They are:

              o market risk:  When the price of stock falls, the value of the
                fund's investments may fall.
              o management risk: Wright's strategy may not produce the expected
                results, causing losses.

     There are risks  associated with investing in foreign  countries  including
currency  risk  (changes in foreign  currency  rates  reducing  the value of the
fund's assets), the collapse of the Mexican economy,  seizure,  expropriation or
nationalization  of a company's assets,  and the impact of political,  social or
diplomatic  events.  Mexico  is  considered  by some to be an  emerging  market.
Emerging  markets tend to be narrower,  less liquid and less  regulated than the
markets of developed countries.  This means there may be fewer opportunities for
investment.  Also, political  instability and currency  fluctuations may be more
extreme.  The statement of additional  information  includes a country  summary.
This summary  contains other  informaton  about  Mexico,including  political and
economic considerations.

     The fund's  share  price may  fluctuate  more than the share price of funds
primarily invested in large companies. Small companies may pose greater risk due
to narrow product lines, limited financial  resources,  less depth in management
or a limited trading market for their stocks.

The fund cannot eliminate risk or assure achievement of its objective and you
may lose money.

(Graphic -- assorted nautical flags)
WHO MAY WANT TO INVEST
     The fund is not intended to be a complete  investment program by itself but
may provide a diversification opportunity for investors seeking participation in
the Mexican economy. The fund is intended for long-term investors. To discourage
short-term investors,  there is a 1.0% redemption fee for shares redeemed within
six months of purchase. The fund may not be appropriate if you are uncomfortable
with the risks associated with investing in foreign stocks.

(Graphic -- ship's log)
PAST  PERFORMANCE
     The  information  on the next page  shows the  fund's  performance  for the
indicated  periods.  These  returns  include  reinvestment  of all dividends and
capital gain distributions, and reflect fund expenses. As with all mutual funds,
past performance does not guarantee future results.

<PAGE>



The bar chart  illustrates  the risks of  investing  in the fund by showing  how
volatile the fund's performance has been for each full year since its inception.

Year-by-Year Total Return as of December 31

   70%
- -------------------------------------------------------------------------------
   60%                                                                   60.91%
- -------------------------------------------------------------------------------
   50%
- -------------------------------------------------------------------------------
   40%                                      42.38%
- -------------------------------------------------------------------------------
   30%
- -------------------------------------------------------------------------------
   20%                       27.49%
- -------------------------------------------------------------------------------
   10%
- -------------------------------------------------------------------------------
    0%
- -------------------------------------------------------------------------------
 (10)%
- -------------------------------------------------------------------------------
 (20)%
- -------------------------------------------------------------------------------
 (30)%      -33.37%                                           -37.21%
- -------------------------------------------------------------------------------
 (40)%
- -------------------------------------------------------------------------------
              1995            1996              1997             1998    1999
Best quarter:26.26%(2nd quarter 1999) Worst quarter:  -43.47% (1st quarter 1995)

     The fund's average annual return is compared with those listed below. While
the fund does not seek to match the returns of these unmanaged indices, they are
good indicators of the  performance of the Mexican stock market.  These indices,
unlike the fund, do not incur fees or charges.

Average Annual Returns as of December 31, 1999
                                                               Life of Fund
                              1 Year            5 Years      (August 2, 1994)
- -------------------------------------------------------------------------------
EquiFund-- Mexico              60.91%            4.09%            -3.08%
Mexican Bolsa IPC Index        88.59%            9.40%             0.64%
FT World ex US Index           31.83%           12.67%            11.25%

(Graphic -- two crosses anchors with a $ in the center)
EXPENSES
     The table describes  the fees and expenses you may pay if you buy and hold
shares of the fund.

SHAREHOLDER FEES(1)
(paid directly from
 your invesment)                 Maximum redemption fee         1.00%
                              (% of redemption proceeds)


ANNUAL FUND OPERATING EXPENSES
(deducted directly from
 fund assets)                      Management fee               0.75%
                                   Distribution (12b-1) fee     0.25%
                                   Other expenses               1.20%
                                -----------------------------------------------
                                   TOTAL OPERATING EXPENSES     2.20%
                                -----------------------------------------------
                                   Fee Waiver and Expense
                                     Reimbursement(3)          (0.06%)
                                -----------------------------------------------
                                   NET OPERATING EXPENSES(2)    2.14%

(1)A redemption fee applies if you redeem your shares within six months of
   purchase.
(2)Under an expense offset arrangement, custodian fees are reduced by credits
   based on the fund's average daily cash balance. Under SEC reporting
   requirements, these reductions are not reflected in the net operating ratio
   above. If reflected, the ratio would be:

NET OPERATING EXPENSES AFTER CUSTODIAN FEE REDUCTIONS           2.00%

(3)Under a written agreement, Wright waives a portion of its advisory fee and
   assumes operating expenses to the extent necessary to limit the expense
   ratio to 2.00%.

The following example will help you compare the cost of investing in the fund to
the cost of  investing  in other  mutual funds by showing what your costs may be
over  time.  It  uses  the  same  assumptions  that  other  funds  use in  their
prospectuses:  $10,000 initial  investment,  5% total return for each year, fund
operating expenses remain the same for each period, and redemption after the end
of each period.

     Your  actual  costs  may be  higher  or  lower,  so use  this  example  for
comparison only. Based on these assumptions your costs at the end of each period
would be:

Example Costs
               One Year        Three Years       Five Years        Ten Years
- -------------------------------------------------------------------------------
                $217             $670              $1,149         $2,472

- -----SIDE BAR TEXT-----
                             Understanding Expenses

Annual fund  operating  expenses are paid by the fund. As a result,  you pay for
them  indirectly  because they reduce the fund's return.  Fund expenses  include
management  fees,  12b-1  fees and  administrative  costs,  such as  shareholder
recordkeeping  and reports,  custodian and pricing  services,  and  registration
fees.

- -----END SIDE BAR TEXT-----

<PAGE>

WRIGHT EQUIFUND -- NETHERLANDS
- --------------------------------------------------------------------------------
CUSIP:  982332801
                           Ticker Symbol:       WENLX
(Graphic -- ship's wheel)
OBJECTIVE
     The fund seeks  total  investment  return  consisting  of price
appreciation  plus income.


(Graphic -- compass)
PRINCIPAL  INVESTMENT  STRATEGIES
     The fund invests in a broadly based portfolio of equity securities selected
by Wright from those companies listed on the Wright Approved Investment List for
the  Netherlands.  At least 65% of the fund's  total  assets are invested in the
equity securities of companies located or doing business in the Netherlands. For
temporary defensive purposes,  the fund may hold cash or invest without limit in
short-term  debt  securities.  Although the fund would do this to reduce losses,
defensive investments mayconflict with and hurt the fund's efforts to achieve
its objective.

     Wright  considers  recent  valuations  and  price/earnings   momentum  when
deciding which companies on the list present the best value in terms of current
price and forcasted  earnings.  Selected  companies may or may not currently pay
dividends on their shares.  Although the fund may acquire only those  securities
that are included in the list, the fund's portfolio is not expected to resemble
the list either in the number of securities  included or in the amount invested
in each security. A security is sold if it is deleted from the list.


     The fund's  objective  may be changed by the trustees  without  shareholder
approval.

(Graphic -- life preserver)
Principal  Risks
      Before you invest in any mutual  fund,  you  should  understand  the risks
involved.  There are two basic risks  prevalent  in mutual  funds  investing  in
common stocks, such as the fund. They are:

              o market risk:  When the price of stock falls, the value of the
                fund's investments may fall.
              o management risk: Wright's strategy may not produce the expected
                results, causing losses.

     There are risks  associated with investing in foreign  countries  including
currency  risk  (changes in foreign  currency  rates  reducing  the value of the
fund's assets),  the collapse of the Dutch economy,  seizure,  expropriation  or
nationalization  of a company's assets,  and the impact of political,  social or
diplomatic events. Additionally,  the secutities markets for the Netherlands are
narrow and there may be fewer  opportunities  for  investment.The  statement  of
additional  information includes a country summary.  This summary contains other
informaton   about   the   Netherlands,   including   political   and   economic
considerations.

     The Netherlands,  along with other European countries, has adopted the Euro
as its common  currency.  Existing  national  currencies of these  countries are
sub-currencies  of the Euro  until July 1, 2002,  when the old  currencies  will
disappear  entirely.  The introduction of the Euro presents some possible risks,
which could  adversely  affect the value of securities held by the fund, as well
as possible adverse tax  consequences.  There could be unpredictable  effects on
trade and commerce, resulting in increased volatility for all financial markets.

     The fund's  share  price may  fluctuate  more than the share price of funds
primarily invested in large companies. Small companies may pose greater risk due
to narrow product lines, limited financial  resources,  less depth in management
or a limited trading market for their stocks.

The fund cannot eliminate risk or assure  achievement of its objective and you
may lose money.

(Graphic -- assorted nautical flags)
WHO MAY WANT TO INVEST
     The fund is not intended to be a complete  investment program by itself but
may provide a diversification opportunity for investors seeking participation in
the Dutch economy. The fund is intended for long-term  investors.  To discourage
short-term investors,  there is a 1.0% redemption fee for shares redeemed within
six months of purchase. The fund may not be appropriate if you are uncomfortable
with the risks associated with investing in foreign stocks.

(Graphic -- ship's log)
PAST PERFORMANCE
     The  information  on the next page  shows the  fund's  performance  for the
indicated  periods.  These  returns  include  reinvestment  of all dividends and
capital gain distributions, and reflect fund expenses. As with all mutual funds,
past performance does not guarantee future results.
<PAGE>


     The bar chart illustrates the risks of investing in the fund by showing how
volatile the fund's performance has been for each full year since its inception
<TABLE>
<CAPTION>

Total Return as of December 31
<S>        <C>       <C>      <C>         <C>        <C>         <C>       <C>        <C>
   40%
- --------------------------------------------------------------------------------------------------------
   30%                                                           36.25%
- --------------------------------------------------------------------------------------------------------
   20%                                                                                24.46%
- --------------------------------------------------------------------------------------------------------
   10%                           19.52%     11.68%    18.84%                15.56%
- --------------------------------------------------------------------------------------------------------
    0%     10.00%
- --------------------------------------------------------------------------------------------------------
 (10)%                -8.20%                                                                     -4.39%
- --------------------------------------------------------------------------------------------------------
 (20)%
- --------------------------------------------------------------------------------------------------------
            1991       1992       1993       1994       1995       1996       1997      1998      1999

 Best quarter:17.51% (4th quarter 1998) Worst quarter: -18.70% (3rd quarter 1996)
</TABLE>

     The fund's average annual return is compared with those listed below. While
the fund does not seek to match the returns of these unmanaged indices, they are
indicators of the performance of the Dutch and International stock markets.  The
CBS Total Return General Index is a better  indicator of the Netherlands  market
than the  FT/S&P  Actuaries  which will not be  included  in the  future.  These
indices, unlike the fund, do not incur fees or charges.

Average Annual Returns as of December 31, 1999
                                                          Life of Fund
                              1 Year          5 Years     (July 2, 1990)
- -------------------------------------------------------------------------------
EquiFund-- Netherlands        -4.39%          17.36%         10.46%
FT/S&P Actuaries Index
     - Netherlands             8.67%          24.28%         19.55%
FT World ex US Index          31.83%          12.67%          8.96%
CBS Total Return General
      Index                   12.05%          25.24%         19.68%

(Graphic -- two crossed anchors with a $ in the center)
EXPENSES
     The table describes  the fees and expenses you may pay if you buy and hold
shares of the fund.

SHAREHOLDER FEES(1)
(paid directly from
 your invesment)                 Maximum redemption fee         1.00%
                              (% of redemption proceeds)


ANNUAL FUND OPERATING EXPENSES
(deducted directly from
 fund assets)                      Management fee               0.75%
                                   Distribution (12b-1) fee     0.25%
                                   Other expenses               0.77%
                                -----------------------------------------------
                                   TOTAL OPERATING EXPENSES(2)  1.77%


(1)A redemption fee applies if you redeem your shares within six months of
   purchase.
(2)Under an expense offset arrangement, custodian fees are reduced by credits
   based on the fund's average daily cash balance. Under SEC reporting
   requirements, these reductions are not reflected in the net operating ratio
   above. If reflected, the ratio would be:

NET OPERATING EXPENSES AFTER CUSTODIAN FEE REDUCTIONS           1.71%

     The  following  example  will help you compare the cost of investing in the
fund to the cost of  investing  in other mutual funds by showing what your costs
may be over time.  It uses the same  assumptions  that other  funds use in their
prospectuses:  $10,000 initial  investment,  5% total return for each year, fund
operating expenses remain the same for each period, and redemption after the end
of each period.

     Your  actual  costs  may be  higher  or  lower,  so use  this  example  for
comparison only. Based on these assumptions your costs at the end of each period
would be:

Example Costs
                 One Year        Three Years       Five Years      Ten Years
- -------------------------------------------------------------------------------
                  $180              $557            $959             $2,084

- -----SIDE BAR TEXT-----
                             Understanding Expenses
Annual fund  operating  expenses are paid by the fund. As a result,  you pay for
them  indirectly  because they reduce the fund's return.  Fund expenses  include
management  fees,  12b-1  fees and  administrative  costs,  such as  shareholder
recordkeeping  and reports,  custodian and pricing  services,  and  registration
fees.

- -----END SIDE BAR TEXT-----

INFORMATION ABOUT YOUR ACCOUNT
- --------------------------------------------------------------------------------

HOW THE FUNDS VALUE THEIR SHARES
The price at which you buy,  sell or exchange fund shares is the net asset value
per share or NAV. This share price is determined by adding the value of a fund's
investments,  cash and other assets,  deducting  liabilities,  and then dividing
that amount by the total number of shares outstanding.


     The NAV for each fund is calculated at the close of regular  trading of the
New York Stock  Exchange  (normally  4:00 p.m.  New York time) each day that the
Exchange is open. It is not calculated on days the Exchange is closed. The price
for a purchase, redemption or exchange of fund shares is the next NAV calculated
after your request is received.


     When the funds  calculate  their share  price,  they value their  portfolio
securities  at the last current  sales price on the market where the security is
normally  traded.  Securities  that  cannot be valued at closing  prices will be
valued by Wright at fair  value in  accordance  with  procedures  adopted by the
trustees.This  could  happen if an event  after the close of the  market  seemed
likely to have a major impact on prices of securities traded on the market.

     The value of all assets and liabilities  expressed in foreign currencies is
converted  into U.S.  dollars at the most recent  market  rates quoted by one or
more major banks shortly  before the close of the Exchange.  Foreign  securities
may trade  during  hours and on days that the  Exchange is closed and the funds'
NAVs are not calculated.  Although the funds' NAVs may be affected, you will not
be able to purchase or redeem shares on these days.

PURCHASING SHARES

Purchasing Shares for Cash

 Shares of the funds may be  purchased  without a sales  charge at NAV.  The
minimum  initial investment  is  $1,000, but this may be waived  for  automatic
investment  program accounts and investments in 401(k) or similar  tax-sheltered
retirement  plans.  The minimum  initial  investment will be reduced to $500 for
shares  purchased  through  certain  investment  advisers,  financial  planners,
brokers or other  intermediaries that charge a fee for their services.  There is
no  minimum  for  subsequent  purchases.  The funds have the right to reject any
purchase  order,  or limit or suspend the offering of their  shares.

     Authorized  dealers,   including   investment   dealers,   banks  or  other
institutions,  may impose  investment  minimums higher than those imposed by the
funds. They may also charge for their services. There are no transaction charges
if you purchase your shares directly from the funds.

 How to Buy Shares

    o If  you  buy  shares  directly  from  the  funds,  please  refer  to  your
      Shareholder Manual for instructions on how to buy fund shares.

    o If you buy  shares  through  bank  trust  departments  or other  fiduciary
      institutions, please consult your trust or investment officer.

    o If you buy shares through a broker, please consult your broker for
      purchase instructions.

    o If you buy shares through an account with a registered investment adviser
      or financial planner, please contact your investment adviser or planner

    o If you buy shares  through a  retirement  plan,  please  consult your plan
      documents or speak with your plan administrator.

- -----SIDE BAR TEXT-----

                              Paying for Shares
You may buy shares by wire,  check,  Federal Reserve draft, or other  negotiable
bank draft,  payable in U.S. dollars and drawn on U.S banks.  Third party checks
will not be accepted. A charge is imposed on any returned checks.

- -----END SIDE BAR TEXT-----

<PAGE>

Purchasing Shares Through Exchange of Securities

You may buy shares by delivering to the funds'  custodian  securities  that meet
that fund's  investment  objective and policies,  have easily  determined market
prices and are otherwise  acceptable.  Exchanged  securities must have a minimum
aggregate  value of  $5,000.  Securities  are  valued  as of the  date  they are
received by the funds. If you want to exchange  securities for fund shares,  you
should  furnish  a list  with a full  description  of the  securities  that  are
proposed to be delivered.  See the Shareholder Manual for detailed instructions.

Distribution  Fee
     Each fund has  adopted a 12b-1 plan  permitting  it to pay a fee to finance
the distribution of its shares.  Wright Investors' Service  Distributors,  Inc.,
the principal  underwriter and distributor of each fund, receives a distribution
fee under the plan of 0.25% of each fund's  average  daily net  assets.  Because
this fee is paid on an ongoing  basis,  it may cost you more than other types of
sales charges over time.

SELLING  SHARES

     You may  redeem  or sell  shares  of the  funds  on any  business  day.  NO
REDEMPTION REQUEST WILL BE PAID UNTIL YOUR SHARES HAVE BEEN PAID FOR IN FULL. IF
THE SHARES TO BE REDEEMED WERE PURCHASED BY CHECK,  THE REDEMPTION  PAYMENT WILL
BE DELAYED UNTIL THE CHECK HAS BEEN COLLECTED, WHICH MAY TAKE UP TO 15 DAYS FROM
THE DATE OF PURCHASE.  Telephone,  mail and internet  redemption  procedures are
described in the Shareholder Manual.

     In times of drastic economic or market conditions,  you may have difficulty
selling shares by telephone or over the internet so you should send your request
by mail or  overnight  delivery.  These  redemption  options  may be modified or
terminated without notice to shareholders.

     Redemption  requests  received in "proper  form"  before 4:00 p.m. New York
time will be processed at that day's NAV.  "Proper form" means that the fund has
received your request, all shares are paid for, and all documentation along with
any  required  signature  guarantee,   are  included.  The  fund  normally  pays
redemption  proceeds by check  within one business day to the address of record.
Payment  will  be  by  wire  if  you  specified  this  option  on  your  account
application.

     For more  information  about  selling  your  shares,  please  refer to your
Shareholder Manual or contact your trust officer, adviser or plan administrator.

- -----SIDE BAR TEXT-----

                                Redemption Fee
If you redeem shares within six months of purchase you will pay a redemption fee
of 1.00%.  This  redemption  fee may be waived on shares  purchased  through  an
investment adviser, financial planner, broker or other intermediary that charges
a fee for its  services  and has made  special  arrangements  with the  funds or
Wright Investors' Service Distributors, Inc.

- -----END SIDE BAR TEXT-----

Redemptions  In-Kind

     Although  the funds  expect to pay  redemptions  in cash,  they reserve the
right to redeem  shares  in-kind by giving the  shareholder  readily  marketable
portfolio  securities  instead of cash. This is done to protect the interests of
remaining shareholders.  If this occurs, you will incur transaction costs if you
sell the securities.

 Involuntary  Redemption

     If your account  falls below $500 a fund may redeem your  shares.  You will
receive notice 60 days before this happens. Your account will not be redeemed if
the balance is below the minimum due to investment  losses.  No  redemption  fee
will be imposed on involuntary redemptions.
<PAGE>

EXCHANGING SHARES

     Shares of the funds may be  exchanged  for  shares of the same class of any
other fund described in this  prospectus.  You may also exchange  shares for the
Standard Shares of The Wright Managed Blue Chip Investment  Funds.  The exchange
of shares  results in the sale of the fund's  shares and the purchase of another
fund's shares.  An exchange results in a gain or loss and is therefore a taxable
event for you.

     You are  limited to four  "round-trip"  exchanges  each year.  A round trip
exchange is an exchange of one fund into another Wright fund and then back again
into the  original  fund.  You  will  receive  60 days  notice  before  the fund
materially amends or terminates the exchange privilege.

- -----SIDE BAR TEXT-----


                                  Market-Timers
The funds  believe  that use of the exchange  privilege  by investors  utilizing
market-timing  strategies adversely affects other fund shareholders.  Therefore,
the funds  generally will not honor requests for exchanges by  shareholders  who
identify  themselves or are  identified as  "market-timers."  Market-timers  are
identified  as those  investors who  repeatedly  make  exchanges  within a short
period.  The funds do not  automatically  redeem  shares  that are  subject to a
rejected exchange request, but will honor any later redemption request.


- -----END SIDE BAR TEXT-----

For more information on exchanging shares, please see the Shareholder Manual or
consult your adviser.

<PAGE>


DIVIDENDS AND TAXES
- -------------------------------------------------------------------------------

Dividends and Distributions

Unless you tell us that you want to receive  your  distributions  in cash,  they
will be reinvested  automatically  in fund shares.  The funds generally make two
different kinds of distributions:

   o Capital gains from the sale of portfolio securities held by a fund.
     The  funds  will  distribute  any net  realized  capital  gains  annually,
     normally in December.
   o Net  investment  income from interest or dividends received on securities
     held by a fund. The funds will distribute their investment income annually.

Most of the funds' distributions are expected to be from capital gains.

TAX CONSEQUENCES
Buying,  selling,  holding or exchanging mutual fund shares may result in a gain
or a loss and is a taxable  event.  Distributions,  whether  received in cash or
additional fund shares are subject to federal income tax.

         Transaction                        Tax Status
- -------------------------------------------------------------------------------
         Income dividends                   Ordinary income
         Short-term capital gains           Ordinary income
         Long-term capital gains            Capital gains

The funds may be subject to foreign  withholding taxes or other foreign taxes on
some of their foreign investments. This will reduce the yield or total return on
those  investments.  Your  investment  in the  funds  may  have  additional  tax
consequences.  Please  consult  your  tax  advisor  on  state,  local  or  other
applicable tax laws.

- -----SIDE BAR TEXT-----
                          Tax Considerations

Unless your investment is in a tax-deferred account you may want to avoid:
 o Investing  in a fund near the end of its  fiscal  year.  If the fund  makes a
   capital gains distribution you will receive some of your investment back as a
   taxable distribution.
 o Selling  shares  at a loss for tax  purposes  and then  making  an  identical
   investment  within 30 days. This results in a "wash sale" and you will not be
   allowed to claim a tax loss.

- -----END SIDE BAR TEXT-----

<PAGE>

MANAGING THE FUNDS
- ------------------------------------------------------------------------------
     Wright  Investors'  Service,Inc.  is a  leading  independent  international
investment  management  and  advisory  firm with more than 35 years  experience.
Wright  manages  about  $4 billion of assets in  portfolios  of all sizes and
styles, as well as a family of mutual funds. Wright developed Worldscope(R), one
of the world's  largest and most  complete  databases of financial  information,
which currently includes more than 23,000 companies in 54 nations.

