EXHIBIT 23P(1)
CODE OF ETHICS
CODE OF ETHICS
OF QUAKER INVESTMENT TRUST
I. INTRODUCTION
This Code of Ethics has been adopted by Quaker Investment Trust (the
"Trust"), each Adviser and/or Sub-adviser to each series of the Trust (the
"Advisers") and Declaration Distributors, Inc., the Trust's principal
underwriter (the "Underwriter") in compliance with Rule 17j-1 (the "Rule")
under the Investment Company Act of 1940, as amended (the "Act") to
establish standards and procedures for the detection and prevention of
activities by which persons having knowledge of the investments and
investment intentions of the Trust may abuse their fiduciary duties to the
Trust, and to deal with other types of conflict-of-interest situations to
which the Rule is addressed.
The Rule makes it "unlawful" for certain persons who have affiliations with
the Trust to engage in conduct which is deceitful, fraudulent or
manipulative, or which involves false or misleading statements, in
connection with the purchase or sale of securities by the Trust. This Code
of Ethics is intended to establish policies and procedures designed to
insure that persons subject to this Code of Ethics and the Rule do not use
any information concerning the investments or investment intentions of the
Trust, or his or her ability to influence such investment related
information, for personal gain or in a manner detrimental to the interests
of the Trust.
II. PRINCIPLES
This Code of Ethics acknowledges the general principles that persons
affiliated with the Trust:
(A) owe a fiduciary obligation to the Trust;
(B) have the duty at all times to place the interests of Trust
shareholders first;
(C) must conduct all of their personal securities transactions in such a
manner as to avoid any actual or potential conflict of interest or
abuse of such person's position of trust and responsibility; and
(D) SHOULD NOT TAKE INAPPROPRIATE ADVANTAGE OF THEIR POSITIONS IN RELATION
TO THE TRUST.
III. DEFINITIONS (AS USED HEREIN)
"Access Person" means:
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(1) any director, officer, general partner or Advisory Person of the Trust
or any Adviser to the Trust.
(A) If an Adviser to the Trust is primarily engaged in a business or
businesses other than advising Funds or other advisory clients,
the term Access Person means any director, officer, general
partner or Advisory Person of the Adviser who, with respect to
any Fund, makes any recommendation, participates in the
determination of which recommendation will be made, or whose
principal function or duties relate to the determination of which
recommendation will be made, or who, in connection with his or
her duties, obtains any information concerning recommendations on
Covered Securities being made by the Adviser to any Fund.
(B) An Adviser is "primarily engaged in a business or businesses
other than advising Funds or other advisory clients" if, for each
of its most recent three fiscal years or for the period of time
since its organization, whichever is less, the Adviser derived,
on an unconsolidated basis, more than 50% of its income (or
loss), before taxes and extraordinary items, from the other
business or businesses.
(2) Any director, officer or general partner of a principal underwriter
who, in the ordinary course of business, makes, participates in or
obtains information regarding, the purchase or sale of Covered
Securities by the Trust for which the principal underwriter acts, or
whose functions or duties in the ordinary course of business relate to
the making of any recommendation to the Trust, regarding the purchase
or sale of Covered Securities.
"Advisory Person" means:
(1) Any employee of the Trust or an Adviser to the Trust (or of any
company in a control relationship to the Trust or an investment
adviser to the Trust) who, in connection with his or her regular
functions or duties, makes, participates in, or obtains information
regarding the purchase or sale of Covered Securities by the Trust, or
whose functions relate to the making of any recommendations with
respect to such purchases or sales; and
(2) Any natural person in a control relationship to the Trust or an
Adviser to the Trust who obtains information concerning
recommendations made to the Trust with regard to the purchase or sale
of Covered Securities by the Trust.
"Affiliated Person" means:
(1) Any officer, director, copartner or employee of the Trust, Adviser
and/or Underwriter;
(2) any person directly or indirectly owning, controlling or holding with
power to vote, 5% or more of the outstanding voting securities of the
Trust, Adviser and/or Underwriter;
(3) any person 5% or more of whose outstanding voting securities are
directly or indirectly owned, controlled or held with power to vote,
by the Trust, Adviser and/or Underwriter; and
(4) any person directly or indirectly controlling, controlled by, or under
common control with the Trust, Adviser and/or Underwriter.