     Wright manages the funds' investments.  Wright is located at 440 Wheelers
Farms Road, Milford, CT 06460. Wright receives a monthly advisory fee for its
services.  The table below lists the advisory fee rates paid for the fiscal year
ended December 31, 1999:
                                                 Fee Paid
                                            (as a % of average
           Fund                               daily net assets)
- -------------------------------------------------------------------------------
         Wright EquiFund-- Hong Kong/China         0.75%(1)
         Wright EquiFund-- Japan                   0.75%(1)
         Wright EquiFund-- Mexico                  0.75%(1)
         Wright EquiFund-- Netherlands             0.75%


 (1) 0.10% after waiver


 -----SIDE BAR TEXT-----
                              Administrator

Eaton Vance Management serves as the funds' administrator and is responsible for
managing their daily business affairs.  Eaton Vance's services include operating
the funds'  order  room,  recordkeeping,  preparing  and  filing  the  documents
required  to comply with  federal and state  securities  laws,  supervising  the
activities of the funds' custodian and transfer agent,  providing  assistance in
connection  with the trustees' and  shareholders'  meetings and other  necessary
administrative services.

- -----END SIDE BAR TEXT-----

Investment Committee

     An  investment   committee  of  senior  officers  controls  the  investment
selections,  policies  and  procedures  of the  funds.  These  officers  are all
experienced  analysts  with  different  areas of expertise and over 195 years of
combined service with Wright. The investment committee consists of the following
members:
<TABLE>
<CAPTION>

Committee Member           Title                                                Joined Wright in
- --------------------------------------------------------------------------------------------------
<S>                         <C>                                                           <C>


Peter M. Donovan, CFA       President and Chief Executive Officer                         1966
Judith R. Corchard          Chairman of the investment committee                          1960
                            Executive Vice President - Investment Management
Jatin J. Mehta, CFA         Executive Vice President                                      1969
Michael F. Flament, CFA     Senior Vice President - Investment and Economic Analysis      1972
James P. Fields,  CFA       Senior Vice President - Fixed Income Investments              1982
Amit S. Khandwala           Senior Vice President - International Investments             1986
Charles T. Simko, Jr., CFA  Senior Vice  President - Investment  Research                 1985
Patricia J. Pierce, CFA     Senior Vice President - Equities                              1999
George F. Faherty, CFA      Vice President - Equities                                     2000
</TABLE>
<PAGE>



Portfolio Turnover

     The funds may sell a portfolio security regardless of how long the security
has been  held.  The funds do not  intend to engage in  trading  for  short-term
profits. However, portfolio turnover rates will vary. In the past turnover rates
have  exceeded and in the future may exceed 100%. A turnover  rate of 100% means
the  securities  owned by a fund were  replaced  once  during  the year.  Higher
turnover rates may result in higher  brokerage costs to the funds, and in higher
net taxable gains for you as an investor, and will reduce the funds' returns.


<PAGE>




FINANCIAL HIGHLIGHTS

     The financial  highlights  will help you understand  each fund's  financial
     performance for the past 5 years.  Certain  information  reflects financial
     results  for a  single  fund  share.  Total  return  shows  how  much  your
     investment   increased  or  decreased  during  the  period,   assuming  you
     reinvested  all  dividends  and  distributions.   Deloitte  &  Touche  LLP,
     independent certified public accountants,  audited this information.  Their
     reports,  along with the funds' financial  statements,  are included in the
     funds' annual report, which is available upon request.
<TABLE>
<CAPTION>



HONG KONG/CHINA SERIES                                                 Year Ended December 31
- ---------------------------------------------------------------------------------------------------------------------------------
                                                            1999         1998         1997(5)      1996          1995
- ---------------------------------------------------------------------------------------------------------------------------------

<S>                                                       <C>          <C>          <C>          <C>          <C>
   Net asset value - beginning of year                    $  9.210     $ 11.980     $ 16.470     $ 13.030     $  13.020
                                                          --------      --------     --------     --------     --------

   Income (loss) from investment operations:
     Net investment income(1)                             $  0.598     $  0.473     $  0.110     $  0.182     $   0.368
     Net realized and unrealized gain (loss)(3)              4.102       (2.693)      (4.600)       3.458        (0.158)
                                                          --------      --------     --------     --------     --------

       Total income (loss)
        from investment operations                        $  4.700     $ (2.220)    $ (4.490)    $  3.640     $   0.210
                                                          --------      --------     --------     --------     --------

   Less distributions:
     Dividends from investment income                     $  -         $ (0.346)    $  -         $  (0.200)   $  (0.200)

     Distributions from capital gains                        -            -            -            -             -

     Return of capital                                       -           (0.204)       -            -             -
                                                          --------      --------     --------     --------     --------

       Total distributions                                $  -         $ (0.550)    $  -         $  (0.200)   $  (0.200)
                                                          --------      --------     --------     --------     --------

   Net asset value - end of year                          $ 13.910     $  9.210     $ 11.980     $ 16.470     $  13.030
                                                         =========     =========    =========    =========    =========
   Total return(2)                                          51.03%      (18.65%)     (27.26%)      27.96%         1.63%

Ratios/Supplemental Data(1):
     Net assets, end of year (000 omitted)                $  5,558     $   7,883    $   6,958    $  34,366    $  25,399
     Ratio of expenses to average net assets                 2.33%         2.38%        1.96%        1.62%        1.59%
     Ratio of expenses after custodian
       fee reduction to average net assets(4)                1.99%         1.99%        1.72%        1.43%        1.34%
     Ratio of net investment income to average
       net assets                                            1.32%         2.32%        0.66%        1.81%        3.26%
     Portfolio turnover rate                                  125%          254%          56%          65%         100%

- --------------------------------------------------------------------------------------------------------------------------------
<FN>

   (1)During the years ended December 31, 1999 and 1998, the investment  adviser
     and the  distributor  voluntarily  reduced their fees,  and the  investment
     adviser was allocated a portion of operating expenses. Had such actions not
     been undertaken,  net investment income per share and the ratios would have
     been as follows:

                                                            1999         1998

   Net investment income per share                        $  0.240     $  0.332
                                                         =========     =========
   Ratios (as a percentage of average net assets):

     Expenses                                                3.12%        3.07%
                                                         =========     =========
     Expenses after custodian fee reduction(4)               2.78%        2.68%
                                                         =========     =========
     Net investment income                                   0.53%        1.63%
                                                         =========     =========

- -------------------------------------------------------------------------------

   (2)Total investment return is calculated assuming a purchase at the net asset
     value on the first day and a sale at the net asset value on the last day of
     each period reported.  Dividends and distributions,  if any, are assumed to
     be invested at the net asset value on the reinvestment date.
   (3)For the year ended December 31, 1995,the per share amount is not in accord
     with the net realized and unrealized  gain (loss) for the period because of
     the timing of sales of fund shares and the amounts per share  realized and
     unrealized gains and losses at such times.
   (4)Custodian  fees were reduced by credits  resulting  from cash balances the
     fund maintained  with the  custodian  (Note 1E). The  computation  of net
     expenses to average  daily net assets  reported  above is computed  without
     consideration of such credits.
   (5)Certain per share amounts are based on average shares outstanding.
</FN>
</TABLE>

<PAGE>

<TABLE>
<CAPTION>


JAPAN SERIES                                                           Year Ended December 31
- ----------------------------------------------------------------------------------------------------------------------------------
                                                            1999         1998         1997(4)      1996          1995
- ----------------------------------------------------------------------------------------------------------------------------------


<S>                                                       <C>          <C>          <C>          <C>          <C>
   Net asset value - beginning of year                    $  7.210     $  6.840     $  7.980     $  8.780     $   9.660
                                                          --------      --------     --------     --------     --------

   Income from investment operations:
     Net investment loss(1)                               $ (0.175)    $ (0.112)    $ (0.100)    $ (0.095)    $  (0.045)
     Net realized and unrealized gain (loss)                 7.595        0.482       (1.040)      (0.705)       (0.835)
                                                          --------      --------     --------     --------     --------

       Total income (loss)
        from investment operations                        $  7.420     $  0.370     $ (1.140)    $ (0.800)    $  (0.880)
                                                          --------      --------     --------     --------     --------

   Less distributions:
     Distributions from investment income                 $  -         $  -         $  -         $  -         $   -

     Distributions from capital gains                        -            -            -            -             -

     Return of capital                                       -            -            -            -             -

                                                          --------      --------     --------     --------     --------
   Net asset value - end of year                          $ 14.630     $  7.210     $  6.840     $  7.980     $   8.780
                                                         =========     =========    =========    =========    =========

   Total return(2)                                         102.91%        5.41%      (14.29%)      (9.11%)       (9.11%)

   Ratios/Supplemental Data(1)
     Net assets, end of year (000 omitted)                $  6,190     $   4,365    $   3,807    $  17,041    $  21,631
     Ratio of expenses to average net assets                 2.16%         2.24%        2.15%        1.75%        1.81%
     Ratio of expenses after custodian
       fee reduction to average net assets(3)                2.02%         2.00%        1.84%        1.65%        1.49%
     Ratio of net investment loss to average net assets     (1.64%)       (1.46%)      (1.24%)      (1.05%)      (0.67%)
     Portfolio turnover rate                                   78%          205%         112%          56%         112%

- -------------------------------------------------------------------------------------------------------------------------------
<FN>

   (1)During the years ended December 31, 1999 and 1998, the investment adviser
     and the  distributor  voluntarily  reduced their fees,  and the  investment
     adviser was allocated a portion of operating expenses. Had such actions not
     been  undertaken,  net investment  loss per share and the ratios would have
     been as follows:

                                                            1999         1998

   Net investment loss per share                          $ (0.297)    $ (0.164)
                                                         =========     =========
   Ratios (as a percentage of average net assets):

     Expenses                                                3.30%        2.92%
                                                         =========     =========
     Expenses after custodian fee reduction(3)               3.16%        2.68%
                                                         =========     =========
     Net investment loss                                    (2.78%)      (2.14%)
                                                         =========     =========

- -------------------------------------------------------------------------------

  (2)Total investment return is calculated  assuming a purchase at the net asset
     value on the first day and a sale at the net asset value on the last day of
     each period reported.  Dividends and distributions,  if any, are assumed to
     be invested at the net asset value on the reinvestment date.
  (3)Custodian  fees were reduced by credits  resulting  from cash  balances the
     fund maintained  with the  custodian  (Note 1E). The  computation  of net
     expenses to average  daily net assets  reported  above is computed  without
     consideration of such credits.
  (4) Certain per share amounts are based on average shares outstanding.
</FN>
</TABLE>

<PAGE>

<TABLE>
<CAPTION>


MEXICO SERIES                                                          Year Ended December 31
- -----------------------------------------------------------------------------------------------------------------------------------
                                                            1999         1998(4)      1997(4)      1996          1995
- -----------------------------------------------------------------------------------------------------------------------------------


<S>                                                       <C>          <C>          <C>          <C>          <C>
   Net asset value - beginning of year                    $  4.810     $  7.660     $  5.380     $  4.220     $   6.480
                                                          --------      --------     --------     --------     --------

   Income from investment operations:
     Net investment income (loss)(1)                      $ (0.060)    $  0.003     $ (0.000)(+) $ (0.012)    $  (0.012)
     Net realized and unrealized gain (loss)                 2.990       (2.853)       2.280        1.172        (2.175)
                                                          --------      --------     --------     --------     --------

       Total income (loss)
        from investment operations                        $  2.930     $ (2.850)    $  2.280     $  1.160     $  (2.187)
                                                          --------      --------     --------     --------     --------

   Less distributions:
     Distributions from investment income                 $  -         $  -         $  -         $  -         $   -

     Distributions from capital gains                        -            -            -            -            (0.030)

     Return of capital                                       -            -            -            -            (0.043)(++)
                                                          --------      --------     --------     --------     --------

       Total distributions                                $  -         $  -         $  -         $  -         $  (0.073)

                                                          --------      --------     --------     --------     --------

   Net asset value - end of year                          $  7.740     $  4.810     $  7.660     $  5.380     $   4.220
                                                         =========     =========    =========    =========    =========
   Total return(2)                                          60.91%      (37.21%)      42.38%       27.49%       (33.37%)

   Ratios/Supplemental Data(1)
     Net assets, end of year (000 omitted)                $  8,387     $   8,737    $  28,468    $  22,028    $  32,493
     Ratio of expenses to average net assets                 2.14%         1.90%        1.61%        1.59%        1.72%
     Ratio of expenses after custodian
       fee reduction to average net assets(3)                2.00%         1.80%        1.45%        1.41%        1.39%
     Ratio of netinvestment income (loss) to
       average net assets                                   (0.76%)        0.05%       (0.06%)      (0.14%)      (0.41%)
     Portfolio turnover rate                                   56%           24%         113%          63%         110%

- ----------------------------------------------------------------------------------------------------------------------------------
<FN>

   (1)During  certain  periods   presented,   the  investment   adviser  and  the
     distributor  voluntarily  reduced their fees and the investment adviser was
     allocated  a portion  of  operating  expenses.  Had such  actions  not been
     undertaken, net investment loss per share and the ratios would have been as
     follows:

                                                            1999

   Net investment loss per share...........               $ (0.065)
                                                         =========
   Ratios (as a percentage of average net assets):

     Expenses..............................                  2.20%
                                                         =========
     Expenses after custodian fee reduction(3)               2.06%
                                                         =========
     Net investment loss...................                 (0.82%)
                                                         =========
- -------------------------------------------------------------------------------

   (2)Total investment return is calculated  assuming a purchase at the net asset
     value on the first day and a sale at the net asset value on the last day of
     each period reported.  Dividends and distributions,  if any, are assumed to
     be invested at the net asset value on the reinvestment date.
  (3)Custodian  fees were reduced by credits  resulting  from cash  balances the
     fund  maintained  with the  custodian  (Note 1E). The  computation  of net
     expenses to average  daily net assets  reported  above is computed  without
     consideration of such credits.
   (4)Certain per share amounts are based on average shares outstanding.

   (+)  Amount  represents  less  than  $0.001  per  share.
   (++) Amount  represents distribution in excess of capital gains.
</FN>
</TABLE>

<PAGE>

<TABLE>
<CAPTION>



NETHERLANDS SERIES                                                     Year Ended December 31
- ---------------------------------------------------------------------------------------------------------------------------------
                                                            1999         1998(2)      1997(2)      1996          1995
- ---------------------------------------------------------------------------------------------------------------------------------


<S>                                                       <C>          <C>          <C>          <C>          <C>
   Net asset value - beginning of period                  $ 11.700     $  9.810     $  8.970     $  8.590     $   8.100
                                                          --------      --------     --------     --------     --------

   Income from investment operations:
     Net investment income (loss)(1)                      $  0.233     $ (0.003)    $ (0.006)    $  0.047     $  (0.004)
     Net realized and unrealized gain (loss)                (0.826)       2.370        1.396        2.943         1.490
                                                          --------      --------     --------     --------     --------

       Total income (loss)
        from investment operations                        $ (0.593)    $  2.367     $  1.390     $  2.990     $   1.486
                                                          --------      --------     --------     --------     --------

   Less distributions:
     Dividends from investment income                     $  -         $  -         $  -         $  -         $    -

     Distributions from capital gains                       (1.287)      (0.477)      (0.550)      (2.610)       (0.996)
     Return of capital                                       -            -            -            -             -
                                                          --------      --------     --------     --------     --------

     Total distributions                                  $ (1.287)    $ (0.477)    $ (0.550)    $ (2.610)    $  (0.996)
                                                          --------      --------     --------     --------     --------

   Net asset value - end of period                        $  9.820     $ 11.700     $  9.810     $  8.970     $   8.590
                                                         =========     =========    =========    =========    =========
   Total return(3)                                          (4.39%)      24.46%       15.44%       36.56%        18.84%

   Ratios/Supplemental Data(1):
     Net assets, end of period (000 omitted)             $   8,696     $ 19,550     $ 12,975     $  7,566     $   7,218
     Ratio of expenses to average net assets                 1.77%        1.88%        1.86%        2.22%         2.26%
     Ratio of expenses after custodian
       fee reduction to average net assets(4)                1.71%        1.72%        1.72%        1.99%         2.00%
     Ratio of net investment income (loss) to
       average net assets                                    1.69%       (0.02%)      (0.05%)       0.83%        (0.13%)
     Portfolio turnover rate                                   48%          88%          29%         124%           87%

- --------------------------------------------------------------------------------------------------------------------------------
<FN>

   (1)During  certain  periods  presented,  either the  investment  adviser,  the
     administrator  and/or the distributor  voluntarily  reduced their fees, and
     the investment adviser was allocated a portion of operating  expenses.  Had
     such actions not been  undertaken,  net investment  income (loss) per share
     and the ratios would have been as follows:

                                                                                                   1996          1995
- ------------------------------------------------------------------------------------------------------------------------------

   Net investment income (loss) per share                                                        $  0.038     $  (0.018)
                                                                                                 =========    =========
   Ratios (as a percentage of average net assets):

     Expenses                                                                                       2.38%         2.45%
                                                                                                 =========    =========
     Expenses after custodian fee reduction(4)                                                      2.15%         2.19%
                                                                                                 =========    =========
     Net investment income (loss)                                                                   0.67%        (0.58%)
                                                                                                 =========    =========

- ----------------------------------------------------------------------------------------------------------------------------------

   (2)Certain per share amounts are based on average shares outstanding.
   (3)Total investment return is calculated assuming a purchase at the net asset
     value on the first day and a sale at the net asset value on the last day of
     each period reported.  Dividends and distributions, if any, are assumed to
     be invested at the net asset value on the reinvestment date.
   (4)Custodian  fees were reduced by credits resulting from cash  balances the
     fund  maintained  with the  custodian  (Note 1E). The  computation of net
     expenses to average  daily net assets  reported  above is computed without
     consideration of such credits.

</FN>
</TABLE>

FOR MORE INFORMATION
     Additional  information  about the funds'  investments  is available in the
funds' semi-annual and annual reports to shareholders.  The funds' annual report
contains a discussion of the market  conditions and investment  strategies  that
affected the funds' performance over the past year.

     You may want to read the statement of additional information (SAI) for more
information  on the  funds  and  the  securities  they  invest  in.  The  SAI is
incorporated  into  this  prospectus  by  reference,  which  means  that  it  is
considered to be part of the prospectus.

     You can get free copies of the  semi-annual and annual reports and the SAI,
request other  information or get answers to your  questions  about the funds by
writing or calling:


      Wright Investors' Service Distributors, Inc.
      440 Wheelers Farms Road
      Milford, CT 06460
      (800) 888-9471
      e-mail: [email protected]


Copies of documents  and  application  forms can be viewed and  downloaded  from
Wright's website: www.wrightinvestors.com.


     Text-only  versions of fund  documents  can be viewed  online or downloaded
from the SEC's web site at http://  www.sec.gov.  You can also obtain  copies by
visiting the SEC's Public  Reference Room in Washington  DC. For  information on
the  operation of the Public  Reference  Room,  call (800)  SEC-0330.  Copies of
documents  may also be obtained  by sending  your  request  and the  appropriate
duplicating fee to the SEC's Public Reference Section, Washington, DC 20549-0102
or by electronic mail at [email protected].


  Investment Company Act file number...........................811-05866

<PAGE>


                                                                  STATEMENT OF
                                                        ADDITIONAL INFORMATION
                                                                   May 1, 2000




                        THE WRIGHT EQUIFUND EQUITY TRUST
                       ---------------------------------

                          Wright EquiFund-Hong Kong/China
                          Wright EquiFund-Japan
                          Wright EquiFund-Mexico
                          Wright EquiFund-Netherlands


                                255 State Street
                           Boston, Massachusetts 02109






                                Table of Contents

                                                                       Page

         The Funds and Their Investment Policies.........................2
         Additional Information about the Trust..........................7
         Officers and Trustees..........................................10
         Control Persons and Principal Holders of Shares................12
         Investment Advisory and Administrative Services................13
         Custodian and Transfer Agent...................................14
         Independent Certified Public Accountants.......................14
         Brokerage Allocation...........................................14
         Principal Underwriter..........................................16
         How the Funds Value their Shares...............................17
         Performance Information........................................17
         Taxes..........................................................18
         Financial Statements...........................................19
         Appendix.......................................................20






This combined  Statement of Additional  Information  is NOT a prospectus  and is
authorized  for  distribution  to  prospective  investors  only if  preceded  or
accompanied by the current  combined  Prospectus of the funds dated May 1, 2000,
as supplemented from time to time, which is incorporated herein by reference.  A
copy of the  Prospectus may be obtained  without  charge from Wright  Investors'
Service  Distributors,   Inc.,  440  Wheelers  Farms  Road,  Milford,  CT  06460
(Telephone: (800) 888-9471).




<PAGE>


                     THE FUNDS AND THEIR INVESTMENT POLICIES


     Each fund is a  diversified  series of an  open-end  management  investment
company.  Unless otherwise defined in this Statement of Additional  Information,
capitalized terms have the meaning given to them in the Prospectus.



     The Funds and their  Investment  Policies -- Each fund invests in a broadly
based portfolio of equity securities selected by the Investment Adviser from the
publicly traded companies in the Wright Approved  Investment List for the nation
or nations in which each fund is permitted to invest.  Only securities for which
adequate  public   information  is  available  and  which  could  be  considered
acceptable for  investment by a prudent  person will comprise a Wright  Approved
Investment  List.  Each fund will invest at least 65% of its total assets in the
securities of companies  located in the country or countries  referred to in its
name.  A fund's  selection  of equity  securities  is  limited  to those  equity
securities  included in the Wright Approved  Investment  List (described  below)
relating to such fund. Each fund will, under normal market conditions, invest at
least 80% of its net  assets  in equity  securities,  including  common  stocks,
preferred stocks,  rights,  warrants and securities convertible into stock. With
respect to the Hong Kong/China,  Japan, and Netherlands  funds the policy stated
in the preceding  sentence is fundamental and may be changed only by the vote of
a majority of a fund's outstanding  voting  securities.  A company is located or
doing  business  in a  foreign  country  if it  satisfies  at  least  one of the
following  criteria:  (i)  the  equity  securities  of the  company  are  traded
principally on stock exchanges in one or more foreign countries; (ii) it derives
50% or more of its total  revenue  from goods  produced,  sales made or services
performed in one or more foreign  countries;  (iii) it maintains  50% or more of
its assets in one or more foreign countries; (iv) it is organized under the laws
of a foreign country;  or (v) its principal  executive  offices are located in a
foreign country.


     Each fund may invest up to 20% of its net assets in an  investment  reserve
in cash (including foreign currency) or cash equivalent securities (high quality
short-term fixed income debt  securities)  whenever such reserve is deemed to be
in the best interests of the  shareholders  for any reason,  including  Wright's
expectation of a decline in the equity markets in which the fund is permitted to
invest.  The  reserve  may  consist of U.S.  Government  securities,  repurchase
agreements,  certificates of deposit, bankers' acceptances, fixed time deposits,
commercial  paper,  finance company paper, and other short-term debt securities.
The  fund  may hold  cash or  invest  without  limit  in  these  securities  for
temporary, defensive purposes.


     Except  as  provided  above  and  except  for  the  fundamental  investment
restrictions  listed below,  the investment  objective and policies of each fund
are not  fundamental  and may be changed by the Trustees of the Trust  without a
vote of the affected  fund's  shareholders.  If any changes were made,  the fund
might  have an  investment  objective  different  from  the  objective  which an
investor considered appropriate at the time the investor became a shareholder in
the fund.  EquiFund will notify the  shareholders  of any material change in its
investment  objective.  There is no assurance  that the funds will achieve their
respective  investment  objectives.  The market price of securities  held by the
funds that are quoted or  denominated in foreign  currencies,  when expressed in
U.S.  dollars,  will  fluctuate in response to changes in exchange rates between
the U.S.  dollar  and the  currencies  in which  the  securities  are  quoted or
denominated.  The net asset value of each fund's shares will also fluctuate as a
result of changes in the value of the securities that it owns.