"Beneficial Interest" means:
any interest by which an Access Person or any member of his or her
immediate family (relative by blood or marriage living in the same
household), can directly or indirectly derive a monetary benefit from
the purchase, sale (or other acquisition or disposition) or ownership
of a security, except such interests as
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Clearing Officers shall determine to be too remote for the purpose of
this Code of Ethics. (A transaction in which an Access Person acquires
or disposes of a security in which he or she has or thereby acquires a
direct or indirect Beneficial Interest will be referred to in this
Code of Ethics as a "personal securities" transaction or as a
transaction for the person's "own account").
At the written request of a person subject to this Code of Ethics, the
Clearing Officers, in their sole discretion or with the advice of
counsel, may from time to time issue written interpretations as to
whether an Access Person has a "Beneficial Interest" in a security or
a transaction, and whether a transaction is or would be considered to
be a "personal securities" transaction or a transaction "for the
person's own" account for purposes of the reporting requirements under
this Code. Any such written interpretations shall be included in
Appendix A attached to and incorporated by reference into this Code of
Ethics, and may be relied upon solely by the person(s) seeking such
interpretations.
"Clearing Officers" means any two officers of the Trust who are not:
(1) parties to the transaction;
(2) related by blood or marriage to a party to the transaction; and
(3) interested in or affiliated persons of the issuer of the securities at
issue.
"Control" means:
the power to exercise a controlling influence over the management or
policies of a company (unless such power is solely the result of an
official position with such company). Any person who owns
beneficially, directly or through one or more controlled companies,
more than 25% of the voting securities of a company shall be presumed
to control such company.
"Covered Security" means:
all stock, debt obligations and other instruments comprising the
investments of the Trust, including any warrant or option to acquire
or sell a security, and financial futures contracts, except that it
does not include:
(1) Direct obligations of the Government of the United States;
(2) Banker's acceptances, bank certificates of deposit, commercial
paper and high quality short-term debt instruments, including
repurchase agreements, and
(3) Shares issued by open-end Funds.
References to a "Security" in this Code of Ethics shall include any
warrant for, option in, or security immediately convertible into that
"Security."
"Fund" means an investment company registered under the Act, and includes
the Trust.
A "security held or to be acquired" by the Trust means:
any Covered Security which, within the most recent 15 calendar days:
(i) is or has been held by the Trust; or (ii) is being or has been
considered by an Adviser for purchase by the Trust.
A security is "being considered for purchase or sale";
from the time an order is given by or on behalf of the Trust to the
order room of the Adviser until all orders with respect to that
security are completed or withdrawn.
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III. General Prohibitions
The specific provisions and reporting requirements of the Rule and this
Code of Ethics are concerned primarily with those investment activities of
ACCESS PERSONS who are associated with the Trust and who thus may benefit
from or interfere with the purchase or sale of portfolio securities by the
Trust. However, the Rule and this Code of Ethics shall also apply to all
Affiliated Persons of the Trust, the Adviser(s) and the Underwriter
("Covered Persons"), unless specifically stated otherwise.
The Rule makes it "unlawful" for Covered Persons to engage in conduct which
is deceitful, fraudulent, or manipulative, or which involves false or
misleading statements, in connection with the purchase or sale of
securities by the Trust. Accordingly, under the Rule and this Code of
Ethics, no Covered Person shall use any information concerning the
investments or investment intentions of the Trust, or his or her ability to
influence such investment intentions, for personal gain or in a manner
detrimental to the interests of the Trust.
In addition, no Covered Person shall, directly or indirectly in connection
with the purchase or sale of a "security held or to be acquired" by the
Trust:
(i) employ any device, scheme or artifice to defraud the Trust; or
(ii) make to the Trust or an Adviser any untrue statement of material fact
or omit to state to any of the foregoing a material fact necessary in
order to make the statements made, in light of the circumstances under
which they are made, not misleading; or
(iii)engage in any act, practice, or course of business which operates or
would operate as a fraud or deceit upon the Trust; or
(iv) engage in any manipulative practice with respect to the Trust.
V. PROHIBITED TRANSACTIONS
BLACKOUT PERIODS
Subject to any additional limiting requirements that may be set forth
below, an ACCESS PERSON may not effect a personal securities transaction in
Covered Securities if he or she knows or should know at the time of
entering into the transaction that:
(i) the Trust has engaged in a transaction in the same security within the
last 15 calendar days, or is engaging in a transaction or is going to
engage in a transaction in the same security in the next 15 calendar
days; or if an Adviser has within the last 15 days considered or is
considering a transaction in the same security for the Trust, or
within the next 15 days is considering such a transaction in the
security, unless
(ii) such ACCESS PERSON (1) obtains advance written clearance of such
transaction by two Clearing Officers and (2) reports to the Trust the
information described in Paragraph VI of this Code of Ethics.
(iii)Any profits realized on unauthorized trades within the proscribed
periods shall be disgorged.
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B. INITIAL PUBLIC OFFERINGS
An ADVISORY PERSON may not acquire any security in an initial public
offering, unless such ADVISORY PERSON (1) obtains advance written clearance
of such transaction by two Clearing Officers and (2) reports to the Trust
the information described in Paragraph VI of this Code of Ethics.
C. PRIVATE PLACEMENTS
(1) An ADVISORY PERSON may not acquire any security in a private
placement, unless such ADVISORY PERSON (1) obtains advance written
clearance of such transaction by two Clearing Officers and (2) reports
to the Trust the information described in Paragraph VI of this Code of
Ethics.
When considering whether to grant approval to the ADVISORY PERSON to
engage in these transactions, the Clearing Officers shall consider,
among other factors, whether the investment opportunity should be
reserved for the Trust, and whether the opportunity is being offered
to the ADVISORY PERSON by virtue of his or her position with the
Trust. If the Clearing Officers find that the investment opportunity
should be reserved to the Trust or that the opportunity is being
offered to the ADVISORY PERSON by virtue of his or her position with
the Trust, the Clearing Officers shall refuse permission for the
ADVISORY PERSON to enter into the transaction.
(2) An ADVISORY PERSON who has been authorized to acquire securities in a
private placement or an initial public offering shall be required to
disclose that investment to the Trust and the appropriate Adviser
whenever such ADVISORY PERSON participates, either directly or
indirectly, in subsequent consideration of an investment in the issuer
by any portfolio in the Trust complex.
(3) In the event that an ADVISORY PERSON has been given approval to
acquire securities in a private placement or an initial public
offering, any decision of the Trust to purchase securities of the
issuer of such private placement or initial public offering shall be
subject to prior review by the Trust's independent trustees who have
no personal interest in the issuer.
D. BAN ON SHORT - TERM TRADING PROFITS
An ADVISORY PERSON may not profit from the purchase and sale, or sale and
purchase, of the same (or equivalent) securities within 60 calendar days.
Any profits realized on such short-term trades shall be disgorged.
F. GIFTS
ADVISORY PERSONS may not accept any gift or other thing of more than de
minimis value from any person or entity that does business with or on
behalf of the Trust.
G. SERVICE AS A DIRECTOR TO OTHER PUBLIC COMPANIES
ADVISORY PERSONS may not serve on the board of directors of any publicly
traded company, without prior authorization of a majority of the Trust's
Board of Trustees, which authorization shall be specifically based upon a
determination that the board service would be consistent with the interests
of the Trust and its shareholders. If and when such board service is
authorized, the ADVISORY PERSON serving as a director will be isolated from
other ADVISORY PERSONS who make investment decisions involving that company
through "Chinese Wall" or other procedures.
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VI. ADVANCE CLEARANCE REQUIREMENT
A. PROCEDURES
(1) From Whom Obtained
Persons who desire to enter into personal securities transactions in
transactions requiring prior approval under paragraph V above, must
obtain the written approval of any two Clearing Officers prior to
entering into such transactions.
(2) Time of Clearance
Transaction clearances must be obtained not more than three (3) days
prior to the transaction. If the trade is not made within three (3)
days of the date of clearance, a new clearance must be obtained.