     The  Wright  Approved  Investment  List -- Wright  has  developed  a Wright
Approved  Investment List for each nation in which a fund invests (the "Approved
List").  Each  Approved List is designed to be a list of  substantially  all the
publicly traded companies in the nation or nations in which each respective fund
is permitted to invest which meet the  requirements of a prudent  investor.  The
prudent  investor  standard  requires  that care,  skill and  caution be used in
selecting  securities  for  investment.  This prudent  investor  standard is the
foundation for the investment  criteria  employed in creating the Approved List.
The Investment Adviser will select securities for investment from those included
in the corresponding Approved List.

     The  Approved  List is adjusted  quarterly  and as  otherwise  necessary to
reflect significant events. Changes in the composition of a List will be made by
determining  whether existing  companies  included in that List continue to meet
the criteria and whether other  companies meet these criteria and should replace
or be added to the companies  already  comprising that Approved List. A detailed
explanation of the objective criteria used in the process of selecting companies
for inclusion in a List is included herein.

     The securities  included in a List will be (i) admitted to official listing
on a stock exchange in any Member State of the EUROPEAN Union,  (ii) admitted to
official  listing on a recognized stock exchange in any other country in Western
Europe, Asia, Oceania,  the American continents,  including Bermuda, and Africa,
(iii)  traded  on  another  regulated  market  in any such  Member  State of the
European  Union or such other  country  referred to above,  provided such market
operates  regularly and is recognized  and open to the public,  or (iv) recently
issued,  provided the terms of the issue  provide that  application  be made for
admission to official  listing on any of the stock  exchanges or other regulated
markets  referred to above,  and provided such listing is secured  within a year
following the date of issuance.

<PAGE>


     In selecting  securities  for the Approved  Lists and for  inclusion in the
portfolios  of the funds,  Wright  utilizes its  international  database,  which
includes  WORLDSCOPE(R).  WORLDSCOPE(R) provides information on more than 23,000
companies  worldwide.  Additional  information  about  the  composition  of  the
Approved  Lists may be obtained  without charge from Wright  Investors'  Service
Distributors,  Inc., 440 Wheelers Farms Road, Milford, CT 06460  (800-888-9471).
The  Approved  Lists are  adjusted as  necessary  to reflect  recent  events.  A
detailed  explanation of the objective criteria used in the selection process is
as follows.


     To be selected for an Approved List, a company must generally have:

     1.  Five years of earnings data (17 quarters of 12 month  earnings).  To be
         selected,  a company's  trailing 12 month earnings during the last four
         quarters or during the last three reported years  cumulatively  must be
         positive.

     2.  Five years of  dividend  information  or positive  verification  that a
         company did not declare a dividend (20  quarters of quarterly  dividend
         information).

     3.  Three years of price information (12 quarters of quarterly prices).  To
         be selected,  a company  generally  must have market  value  (number of
         shares times price) equal to or greater than $50 million.

     4.  Book value  information  for the past five years (20  quarters).  To be
         selected, book value must be equal to or greater than $50 million.

     5.  Industry group  information.  Companies that are closed-end  investment
         companies, real estate investment trusts or non-bank securities brokers
         or dealers will not be included.

     Acquired  companies may continue to be included in the relevant Index up to
their acquisition date.

     Temporary  Defensive  Investments  -- During  periods of unusual  market or
economic conditions, when Wright believes that investing for temporary defensive
purposes is appropriate, all or any portion of each fund's assets may be held in
cash  (including,  subject to the  requirements of the Internal  Revenue Code of
1986, as amended (the "Code") applicable to regulated investment companies,  the
foreign  currency  of the  nation or  nations  in which  such fund  invests)  or
invested in short-term  obligations,  including  but not limited to  obligations
issued or  guaranteed  by the U.S.  or any  foreign  government  or any of their
respective agencies or  instrumentalities;  obligations of public  international
agencies;  commercial  paper  which at the date of  investment  is rated  A-1 by
Standard & Poor's  Ratings  Group ("S&P") or P-1 by Moody's  Investors  Service,
Inc. ("Moody's"),  or, if not rated by such rating  organizations,  is deemed by
the Investment Adviser pursuant to procedures  established by the Trustees to be
of  comparable  quality;   short-term  corporate   obligations  and  other  debt
instruments  which at the date of investment are rated AA or better by S&P or Aa
or better by Moody's or, if unrated,  which are deemed by the Investment Adviser
pursuant to procedures  established by the Trustees to be of comparable quality;
and certificates of deposit,  bankers' acceptances and time deposits of domestic
or foreign banks which are  determined  to be of high quality by the  Investment
Adviser.  Temporary  investments may be denominated either in U.S. dollars or in
the currency of the nation in which the fund primarily invests.

     U.S. Government,  Agency and Instrumentality  Securities -- U.S. Government
securities are issued by the U.S.  Treasury and include bills,  certificates  of
indebtedness,  notes,  and bonds.  Agencies  and  instrumentalities  of the U.S.
Government  are  established  under  the  authority  of an act of  Congress  and
include,  but are not limited to, the Government National Mortgage  Association,
the Tennessee  Valley  Authority,  the Bank for  Cooperatives,  the Farmers Home
Administration,  Federal Home Loan Banks,  Federal  Intermediate  Credit  Banks,
Federal Land Banks, and the Federal National Mortgage Association.


     Repurchase  Agreements -- Each fund may enter into repurchase agreements in
order to earn  income on  temporarily  uninvested  cash.  Repurchase  agreements
involve the  purchase of U.S.  Government  securities  or of other high  quality
short-term debt  obligations.  At the same time a fund purchases the security it
resells  such  security  to the  vendor  which is a member  bank of the  Federal
Reserve  System,  a  recognized  securities  dealer or any  foreign  bank  whose
creditworthiness  has been  determined by Wright to be at least equal to that of
issuers of  commercial  paper rated  within the two highest  grades  assigned by
Moody's or S&P, and is  obligated to redeliver  the security to the vendor on an
agreed-upon date in the future. A repurchase agreement with foreign banks may be
available  with  respect to  government  securities  of the  particular  foreign
jurisdiction.  The resale price is in excess of the purchase  price and reflects
an  agreed-upon  market  rate  unrelated  to the  coupon  rate on the  purchased
security. Such transactions afford an opportunity for a fund to earn a return on
cash which is only  temporarily  available.  A fund's risk is the ability of the
vendor  to pay an  agreed  upon sum upon the  delivery  date,  which  the  Trust
believes is limited to the  difference  between the market value of the security
and the  repurchase  price provided for in the  repurchase  agreement.  However,
bankruptcy or insolvency  proceedings affecting the vendor of the security which
is subject to the repurchase agreement, prior to the repurchase, may result in a
delay in a fund being able to resell the security. Repurchase agreements are
considered to be loans under the Investment Company Act of 1940.
<PAGE>


     There is no  percentage  limit on the amount of any fund's  investments  in
repurchase  agreements,  except for the  requirement  that,  under normal market
conditions,  at least 80% of each  fund's net assets  will be invested in equity
securities.

     Certificates of Deposit -- are certificates  issued against funds deposited
in a bank, are for a definite  period of time,  earn a specified rate of return,
and are normally negotiable.

     Bankers'  Acceptances -- are short-term credit  instruments used to finance
the import,  export,  transfer or storage of goods.  They are termed  "accepted"
when a bank guarantees their payment at maturity.

     Fixed Time Deposits -- are bank  obligations  payable at a stated  maturity
date and bearing  interest at a fixed rate. Fixed time deposits may be withdrawn
on demand by the  investor,  but may be  subject to early  withdrawal  penalties
which vary  depending upon market  conditions and the remaining  maturity of the
obligation.  There are no  contractual  restrictions  on the right to transfer a
beneficial interest in a fixed time deposit to a third party,  although there is
no market for such deposits.

     Commercial  Paper and Finance  Company Paper -- refers to promissory  notes
issued by corporations in order to finance their short-term credit needs.

     Restricted  Securities -- Securities that are not freely tradeable or which
are  subject  to  restrictions  on sale  under  the  Securities  Act of 1933 are
considered  restricted.  Such  securities  are  illiquid and may be difficult to
properly value.  Each fund's holdings of illiquid  securities may not exceed 15%
of its net assets.  Illiquid securities include securities legally restricted as
to  resale.  Securities  eligible  for  resale  pursuant  to Rule 144A under the
Securities  Act of 1933 may,  however,  be treated  as liquid by the  Investment
Adviser  pursuant  to  procedures   adopted  by  the  Trustees,   which  require
consideration  of  factors  such as  trading  activity,  availability  of market
quotations  and number of dealers  willing to purchase the  security.  Moreover,
investments in Rule 144A  securities may increase the level of fund  illiquidity
to the extent qualified  institutional  buyers become uninterested in purchasing
such securities.

     Convertible  Securities  -- Each fund may from time to time invest up to 5%
of  its  total  assets  in  debt  securities  and  preferred  stocks  which  are
convertible  into, or carry the right to purchase,  common stock or other equity
securities.  The debt security or preferred stock may itself be convertible into
or exchangeable for equity securities, or the purchase right may be evidenced by
warrants  attached  to the  security  or  acquired  as part of a unit  with  the
security.  Convertible  securities  may  be  purchased  for  their  appreciation
potential  when they yield more than the  underlying  securities  at the time of
purchase or when they are considered to present less risk of principal loss than
the underlying securities. Generally speaking, the interest or dividend yield of
a convertible security is somewhat less than that of a non-convertible  security
of similar quality issued by the same company.

     Warrants and Rights -- Wright  EquiFund - Mexico may purchase  warrants and
each fund may purchase rights. No fund intends to invest more than 5% of its net
assets in  warrants  and  rights as the case may be (other  than those that have
been acquired in units or attached to other securities). Warrants and rights are
options to purchase  equity  securities at a specific price valid for a specific
period of time. They do not represent ownership of the securities,  but only the
right to buy them.  The prices of warrants  and rights do not  necessarily  move
parallel to the prices of the  underlying  securities.  Warrants  and rights may
become valueless if not sold or exercised prior to their expiration.

     Foreign  Securities -- The funds may invest in foreign  securities,  and in
certificates  of deposit,  bankers'  acceptances,  fixed time deposits issued by
major foreign banks and foreign  branches of United States banks,  to any extent
deemed appropriate by Wright and consistent with a fund's investment  objective.
Investing in securities of foreign governments or securities issued by companies
whose  principal  business  activities are outside the United States may involve
significant risks not associated with domestic investments.  For example,  there
is generally  less  publicly  available  information  about  foreign  companies,
particularly  those not subject to the disclosure and reporting  requirements of
the U.S.  securities  laws.  Foreign  issuers are generally not bound by uniform
accounting,  auditing and financial reporting  requirements  comparable to those
applicable to domestic issuers.  Investments in foreign  securities also involve
the  risks  of  possible  adverse  changes  in  exchange  control   regulations,
expropriation or confiscatory taxation,  limitation on removal of funds or other
assets of a fund,  political or financial  instability  or diplomatic  and other
developments  which  could  affect  such  investments.   Further,  economies  of
particular  countries or areas of the world may differ  favorably or unfavorably
from the economy of the U.S. To the extent investments in foreign securities are
denominated or quoted in currencies of foreign countries, a fund may be affected
favorably or  unfavorably  by changes in currency  exchange  rates and may incur
costs in connection with conversion between currencies.
<PAGE>


     It is anticipated  that in most cases the best available market for foreign
securities will be on exchanges or in  over-the-counter  markets located outside
the U.S. Foreign stock markets, while growing in volume and sophistication,  are
generally  not as  developed  as those in the U.S.  Securities  of some  foreign
issuers may be less liquid and more volatile than  securities of comparable U.S.
companies  (this is  particularly  true of issuers  located in  emerging  market
countries;  however,  the  funds,  other than  Mexico  fund,  do not  anticipate
investments  in  securities  of  developing  countries).  In  addition,  foreign
brokerage commissions are generally higher than commissions on securities traded
in the  U.S.  and may be  non-negotiable.  In  general,  there  is less  overall
governmental  supervision  and regulation of securities  exchanges,  brokers and
listed companies than in the U.S.


     The above risks may be intensified for  investments in emerging  markets or
countries  with  limited  or  developing  capital  markets  such as  Mexico  and
countries located in the Asia-Pacific  region.  Security prices in these markets
can be significantly more volatile than in more developed countries,  reflecting
the  greater   uncertainties  of  investing  in  less  established  markets  and
economies.  Political,  legal and economic  structures in many of these emerging
market countries may be undergoing  significant evolution and rapid development,
and  they  may  lack  the  social,  political,   legal  and  economic  stability
characteristic of more developed  countries.  Emerging market countries may have
failed  in the  past  to  recognize  private  property  rights.  They  may  have
relatively  unstable  governments,   present  the  risk  of  nationalization  of
businesses,  restrictions on foreign ownership,  or prohibitions on repatriation
of assets,  and may have less  protection of property rights than more developed
countries.  Their economies may be predominantly based on only a few industries,
may be highly vulnerable to changes in local or global trade conditions, and may
suffer  from  extreme  and  volatile  debt  burdens or  inflation  rates.  Local
securities  markets may trade a small number of securities  and may be unable to
respond  effectively to increases in trading volume,  potentially  making prompt
liquidation of substantial holdings difficult or impossible at times. A fund may
be required to establish special custodial or other  arrangements  before making
certain  investments in those countries.  Securities of issuers located in these
countries  may have limited  marketability  and may be subject to more abrupt or
erratic price movements.

     Each fund may, but does not expect to, invest in foreign  securities in the
form of American  Depositary  Receipts ("ADRs"),  European  Depositary  Receipts
("EDRs"), International Depositary Receipts ("IDRs") or other similar securities
representing  securities of foreign issuers.  ADRs are receipts typically issued
by a United States bank or trust company evidencing  ownership of the underlying
foreign  securities.  EDRs and IDRs are receipts  typically issued by a European
bank or trust company evidencing ownership of the underlying foreign securities.

     Foreign Currency  Exchange  Transactions -- The funds may engage in foreign
currency exchange transactions. Investments in securities of foreign governments
and companies whose principal business activities are located outside the United
States will frequently  involve  currencies of foreign  countries.  In addition,
assets of a fund may temporarily be held in bank deposits in foreign  currencies
during the completion of investment programs.  Therefore,  the value of a fund's
assets, as measured in U.S. dollars, may be affected favorably or unfavorably by
changes in foreign  currency  exchange rates and exchange  control  regulations.
Although  each fund values its assets daily in U.S.  dollars,  the fund does not
intend to convert its  holdings  of foreign  currencies  into U.S.  dollars on a
daily basis. A fund may conduct its foreign currency exchange  transactions on a
spot (i.e.,  cash)  basis at the spot rate  prevailing  in the foreign  currency
exchange  market.  The fund will  convert  currency on a spot basis from time to
time and will incur costs in connection with such currency conversion.  Although
foreign exchange  dealers do not charge a fee for conversion,  they do realize a
profit based on the difference  (the "spread")  between the prices at which they
are buying and selling  various  currencies.  Thus, a dealer may offer to sell a
foreign currency to a fund at one rate, while offering a lesser rate of exchange
should the fund desire to resell that  currency to the dealer.  The funds do not
intend to speculate in foreign currency exchange rates.

     As an alternative to spot transactions,  a fund may enter into contracts to
purchase or sell foreign  currencies at a future date ("forward  contracts").  A
forward contract  involves an obligation to purchase or sell a specific currency
at a future date and price fixed by agreement between the parties at the time of
entering into the contract.  These contracts are traded in the interbank  market
conducted directly between currency traders (usually large commercial banks) and
their  customers.  Although a forward  contract  generally  involves  no deposit
requirement and no commissions are charged at any stage for trades,  a fund will
maintain  segregated  accounts in connection with such  transactions.  The funds
intend to enter into such contracts only on net terms.

     A fund may enter into forward  contracts  under two  circumstances.  First,
when a fund enters into a contract for the purchase or sale of a security quoted
or  denominated in a foreign  currency,  it may desire to "lock in" the price of
the security.  This is accomplished by entering into a forward  contract for the
purchase or sale,  for a fixed  amount of the foreign  currency  involved in the
underlying security transaction  ("transaction hedging").  Such forward contract
transactions  will  enable the fund to protect  itself  against a possible  loss
resulting  from an adverse  change in the  relationship  between  the  different
currencies  during the period between the date the security is purchased or sold
and the date of payment for the security.
<PAGE>


     Second,  when Wright  believes  that the currency of a  particular  foreign
country may suffer a decline,  a fund may enter into a forward  contract to sell
the amount of  foreign  currency  approximating  the value of some or all of the
securities quoted or denominated in such foreign currency.  The precise matching
of the forward  contract  amounts and the value of the securities  involved will
not  generally  be  possible.  The future  value of such  securities  in foreign
currencies  will change as a consequence of  fluctuations in the market value of
those  securities  between the date the forward contract is entered into and the
date  it  matures.   The   projection  of  currency   exchange   rates  and  the
implementation  of a short-term  hedging  strategy are highly  uncertain.


     The fund will place cash or liquid  securities in a segregated
account.  The amount of such  segregated  assets  will be at least  equal to the
value  of a  fund's  total  assets  committed  to the  consummation  of  forward
contracts  involving  the  purchase  of  foreign  currency.  If the value of the
securities  placed  in the  segregated  account  declines,  additional  cash  or
securities  will be placed in the  account on a daily basis so that the value of
the amount will equal the amount of the fund's  commitments with respect to such
contracts.


     At the  maturity  of a  forward  contract,  the fund may  elect to sell the
portfolio security and make delivery of the foreign currency. Alternatively, the
fund may retain the security and terminate its contractual obligation to deliver
the foreign  currency by  purchasing an identical  offsetting  contract from the
same currency trader.


     It is impossible  to forecast with  precision the market value of portfolio
securities  at the  expiration  of a forward  contract.  Accordingly,  it may be
necessary for a fund to purchase  additional foreign currency on the spot market
(and bear the expense of such purchase) if the fund intends to sell the security
and the market value of the security is less than the amount of foreign currency
that the fund is obligated to deliver.  Conversely,  it may be necessary to sell
on the spot market some of the foreign  currency  received  upon the sale of the
portfolio  security if its market value  exceeds the amount of foreign  currency
that the fund is obligated to deliver.

     If a fund  retains the  portfolio  security  and  engages in an  offsetting
transaction,  the fund  will  incur a gain or loss (as  described  below) to the
extent  that there has been a change in  forward  contract  prices.  If the fund
engages  in an  offsetting  transaction,  it may  subsequently  enter into a new
forward  contract to sell the foreign  currency.  Should forward contract prices
decline  during  the  period  between  the date the fund  enters  into a forward
contract  for the sale of the  foreign  currency  and the date it enters into an
offsetting  contract  for the  purchase of the foreign  currency,  the fund will
realize a gain to the  extent  that the price of the  currency  it has agreed to
sell exceeds the price of the currency it has agreed to purchase. Should forward
contracts  prices  increase,  the fund will suffer a loss to the extent that the
price of the  currency  it has  agreed  to  purchase  exceeds  the  price of the
currency it has agreed to sell.

     A fund  will  not  speculate  in  forward  contracts  and  will  limit  its
transactions  in such contracts to those described  above. Of course,  a fund is
not  required  to enter into such  transactions  with  respect to its  portfolio
securities quoted or denominated in a foreign currency and will not do so unless
deemed  appropriate  by Wright.  This method of protecting the value of a fund's
securities  against a  decline  in the value of a  currency  does not  eliminate
fluctuations in the underlying prices of the securities. It simply establishes a
rate of exchange  which the fund can achieve at some future time.  Additionally,
although  such  contracts  tend to minimize the risk of loss due to a decline in
the value of the hedged  currency,  they also tend to limit any  potential  gain
which might be realized if the value of such currency increases.

     There is no other  percentage  limitation on any fund's holdings of foreign
currencies or forward  contracts,  except for the requirement that, under normal
market  conditions,  at least 80% of the fund's net assets  will be  invested in
equity securities.  A fund's foreign currency transactions may be limited by the
requirements  of  Subchapter  M of the Code  for  qualification  as a  regulated
investment company.

     Lending  Portfolio  Securities  -- Each fund may seek to increase its total
return by lending portfolio  securities to broker-dealers or other institutional
borrowers.  Such loans are required to be continuously  secured by collateral in
cash or liquid securities.  During the existence of a loan, a fund will continue
to receive the equivalent of the interest or dividends paid by the issuer on the
securities  loaned  and will  also  receive a fee,  or all or a  portion  of the
interest, if any, on investment of the collateral.  However, the fund may at the
same time pay a transaction fee to such borrowers and  administrative  expenses,
such as  finders  fees to third  parties.  A fund may  invest  the  proceeds  it

<PAGE>

receives  from a  securities  loan in the  types of  securities  in which it may
invest.  As with other extensions of credit there are risks of delay in recovery
or  even  loss  of  rights  in the  securities  loaned  if the  borrower  of the
securities  fails  financially.   However,  the  loans  will  be  made  only  to
organizations  deemed by the Investment Adviser to be of good standing and when,
in the judgment of the Investment Adviser, the consideration which can be earned
from  securities  loans of this type justifies the attendant risk. The financial
condition of the borrower  will be  monitored  by the  Investment  Adviser on an
ongoing basis and collateral  values will be continuously  maintained at no less
than 100% by "marking to market"  daily.  If the Investment  Adviser  decides to
make securities  loans,  it is intended that the value of the securities  loaned
would not exceed 30% of the fund's total assets.


                     ADDITIONAL INFORMATION ABOUT THE TRUST

     The Trust's  Declaration of Trust may be amended with the affirmative  vote
of a majority of the  outstanding  shares of the Trust or, if the interests of a
particular Wright EquiFund are affected,  a majority of such fund's  outstanding
shares.  The Trust may be terminated  (i) upon the sale of the Trust's assets to
another open-end  management  investment  company, if approved by the holders of
two-thirds of the outstanding  shares of the Trust,  except that if the Trustees
of the  Trust  recommend  such sale of  assets,  the  approval  by the vote of a
majority of the Trust's  outstanding  shares  will be  sufficient;  or (ii) upon
liquidation  and  distribution  of the assets of the  Trust,  if  approved  by a
majority of its Trustees or by the vote of a majority of the Trust's outstanding
shares. If not so terminated, the Trust may continue indefinitely.

     The Trust's Declaration of Trust further provides that the Trust's Trustees
will not be liable for errors of judgment  or mistakes of fact or law;  however,
nothing in the  Declaration of Trust protects a Trustee against any liability to
which he would otherwise be subject by reason of willful misfeasance, bad faith,
gross negligence, or reckless disregard of the duties involved in the conduct of
his office.