(3) Form
Persons seeking authorization to enter into transactions requiring
prior clearance shall complete and sign a form approved for that
purpose by the Trust, which form shall set forth the details of the
proposed transaction. An example of such form is annexed hereto as
Schedule A ("Clearance Forms"). Upon obtaining authorization to enter
into the subject transaction, the Clearing Officers authorizing the
transaction shall affix their signatures to the Clearance Form to
indicate such approval.
(4) Filing
Copies of all completed Clearance Forms, with all required signatures,
shall be retained by the Administrator of this Code of Ethics in
accordance with the record keeping requirements set forth in Section
XII of this Code of Ethics.
B. FACTORS CONSIDERED IN CLEARANCE OF PERSONAL TRANSACTIONS
Clearing Officers may refuse to grant clearance of a personal transaction
in their sole discretion without being required to specify any reason for
the refusal. Generally, Clearing Officers will consider the following
factors in determining whether or not to authorize a proposed transaction:
(1) Whether the amount or nature of the transaction, or person
entering into the transaction, is likely to affect the price or
market for the Security;
(2) Whether the individual making the proposed purchase or sale is
likely to benefit from purchases or sales in the same or similar
security being made or being considered by the Trust; and
(3) Whether the security proposed to be purchased or sold is one that
would qualify for purchase or sale by the Trust.
VII. EXEMPT TRANSACTIONS
Neither the prohibitions nor the reporting requirements of this Code of
Ethics apply to:
(A) Purchases, sales or other acquisitions or dispositions of Securities
for an account over which the person has no direct influence or
control and does not exercise indirect influence or control;
(B) Purchases, sales or other acquisitions or dispositions of securities
which are not eligible for purchase or sale by any portfolio of the
Trust;
(C) Involuntary purchases or sales;
(D) Purchases which are part of an automatic dividend reinvestment plan;
and
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(E) Purchases or other acquisitions or dispositions resulting from the
exercise of rights acquired from an issuer as part of a pro rata
distribution to all holders of a class of securities of such issuer
and the sale of such rights;
VIII. REPORTING OF SECURITIES TRANSACTIONS
A. Reporting Requirements of Access Persons
(1) Reports Required: Unless specifically excepted by other provisions of
this Code of Ethics, every ACCESS PERSON of the Trust, Adviser(s) and
Underwriter must provide to the Administrator of this Code of Ethics
and the Adviser(s) or Underwriter, as applicable, the following
reports:
(a) Initial Holdings Reports- Not later than ten (10) days after a
person becomes an ACCESS PERSON, such person shall complete, sign
and deliver to the Trust, and the Adviser(s) or Underwriter, as
applicable, an Initial Holdings Report, a form of which is
attached to this Code of Ethics as Schedule B; except that
(i) Any person who qualified as an ACCESS PERSON prior to March
1, 2000 shall be exempt from filing an Initial Holdings
Report.
(b) Quarterly Transaction Reports- Not later than ten (10) days after
the end of each calendar quarter, each ACCESS PERSON shall make a
written report ("Quarterly Transaction Report"), a form of which
is attached to this Code of Ethics as Schedule C, to the
Administrator of this Code of Ethics and the Adviser(s) or
Underwriter, as applicable, which;
(1) With respect to any transaction during the previous calendar
quarter in a Covered Security in which the ACCESS PERSON had
any direct or indirect Beneficial Ownership, contains the
following information:
(i) The date of the transaction, the title, the interest
rate and maturity date (if applicable), the number of
shares and the principal amount of each Covered
Security involved:
(ii) The nature of the transaction (i.e., purchase, sale or
any other type of acquisition or disposition);
(iii)The price of the Covered Security at which the
transaction was effected;
(iv) The name of the broker, dealer or bank with or through
which the transaction was effected; and
(v) The date that the report is submitted by the ACCESS
PERSON.
(2) With respect to any account established by the ACCESS PERSON
in which any securities were held during the previous
quarter for the direct or indirect benefit or the ACCESS
PERSON, contains the following information:
(ii) The name of the broker, dealer or bank with whom the
ACCESS PERSON established the account;
(iii) The date the account was established; and
(iv) The date that the report is submitted by the ACCESS
PERSON.