     The Trust is an organization of the type commonly known as a "Massachusetts
business  trust." Under  Massachusetts  law,  shareholders  of such a trust may,
under  certain  circumstances,  be held  personally  liable as partners  for the
obligations of the trust.  The Trust's  Declaration of Trust contains an express
disclaimer of shareholder liability in connection with the Trust property or the
acts,  obligations  or  affairs  of the  Trust.  The  Declaration  of Trust also
provides for  indemnification  out of the Trust property of any shareholder held
personally  liable for the claims and  liabilities  to which a  shareholder  may
become subject by reason of being or having been a  shareholder.  Thus, the risk
of a shareholder incurring financial loss on account of shareholder liability is
limited to  circumstances  in which the Trust itself would be unable to meet its
obligations. The Investment Adviser does not consider this risk to be material.

Investment Restrictions

     The following  investment  restrictions  have been adopted by each fund and
may be  changed  as to a fund  only by the vote of a  majority  of the  affected
fund's outstanding  voting securities,  which means the lesser of (a) 67% of the
shares of the fund if the  holders of more than 50% of the shares are present or
represented  at the meeting or (b) more than 50% of the shares of the fund. If a
percentage restriction contained herein is adhered to at the time of investment,
a later  increase or decrease in the  percentage  resulting from a change in the
value of portfolio securities or the amount of net assets will not be considered
a violation of any of the  following  restrictions.  As a matter of  fundamental
investment policy, each fund may not:

(The  following   fundamental   investment   restrictions  apply  only  to  Hong
Kong/China, Japan and Netherlands.)

     (1) Borrow  money  other  than  from  banks  and then only up to 1/3 of the
         current  market  value  of  its  total  assets  (including  the  amount
         borrowed) and only if such borrowing is incurred as a temporary measure
         for  extraordinary  or emergency  purposes or to facilitate the orderly
         sale of portfolio  securities to accommodate  redemption  requests;  or
         issue any  securities  other  than its  shares of  beneficial  interest
         except  as  appropriate  to  evidence  indebtedness  which  the fund is
         permitted to incur.  (Each fund anticipates paying interest on borrowed
         money at rates comparable to its yield and no fund has any intention of
         attempting to increase its net income by means of borrowing);

     (2) Pledge,  mortgage or  hypothecate  its assets to an extent greater than
         1/3 of the total assets of the fund taken at market;

     (3) Purchase  the  securities  of any one issuer  (other  than  obligations
         issued or guaranteed by the U.S. Government or any of its agencies,  or
         securities of other regulated investment  companies) if, as a result of
         such  purchase,  more than 5% of that  fund's  total  assets  (taken at
         current  value) would be invested in the  securities  of such issuer or
         securities  of any one issuer held by that fund would exceed 10% of the
         outstanding  voting  securities of such issuer at the end of any fiscal
         quarter of the fund,  provided that,  with respect to 50% of the fund's
         assets,  the fund may invest up to 25% of its assets in the  securities
         of any one issuer;
<PAGE>

     (4) Purchase  or  retain  securities  of any  issuer  if 5% or  more of the
         issuer's  securities  are owned by those  officers  and Trustees of the
         Trust or its investment  adviser or administrator  who own individually
         more than 1/2 of 1% of the issuer's securities;

     (5) Purchase securities on margin or make short sales except sales against
         the box or purchase warrants;

     (6) Buy or sell commodities,  or commodity  contracts (except that the fund
         may purchase or sell currencies and put and call options on securities,
         indices or currencies and enter into forward foreign currency  exchange
         contracts), unless acquired as a result of ownership of securities;

     (7) Purchase any  securities  which would cause more than 25% of the market
         value of its total  assets at the time of such  purchase to be invested
         in the securities of issuers having their principal business activities
         in the same  industry,  provided that there is no limitation in respect
         to  investments  in  obligations  issued  or  guaranteed  by  the  U.S.
         Government or its agencies or instrumentalities;

     (8) Underwrite securities issued by other persons except to the extent that
         the  purchase of  securities  in  accordance  with a fund's  investment
         objectives and policies  directly from the issuer thereof and the later
         disposition thereof may be deemed to be underwriting;

     (9) Make loans, except (i) through the loan of a portfolio  security,  (ii)
         by entering into repurchase agreements and (iii) to the extent that the
         purchase of debt  instruments,  if any, in  accordance  with the fund's
         investment objective and policies may be deemed to be loans;

    (10) Purchase from or sell to any of the Trust's  Trustees or officers,  its
         investment adviser, its administrator,  its principal  underwriter,  if
         any,  or  the  officers  or  directors  of  said  investment   adviser,
         administrator,  or principal  underwriter,  portfolio securities of the
         fund;

    (11) Purchase or retain securities of other open-end  investment  companies,
         except  when  such  purchases  are  part  of a  merger,  consolidation,
         reorganization or assets acquisition;

    (12) Acquire  real estate but it may lease  office space for its own use and
         invest  in (1)  readily  marketable  interests  of real  estate or real
         estate  limited  partnership  interests,  investment  trusts or readily
         marketable  securities  of  issuers  (other  than real  estate  limited
         partnerships)  whose business involves the purchase of real estate; and
         (2) securities secured by real estate or interests therein; or

    (13) With respect to 75% of its total assets, (i) invest more than 5% of its
         total  assets in  securities  of any one issuer,  excluding  securities
         issued or guaranteed by the United States government or by its agencies
         and instrumentalities and options or (ii) purchase more than 10% of the
         voting securities of any class of any issuer.

     For  the  purpose  of  investment   restrictions  (1),  (2)  and  (5),  the
arrangements (including escrow, margin and collateral  arrangements) made by any
such fund with  respect to its  transactions  in  currency  options,  options on
securities  and  forward  foreign  currency  exchange  contracts  shall  not  be
considered  to be (i) a  borrowing  of  money  or  the  issuance  of  securities
(including senior  securities) by that fund, (ii) a pledge of its assets,  (iii)
the purchase of a security on margin or (iv) a short sale or position.


(The following fundamental investment restrictions apply only to Mexico.)

     (1) Borrow  money  other  than  from  banks  and then only up to 1/3 of the
         current  market  value  of  its  total  assets  (including  the  amount
         borrowed) and only if such borrowing is incurred as a temporary measure
         for  extraordinary  or emergency  purposes or to facilitate the orderly
         sale of portfolio  securities to accommodate  redemption  requests;  or
         issue any  securities  other  than its  shares of  beneficial  interest
         except  as  appropriate  to  evidence  indebtedness  which  the fund is
         permitted to incur.  (Each fund anticipates paying interest on borrowed
         money at rates comparable to its yield and no fund has any intention of
         attempting to increase its net income by means of borrowing);

     (2) Pledge,  mortgage or  hypothecate  its assets to an extent greater than
         1/3 of the total assets of the fund taken at market;
<PAGE>

     (3) Buy or sell commodities,  or commodity  contracts (except that the fund
         may purchase or sell currencies and put and call options on securities,
         indices or currencies and enter into forward foreign currency  exchange
         contracts), unless acquired as a result of ownership of securities;

     (4) Purchase any  securities  which would cause more than 25% of the market
         value of its total  assets at the time of such  purchase to be invested
         in the securities of issuers having their principal business activities
         in the same  industry,  provided that there is no limitation in respect
         to  investments  in  obligations  issued  or  guaranteed  by  the  U.S.
         Government or its agencies or instrumentalities;

     (5) Underwrite securities issued by other persons except to the extent that
         the  purchase of  securities  in  accordance  with a fund's  investment
         objectives and policies  directly from the issuer thereof and the later
         disposition thereof may be deemed to be underwriting;

     (6) Make loans, except (i) through the loan of a portfolio  security,  (ii)
         by entering into repurchase agreements and (iii) to the extent that the
         purchase of debt  instruments,  if any, in  accordance  with the fund's
         investment objective and policies may be deemed to be loans;

     (7) Purchase  or sell real  estate,  except  that a fund may (i) acquire or
         lease  office  space  for its own use,  (ii)  invest in  securities  of
         issuers that invest in real estate or interests  therein,  (iii) invest
         in  securities  that are secured by real estate or  interests  therein,
         (iv)  purchase and sell  mortgage-related  securities  and (v) hold and
         sell real  estate  acquired by a fund as a result of the  ownership  of
         securities; or

     (8) With respect to 75% of its total assets, (i) invest more than 5% of its
         total  assets in  securities  of any one issuer,  excluding  securities
         issued or  guaranteed  by the U.S.  Government  or by its  agencies and
         instrumentalities and options thereon or (ii) purchase more than 10% of
         the voting securities of any class of any issuer.

     For the purpose of fundamental  investment  restrictions  (1) and (2) above
and nonfundamental investment restriction (h) below, the arrangements (including
escrow,  margin and collateral  arrangements) made by a fund with respect to its
transactions  in currency  options,  options on securities  and forward  foreign
currency  exchange  contracts  shall not be  considered to be (i) a borrowing of
money or the issuance of securities  (including senior securities) by that fund,
(ii) a pledge of its assets,  (iii) the purchase of a security on margin or (iv)
a short sale or position.

     The following are nonfundamental policies of each fund which may be changed
by the  Trustees  without  shareholder  approval.  The  funds  have  no  current
intention  of  borrowing  for  leverage  purposes,  making  securities  loans or
engaging in short sales.  The funds have no current  intention of investing more
than 5% of net assets in Rule 144A securities. No fund will:

     (a) Purchase  oil,  gas or other  mineral  leases or  purchase  partnership
         interests  in oil,  gas or other  mineral  exploration  or  development
         programs;

     (b) Invest more than 5% of its total  assets in the  securities  of issuers
         which,  together  with their  predecessors,  have a record of less than
         three years' continuous operation;

     (c) Purchase securities issued by any other investment  company,  except by
         purchase in the open market where no commission or profit to sponsor or
         dealer  results from such purchase,  other than the customary  broker's
         commission,  or except  where such  purchase,  although not made on the
         open market, is part of a plan of merger or  consolidation.  Subject to
         the preceding sentence, a fund may invest in other investment companies
         to the full extent  allowed by the 1940 Act. Under the 1940 Act, a fund
         may not acquire more than 3% of the  outstanding  voting  securities of
         another  investment  company,  invest more than 5% of its assets in any
         single  investment  company  or invest  more than 10% of its  assets in
         other investment companies as a group;

     (d) Enter into an agreement to purchase securities while its borrowings
         exceed 5% of its total assets;

     (e) Invest  (1) more than 15% of its net  assets in  illiquid  investments,
         including  repurchase  agreements  maturing  in more than  seven  days,
         securities  that are not readily  marketable and restricted  securities
         not eligible for resale  pursuant to Rule 144A under the Securities Act
         of 1933  (the  "1933  Act");  (2) more  than 10% of its net  assets  in
         restricted   securities,   excluding  securities  eligible  for  resale
         pursuant to Rule 144A or foreign  securities  which are offered or sold
         outside the United  States in  accordance  with  Regulation S under the
         1933  Act;  or (3)  more  than  15% of its  net  assets  in  restricted
         securities (including those eligible for resale under Rule 144A);
<PAGE>

     (f) Invest  more  than 10% of its total  assets  in  shares of real  estate
         investment  trusts  that are not readily  marketable  or invest in real
         estate limited partnerships;


(In addition, the following nonfundamental investment restrictions apply only to
Mexico.)

     (g) Purchase  or  retain  securities  of any  issuer  if 5% or  more of the
         issuer's  securities  are owned by those  officers  and Trustees of the
         Trust or its investment  adviser or administrator  who own individually
         more than 1/2 of 1% of the issuer's securities;

     (h) Purchase securities on margin or make short sales except short sales
         against the box or purchase warrants; or

     (i) Purchase  from  or  sell  to any  of  its  Trustees  or  officers,  its
         investment adviser, its administrator,  its principal  underwriter,  if
         any,  or  the  officers  or  directors  of  said  investment   adviser,
         administrator,  and principal underwriter,  portfolio securities of the
         fund.



                              OFFICERS AND TRUSTEES


     The  officers  and  Trustees  of the  Trust  are  listed  below.  Except as
indicated,  each  individual  has held the office shown or other  offices in the
same  company  for the last  five  years.  Those  Trustees  who are  "interested
persons"  (as  defined  in the 1940  Act) of the  Trust,  Wright,  The  Winthrop
Corporation  ("Winthrop"),  Eaton Vance,  Eaton Vance's wholly owned subsidiary,
Boston Management and Research ("BMR"),  Eaton Vance's parent, Eaton Vance Corp.
("EVC") or of Eaton Vance's trustee, Eaton Vance, Inc. ("EV") by virtue of their
affiliation with either the funds, Wright,  Winthrop,  Eaton Vance, BMR, EVC, or
EV, are indicated by an asterisk (*).


PETER M. DONOVAN (57), President and Trustee*
President,  Chief  Executive  Officer and Director of Wright and Winthrop;  Vice
President,  Treasurer and a Director of Wright Investors' Service  Distributors,
Inc.
Address: 440 Wheelers Farms Road, Milford, CT 06460

H. DAY BRIGHAM, Jr. (73), Vice President, Secretary and Trustee*
Retired Vice  President,  Chairman of the  Management  Committee and Chief Legal
Officer of Eaton Vance,  EVC, BMR and EV and a Director of EVC and EV;  Director
of Wright and Winthrop since February, 1997.
Address: 92 Reservoir Avenue, Chestnut Hill, MA 02467

JUDITH R. CORCHARD (61), Vice President and Trustee*
Executive Vice President, Senior Investment  Officer, Chairman of the Investmen
Committee and Director of Wright and Winthrop.  Ms. Corchard was appointed a
Trustee of the Trust on December 10, 1997.
Address: 440 Wheelers Farms Road, Milford, CT 06460

A.M. MOODY III (63), Vice President & Trustee*
Senior Vice President, Wright and Winthrop; President, Wright Investors' Service
Distributors, Inc.
Address: 440 Wheelers Farms Road, Milford, CT 06460

DORCAS R. HARDY (53), Trustee
President,  Dorcas R. Hardy & Associates  (a public  policy and  government
relations firm),  Spotsylvania,  VA; Director,  The Options Clearing Corporation
and First Coast  Service  Options,  Jacksonville,  FL (FL Blue Cross Blue Shield
subsidiary);  1996-1998 - Chairman and CEO of Work  Recovery,  Inc. (an advanced
rehabilitation  technology firm),  Tucson, AZ; 1986-1989 - U.S.  Commissioner of
Social Security. Ms. Hardy was elected a Trustee on December 9, 1998.
Address:  11407 Stonewall Jackson Drive Spotsylvania, VA  22553

LELAND MILES (76), Trustee
President  Emeritus,   University  of  Bridgeport   (1987-present);   President,
University of Bridgeport (1974-1987); Director, United Illuminating Company.
Address: 332 North Cedar Road, Fairfield, CT 06430
<PAGE>

LLOYD F. PIERCE (81), Trustee
Retired Vice Chairman (prior to 1984-President),  People's Bank, Bridgeport, CT;
Member, Board of Trustees,  People's Bank,  Bridgeport,  CT; Board of Directors,
Southern Connecticut Gas Company; Chairman, Board of Directors, COSINE.
Address: 140 Snow Goose Court, Daytona Beach, FL 32119

RICHARD E. TABER (51), Trustee
Chairman and Chief Executive Officer of First County Bank,  Stamford,  CT
(1989-present). Mr.Taber was appointed as a Trustee of the Trust on
March 18, 1997.
Address: 117 Prospect Street, Stamford, CT 06901

RAYMOND VAN HOUTTE (75), Trustee
President  Emeritus and Counselor of The Tompkins County Trust Co., Ithaca,
NY (since January 1989);  President and Chief  Executive  Officer,  The Tompkins
County Trust Company (1973-1988);  President, New York State Bankers Association
(1987-1988);  Director,  McGraw Housing Company,  Inc., Deanco, Inc., Evaporated
Metal Products and Ithaco, Inc.
Address: One Strawberry Lane, Ithaca, NY 14850

JAMES L. O'CONNOR (55), Treasurer
Vice President, Eaton Vance, BMR and EV. Officer of various investment companies
managed by Eaton Vance or BMR.
Address: 255 State Street, Boston, MA 02109

JANET E. SANDERS (64), Assistant Treasurer and Assistant Secretary
Vice President of Eaton Vance, BMR and EV. Officer of various investment
companies managed by Eaton Vance or BMR.
Address: 255 State Street, Boston, MA 02109

WILLIAM J. AUSTIN, JR. (48), Assistant Treasurer
Assistant  Vice  President of Eaton  Vance,  BMR and EV.  Officer of various
 investment  companies  managed by Eaton Vance or BMR. Mr.
Austin was elected Assistant Treasurer of the Trust on December 18, 1991.
Address: 255 State Street, Boston, MA 02109

A. JOHN MURPHY (37), Assistant Secretary
Vice President of Eaton Vance, BMR and EV since March 1, 1994; employee of Eaton
Vance since March 1993. Officer of various investment companies managed by Eaton
Vance or BMR. Mr.  Murphy was elected  Assistant  Secretary of the Trust on June
21, 1995.
Address: 255 State Street, Boston, MA 02109

ERIC G. WOODBURY (42), Assistant Secretary
Vice  President  of Eaton  Vance,  BMR and EV since  February  1993.  Officer of
various  investment  companies  managed by Eaton Vance or BMR. Mr.  Woodbury was
elected Assistant Secretary of the Trust on June 21, 1995.
Address: 255 State Street, Boston, MA 02109

     All of the Trustees and officers hold  identical  positions with The Wright
Managed Income Trust,  The Wright Managed Equity Trust,  The Wright Managed Blue
Chip Series Trust, Catholic Values Investment Trust, The Wright Asset Allocation
Trust, and The Wright Blue Chip Master Portfolio Trust. The fees and expenses of
those Trustees (Messrs.  Miles, Pierce, Taber, Van Houtte and Ms. Hardy) who are
not  "interested  persons" of the Trust and of Mr. Brigham are paid by the funds
and the other series of the Trust.  They also receive  additional  payments from
other  investment  companies  for  which  Wright  provides  investment  advisory
services.  The Trustees who are employees of Wright receive no compensation from
the  Trust.  The Trust does not have a  retirement  plan for its  Trustees.  For
Trustee  compensation from the Trust for the fiscal year ended December 31, 1999
and for the total compensation paid to the Trustees from the Wright Fund complex
for the fiscal year ended December 31, 1999, see the following table.
<PAGE>


                               COMPENSATION TABLE
                  Registrant - The Wright EquiFund Equity Trust

<TABLE>
<CAPTION>
                                        Aggregate Compensation            Pension          Benefits       Total Compensation
                                            From The Wright              Benefits           Annual          from Funds and
Trustees                                 EquiFund Equity Trust            Accrued        Benefit Paid       Fund Complex(1)
- ---------------------------------------------------------------------------------------------------------------------------------

<S>                                              <C>                      <C>                <C>               <C>

H. Day Brigham, Jr.                              $1,750                    None              None              $11,250
Dorcas Hardy                                      1,750                    None              None               11,250
Leland Miles                                      1,750                    None              None               11,250
Lloyd F. Pierce                                   1,750                    None              None               11,250
Richard E. Taber                                  1,750                    None              None               11,250
Raymond Van Houtte                                1,250                    None              None                8,250


- -----------------------------------------------------------------------------------------------------------------------------------


(1)  Total  compensation paid is from The Wright EquiFund Equity Trust (4 funds)
     and the other funds in the Wright  Fund  complex for a total of 22 funds as
     of December 31, 1999.
</TABLE>


     The Trust's  Board of Trustees has  established  an  Independent  Trustees'
Committee  and an Audit Committee, each consisting  of all of the  Independent
Trustees who are Messrs.  Miles,  Pierce  (Chairman),  Taber, Van Houtte and Ms.
Hardy. The responsibilities of the Independent Trustees' Committee include those
of a nominating  committee for additional or  replacement  trustees of the Trust
and a contract review committee for  consideration of renewals or changes in the
investment advisory agreements,  distribution  agreements and distribution plans
and other agreements as appropriate. The responsibilities of the Audit Committee
are: (a) to oversee the Trusts'  accounting and financial  reporting  practices,
their internal  controls and, as appropriate,  the internal  controls of certain
service  providers;  (b) to oversee the quality and  objectivity  of the Trusts'
financial  statements and the  independent  audit  thereof;  and (c) to act as a
liaison between the Trusts' independent auditors and the full Board of Trustees.




                 CONTROL PERSONS AND PRINCIPAL HOLDERS OF SHARES


     As of April 1, 2000,  the Trustees  and officers of the Trust,  as a group,
owned in the aggregate less than 1% of the  outstanding  shares of any fund that
was then offering its shares to the public.

     As of the same date, the following  shareholders were record holders of the
following  percentages  of the  outstanding  shares of the funds  that were then
offering shares to the public:

<TABLE>
<CAPTION>



                       PERCENT OF OUTSTANDING SHARES OWNED


NAME AND ADDRESS                              Hong Kong/China            Japan                Mexico            Netherlands
- ----------------------------------------------------------------------------------------------------------------------------------

<S>                                                <C>                   <C>                   <C>                 <C>
Charles Schwab & Co. Inc.*                         38.8%                 41.1%                 52.8%               52.9%
Attn: Suzanne Williamson
Mutual Funds Dept.
101 Montgomery St.
San Francisco, CA 94104
- ----------------------------------------------------------------------------------------------------------------------------------

National Investor Services Corp.                   27.8%                 25.8%                  6.4%                _
For the Exclusive Benefit of Our Customers
55 Water Street 32nd Floor
New York, NY 10041
- ----------------------------------------------------------------------------------------------------------------------------------

*Held on behalf of their clients.
</TABLE>

<PAGE>



                 INVESTMENT ADVISORY AND ADMINISTRATIVE SERVICES


     The funds have engaged Wright to act as their  investment  adviser pursuant
to an Investment  Advisory Contract.  Wright furnishes the funds with investment
advice and management services.  The School for Ethical Education,  440 Wheelers
Farms  Road,  Milford,  CT 06460,  may be  considered  a  controlling  person of
Wright's  parent,  Winthrop,  and Wright by reason of its ownership of more than
25% of the outstanding shares of Winthrop.


     Pursuant to the  Investment  Advisory  Contract,  Wright will carry out the
investment  and   reinvestment  of  the  assets  of  the  funds,   will  furnish
continuously  an investment  program with respect to the funds,  will  determine
which securities should be purchased, sold or exchanged, and will implement such
determinations.   Wright  will  furnish  to  the  funds  investment  advice  and
management  services,  office  space,  equipment  and  clerical  personnel,  and
investment advisory,  statistical and research facilities.  In addition,  Wright
has arranged for certain members of the Eaton Vance and Wright  organizations to
serve without  salary as officers or Trustees of the Trust.  In return for these
services, each fund is obligated to pay a monthly advisory fee calculated at the
rates set forth in the funds' current Prospectus.


     The investment adviser and each fund have adopted Codes of Ethics governing
personal securities transactions. Under the Codes, Wright employees may purchase
and sell securities subject to certain pre-clearance and reporting  requirements
and other  procedures.  These  Codes of  Ethics  are on public  file  with,  and
available from, the Securities and Exchange Commission.


     It should  be noted  that,  in  addition  to  compensating  Wright  for its
advisory  services to the funds,  the  advisory  fee is  intended  to  partially
compensate  Wright for the  maintenance  of the Indices which form the basis for
the  selection  of  securities  for the funds.  Other  mutual funds and accounts
advised by Wright may use the Indices as may other entities not affiliated  with
Wright.


     The following  table sets forth the net assets of each fund at December 31,
1999 and the  advisory  fee earned from each such fund  during the fiscal  years
ended December 31, 1999, 1998 and 1997.
<TABLE>
<CAPTION>


                                             Aggregate          Fee Earned for        Fee Earned for        Fee Earned for
                                           Net Assets at       Fiscal Year Ended     Fiscal Year Ended     Fiscal Year Ended
FUNDS                                        12/31/98              12/31/99              12/31/98              12/31/97
- ------------------------------------------------------------------------------------------------------------------------------------

<S>                                        <C>                   <C>                   <C>                  <C>
Hong Kong/China                            $ 5,558,491           $ 37,774(1)           $ 46,869(2)          $     97,167
Japan                                        6,190,006             31,243(1)             36,190(3)                79,721
Mexico                                       8,386,928             72,227(1)              103,799                229,596
Netherlands                                  8,696,201              106,449               123,437                 92,173
- -----------------------------------------------------------------------------------------------------------------------------------
<FN>

(1)  To enhance the net income of the Hong Kong/China,  Japan and Mexico series,
     Wright made a reduction in its  advisory fee by $22,774,  $31,243 and $950,
     respectively.  In addition, $4,530, $5,665 and $700 of expenses of the Hong
     Kong/China,  Japan and Mexico  series,  respective,  were  allocated to the
     investment adviser.

(2)  To  enhance  the net income of the Fund,  Wright  made a  reduction  of its
     investment  advisory fee by $27,221.  In addition,  $3,200 of expenses were
     allocated to the investment adviser.

(3)  To  enhance  the net income of the Fund,  Wright  made a  reduction  of its
     investment  advisory  fee by $22,412.  In addition,  $750 of expenses  were
     allocated to the investment adviser.
</FN>
</TABLE>

     The Trust has engaged Eaton Vance to act as the administrator for each fund
pursuant  to  an   Administration   Agreement.   For  its  services   under  the
Administration  Agreement,   Eaton  Vance  is  entitled  to  receive  a  monthly
administration   fee  from  each  fund.  The  following  table  sets  forth  the
administration  fees as a percentage  of average daily net assets for the fiscal
year ended  December  31, 1999 and the fees earned from each fund for the fiscal
years ended December 31, 1999, 1998 and 1997.

<TABLE>
<CAPTION>

                                   Fee Paid as a % of
                                Average Daily Net Assets        Fee Earned for        Fee Earned for        Fee Earned for
                                    Fiscal Year Ended          Fiscal Year Ended     Fiscal Year Ended     Fiscal Year Ended
FUNDS                                   12/31/99                   12/31/99              12/31/98              12/31/97
- -----------------------------------------------------------------------------------------------------------------------------------

<S>                                       <C>                      <C>                   <C>                   <C>
Hong Kong/China                           0.10%                    $ 5,063               $ 6,256               $12,954
Japan                                     0.10%                      4,194                 4,833                10,629
Mexico                                    0.10%                      9,643                13,837                30,613
Netherlands                               0.10%                     14,193                16,458                12,289
- -----------------------------------------------------------------------------------------------------------------------------------
</TABLE>
<PAGE>

     Eaton Vance is a business trust  organized under  Massachusetts  law. Eaton
Vance,  Inc.  ("EV")  serves as trustee of Eaton  Vance.  Eaton Vance and EV are
wholly  owned  subsidiaries  of Eaton  Vance  Corporation  ("EVC"),  a  Maryland
corporation and publicly held holding company.  EVC through its subsidiaries and
affiliates  engages  primarily  in  investment  management,  administration  and
marketing activities.

     Each fund will be responsible  for all expenses  relating to its operations
and not designated as expenses of Wright under the Investment  Advisory Contract
or of  Eaton  Vance  under  the  Administration  Agreement,  including,  without
limitation, the fees and expenses of its custodian and transfer agent, including
those  incurred  for  determining  each fund's net asset value and keeping  each
fund's  books;  the cost of share  certificates;  membership  dues in investment
company  organizations;  brokerage  commissions  and fees;  fees and expenses of
registering its shares;  expenses of reports to  shareholders,  proxy statements
and other expenses of shareholders' meetings;  insurance premiums;  printing and
mailing  expenses;  interest,  taxes and corporate  fees;  legal and  accounting
expenses;  expenses  of  Trustees  not  affiliated  with Eaton  Vance or Wright;
distribution  expenses incurred pursuant to the Trust's  distribution  plan; and
investment  advisory and administration  fees. Each fund will also bear expenses
incurred in  connection  with  litigation  in which the Trust is a party and the
legal  obligation the Trust may have to indemnify its officers and Trustees with
respect thereto.


     The Investment  Advisory  Contract of all the funds and the  Administration
Agreement  of all the funds will remain in effect until  February 28, 2001.  The
funds'  Investment  Advisory Contract may be continued with respect to each fund
from year to year  thereafter  so long as such  continuance  after  February 28,
2001,  as the case may be, is  approved at least  annually  (i) by the vote of a
majority of the Trustees who are not  "interested  persons" of the Trust,  Eaton
Vance or Wright cast in person at a meeting  specifically called for the purpose
of voting on such  approval and (ii) by the Board of Trustees of the Trust or by
vote of a majority of the  shareholders  of that fund. The  Investment  Advisory
Contract and Administration Agreement may be terminated as to a fund at any time
without  penalty on sixty (60) days' written  notice by the Board of Trustees or
Directors of either party, or by vote of the majority of the outstanding  shares
of that fund, and each agreement  will terminate  automatically  in the event of
its  assignment.  Each  agreement  provides  that,  in the  absence  of  willful
misfeasance,   bad  faith,   gross  negligence  or  reckless  disregard  of  its
obligations  or duties to the Trust  under such  agreement  on the part of Eaton
Vance or Wright.  Eaton  Vance or Wright will not be liable to the Trust for any
loss incurred.




                          CUSTODIAN AND TRANSFER AGENT

     Investors Bank & Trust Company ("IBT"),  200 Clarendon  Street,  Boston, MA
02116,  acts as  custodian  for the funds.  IBT has the  custody of all cash and
securities of the funds,  maintains the funds' general  ledgers and computes the
daily net asset  value per  share.  In such  capacity  it  attends to details in
connection  with the sale,  exchange,  substitution,  transfer or other dealings
with the funds'  investments,  receives  and  disburses  all funds and  performs
various other  ministerial  duties upon receipt of proper  instructions from the
funds.  The funds will employ  foreign  sub-custodians  in accordance  with Rule
17f-5 under the 1940 Act.


     PFPC,Inc.,P.O. Box 9697, Providence, RI 02940 is the funds' transfer agent.




                    INDEPENDENT CERTIFIED PUBLIC ACCOUNTANTS



    Deloitte & Touche LLP, 200 Berkeley  Street,  Boston,  MA 02116-5022 are the
Trust's independent certified public accountants,  providing audit services, tax
return  preparation,  and  assistance  and  consultation  with  respect  to  the
preparation  of  filings  with  the  Securities  and  Exchange   Commission  and
preparation of the funds' federal and state tax returns.




                              BROKERAGE ALLOCATION

     Purchases and sales of securities on a securities  exchange are effected by
brokers,  and  the  funds  pay a  brokerage  commission  for  this  service.  In
transactions  on stock  exchanges in the United States,  these  commissions  are
negotiated,  whereas on many foreign stock  exchanges the commissions are fixed.
In the over-the-counter market,  securities are normally traded on a "net" basis
with  dealers  acting  as  principal  for their  own  accounts  without a stated
commission,  although the price of the securities  usually  includes a profit to
the dealer. In underwritten offerings, securities are purchased at a fixed price
which includes an amount of compensation to the underwriter,  generally referred
to as the  underwriter's  concession  or discount.  On occasion,  certain  money
market  instruments may be purchased  directly from an issuer,  in which case no
commissions or discounts are paid.
<PAGE>

     Wright places the portfolio  security  transactions for each fund, which in
some cases may be effected in block  transactions  which include other  accounts
managed by Wright.  Wright  provides  similar  services  directly for bank trust
departments  and other  clients.  Wright  seeks to  execute  portfolio  security
transactions  on the  most  favorable  terms  and in the most  effective  manner
possible.  In seeking  best  execution,  Wright  will use its best  judgment  in
evaluating the terms of a transaction,  and will give  consideration  to various
relevant  factors,  including  without  limitation  the  size  and  type  of the
transaction,  the nature and  character  of the  markets for the  security,  the
confidentiality,  speed and  certainty of effective  execution  required for the
transaction,   the  reputation,   experience  and  financial  condition  of  the
broker-dealer and the value and quality of service rendered by the broker-dealer
in other  transactions,  and the  reasonableness of the brokerage  commission or
markup, if any.

     It is expected that on frequent  occasions there will be many broker-dealer
firms which will meet the foregoing  criteria for a particular  transaction.  In
selecting  among such  firms,  the funds may give  consideration  to those firms
which supply  brokerage and research  services,  quotations and  statistical and
other  information  to Wright for their use in servicing  their  accounts.  Such
brokers may include firms which purchase  investment  services from Wright.  The
term  "brokerage  and  research  services"  includes  advice  as to the value of
securities,  the advisability of investing in, purchasing or selling securities,
and the  availability  of securities  or  purchasers  or sellers of  securities;
furnishing  analyses and reports  concerning  issuers,  industries,  securities,
economic factors and trends, portfolio strategy and the performance of accounts;
and  effecting  securities  transactions  and  performing  functions  incidental
thereto (such as clearance and settlement). Such services and information may be
useful and of value to Wright in servicing  advisory clients other than the fund
which paid the  brokerage  commissions  and the other  funds.  The  services and
information  furnished  by a  particular  firm  may not  necessarily  be used in
connection  with the funds or the fund which paid brokerage  commissions to such
firm.  The  advisory  fee  paid by the  funds  to  Wright  is not  reduced  as a
consequence  of Wright's  receipt of such services and  information.  While such
services and  information  are not expected to reduce  Wright's  normal research
activities  and  expenses,  Wright  would,  through  use of  such  services  and
information,  avoid the  additional  expenses  which would be incurred if Wright
should attempt to develop  comparable  services and information  through its own
staff.

     Subject to the  requirement  that Wright use its best efforts to seek
to execute each fund's portfolio  security  transactions at advantageous  prices
and at reasonably  competitive  commission rates, Wright, as indicated above, is
authorized  to consider as a factor in the selection of any  broker-dealer  firm
with whom a fund's  portfolio  orders  may be placed the fact that such firm has
sold  or is  selling  shares  of the  funds  or of  other  investment  companies
sponsored  by Wright.  This  policy is  consistent  with a rule of the  National
Association of Securities Dealers,  Inc., which rule provides that no firm which
is a member of the  Association may favor or  disfavor  the  distribution  of
shares of any particular  investment company or group of investment companies on
the basis of  brokerage  commissions  received or expected by such firm from any
source.

     Under the funds' Investment Advisory Contract,  Wright has the authority to
pay commissions on portfolio  transactions  for brokerage and research  services
exceeding  that which other  brokers or dealers  might charge  provided  certain
conditions are met.

     The funds' Investment  Advisory Contract expressly  recognize the practices
which are provided for in Section 28(e) of the  Securities  Exchange Act of 1934
by  authorizing  the  selection  of a broker  or dealer  which  charges a fund a
commission  which is in excess of the  amount of  commission  another  broker or
dealer would have charged for effecting that  transaction if it is determined in
good faith that such  commission  was reasonable in relation to the value of the
brokerage and research services which have been provided.

     If  purchases  or sales of  securities  of the funds and one or more  other
investment  companies or clients supervised by Wright are considered at or about
the same time,  transactions  in such  securities  will be  allocated  among the
several investment  companies and clients in a manner deemed equitable to all by
Wright, taking into account the respective sizes of the funds, and the amount of
securities to be purchased or sold. It is recognized that it is possible that in
some cases this procedure could have a detrimental effect on the price or volume
of the security so far as the funds are concerned. However, in other cases it is
possible that the ability to participate in volume transactions and to negotiate
lower brokerage commissions will be beneficial to the funds.


     During the fiscal years ended  December 31, 1999,  1998 and 1997, the funds
paid the following amounts on brokerage commissions:

                               1999                  1998                  1997
- -------------------------------------------------------------------------------

     Hong Kong/China        $ 44,921              $102,746         $    94,968
     Japan                    24,406                69,966             164,620
     Mexico                   51,129                49,978             204,815
     Netherlands              56,231                82,246              32,190

- -------------------------------------------------------------------------------

<PAGE>


                              PRINCIPAL UNDERWRITER

     The Trust has adopted a Distribution  Plan (the "Plan") as described in the
Prospectus on behalf of the funds in  accordance  with Rule 12b-1 under the 1940
Act and the Rules of the NASD.

     The Trust has entered into a  distribution  contract on behalf of the funds
with WISDI,  providing for WISDI to act as a separate distributor of each fund's
shares.

     Under the Plan,  the President or Vice President of the Trust shall provide
to the  Trustees  for  their  review,  and the  Trustees  shall  review at least
quarterly,  a written  report  of the  amounts  expended  under the Plan and the
purposes for which such expenditures were made.

     The Plan was approved by the  Trustees on June 16,  1993.  Under its terms,
the Plan  remains in effect  from year to year,  provided  such  continuance  is
approved  annually  by a vote  of its  Trustees,  including  a  majority  of the
Trustees who are not  interested  persons of the Trust and who have no direct or
indirect  financial  interest in the operation of the Plan.  The Plan may not be
amended to increase materially the amount to be spent for the services described
therein as to a fund without  approval of a majority of the  outstanding  voting
securities  of that fund and all  material  amendments  of the Plan must also be
approved by the Trustees of the Trust in the manner  described  above.  The Plan
may be terminated  at any time as to a fund without  payment of any penalty by a
vote of a majority of the Trustees of the Trust who are not  interested  persons
of the  Trust  and who have no  direct or  indirect  financial  interest  in the
operation  of the  Plan or by  vote  of a  majority  of the  outstanding  voting
securities  of that fund.  So long as the Plan is in effect,  the  selection and
nomination  of  Trustees  who are not  interested  persons of the Trust shall be
committed to the discretion of the Trustees who are not such interested persons.
The  Trustees of the Trust have  determined  that in their  judgment  there is a
reasonable   likelihood   that  the  Plan  will  benefit  the  funds  and  their
shareholders.


     The following  table shows the fee payable to WISDI under the Plans and the
amount of such fee actually paid by each fund for the fiscal year ended December
31, 1999.

<TABLE>
<CAPTION>
                              Distribution          Distribution Expenses         Distribution        Distribution Expenses
                                Expenses               Reduced by the               Expenses         Paid as a % of Average
                                Allowable           Principal Underwriter         Paid By Fund           Net Asset Value
- ----------------------------------------------------------------------------------------------------------------------------------

<S>                              <C>                       <C>                            <C>                     <C>
Hong Kong/China                  $12,591                   $12,591                        $ 0                     0%
Japan                             10,414                    10,414                          0                     0%
Mexico                            23,934                     4,855                     19,079                  0.20%
Netherlands                       35,483                        -                      35,483                  0.25%
- ---------------------------------------------------------------------------------------------------------------------------------
</TABLE>


     For the fiscal year ended  December  31, 1999,  it is estimated  that WISDI
spent  approximately the following  amounts on behalf of the funds.  WISDI spent
more than it received on behalf of Hong Kong/China and Japan.


                  Wright Investors' Service Distributors, Inc.
                      Financial Summaries for the Year 1999

<TABLE>
<CAPTION>

                                          Printing &                         Commissions       Adminis-
                                            Mailing         Travel &          & Service         tration
FUNDS                   Promotional      Prospectuses     Entertainment         Fees           and Other           Total
- -----------------------------------------------------------------------------------------------------------------------------------

<S>                       <C>                <C>              <C>               <C>                <C>            <C>
Hong Kong/China           $ 1,637            $ 110            $ 100             $ 468              $ 201          $ 2,518
Japan                       1,353               92               83               387                166            2,082
Mexico                     12,401              839              763             3,548              1,526           19,079
Netherlands                23,064            1,561            1,419             6,600              2,838           35,483
- -----------------------------------------------------------------------------------------------------------------------------------
</TABLE>

<PAGE>



                        HOW THE FUNDS VALUE THEIR SHARES

     The  Trust  values  the  shares  of each fund once on each day the New York
Stock Exchange  ("NYSE") is open as of the close of regular  trading on the NYSE
(normally  4:00 p.m. New York time).  The net asset value is  determined  in the
manner authorized by the Trustees of the Trust by the funds' custodian (as agent
for the  funds)  with the  assistance  of Wright  for  securities  that  involve
valuation problems. Such determination is accomplished by dividing the number of
outstanding  shares of each fund into its net worth  (the  excess of its  assets
over its liabilities).

     Portfolio  securities  traded  on more  than  one  United  States  national
securities  exchange  or foreign  securities  exchange  are valued by the funds'
custodian  at the last sale price on the  business day as of which such value is
being determined at the close of the exchange  representing the principal market
for such  securities.  Securities  which cannot be valued at such prices will be
valued by Wright at fair  value in  accordance  with  procedures  adopted by the
Trustees. Foreign currencies,  options on foreign currencies and forward foreign
currency  contracts  will be valued at their last sales price as  determined  by
published quotations or as supplied by banks that deal in such instruments.  The
value of all assets and  liabilities  expressed  in foreign  currencies  will be
converted  into U.S.  dollar  value at the mean  between  the buying and selling
rates of such currencies  against U.S. dollars last quoted by any major bank. If
such  quotations are not  available,  the rate of exchange will be determined in
good faith by or under procedures established by the Trustees. Securities traded
over-the-counter,  unlisted  securities and listed  securities for which closing
sale  prices are not  available  are valued at the mean  between  latest bid and
asked  prices  or, if such bid and asked  prices  are not  available,  at prices
supplied by a pricing agent selected by Wright, unless such prices are deemed by
Wright not to be representative of market values at the close of business of the
NYSE.  Securities  for  which  market  quotations  are  unavailable,  restricted
securities,  securities  for  which  prices  are  deemed  by  Wright  not  to be
representative of market values and other assets will be appraised at their fair
value as determined in good faith  according to  guidelines  established  by the
Trustees of the Trust. Short-term obligations with remaining maturities of sixty
days or less are valued at amortized  cost,  which the Trustees have  determined
approximates market value. Options traded on exchanges and over-the-counter will
be valued at the last  current  sales  price on the market  where such option is
principally  traded.  Over-the-counter  and listed options for which a last sale
price is not  available  will be valued on the basis of  quotations  supplied by
dealers who regularly trade such options of if such quotations are not available
or deemed by Wright not to be representative of market values, at fair value.

     Trading in securities on European and Far Eastern securities  exchanges and
over-the-counter markets is normally completed well before the close of business
on each  business  day in New York  (i.e.,  a day on which  the NYSE is open for
trading).  In addition,  European or Far Eastern securities trading generally or
in a particular  country or countries may not take place on all business days in
New York.  Furthermore,  trading  takes  place in  Japanese  markets  on certain
Saturdays and in various  foreign markets on days which are not business days in
New York and on which the  funds'  net asset  values  are not  calculated.  Such
calculation does not take place  contemporaneously with the determination of the
prices of the majority of the  portfolio  securities  used in such  calculation.
Events affecting the values of portfolio  securities that occur between the time
their prices are determined and the close of the NYSE will not be reflected in a
fund's  calculation  of net asset value unless Wright deems that the  particular
event would materially affect net asset value, in which case the securities will
be valued at their  fair  value  according  to  procedures  decided  upon by the
Trustees.



                             PERFORMANCE INFORMATION

     The average  annual total return of each fund is determined for a specified
period by calculating the actual dollar amount of investment  return on a $1,000
investment  in the fund made at the  maximum  public  offering  price (net asset
value)  at  the  beginning  of the  period,  and  then  calculating  the  annual
compounded  rate of return which would  produce that amount.  Total return for a
period of one year is equal to the actual return of the fund during that period.
This calculation  assumes that all dividends and distributions are reinvested at
net asset value on the reinvestment dates during the period.

     The average  annual total  return will be  calculated  using the  following
formula:
                                        n
                                P (1 + T) = ERV

where:   P      =   A hypothetical initial payment of $1,000
         T      =   Average annual total return
         n      =   Number of years
         ERV    =   Ending redeemable value of a hypothetical $1,000 payment
                    at the end of the period.

     Each fund's  yield is computed by dividing  its net  investment  income per
share  earned  during a recent  thirty-day  period by the product of the average
daily number of shares  outstanding and entitled to receive dividends during the
period and the maximum  offering  price (net asset  value) per share on the last
day of the period. The results are compounded on a bond equivalent (semi-annual)
basis and then they are annualized.  Net investment income per share is equal to
the fund's  dividends and interest earned during the period,  reduced by accrued
expenses for the period.
<PAGE>

     The  yield  earned  by each fund  will be  calculated  using the  following
formula:
                         6
YIELD =  2  [ ( a-b  +  1) -  1 ]
                ---
                cd

where:   a    =   Dividends and interest earned during the period
         b    =   Expenses accrued for the period (after reductions)
         c    =   The average  daily number of shares  outstanding  during the
                  period that were entitled to receive  dividends
         d    =   The maximum offering price(net asset value) per share on the
                  last day of the period.

     A fund's yield or total return may be compared to the Consumer  Price Index
and various  domestic or foreign  securities  indices.  A fund's  yield or total
return and comparisons with these indices may be used in  advertisements  and in
information furnished to present or prospective shareholders.

     From time to time,  evaluations of a fund's performance made by independent
sources may be used in advertisements and in information furnished to present or
prospective  shareholders.   These  may  include  rankings  prepared  by  Lipper
Analytical Services, Inc., an independent service which monitors the performance
of mutual funds. The Lipper  performance  analysis  reflects the reinvestment of
dividends  and capital gain  distributions  but does not take sales charges into
consideration and is prepared without regard to tax consequences.


     The following table shows the average annual total return for the one year,
three year,  five year and life of fund (as  applicable)  for the periods  ended
December 31, 1999:
<TABLE>
<CAPTION>

FUNDS                                    One Year      Three Years        Five Years     Inception of Fund     Date of Fund
- ----------------------------------------------------------------------------------------------------------------------------------

<S>                                        <C>              <C>               <C>               <C>               <C>
Hong Kong/China                            51.03%          -3.68%             3.05%             6.03%             6/28/90
Japan                                     102.91%          22.39%             8.66%             6.92%             2/14/94
Mexico                                     60.91%          12.89%             4.09%            -3.08%             8/02/94
Netherlands                                -4.39%          11.20%            17.36%            10.46%             6/28/90

- -----------------------------------------------------------------------------------------------------------------------------------
</TABLE>


                                      TAXES

     Among  the  requirements  for  qualification  of each  fund as a  regulated
investment  company  are the  following:  (1) at least 90% of the  fund's  gross
income for the taxable year must be derived from interest, dividends, gains from
the sale or other  disposition of stock or securities and certain other types of
income and (2) at the close of each  quarter of its taxable  year,  (a) at least
50% of the value of the fund's  assets must be  comprised of cash and cash items
(including  receivables),  U.S.  Government  securities,   securities  of  other
regulated  investment  companies and other securities  limited in respect of any
one issuer to not more than 5% of the value of the fund's total  (gross)  assets
and not more than 10% of the voting  securities  of such issuer and (b) not more
than  25% of the  value of its  total  (gross)  assets  may be  invested  in the
securities  of any  one  issuer  (other  than  U.S.  Government  securities  and
securities  of other  regulated  investment  companies) or certain other issuers
controlled  by the fund.  These  requirements  may limit a fund's  activities in
foreign  currencies and foreign currency  forward  contracts to the extent gains
relating to such  activities are  considered not directly  related to the fund's
principal business of investing in securities or to the extent the sizes of such
positions are limited by these tax diversification requirements.