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(c) Annual Holding Reports- Not later than thirty (30) days after the
end of the Trust's fiscal year end, each ACCESS PERSON shall make
a written report, a form of which is attached to this Code of
Ethics as Schedule D ("Annual Holdings Report"), to the
Administrator of this Code of Ethics and the Adviser(s) or
Underwriter, as applicable, which:
(1) Sets forth the title, number of shares and principal amount
of each Covered Security in which the ACCESS PERSON had any
direct or indirect beneficial ownership;
(2) Sets forth the name of any broker, dealer or bank with whom
the ACCESS PERSON maintains an account in which any
securities are held for the direct or indirect benefit of
the ACCESS PERSON;
(3) Contains the date that the report is submitted by the ACCESS
PERSON; and
(4) States that the information contained in the Annual Holdings
Report is current as of a date not greater than thirty (30)
days prior to the date the report was submitted.
B. EXEMPTIONS FROM REPORTING
(1) A person need not make an Initial Holdings Report with respect to
transactions effected for, and Covered Securities held in, any account
over which the person has no direct or indirect influence or control.
(2) A trustee of the Trust who is not an "interested person" of the Trust,
as such term is defined in Section 2(a)(19) of the Act, and who would
otherwise be required to make a report solely by reason of being a
trustee of the Trust, need not make:
(a) An Initial Holdings Report or an Annual Holdings Report; and
(b) A Quarterly Transaction Report, unless the trustee knew, or in
the ordinary course of fulfilling his or her official duties as a
trustee should have known, that during the fifteen (15) day
period immediately before or after the trustee's transaction in a
Covered Security, the Trust purchased or sold the Covered
Security, or the Trust or an Adviser considered purchasing or
selling the Covered Security.
(3) An ACCESS PERSON of the Trust's Underwriter need not make a report to
the Underwriter, if such person makes a report to the Trust and:
(a) The Underwriter is not an affiliated person of the Trust or any
Adviser to the Trust; and
(b) The Underwriter has no officer, director or general partner who
serves as an officer, director or general partner of the Trust or
an Adviser to the Trust.
(4) An ACCESS PERSON of an Adviser need not make a report to the
Adviser, if such person makes a report to the Trust and all of
the information contained in such report would duplicate
information required to be recorded under ss.ss. 275.204-2(a)(12)
or 275.204(a)(13) of the Investment Advisers Act of 1940, as
amended.
(5) An ACCESS PERSON need not make a Quarterly Transaction Report if
the Report would duplicate information contained in broker trade
confirmations or account statements received by the Trust with
respect to the ACCESS PERSON for the applicable quarterly
reporting period, but only if such broker trade confirmations or
account statements contain ALL of the information required to be
reported in the Quarterly Transaction Reports.
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C. RESPONSIBILITY TO REPORT
The responsibility for taking the initiative to report is imposed on
each individual required to make a report. Any effort by the Trust to
facilitate the reporting process does not change or alter that
responsibility.
D. WHERE TO FILE REPORT
All reports must be filed with the Administrator of this Code of
Ethics.
IX. CONFIDENTIALITY OF TRUST TRANSACTIONS
Until disclosed in a public report to shareholders or to the SEC in the
normal course of the Trust's business, all information concerning
Securities "being considered for purchase or sale" by the Trust shall be
kept confidential by all ACCESS PERSONS and disclosed by them only on a
"need to know" basis. It shall be the responsibility of the Administrator
of this Code of Ethics to report any inadequacy found by him or her to the
Board of Trustees of the Trust or any committee appointed by the Board to
deal with such information.
X. Sanctions
Any violation of this Code of Ethics shall be subject to the imposition of
such sanctions by the Trust as may be deemed appropriate under the
circumstances to achieve the purposes of the Rule and this Code of Ethics
which may include suspension or termination of employment, a letter of
censure and/or restitution of an amount equal to the difference between the
price paid or received by the Trust and the more advantageous price paid or
received by the offending person. Sanctions for violation of this Code of
Ethics by a trustee of the Trust will be determined by a majority vote of
its independent trustees.
XI. ADMINISTRATION AND CONSTRUCTION
(A) The administration of this Code of Ethics shall be the responsibility
of the Secretary of the Trust who shall serve as the "Administrator"
of this Code of Ethics.