     Each fund's use of the accounting practice known as equalization may affect
the amount, timing and character of distributions to shareholders. Investment by
a fund in a stock of a "passive foreign  investment  company" may cause the fund
to recognize income prior to the receipt of distributions from such a company or
to become subject to tax upon the receipt of certain excess  distributions from,
or upon  disposition  of its stock of, such a company,  although an election may
generally  be  available  for  taxable  years  beginning  after  1997 that would
ameliorate some of these adverse tax consequences.
<PAGE>

     A fund's transactions in foreign currencies,  foreign  currency-denominated
debt securities,  foreign currency forward contracts and receivables or payables
denominated in a foreign currency are subject to special tax rules under Section
988 of the  Code  which  will  generally  cause  gains  and  losses  from  these
transactions to be treated as ordinary income and losses. Certain positions held
by a fund may be  required  to be "marked to  market"  (treated  as if they were
closed out) on the last business day of each taxable year, and any  constructive
sales of certain  appreciated  financial  positions may also require the current
recognition  of the gain in such  positions.  In  addition,  if certain of these
positions held by the fund  substantially  diminish the fund's risk of loss with
respect  to  securities  or  other  positions  in  the  fund's  portfolio,  this
combination  of positions may be treated as a straddle for tax purposes with the
possibility  of deferral  of losses and  adjustments  in the  holding  period of
securities or other positions held by the fund.

     In order to avoid  federal  excise tax,  each fund must  distribute  (or be
deemed  to have  distributed)  by  December  31 of each year at least 98% of its
ordinary  income  for such  year,  at least 98% of the  excess  of its  realized
capital gains over its realized capital losses for the one-year period ending on
October  31 of  such  year,  after  reduction  by  any  available  capital  loss
carryforwards,  and 100% of any income and capital gains from the prior year (as
previously  computed)  that was not paid out  during  such year and on which the
fund paid no federal income tax.

     Special  tax  rules  apply  to  IRA  and  other  retirement  plan  accounts
(including  penalties on certain  distributions  and other  transactions) and to
other special classes of investors, such as tax-exempt  organizations,  banks or
insurance  companies.  Investors  should  consult  their tax  advisers  for more
information.

     Redemptions  (including exchanges) and other dispositions of fund shares in
transactions that are treated as sales for tax purposes will generally result in
the recognition of taxable gain or loss by shareholders that are subject to tax.
Shareholders  should  consult  their own tax  advisers  with  reference to their
individual   circumstances  to  determine  whether  any  particular  redemption,
exchange or other  disposition of fund shares is properly  treated as a sale for
tax purposes, as this discussion assumes. Any loss realized upon the redemption,
exchange  or other  sale of shares of a fund  with a tax  holding  period of six
months or less will be treated as a long-term  capital loss to the extent of any
distributions  of long-term  capital gains  designated as capital gain dividends
with  respect  to such  shares.  All or a portion  of a loss  realized  upon the
redemption,  exchange or other sale of fund shares maybe  disallowed under "wash
sale"  rules to the  extent  shares of the same fund are  purchased  within  the
period  beginning  30 days  before  and  ending  30 days  after the date of such
redemption, exchange or other sale.

     Capital loss carryforwards will reduce the applicable fund's taxable income
arising from future net realized  capital gains,  if any, to the extent they are
permitted to be used under the Code and applicable Treasury regulations prior to
their  expiration  dates,  and  thus  will  reduce  the  amounts  of the  future
distributions  to  shareholders  that would  otherwise  be necessary in order to
relieve that fund of liability for federal income tax.


     As of December 31, 1999, the funds,  for federal  income tax purposes,  had
capital loss carryovers expiring as follows:
<TABLE>
<CAPTION>

Dec.    Hong Kong/China              Japan                    Mexico                  Netherlands
- -----------------------------------------------------------------------------------------------------------------------

<S>     <C>                        <C>                      <C>                              <C>
2003    $     -                    $ 693,828                $1,285,657                       $ -
2005          -                    1,302,416                        -                          -
2006     1,982,849                   997,042                        -                      20,220

- --------------------------------------------------------------------------------------------------------------------------
</TABLE>




                              FINANCIAL STATEMENTS

     The audited financial  statements of, and the independent  auditors' report
for the funds,  appear in the funds' most recent annual report to  shareholders,
and are incorporated by reference into this Statement of Additional Information.
A copy of the  annual  report  is  attached  to  this  Statement  of  Additional
Information.


     Registrant  incorporated by reference the audited financial information for
the funds for the fiscal  year  ended  December  31,  1999 as  previously  filed
electronically  with the Securities and Exchange Commission on February 22, 2000
(Accession Number 0000715165-00-000008).


<PAGE>
                                    APPENDIX

===============================================================================


                             INFORMATION CONCERNING
                         THE NATIONS IN WHICH THE FUNDS
                                   WILL INVEST



     The Funds will invest in securities quoted or denominated in the currencies
of countries other than the United States. The following  summaries are designed
to provide a general  discussion  of economic  and other  conditions  in each of
these  countries.  The  information  in these  summaries  has been  derived from
sources  that  Wright  believes  to be  reliable,  but the  data  has  not  been
independently verified.

     International investments,  like many things, have both benefits and risks.
The   benefits   can  be  quite   substantial.   One  of  the  key  benefits  is
diversification,  as the correlation among  international  securities tend to be
much lower than the  correlation  among  securities  within any single  country.
There are also risks to be  considered.  Investors in any single  country should
understand  the economic  potential of  investments in such a country as well as
the relationship of the currency of that country to the investor's own currency.
Several other items must be considered by the investor including the reliability
of  information   about  the  various   companies  within  the  country,   legal
restrictions,  and the  economic and social  characteristics  that are unique to
each  country.  See Appendix A in the Statement of  Additional  Information  for
additional economic and financial information about countries in which the Funds
may invest.  The Wright  EquiFunds limit their  investment  consideration to the
world's   major   industrialized   nations  and  to  those   nations  for  which
WORLDSCOPE(R),  the information  database of Wright  Investors'  Service,  Inc.,
provides comprehensive and reliable investment information.



                      Political and Economic Considerations


     Potential  international  investors must be aware of political and economic
actions that might change the investment environment.  For example, the union of
11  nations  under  one  currency,  the euro,  as of  January  1,  1999  created
uncertainty as to currency valuations,  economic policies and inflation.  At the
same time,  the euro holds out the promise of stronger  growth for an integrated
Europe.  Likewise,  Hong  Kong's  reunification  with China in July 1997  raised
significant  questions as to the  sustainability  of Hong Kong's strong economic
performance  within a greater  China.  However,  Wright  believes  that European
economic  integration  offering  substantial  long-term economic benefits to the
member nations will ultimately come to pass.



                       Restrictions on Foreign Investment


     Another issue that must be addressed by global investors is the possibility
of investment  restrictions.  Some countries  impose  restrictions on foreigners
investing in their country.  These  restrictions may limit the amount of foreign
investment or in some cases create a separate  class of securities  which may be
purchased by foreigner  investors at a different  price from similar  securities
purchased by domestic  investment.  The countries in which the Funds will invest
do  not  impose  restrictions  on  portfolio  investments  although  Sweden  and
Switzerland  do have two classes of shares (see below) while Sweden and Japan do
have some special  regulations  which the Fund must comply with. Other potential
pitfalls  to  foreign  investment  include  high  transaction  costs,  including
brokerage fees, stock turnover taxes,  exchange rates, and miscellaneous  costs.
These vary widely by type of investment and by country.  Consideration must also
be given to withholding  taxes. Most countries levy  non-refundable  withholding
taxes on  interest  and  dividend  income  earned by  non-residents  on domestic
investments.  The  withholding tax rates disclosed below are subject to changes.
While the existence of  reciprocal  tax treaties  between many  countries may to
some extent mitigate that impact,  such treaties are frequently not available to
institutions  such as open-ended  mutual funds. Note that unlike in the U.S. and
Canada, where dividends are generally paid quarterly,  dividends in most nations
are paid only once (annually) or twice  (semi-annually) a year. Liquidity or the
ability of an investor to dispose of his or her holdings quickly at a reasonable
cost may be a special concern with foreign  investments.  Sometimes there may be
difficulties  involved in selling instruments in those countries where secondary
markets are not broad or actively  traded.  Political or sovereign risk is still
another  concern.  This  addresses the issue of whether the  government may take
action  that would  reduce the value of an  investor's  assets.  The  industrial
nations  involved with the Funds are basically stable and, except as noted under
Political and Economic Considerations above, it is not believed that there would
be a significant change due to an election or revolution.
<PAGE>

     The size of the markets is another concern.  In December of 1999, the world
equity market was valued at nearly 25 trillion U.S. dollars. The world market is
dominated by the U.S. ($12 trillion), Europe ($7 trillion), Japan ($3 trillion),
other Pacific ($0.8 trillion) and other Americas ($0.7 trillion). Following is a
table summarizing the market capital,  total return performance,  price/earnings
ratios and normal settlement time of markets of interest currently.

<TABLE>
<CAPTION>

                                          1997          1998         1999
                                          FTSE          FTSE         FTSE         1999
                            Market      National      National     National     Dividend
      MARKET                Capital      Return        Return       Return        Yield      SETTLEMENT
                              (1)          (2)           (2)          (2)          (2)
- --------------------------------------------------------------------------------------------------------------------------------

<S>                            <C>        <C>            <C>        <C>           <C>       <C>
      Hong Kong/China          $327      -27.2%         -9.1%       57.3%         2.4%       Next business day
      Japan                  $3,418      -25.5%          6.5%       72.2%         0.6%       Three business days
      Mexico                   $105       49.8%        -35.4%       92.3%         1.2%       Two business days, see note (3)
      Netherlands              $560       24.8%         32.0%        8.7%         1.7%       Within 10 days

- -----------------------------------------------------------------------------------------------------------------------------------
<FN>

   (1)  Billions  of U.S. $.  Estimated  by FTSE  International  on the basis of
        approximately 2,200 securities in 29 national indices.

   (2)  Total return measured in U.S. $.  Dividend yield at year-end 1999.

   (3)  For Exchange Traded Securities.

</FN>
</TABLE>
<PAGE>

                                COUNTRY SUMMARIES

===============================================================================



HONG KONG is situated  at the  southeastern  tip of China.  A total area of just
1,100 square kilometers covers Hong Kong Island, Kowloon and the New Territories
and Islands. The population is about 6.7 million.  English and Cantonese are the
languages  of  commerce.  Textiles,  apparel,  telecommunications,  real estate,
financing,  construction are the chief industries. Hong Kong dollar is the legal
tender  and has been  linked to the US dollar at the rate of  HK$7.75 to US$1.00
since 1983.

     On July  1997,  Hong  Kong  became a Special  Administrative  Region of the
People's  Republic of China.  Under the agreement between the United Kingdom and
China  that  led to  the  change  in  sovereignty,  China  committed  itself  to
preserving  "Hong  Kong's way of life" for the next 50 years.  This is seen as a
guarantee that protects Hong Kong's capitalist  system.  While Hong Kong used to
be a low-cost  manufacturing  center, it has abdicated this role to the southern
provinces  of China  and  beyond in favor of  turning  itself  into the  primary
financial center of China and South East Asia. Indeed, most of the trade between
China and the rest of the world now flows through Hong Kong. Hong Kong's economy
is  increasingly a service  economy that has achieved a high standard of living.
Recent statistics  indicate a per capita GDP at constant (1995) market prices of
US$23,950 in 1997.


JAPAN is located in the Archipelago off the east coat of Asia. The population is
estimated to be 125.6 million. Major cities are Tokyo, Yokohama,  Osaka, Nagoya,
Kyoto, Sapporo and Kobe. Electrical and electronic equipment,  autos,  machinery
and  chemical  are the  chief  industries.  The  currency  is the  Japanese  Yen
(December 1999: JPY 102.1 = $1U.S.).  The Gross Domestic  Product (1995 constant
price) was $5,391  billion in 1997, or about $42,700 per capita.  The 1997 trade
balance was positive $89 billion.


MEXICO forms the southernmost part of the North American continent together with
Canada and the  United  States of  America.  Due to its  geographical  location,
Mexico  experiences a variety of climate extremes.  The terrain ranges from arid
deserts to year round  snow-covered  areas.  Its capital is Mexico  City;  other
large cities include Guadalajara and Monterrey.  These three metropolitan cities
make up 2% of the national territory,  and house 25% of the country's nearly 100
million people. The official language is Spanish;  however,  English is commonly
used for  international  business.  1997 Gross Domestic Product (GDP) totaled US
$323 billion (1995 constant U.S. dollars), the 16th largest worldwide. Principal
natural resources are silver,  petroleum and oil. Mexico is the world's foremost
producer of silver. Steel,  chemicals,  electric goods, textiles and tourism are
important  industries.  The national  currency of Mexico is the Peso,  which was
valued at MP 9.475 = USD 1 on December 31, 1999.

     Under its Political Constitution,  Mexico is a democratic republic governed
by three branches of power:  executive,  legislative  and judicial.  The country
consists of 31 free, sovereign states.  There is one federal district,  the seat
of the executive,  located in the nation's capital. The President is the head of
government  and chief of state.  The president of Mexico,  for the six-year term
from  1994 to  2000,  is Dr.  Ernesto  Zedillo  Ponce de  Leon.  (Elections  are
scheduled for July 2000.)

     La Bolsa Mexicana de Valores,  or The Mexico Stock Exchange,  is located in
Mexico  City.  The  first  organized  securities  market in the  country  (Bolsa
Nacional de Mexico) was founded in 1894.  Trading has been halted twice  briefly
in the  meantime,  once  during the  Revolution  and again as a result of global
financial  difficulties following World War One. The majority of transactions on
the Exchange are accomplished  through "open outcry."  Securities have gradually
been converted to a computerized  trading system which began in October of 1997.
Capital gains earned on shares are tax exempt,  while dividends are subject to a
10% withholding tax.


NETHERLANDS is located in  northwestern  Europe on the North Sea. The population
is estimated to be 15.6 million. Major cities are Amsterdam,  Rotterdam & Hague.
Metals,  machinery,  chemicals, oil refinery,  diamond cutting,  electronics and
tourism are the chief  industries.  The language spoken is Dutch. Most people in
business also speak English.  The currency is the Dutch Guilder  (December 1999:
NLG2.189 = $1 U.S.),  but as of January.  1, 1999,  the guilder was fixed in the
euro at NLG2.203751 = EUR1.00.  The Gross Domestic Product (1995 constant price)
was $424 billion in 1997, or about $27,175 per capita. The trade balance for the
latest  12 months  was  positive  $12  billion.  Netherlands  is a member of the
European Union.

<PAGE>



                                     PART C
                                ------------------
                                Other Information


Item 23. Exhibits

         (a)  (1) Declaration  of Trust  dated July 14, 1989 as Amended and
                  Restated   December  20,  1989  filed  as  Exhibit  (1)(a)  to
                  Post-Effective  Amendment  No. 9 filed  October  13,  1995 and
                  incorporated herein by reference.
              (2) Amendment  to the  Declaration  of Trust  dated April 13, 1995
                  filed as  Exhibit  (1)(b) to  Post-Effective  Amendment  No. 9
                  filed October 13, 1995 and incorporated herein by reference.
              (3) Amended and Restated  Establishment  and Designation of Series
                  dated   December   9,  1998   filed  as   Exhibit   (a)(3)  to
                  Post-Effective  Amendment  No.  16 on  February  24,  1999 and
                  incorporated herein by reference.

         (b)  By-laws  dated  July 14,  1989  filed as  Exhibit  (2) to
              Post-Effective  Amendment  No. 9 filed  October  13,  1995 and
              incorporated herein by reference.

         (c)  Not Applicable

         (d)  (1) Investment  Advisory  Contract between the Registrant and
                  Wright  Investors'  Service,  Inc. dated September 23, 1998
                  filed as Exhibit (d)(1) to Post-Effective Amendment No. 16
                  on February 24, 1999 and incorporated herein by reference.
              (2) Amended  and  Restated  Administration  Agreement  between the
                  Registrant and Eaton Vance  Management  dated February 1, 1998
                  filed as Exhibit  (5)(b) to  Post-Effective  Amendment  No. 15
                  filed April 30, 1998 and incorporated herein by reference.

         (e)  Distribution Contract dated March 23, 1990 filed as Exhibit (6) to
              Post-Effective   Amendment  No.  9  filed  October  13,  1995  and
              incorporated herein by reference.

         (f)  Not Applicable

         (g)  (1) Custodian  Agreement  with  Investors Bank & Trust Company
                  dated December 19, 1990 filed as Exhibit (8) to Post-Effective
                  Amendment No. 9 filed October 13, 1995 and incorporated herein
                  by reference.
              (2) Amendment  dated  September  20,  1995  to  Master   Custodian
                  Agreement filed as Exhibit (8)(b) to Post-Effective  Amendment
                  No. 10 filed  February  29,  1996 and  incorporated  herein by
                  reference.
              (3) Amendment  dated  September  24,  1997  to  Master   Custodian
                  Agreement filed as Exhibit (g)(3) to Post-Effective  Amendment
                  No.  16 on  February  24,  1999  and  incorporated  herein  by
                  reference.

         (h)  Not Applicable

         (i)  (1) Opinion of Counsel  dated  April 7, 1998 filed as Exhibit
                  10 to  Post-Effective  Amendment  No. 15 and  incorporated
                  herein by reference.
              (2) Consent of Counsel filed herewith.

         (j)  Consent of Independent Auditors filed herewith.

         (k)  Not Applicable

         (l)  Agreement  with  Wright  Investors'  Service in  consideration  of
              providing initial capital dated December 20, 1989 filed as Exhibit
              (13) to Post-Effective  Amendment No. 9 filed October 13, 1995 and
              incorporated herein by reference.
<PAGE>

         (m)  (1) Amended Distribution Plan pursuant to Rule 12b-1 under the
                  Investment  Company  Act of 1940  dated  July 7, 1993 filed as
                  Exhibit  (15)(a)  to  Post-Effective  Amendment  No.  9  filed
                  October 13, 1995 and incorporated herein by reference.
              (2) Agreement   Relating   to   Implementation   of  the   Amended
                  Distribution  Plan dated July 7, 1993 filed as Exhibit (15)(b)
                  to  Post-Effective  Amendment No. 9 filed October 13, 1995 and
                  incorporated herein by reference.

         (n)  Not Applicable

         (o)  Not Applicable

         (p)  (1) Power of  Attorney  dated  March 26, 1998 filed as Exhibit
                  17(a) to Post-Effective  Amendment No. 15 filed April 29, 1998
                  and incorporated herein by reference.
              (2) Power of  Attorney  dated  December  9, 1998  filed as Exhibit
                  (p)(2) to Post-Effective Amendment No. 16 on February 24, 1999
                  and incorporated herein by reference.

         (q)  Codes of Ethics filed herewith.


Item 24.  Persons Controlled by or under Common Control with Registrant

     Not Applicable



Item 25.  Indemnification

The  Registrant's  By-Laws filed as Exhibit No. 2 to  Post-Effective
Amendment No. 9 contain  provisions  limiting the liability,  and
providing for indemnification, of the Trustees and officers under certain
circumstances.

Registrant's  Trustees  and  officers  are insured  under a standard investment
company errors and omissions insurance  policy covering loss incurred by reason
of negligent errors and omissions committed in their capacities as such.


Item 26.  Business and Other Connections of Investment Adviser

Reference is made to the information set forth under the captions "Officers and
Trustees"  and  "Investment  Advisory  and  Administrative   Services"  in  the
Statements of Additional Information,  which information is incorporated herein
by reference.


Item 27.  Principal Underwriter

     (a) Wright  Investors' Service  Distributors,  Inc. (a  wholly-owned
         subsidiary of The Winthrop  Corporation)  acts as principal
         underwriter for each of the investment companies named below.


                         The Wright Managed Equity Trust
                         The Wright Managed Income Trust
                        The Wright EquiFund Equity Trust
                        Catholic Values Investment Trust
                        The Wright Asset Allocation Trust
<PAGE>
<TABLE>
<CAPTION>

                 <S>                                    <C>                                      <C>
     (b)
                 (1)                                     (2)                                    (3)
         Name and Principal                     Positions and Offices                  Positions and Offices
          Business Address                   with Principal Underwriter                   with Registrant
- -------------------------------------------------------------------------------------------------------------------------------

          A. M. Moody  III*                           President                     Vice President and Trustee
          Peter M. Donovan*                 Vice President and Treasurer               President and Trustee
          Vincent M. Simko*                 Vice President and Secretary                       None

- ---------------------------------------------------------------------------------------------------------------------------------

                    * Address is 440 Wheelers Farms Road, Milford, CT 06460
</TABLE>


     (c) Not Applicable.


Item 28.  Location of Accounts and Records

All applicable  accounts,  books and documents  required to be maintained by the
Registrant by Section 31(a) of the Investment  Company Act of 1940 and the Rules
promulgated  thereunder are in the  possession  and custody of the  registrant's
custodian,  Investors Bank & Trust Company,  200 Clarendon  Street,  Boston,  MA
02116, and its transfer agent, PFPC, Inc., 4400 Computer Drive, Westborough,  MA
01581-5120,  with the  exception of certain  corporate  documents  and portfolio
trading  documents  which  are  either  in the  possession  and  custody  of the
Registrant's administrator, Eaton Vance Management, 255 State Street, Boston, MA
02109  or of the  investment  adviser,  Wright  Investors'  Service,  Inc.,  440
Wheelers  Farms  Road,  Milford,  CT  06460.  Registrant  is  informed  that all
applicable accounts, books and documents required to be maintained by registered
investment   advisers  are  in  the  custody  and  possession  of   Registrant's
administrator,  Eaton Vance  Management,  or of the investment  adviser,  Wright
Investors' Service, Inc.


Item 29.  Management Services

Not Applicable


Item 30.  Undertakings

     (a) Registrant  undertakes to comply with Section  16(c) of the  Investment
         Company Act of 1940, as amended,  which relates to the assistance to be
         rendered to shareholders by the Trustees of the Registrant in calling a
         meeting of shareholders  for the purpose of voting upon the question of
         the removal of a Trustee.

     (b) The  annual  report  also  contains  performance   information  and  is
         available to any recipient of the  Prospectus  upon request and without
         charge by writing to the Wright Investors' Service Distributors,  Inc.,
         440 Wheelers Farms Road, Milford, CT 06460.



<PAGE>


                                   Signatures

     Pursuant  to  the  requirements  of the  Securities  Act of  1933  and  the
Investment  Company Act of 1940, the  Registrant  certifies that it meets all of
the  requirements  for  effectiveness  of  this  Amendment  to the  Registration
Statement  pursuant to Rule 485(b) under the Securities Act of 1933 and has duly
caused this Amendment to the  Registration  Statement to be signed on its behalf
by the undersigned,  thereunto duly authorized,  in the City of Bridgeport,  and
the State of Connecticut on the 26th day of April, 2000.

                                             The Wright EquiFund Equity Trust

                                          By:      Peter M. Donovan*
                                             ----------------------------------
                                                   Peter M. Donovan, President


Pursuant to the requirements of the Securities Act of 1933, this  Post-Effective
Amendment to the  Registration  Statement has been signed below by the following
persons in the capacities and on the 26th day of April, 2000.

SIGNATURE                                           TITLE
- -------------------------------------------------------------------------------

Peter M. Donovan*                             President, Principal
- -------------------                          Executive Officer & Trustee
Peter M. Donovan

James L. O'Connor*                             Treasurer, Principal
- -------------------                         Financial and Accounting Officer
James L. O'Connor

H. Day Brigham, Jr.*                                  Trustee
- --------------------
H. Day Brigham, Jr.

Judith R. Corchard*                                   Trustee
- ---------------------
Judith R. Corchard

Dorcas R. Hardy*                                      Trustee
- ------------------
Dorcas R. Hardy

Leland Miles*                                         Trustee
- ------------------
Leland Miles

/s/A. M. Moody III                                    Trustee
- ------------------
A. M. Moody III

Lloyd F. Pierce*                                      Trustee
- ------------------
Lloyd F. Pierce

Richard E. Taber*                                     Trustee
- ------------------
Richard E. Taber

Raymond Van Houtte*                                   Trustee
- --------------------
Raymond Van Houtte

By /s/ A. M. Moody III
- ----------------------
A. M. Moody III
Attorney-in-Fact



<PAGE>


                                  Exhibit Index

     The  following exhibits are filed as part of this amendment to the
Registration Statement pursuant to Rule 483 of Regulation C.

Exhibit No.           Description
- ------------          -------------

      (i) (2)         Consent of Counsel

      (j)             Consent of Independent Auditors

      (q)             Codes of Ethics





                                Hale and Dorr LLP
                               Counsellors At Law
                                 60 State Street
                           Boston, Massachusetts 02109
                         617-526-6000   FAX 617-526-5000


                                                          April 25, 2000



Securities and Exchange Commission
450 Fifth Street
Washington, D.C.  20549

         Re:      Post-Effective Amendment No. 18 to the Registration
                  Statement of The Wright EquiFund Equity Trust (Trust)
                  File Nos. 33-30085; 811-5866 (PEA no. 18)
                  -------------------------------------------------------

Gentlemen:

     Hale and Dorr LLP hereby  consents to the  incorporation  by reference into
PEA no. 18 of its opinion,  dated April 7, 1998,  filed with the  Securities and
Exchange  Commission  on April 30,  1998,  as exhibit  no. 10 to  post-effective
amendment no. 15.

     The consent  may not be used for any purpose  other than as set forth above
without our further consent.


                                                         Very truly yours,

                                                      /s/Hale and Dorr LLP

                                                         Hale and Dorr LLP




                                                                  EXHIBIT j

                          Independent Auditors' Consent


     We  consent  to the  incorporation  by  reference  in  this  Post-Effective
Amendment No. 18 to the  Registration  Statement of The Wright  EquiFund  Equity
Trust  (1933  Act File No.  33-30085)  on  behalf of the  Wright  EquiFund  Hong
Kong/China Series,  Wright EquiFund Japan Series, Wright EquiFund Mexico Series,
and Wright  EquiFund  Netherlands  Series of our report dated  February 4, 2000,
relating to the Series referenced above,  which report is included in the Annual
Report to Shareholders for the year ended December 31, 1999, in the Statement of
Additional Information which is part of such Registration Statement.

     We also consent to the  reference to our Firm under the heading  "Financial
Highlights"  in the  Prospectus  and under the  caption  "Independent  Certified
Public Accountants" in the Statement of Additional Information.


/s/ Deloitte & Touche LLP
DELOITTE & TOUCHE LLP

Boston, Massachusetts
April 26, 2000




                                 CODE OF ETHICS
                                   ADOPTED BY
                         THE WRIGHT MANAGED INCOME TRUST
                         THE WRIGHT MANAGED EQUITY TRUST
                        THE WRIGHT EQUIFUND EQUITY TRUST
                       THE WRIGHT ASSET ALLOCATION TRUST
                    THE WRIGHT MANAGED BLUE CHIP SERIES TRUST
                   THE WRIGHT BLUE CHIP MASTER PORTFOLIO TRUST
                      THE CATHOLIC VALUES INVESTMENT TRUST




                            As Adopted March 23, 2000



         Each of The Wright  Managed  Income Trust,  The Wright  Managed  Equity
Trust, The Wright EquiFund Equity Trust, The Wright Asset Allocation  Trust, The
Wright  Managed Blue Chip Series  Trust,  The Wright Blue Chip Master  Portfolio
Trust and The Catholic  Values  Investment  Trust (the "Funds") has adopted this
Code of Ethics, pursuant to Rule 17j-1 under the Investment Company Act of 1940,
as  amended  (the  "1940  Act"),  with  respect  to  certain  types of  personal
securities transactions by the officers and Trustees of the Funds which might be
deemed to create  possible  conflicts  of interest  and to  establish  reporting
requirements and enforcement procedures with respect to such transactions.

I.       Code Provisions Applicable Only to Affiliated Officers and Trustees of
         the Funds.

         A.  INCORPORATION  OF ADVISER'S  CODE OF ETHICs.  The provisions of the
Adviser's Code of Ethics of Wright Investors' Service (the "Adviser"),  which is
attached as  APPENDIX A hereto,  are hereby  incorporated  herein as each Fund's
Code of  Ethics  applicable  to  Officers  and  Trustees  of such  Fund  who are
employees or  affiliates of the Adviser.  A violation of the  Adviser's  Code of
Ethics by any such Officer or Trustee of a Fund shall  constitute a violation of
the Fund's Code of Ethics.  Reports of the Adviser's  personnel  required by the
Adviser's Code of Ethics shall be deemed to be reports with the Funds under this
Code of Ethics, and shall at all times be available to the Funds.
         B.  REPORTS UNDER THE ADMINISTRATOR'S CODE OF ETHICS.  Officers and
Trustees of the Funds who are employees of the Administrator shall file copies
of the reports required by the Administrator's Code of Ethics with the Review
Officer (as defined in Section I.C. of this Code). Such filings shall be deemed
to be filings with the Funds under this Code of Ethics, and shall at all
times be available to the Funds.
         C. REVIEW.  The person designated as the review officer by the Trustees
of each  Fund  (the  "Review  Officer")  shall  compare  the  reported  personal
securities  transactions with completed and contemplated  portfolio transactions
of the Funds to determine  whether a violation  of this Code may have  occurred.
Before  making any  determination  that a violation  has been  committed  by any
person,  the Review  Officer  shall give such  person an  opportunity  to supply
additional  explanatory  material.  If  the  Review  Officer  determines  that a
material violation of this Code has or may have occurred, he or she shall submit
his or her written  determination,  together with the transaction report and any
additional explanatory material provided by the individual,  to the President of
the Adviser,  who shall make an independent  determination of whether a material
violation has occurred.

        D.  SANCTIONS.  If the Review  Officer or the  President of the Adviser
finds that a material violation has occurred,  he shall report the violation and
any sanctions imposed by the Adviser to the Trustees of the affected Funds. If a
securities  transaction of the Review Officer or the President of the Adviser is
under  consideration,  an alternate review officer  appointed by the Trustees of
each Fund, who may be a Vice President or other senior officer of the Adviser or
an unaffiliated  third party, shall act in all respects in the manner prescribed
herein for the Review Officer or the President of the Adviser.

II. CODE PROVISIONS APPLICABLE ONLY TO INDEPENDENT TRUSTEES OF THE FUNDS.

       A. DEFINITIONS.

     (1)  "Beneficial  ownership"  shall be interpreted in the same manner as it
would be in determining whether a person is subject to the provisions of Section
16 of the  Securities  Exchange  Act of  1934  and  the  rules  and  regulations
thereunder.  Application  of this  definition is explained in more detail in the
form of report attached as Appendix B hereto.

     (2)  "Control"  shall  have the same  meaning  as that set forth in Section
2(a)(9) of the 1940 Act. Generally, it means the power to exercise a controlling
influence  over the  management  or policies of a company,  unless such power is
solely the result of an official position with such company.

     (3)  "Independent  Trustee"  means  a  Trustee  of any  Fund  who is not an
employee or affiliate of the Adviser or the Administrator.

     (4)  "Purchase or sale of a security"  includes,  among other  things,  the
writing of an option to purchase or sell a security.

     (5)  "Security"  shall  have the same  meaning as that set forth in Section
2(a)(36) of the 1940 Act (generally,  all  securities)  except that it shall not
include direct  obligations  of the  Government of the United  States,  bankers'
acceptances,  bank  certificates  of deposit,  commercial  paper,  high  quality
short-term  debt  instruments  (including  repurchase  agreements) and shares of
registered open-end investment companies.

     (6) A Security is "being  considered for purchase or sale" by a Fund when a
recommendation that the Fund purchase or sell the Security has been communicated
by a member of the Adviser's Investment Department to an officer of such Fund.

       B.  PROHIBITED PURCHASES AND SALES.  No Independent Trustee of any Fund
shall purchase or sell, directly or indirectly, any Security in which he has,
or by reasons of such transaction acquires, any direct or indirect beneficial
ownership and which to his actual knowledge at the time of such purchase or
sale:

(1)   is being considered for purchase or sale by such Fund; or
(2)   is being purchased or sold by such Fund.

       C.  EXEMPTED TRANSACTIONS.  The prohibitions of Section IIB of this Code
 shall not apply to:

(1)  purchases  or sales  effected  in any  account  over which the  Independent
Trustee has no direct or indirect  influence or control;

(2) purchases or sales
which are  non-volitional on the part of the Independent  Trustee or a Fund;

(3)purchases  which  are  part of an  automatic  dividend  reinvestment  plan;

(4)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;

(5) purchases or sales other than those  exempted in Paragraphs (1) through
(4) above, (a) which will not cause the Independent Trustee to gain improperly a
personal profit as a result of his relationship with any Fund, or (b) which will
only remotely affect a Fund because the proposed  transaction  would be unlikely
to  affect  a  highly  institutional  market,  or  (c)  which,  because  of  the
circumstances of the proposed  transaction,  are not related economically to the
Securities  purchased or sold or to be purchased or sold by a Fund,  and in each
case which are previously  approved by the Review Officer,  which approval shall
be confirmed in writing.

     D.  REPORTING.  Whether or not one of the exemptions  listed in Section IIC
hereof applies, each Independent Trustee of each Fund shall file with the Review
Officer a written report  containing  the  information  described  below in this
Section  IID with  respect to each  transaction  in any  Security  in which such
Independent Trustee has, or by reasons of such transaction acquires,  any direct
or indirect beneficial  ownership,  if such Independent  Trustee, at the time he
entered  into that  transaction,  actually  knew or, in the  ordinary  course of
fulfilling his official duties as a Trustee of such Fund should have know,1 that
during  the  15-day  period  immediately  preceding  or  after  the date of that
transaction:

(a)  such Security was or is to be purchased or sold by the Fund, or
(b)  such Security was or is being considered for purchase or sale by the Fund;

PROVIDED, HOWEVER, that such Independent Trustee shall not be required to make a
report with  respect to any  transaction  effected for any account over which he
does not have any direct or  indirect  influence  or  control.  Each such report
shall be deemed to be filed with the Funds for  purposes  of this Code,  and may
contain a statement  that the report  shall not be  construed as an admission by
the Independent Trustee that he has any direct or indirect beneficial  ownership
in the Security to which the report relates.

     Such  report  shall be made not  later  than 10 days  after  the end of the
calendar  quarter  in which the  transaction  to which the  report  relates  was
effected, and shall contain the following information:

(i) The date of the transaction,  the title,  interest rate and maturity date
(if  applicable),  the number of shares, and the principal amount of each
security involved;

(ii) The nature of the transaction  (i.e.,  purchase,  sale or any other type of
acquisition  or  disposition);

(iii)  The price at which  the  transaction  was effected;

(iv) The name of the broker,  dealer or bank with or through whom the
transaction was effected; and

(v) The date that the report is submitted.
Any report  concerning a purchase or sale  prohibited  under  Section IIB hereof
with respect to which the Independent  Trustee relies upon one of the exemptions
provided in Section IIC shall contain a brief statement of the exemption  relied
upon and the circumstances of the transaction.

       E. REVIEW.  The Review  Officer  shall  compare the  reported  personal
securities  transactions with completed and contemplated  portfolio transactions
of each Fund to determine whether any transaction ("Reviewable  Transaction") of
the type listed in Section IIB (without regard to exemptions provided by Section
IIC(1) through (5)) may have occurred.  If the Review Officer  determines that a
Reviewable  Transaction  may  have  occurred,  he  shall  submit  the  pertinent
information  regarding the  transaction  to counsel for the Funds.  Such counsel
shall determine whether a material  violation of this Code has occurred,  taking
into account all the exemptions  provided  under Section IIC.  Before making any
determination that a violation has occurred,  such counsel shall give the person
involved  an  opportunity  to  supply  additional   information   regarding  the
transaction in question.

     F. SANCTIONS.  If such counsel determines that a material violation of this
Code has  occurred,  such counsel  shall so advise the President of the affected
Fund and an ad hoc  committee  consisting  of the  Independent  Trustees of such
Fund, other than the person whose transaction is under  consideration,  and such
counsel shall provide the committee  with a report of the matter,  including any
additional  information  supplied by such person.  The committee may impose such
sanctions as it deems appropriate.

III.  MISCELLANEOUS CODE PROVISIONS.

     A.  AMENDMENT  OR REVISION OF THE  ADVISER'S  CODE OF ETHICS.  Any material
change or  amendment  to the  Adviser's  Code of Ethics  must be approved by the
Board of Trustees of the Funds (including a majority of Independent Trustees) no
later than six months of its adoption by the Adviser. Such amendment or revision
shall be deemed to be an amendment or revisions of Section IA of this Code,  and
a copy of such amendment or revision shall be appended hereto.

     B.  ANNUAL  REPORT AND  CERTIFICATION  OF THE  ADVISER.  No later than once
annually,   the  Adviser  shall   prepare  and  submit  a  written   report  and
certification to the Trustees of the Funds, as required by Paragraph C.8. of the
Adviser's Code of Ethics (Appendix A hereto).

     C.  RECORDS.  Each Fund  shall  maintain  records  in the manner and to the
extent set forth below,  which records may be  maintained  in electronic  format
under the conditions  described in Rule 31a-2(f)(a) under the 1940 Act and shall
be available for examination by  representatives  of the Securities and Exchange
Commission:

     (1) A copy of this Code and any other code which is, or at any time  within
the past  five  years  has  been,  in  effect  shall be  preserved  in an easily
accessible place;
     (2) A record of any  violation  of this Code and of any  action  taken as a
result of such violation shall be preserved in an easily  accessible place for a
period of not less than five years following the end of the fiscal year in which
the violation occurs;
     (3) A copy of each  report  made by an Officer or Trustee  pursuant to this
Code shall be  preserved  for a period of not less than five years after the end
of the  fiscal  year in which it is  made,  the  first  two  years in an  easily
accessible place;
     (4) A list of all persons who are, or within the past five years have been,
required to make reports  pursuant to this Code shall be  maintained in a easily
accessible place;
     (5) A copy of each  annual  written  report and  certification  made by the
Adviser to the Board of Trustees of the Funds must be maintained for a period of
five years after the end of the fiscal  year in which it is made,  the first two
years in an easily accessible place; and
     (6) A record of any decision,  and the reasons supporting the decision,  to
approve the  acquisition  by Access  Persons of any initial  public  offering or
private  placement  securities shall be maintained for at least five years after
the end of the fiscal year in which the approval was granted.
     C.  CONFIDENTIALITY.  All reports of securities  transactions and any other
information  filed with the Funds or  furnished  to any person  pursuant to this
Code shall be treated as  confidential,  but are  subject to review as  provided
herein and by representatives of the Securities and Exchange Commission.
     D. INTERPRETATION OF PROVISIONS. The Trustees of each Fund may from time to
time adopt such interpretations of this Code as they deem appropriate.
     E. EFFECT OF  VIOLATION OF THE CODE.  In adopting  Rule 17j-1 under the
1940  Act,  the  Securities  and  Exchange  Commission   specifically  noted  in
Investment Company Act Release No. IC-11421 that a violation of any provision of
a particular code of ethics, such as this Code, would not be considered a per se
unlawful act  prohibited  by the general  anti-fraud  provisions of the Rule. As
stated in the Release:

         "....the  Commission believes that such a violation should and would be
considered,  with all the  surrounding  facts and  circumstances,  merely as one
piece of evidence in determining whether, in addition to a violation of the code
of  ethics,  a  violation  of the  anti-fraud  provisions  of the Rule  also has
occurred."

In adopting  this Code of Ethics,  it is not  intended  that a violation of this
Code is or should be considered to be a violation of Rule 17j-1.

<PAGE>


                         WRIGHT INVESTORS' SERVICE, INC.
                      CODE OF ETHICS - PERSONAL INVESTMENTS

A. STATEMENT OF GENERAL PRINCIPLES

         All  directors,  officers and employees of Wright  Investors'  Service,
Inc. ("Wright") shall conduct themselves with integrity and dignity and act in a
thoroughly  ethical  manner in  dealings  with  clients,  the  public and fellow
employees.  All such  persons  shall  have the  duty at all  times to place  the
interests of the shareholders of  Wright-managed  mutual funds (the "Funds") and
Wright's  other  clients  first,  and may not in any respect  take  advantage of
client  transactions.  It is essential that we avoid not only actual  conflicts,
but  also  any  appearance  of  conflicts  of  interest  and  any  abuse  of  an
individual's  position of trust and responsibility.  No Code of Ethics can cover
every possible circumstance,  and an individual's conduct must depend ultimately
upon his sense of fiduciary obligation to the Funds and Wright's direct advisory
clients.

       This Code of Ethics ("Code") supersedes Wright's prior code and Statement
of  Policy.  The  management  of Wright  believes  this Code meets  current  SEC
requirements and is appropriate and desirable for the Company.

         All requests and reports provided to anyone pursuant to this Code shall
be treated as confidential,  but are subject to review as provided herein and by
representatives of the Securities and Exchange Commission.

B. APPLICABILITY OF RESTRICTIONS AND PROCEDURES

PERSONS AFFECTED.

         ALL  EMPLOYEES*  located in any office of Wright  must  comply with the
         requirements of Paragraphs C-1 through C-3, below and all provisions of
         Section E. Employees must also  familiarize  themselves  with all other
         parts of this Code.

         ACCESS  PERSONS  (as  defined  in  Exhibit  A)  must  comply  with  the
         requirements  of  Paragraphs  C-1  through  C-6,  inclusive,   and  all
         provisions  of  Section  E.  Access   Persons  must  also   familiarize
         themselves with all other parts of this Code.

ACCOUNTS INCLUDED.

         Wright's policies and procedures  concerning personal investments apply
         to all securities accounts in which the affected employee has "a direct
         or indirect  beneficial  ownership," unless the employee has no "direct
         or indirect  influence  or control"  over the  account.  The concept of
         BENEFICIAL  OWNERSHIP  is an  important  part of this  Code and is more
         extensively defined in Exhibit A.

  *  For  purposes  of  clarity,  all  employees  of  The  Winthrop  Corporation
performing services for Wright are referred to as employees of Wright.


 TYPES OF SECURITIES COVERED.

         In general this Code  employs the terms  Security to mean shares of any
         publicly-traded  company,  including puts, calls,  options and warrants
         for such securities,  and open-end and closed-end mutual funds,  except
         direct  obligations of the US Government,  bank certificates of deposit
         and money market funds.

C.   COMPLIANCE PROCEDURES

         1. Disclosure of Personal Holdings. As a condition to employment,  each
newly-hired  person must (i) make full  disclosure of any brokerage  account and
all publicly-traded  securities beneficially owned by the employee or members of
the employee's immediate family; (ii) agree to comply with the Company's written
policies restricting personal trading and prohibiting insider trading; and (iii)
provide a written  acknowledgment  of receipt of such policies.  This disclosure
must include all of the information requested on Exhibit B-1.

         2.  Preclearance.  No  employee of Wright may buy or sell shares of any
Security without the prior approval of the Chief Executive  Officer (CEO) or the
Chief Investment  Officer (CIO) of Wright.  Any such approval will only be given
in accordance  with the provisions of Paragraph D,  "Guidelines  for Approval of
Securities  Transactions."  The  approval  will  remain  valid for  three  days.
Employees  who receive  approvals for trades must have the broker send a copy of
the confirmation to the Legal Department.

         3. Annual  Certification  of  Compliance.  All employees  shall certify
annually that they (i) have read and understand  this Code;  (ii) recognize that
they are subject thereto;  (iii) have complied with its requirements,  including
any  necessary  preclearance;  and (iv) have  disclosed or reported all personal
securities  transactions  required to be disclosed or reported  pursuant to this
Code. The form of such certification is set forth in Exhibit B-2.

         4. Broker/Dealer  Reports. All employees shall cause each broker/dealer
at which they have an account to send a copy of all quarterly and annual account
statements to the Legal Department.

     5.  Quarterly  Report of  Transactions.  Each Access Person must file every
quarter with the Legal  Department a report of all  transactions  in Securities.
(See Exhibit B-3) Transactions encompass sales, purchases and other acquisitions
or  dispositions,   including  gifts  and  exercise  of  conversion   rights  or
subscription rights. In addition,  if the Access Person established a securities
account  during the  quarter,  the report must  disclose the name of the broker,
dealer or bank with whom the account is established and the date the account was
established.  The report must be filed with the Legal  Department  even if there
were no reportable transactions during the prior calendar quarter, in which case
the employee should state on the form that there were no such transactions.  The
report is due ten days after the end of each calendar quarter. Failure to submit
the report in a timely manner is a violation of SEC  regulations  and this Code,
and may be a cause for sanctions.  Copies of all brokerage  statements should be
attached to an Access Person's signed report.

     6. Annual Disclosure.  No less than once annually, all Access Persons shall
submit to the Legal Department a list of all of his/her securities holdings. The
specific  information  of this  report  is  identical  to  that  of the  Initial
Disclosure  of  Investments.  Brokerage  statements  may  be  substituted  for a
separate report.

         7.  Monitoring of Compliance.  Within thirty days after the end of each
quarter, the Legal Department* shall review the Quarterly and Annual Reports for
reconciliation  with  the  Initial  Disclosure,   Annual  Disclosure,   and  the
Preclearance  Approvals  given in the same quarter or year, as  applicable.  The
Legal Department will investigate all apparent  violations of this Code and will
prepare a report for the President of Wright.

     8.  Review by the Board of  Trustees.  No less than once each year,  Wright
shall prepare and submit a written report to the Trustees of the Funds that

o     describes  any issues  arising under this Code of Ethics 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
o     certifies that Wright has adopted procedures reasonably necessary to
      prevent violations of this Code.

         If there have been any material  changes to the Code of Ethics,  Wright
will submit such changes to the Trustee at the next meeting of the Board.

       The Trustees  shall review any  violations  of the Code  specified in the
annual  report  and  any  recommended  changes  in  existing   restrictions  and
procedures.  They  should  then  take  such  action,  if any,  as they  may deem
appropriate.

         9. Additional  Disclosure.  Wright's Code of Ethics shall be filed with
the SEC as an  exhibit  to the  registration  statement  of each  Wright-managed
mutual  fund.  There  will be  disclosure  in the Funds'  prospectuses  or their
statements of additional  information that (i) Wright has a code of ethics, (ii)
whether  personnel of Wright are permitted to invest in securities for their own
accounts, and (iii) that the code is on public file, and available from the SEC.


* As of March,  2000, Helen George,  Senior Vice President of Legal Affairs,  is
the person responsible for reviewing the reports.


D.  GUIDELINES FOR APPROVAL OF SECURITIES TRANSACTIONS

         1. Initial  Public  Offerings.  Generally no approval will be given for
any employee to purchase  securities  of a publicly  owned  corporation  that is
making an initial public offering of its  securities,  except in connection with
the exercise of rights issued in respect of securities  such employee  owns. The
reason for this rule is that it precludes  the  appearance  that an employee has
used our clients'  market stature as a means of obtaining for himself or herself
"hot" issues which would otherwise not be offered to him or her. Any realization
of  short-term  profits may create at least the  appearance  that an  investment
opportunity  that should have been available to a direct  advisory  account or a
Fund account was diverted to the personal benefit of an employee.

         2.  Limited  Offerings.  Any  prior  approval  of  any  acquisition  of
securities in a limited offering (such as a private  placement) should take into
account,  among other  factors,  whether the  investment  opportunity  should be
reserved  for a Fund and its  shareholders  or other  client,  and  whether  the
opportunity  is being  offered to an individual by virtue of his or her position
with the investment adviser.

         3.  Blackout  Periods.  No employee  shall be  authorized to exercise a
securities  transaction  within  seven  calendar  days  before or after a direct
advisory  account or a Fund in the Wright  complex has a pending "buy" or "sell"
order in that same security until that order is executed or withdrawn.

         4. Short Sales and Options. Usually no approval will be given for short
sales. Also prohibited are buying,  selling or exercising put or call options or
combinations  thereof of securities  held by a Fund or other advisory  client or
which are being  considered  for  purchase  for  them.  It should be noted,  for
example,  that an  exercise  of an option or the  covering of a short sale could
conflict  with current  trading for clients.  However,  where any such option is
held by a member of an employee's  family,  approval may be given provided there
is no conflict with the interests of the Funds or other Wright clients.

         5. Short-Term Trading Profits.  Short-term trading,  i.e., profiting in
the  purchase  and  sale  or sale  and  purchase  of the  same  (or  equivalent)
securities  within 60 calendar  days, is prohibited  and approval will generally
not be given.  The  management  of Wright  believes that  short-term  trading by
Access  Persons  may  increase  the risk of  conflicts  of  interest,  affect an
individual's  investment judgment,  and in some instances divert an individual's
attention from the best  interests of our Funds and other clients.  Where one or
both sides of a short-term trade have not been pre-cleared,  there is presumably
already a violation  and the whole matter  should be handled under the Sanctions
section of this Code,  with  disgorgement  of profits being only one alternative
available to the President of Wright.

         6. Margin Accounts. Margin Accounts are absolutely prohibited and no
approval will be given.

         7. By-Law Violation. No approval will be given which would result in an
employee's  holdings  exceeding  1/2 of 1% of the  shares or  securities  of any
publicly-owned issuer.

         8. General  Standards.  In the rare case where  approval is given for a
transaction  involving  an  initial  public  offering  or  a  limited  offering,
additional  written  disclosure  will be required and will be  maintained in the
Legal Department. In authorizing any other types of transactions, the CEO or CIO
may consider  the extent to which the employee has access to pending  investment
decisions,  the number of transactions already approved for such employee within
the past six  months,  whether the  employee  has made  unreasonable  use of the
company's  resources during business hours in arriving at a personal  investment
decision,  and any other  factors  that are,  in the  opinion of the CEO or CIO,
pertinent to the matter.

E.  RESPONSIBILITIES OF ALL EMPLOYEES RELATING TO PERSONAL INVESTMENTS.

         1. Securities Recommended by a Member of the Investment Committee. Each
member of the Investment  Committee who makes a  recommendation  as to whether a
security  shall be  purchased,  sold or held in the  account of a Fund or client
shall  fully  apprise  the  CEO or CIO of  Wright  of  any  direct  or  indirect
beneficial ownership the employee has in such security.

         2. By-Law Provision.  The by-laws of the Wright Funds generally provide
that a Wright Fund shall not purchase or retain in its portfolio any  securities
issued by an issuer any of whose officers,  directors or security  holders is an
officer or director of the Fund, or is an officer or director of the  investment
adviser of the Fund,  if after the purchase of the  securities of such issuer by
the Fund one or more of such  persons owns  beneficially  more than 1/2 of 1% of
the shares or securities,  or both, of such issuer, and such persons owning more
than 1/2 of 1% of such shares or securities  together own beneficially more than
5% of such shares or securities, or both. In view of the foregoing, and to avoid
any  possibility  of an  inadvertent  violation  of this  by-law  provision,  no
approval will be given that would result in an employee's holdings exceeding 1/2
of 1% of the shares or securities of any publicly-owned  issuer. Any request for
prior  approval  of a trade in this type of  security  must state  whether  this
provision applies.

         3. Gifts.  No employee  shall  accept gifts of a value in excess of $35
from any person or entity that does  business with or on behalf of a Wright Fund
or direct advisory account.  Any gift in excess of $35 shall be disclosed to the
President of Wright before acceptance by the employee.

         4.  Service As a  Director.  No  employee  shall  serve on the board of
directors of a publicly traded company,  absent prior authorization based upon a
determination  by the  President  of  Wright  that the  board  service  would be
consistent with the interests of the Fund and its shareholders which may have an
investment in such public company.  In the relatively  small number of instances
in which board service may be authorized,  Access  Persons  serving as directors
should be  isolated  from those  making  investment  decisions  through  written
procedures applicable to the person's position in Wright.

         5.  Sanctions.  Careful  adherence to this Code of Ethics is one of the
basic  conditions of employment of every  employee.  Any employee  violating any
provision of this Code of Ethics,  including the Compliance  Procedures,  may be
subject to sanction,  including but not limited to suspension or  termination of
employment,  censure or disgorgement  of profits,  at the  determination  of the
President of Wright.



                                                          Exhibit A

ACCESS PERSONS*

         Using the Investment Company Act definition, an Access Person includes:

         (i) any officer or director of Wright;
         (ii) any  employee  of  Wright  who,  in  connection  with his  regular
         functions  or duties,  makes,  participates  in or obtains  information
         regarding the purchase or sale of a security by a registered investment
         company, or whose functions relate to the making of any recommendations
         with respect to such  purchases or sales;  and
        (iii) any natural person in a control relationship to Wright who
         obtains information  concerning recommendations  regarding  the
         purchase  or sale of a security  for a Wright-managed mutual fund.

         The current list of positions at Wright  deemed to be "Access  Persons"
are:  directors,  officers,  trading department  personnel,  analysts and others
involved in making  recommendations to portfolio managers,  and any employee who
has  direct  contact  with  clients  and/or  receives  advance  notice  from the
Investment Committee of contemplated portfolio transactions.

BENEFICIAL OWNERSHIP

         Under  current  SEC  interpretations,   Beneficial  Ownership  includes
securities  accounts of a spouse,  minor children and relatives  resident in the
employee's  home,  as well as  accounts  of  another  person if by reason of any
contract,  understanding,  relationship,  agreement  or  other  arrangement  the
employee  obtains  therefrom  benefits  substantially  equivalent  to  those  of
ownership.

       When an employee has a  substantial  measure of influence or control over
an account, but not direct or indirect beneficial ownership (as for example when
the  employee  serves as executor or trustee for someone  outside his  immediate
family,  or manages or helps to manage a  charitable  a account),  the rules set
forth in this Code of Ethics will not be considered  to be directly  applicable,
but in all transactions involving any such account the employee will be expected
to conform to the spirit of these rules and specifically avoid any activity that
conflicts or might appear to conflict with the interests of our clients.

* Since all  provisions  of this Code  restrict all Access  Persons,  no special
mention of Investment Personnel,  as defined by the SEC, has been made. Further,
any director of Wright who is not an  "interested  person" of Wright (as defined
in applicable SEC  regulations)  need not make any initial,  annual or quarterly
report,  unless the director knows, or should have known, of a possible conflict
of interest between his/her securities  transaction and the investment decisions
of Wright or the Funds.  Within thirty days after the adoption of this Code, the
Legal  Department of Wright shall send each such director a notice that includes
a full  explanation  of  the  types  of  transactions  that  are,  in any  case,
prohibited  and the  circumstances  under which it may be  necessary to report a
transaction.

<PAGE>


                  WRIGHT INVESTORS' SERVICE DISTRIBUTORS, INC.
                      CODE OF ETHICS - PERSONAL INVESTMENTS

A. STATEMENT OF GENERAL PRINCIPLES

         Wright Investors' Service  Distributors,  Inc.  ("Distributors") is the
principal  underwriter  of a family of mutual  funds  (the  "Funds")  managed by
Distributors'  affiliate,   Wright  Investors'  Service,  Inc.  ("Wright").  All
directors,  officers and employees of Distributors shall conduct themselves with
integrity  and dignity and act in a thoroughly  ethical  manner in dealings with
clients,  the public and fellow employees.  All such persons shall have the duty
at all times to place the interests of the  shareholders  of the Funds,  and may
not in any respect take  advantage of  transactions  made by or on behalf of the
Funds.  It is essential  that we avoid not only actual  conflicts,  but also any
appearance of conflicts of interest and any abuse of an individual's position of
trust  and   responsibility.   No  Code  of  Ethics  can  cover  every  possible
circumstance,  and an individual's conduct must depend ultimately upon his sense
of fiduciary obligation to the Funds.

       This Code of Ethics  ("Code")  supersedes  Distributors's  prior code and
Statement of Policy.  The  management of  Distributors  believes this Code meets
current SEC requirements and is appropriate and desirable for the Company.

         All requests and reports provided to anyone pursuant to this Code shall
be treated as confidential,  but are subject to review as provided herein and by
representatives of the Securities and Exchange Commission.

B. APPLICABILITY OF RESTRICTIONS AND PROCEDURES

Persons Affected.

         ALL EMPLOYEES*  located in any office of Distributors  must comply with
         the   requirements  of  Paragraphs  C-1  through  C-3,  below  and  all
         provisions of Section E.  Employees  must also  familiarize  themselves
         with all other parts of this Code.

         ACCESS  PERSONS  (as  defined  in  Exhibit  A)  must  comply  with  the
         requirements  of  Paragraphs  C-1  through  C-6,  inclusive,   and  all
         provisions  of  Section  E.  Access   Persons  must  also   familiarize
         themselves with all other parts of this Code.

ACCOUNTS INCLUDED.

         Distributors's  policies and procedures concerning personal investments
         apply to all securities  accounts in which the affected employee has "a
         direct or indirect  beneficial  ownership,"  unless the employee has no
         "direct or indirect influence or control" over the account. The concept
         of Beneficial  Ownership is an important  part of this Code and is more
         extensively defined in Exhibit A.

     * For  purposes of  clarity,  all  employees  of The  Winthrop  Corporation
performing   services  for   Distributors   are  referred  to  as  employees  of
Distributors.

 TYPES OF SECURITIES COVERED.

         In general this Code  employs the terms  Security to mean shares of any
         publicly-traded  company,  including puts, calls,  options and warrants
         for such securities,  and open-end and closed-end mutual funds,  except
         direct  obligations of the US Government,  bank certificates of deposit
         and money market funds.

C.   COMPLIANCE PROCEDURES*

         1. Disclosure of Personal Holdings. As a condition to employment,  each
newly-hired  person must (i) make full  disclosure of any brokerage  account and
all publicly-traded  securities beneficially owned by the employee or members of
the employee's immediate family; (ii) agree to comply with the Company's written
policies restricting personal trading and prohibiting insider trading; and (iii)
provide a written  acknowledgment  of receipt of such policies.  This disclosure
must include all of the information requested on Exhibit B-1.

         2. Preclearance.  No employee of Distributors may buy or sell shares of
any Security  without the prior approval of the President of  Distributors.  Any
such approval will only be given in accordance  with the provisions of Paragraph
D,  "Guidelines  for Approval of  Securities  Transactions."  The approval  will
remain valid for three days.  Employees  who receive  approvals  for trades must
have  the  broker  send  a  copy  of  the   confirmation  to  the  President  of
Distributors.

         3. Annual  Certification  of  Compliance.  All employees  shall certify
annually that they (i) have read and understand  this Code;  (ii) recognize that
they are subject thereto;  (iii) have complied with its requirements,  including
any  necessary  preclearance;  and (iv) have  disclosed or reported all personal
securities  transactions  required to be disclosed or reported  pursuant to this
Code. The form of such certification is set forth in Exhibit B-2.

         4. Broker/Dealer  Reports. All employees shall cause each broker/dealer
at which they have an account to send a copy of all quarterly and annual account
statements to the president of Distributors.

         5. Quarterly Report of Transactions. Each Access Person must file every
quarter  with the  President of  Distributors  a report of all  transactions  in
Securities.  (See Exhibit B-3) Transactions encompass sales, purchases and other
acquisitions or dispositions,  including gifts and exercise of conversion rights
or  subscription  rights.  In  addition,  if the  Access  Person  established  a
securities account during the quarter,  the report must disclose the name of the
broker,  dealer or bank with whom the  account is  established  and the date the
account  was  established.  The  report  must be  filed  with the  President  of
Distributors even if there were no reportable transactions during the
prior calendar quarter, in which case the employee should state on the form that
there  were no such  transactions.  The  report is due ten days after the end of
each  calendar  quarter.  Failure to submit  the report in a timely  manner is a
violation of SEC  regulations  and this Code,  and may be a cause for sanctions.
Copies of all  brokerage  statements  should be attached  to an Access  Person's
signed report.

*At the present time, all employees of  Distributors  also perform  services for
Wright.  Therefore, a copy of any disclosure,  preclearance (whether approved or
disapproved), report or certification required under Wright's Code of Ethics may
be submitted to the President of Distributors in order to comply with this Code.

     6. Annual Disclosure.  No less than once annually, all Access Persons shall
submit to the  President  of  Distributors  a list of all of his/her  securities
holdings.  The specific  information  of this report is identical to that of the
Initial Disclosure of Investments. Brokerage statements may be substituted for a
separate report.

     7.  Monitoring  of  Compliance.  Within  thirty  days after the end of each
quarter, Internal Counsel for Distributors shall review the Quarterly and Annual
Reports for reconciliation with the Initial Disclosure,  Annual Disclosure,  and
the Preclearance Approvals given in the same quarter or year, as applicable. The
Internal Counsel will investigate all apparent  violations of this Code and will
prepare a report for the President of Distributors.

     8.  Review  by the  Board  of  Trustees.  No  less  than  once  each  year,
Distributors  shall  prepare and submit a written  report to the Trustees of the
Funds that

o        describes  any issues  arising under this Code of Ethics 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
o        certifies that Distributors has adopted procedures reasonably necessar
         to prevent violations of this Code.

         If  there  have  been  any  material  changes  to the  Code of  Ethics,
Distributors  will submit such changes to the Trustee at the next meeting of the
Board.

       The Trustees  shall review any  violations  of the Code  specified in the
annual  report  and  any  recommended  changes  in  existing   restrictions  and
procedures.  They  should  then  take  such  action,  if any,  as they  may deem
appropriate.

         9. Additional Disclosure.  Distributors's Code of Ethics shall be filed
with the SEC as an exhibit to the  registration  statement  of each Fund.  There
will be disclosure in the Funds'  prospectuses or their statements of additional
information that (i) Distributors has a code of ethics,  (ii) whether  personnel
of  Distributors  are permitted to invest in securities  for their own accounts,
and (iii) that the code is on public file, and available from the SEC.



* As of March,  2000,  Helen W. George is Internal  Counsel for Distributors and
the person responsible for reviewing the reports.

D.  GUIDELINES FOR APPROVAL OF SECURITIES TRANSACTIONS

         1. Initial  Public  Offerings.  Generally no approval will be given for
any employee to purchase  securities  of a publicly  owned  corporation  that is
making an initial public offering of its  securities,  except in connection with
the exercise of rights issued in respect of securities  such employee  owns. The
reason for this rule is that it precludes  the  appearance  that an employee has
used the Funds'  market  stature as a means of obtaining  for himself or herself
"hot" issues which would otherwise not be offered to him or her. Any realization
of  short-term  profits may create at least the  appearance  that an  investment
opportunity  that should have been  available  to a Fund account was diverted to
the personal benefit of an employee.

         2.  Limited  Offerings.  Any  prior  approval  of  any  acquisition  of
securities in a limited offering (such as a private  placement) should take into
account,  among other  factors,  whether the  investment  opportunity  should be
reserved for a Fund and its  shareholders,  and whether the opportunity is being
offered to an  individual  by virtue of his or her position  with the  principal
underwriter of the Funds.

         3.  Blackout  Periods.  No employee  shall be  authorized to exercise a
securities  transaction  within  seven  calendar  days  before or after a direct
advisory  account or a Fund in the Wright  complex has a pending "buy" or "sell"
order in that same security until that order is executed or withdrawn.

         4. Short Sales and Options. Usually no approval will be given for short
sales. Also prohibited are buying,  selling or exercising put or call options or
combinations thereof of securities held by a Fund, or which are being considered
for purchase for a Fund. It should be noted, for example, that an exercise of an
option or the covering of a short sale could conflict with current trading for a
Fund.  However,  where  any such  option  is held by a member  of an  employee's
family,  approval may be given  provided there is no conflict with the interests
of the Fund(s).

         5. Short-Term Trading Profits.  Short-term trading,  i.e., profiting in
the  purchase  and  sale  or sale  and  purchase  of the  same  (or  equivalent)
securities  within 60 calendar  days, is prohibited  and approval will generally
not be given. The management of Distributors believes that short-term trading by
Access  Persons  may  increase  the risk of  conflicts  of  interest,  affect an
individual's  investment judgment,  and in some instances divert an individual's
attention  from the best  interests  of the Funds.  Where one or both sides of a
short-term  trade  have not been  pre-cleared,  there is  presumably  already  a
violation and the whole matter should be handled under the Sanctions  section of
this Code, with disgorgement of profits being only one alternative  available to
the President of Distributors.

         6. Margin Accounts. Margin Accounts are absolutely prohibited and no
 approval will be given.

         7. By-Law Violation. No approval will be given which would result in an
employee's  holdings  exceeding  1/2 of 1% of the  shares or  securities  of any
publicly-owned issuer.

         8. General  Standards.  In the rare case where  approval is given for a
transaction  involving  an  initial  public  offering  or  a  limited  offering,
additional  written  disclosure  will be required and will be  maintained by the
President of Distributors.  In authorizing any other types of transactions,  the
President  may  consider  the extent to which the employee has access to pending
investment  decisions,  the number of  transactions  already  approved  for such
employee within the past six months,  whether the employee has made unreasonable
use of the company's  resources  during business hours in arriving at a personal
investment  decision,  and any other  factors  that are,  in the  opinion of the
President, pertinent to the matter.

E.  RESPONSIBILITIES OF ALL EMPLOYEES RELATING TO PERSONAL INVESTMENTS.

         1. Securities Recommended by a Member of the Investment Committee. Each
member of the Investment  Committee of Wright who is an employee of Distributors
and who makes a recommendation as to whether a security shall be purchased, sold
or held in the account of a Fund or client shall fully  apprise the President of
Distributors of any direct or indirect beneficial  ownership the employee has in
such security.

         2. By-Law Provision.  The by-laws of the Wright Funds generally provide
that a Wright Fund shall not purchase or retain in its portfolio any  securities
issued by an issuer any of whose officers,  directors or security  holders is an
officer or director of the Fund,  or is an officer or director of the  principal
underwriter  of the Fund, if after the purchase of the securities of such issuer
by the Fund one or more of such persons owns beneficially more than 1/2 of 1% of
the shares or securities,  or both, of such issuer, and such persons owning more
than 1/2 of 1% of such shares or securities  together own beneficially more than
5% of such shares or securities, or both. In view of the foregoing, and to avoid
any  possibility  of an  inadvertent  violation  of this  by-law  provision,  no
approval will be given that would result in an employee's holdings exceeding 1/2
of 1% of the shares or securities of any publicly-owned  issuer. Any request for
prior  approval  of a trade in this type of  security  must state  whether  this
provision applies.

         3. Gifts.  No employee  shall  accept gifts of a value in excess of $35
from any person or entity that does  business with or on behalf of a Wright Fund
or  Distributors.  Any gift in excess of $35 shall be disclosed to the President
of Distributors before acceptance by the employee.

         4.  Service As a  Director.  No  employee  shall  serve on the board of
directors of a publicly traded company,  absent prior authorization based upon a
determination  by the President of Distributors  that the board service would be
consistent with the interests of the Fund and its shareholders which may have an
investment in such public company.  In the relatively  small number of instances
in which board service may be authorized, Access Persons serving as directors of
Distributors  should be isolated  from  personnel  of Wright  making  investment
decisions  through  written  procedures  applicable to the person's  position in
Distributors.

         5.  Sanctions.  Careful  adherence to this Code of Ethics is one of the
basic  conditions of employment of every  employee.  Any employee  violating any
provision of this Code of Ethics,  including the Compliance  Procedures,  may be
subject to sanction,  including but not limited to suspension or  termination of
employment,  censure or disgorgement  of profits,  at the  determination  of the
President of Distributors.



                                                             Exhibit A

ACCESS PERSONS*

         Using the Investment Company Act definition,  an Access Person includes
any director or officer of Distributors who, in the ordinary course of business,
makes, participates in or obtains information regarding, the purchase or sale of
Securities by any Fund for which  Distributor acts, or whose functions or duties
in the ordinary course of business relate to the making of any recommendation to
any of the Funds regarding the purchase or sale of Securities.

         The current  list of  positions  at  Distributors  deemed to be "Access
Persons" are: directors,  officers, and any employee who receives advance notice
from the Investment Committee of Wright of contemplated portfolio transactions.

BENEFICIAL OWNERSHIP

         Under  current  SEC  interpretations,   Beneficial  Ownership  includes
securities  accounts of a spouse,  minor children and relatives  resident in the
employee's  home,  as well as  accounts  of  another  person if by reason of any
contract,  understanding,  relationship,  agreement  or  other  arrangement  the
employee  obtains  therefrom  benefits  substantially  equivalent  to  those  of
ownership.

       When an employee has a  substantial  measure of influence or control over
an account, but not direct or indirect beneficial ownership (as for example when
the  employee  serves as executor or trustee for someone  outside his  immediate
family,  or manages or helps to manage a  charitable  a account),  the rules set
forth in this Code of Ethics will not be considered  to be directly  applicable,
but in all transactions involving any such account the employee will be expected
to conform to the spirit of these rules and specifically avoid any activity that
conflicts or might appear to conflict with the interests of our clients.



* Since all  provisions  of this Code  restrict all Access  Persons,  no special
mention of Investment Personnel,  as defined by the SEC, has been made. Further,
any director of Distributors  who is not an "interested  person" of Distributors
(as defined in applicable SEC regulations) need not make any initial,  annual or
quarterly report, unless the director knows, or should have known, of a possible
conflict of interest between his/her  securities  transaction and the investment
decision of the Funds.  Within thirty days after the adoption of this Code,  the
Internal  Counsel for  Distributors  shall send each such director a notice that
includes a full explanation of the types of transactions  that are, in any case,
prohibited  and the  circumstances  under which it may be  necessary to report a
transaction.



© 2022 IncJournal is not affiliated with or endorsed by the U.S. Securities and Exchange Commission