(B) The duties of such Administrator shall include:
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(1) Continuous maintenance of a current list of the names of all
ACCESS PERSONS with an appropriate description of their title or
employment;
(2) Providing each COVERED PERSON a copy of this Code of Ethics and
informing them of their duties and obligations thereunder, and
assuring that COVERED PERSONS who are not ACCESS PERSONS are
familiar with applicable requirements of this Code of Ethics;
(3) Supervising the implementation of this Code of Ethics by the
Adviser(s) and Underwriter and the enforcement of the terms
hereof by the Adviser(s) and Underwriter;
(4) Maintaining or supervising the maintenance of all records and
reports required by this Code of Ethics;
(5) Preparing listings of all transactions effected by any ACCESS
PERSON within fifteen (15) days of the date on which the same
security was held, purchased or sold by the Trust;
(6) Determining whether any particular securities transaction should
be exempted pursuant to the provisions of this Code of Ethics;
(7) Issuing either personally, or with the assistance of counsel as
may be appropriate, an interpretation of this Code of Ethics
which may appear consistent with the objectives of the Rule of
this Code of Ethics;
(8) Conducting of such inspections or investigations, including
scrutiny of the listings referred to in the preceding
subparagraph, as shall reasonably be required to detect and
report, with his or her recommendations, any apparent violations
of this Code of Ethics to the Board of Trustees of the Trust or
any Committee appointed by them to deal with such information;
(9) Submitting a quarterly report to the trustees of the Trust
containing a description of any violation and the sanction
imposed; transactions which suggest a possibility of a violation,
and any exemptions or waivers found appropriate by the
Administrator; and any other significant information concerning
the appropriateness of this Code of Ethics.
XII. REQUIRED RECORDS
The Administrator shall maintain or cause to be maintained in an easily
accessible place, the following records:
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(A) A copy of this and any other Code of Ethics adopted pursuant to the
Rule which has been in effect during the past five (5) years;
(B) A record of any violation of such Codes of Ethics and of any action
taken as a result of such violation;
(C) A copy of each report made by the Administrator within two (2) years
from the end of the fiscal year of the Trust in which such report and
interpretation is made or issued and for an additional three (3) years
in a place which need not be easily accessible;
(D) A list of all persons who are, or within the past five (5) years have
been, required to make reports pursuant to the Rule and this Code of
Ethics; and
(E) A copy of all Initial Holdings Reports, Quarterly Transactions
Reports, and Annual Holdings Reports submitted within the last five
(5) years, the first two (2) years in an easily accessible place.
XIII. AMENDMENTS AND MODIFICATIONS
This Code of Ethics may not be amended or modified except in a written form
which is specifically approved by majority vote of the Independent Trustees
of the Trust.
This Code of Ethics was adopted by the Trust's Board of Trustees, including a
majority of the Trust's "Independent Trustees", at a meeting held on
______________________, 2000.
Witness my Signature:
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Laurie Keyes
Secretary to the Trust
<PAGE>
APPENDIX A
WRITTEN INTERPRETATIONS
TO THE CODE OF ETHICS
OF
QUAKER INVESTMENT TRUST
1. WRITTEN INTERPRETATION PURSUANT TO REQUEST OF MANU DAFTARY
Manu Daftary is the principal of DG Capital Management, Inc., a Massachusetts
corporation offering investment services. Mr. Daftary, being concurrently an
employee of and portfolio manager for Quaker Financial Advisors, Inc., a
Pennsylvania corporation providing investment advisory services to Portfolios of
the Trust, recognizes that he is an "Access Person" and an "Advisory Person", as
such terms are defined in the Code of Ethics (the "Code") of Quaker Investment
Trust (the "Trust"). Mr. Daftary seeks an opinion from the Clearing Officers of
the Trust with respect to Mr. Daftary's reporting obligations, if any, relating
to accounts of and transactions undertaken by DG Capital Management for such
accounts.
After reviewing the accounts and transactions as disclosed by Mr. Daftary, we
are of the opinion that:
a. Mr. Daftary does not have a "Beneficial Interest", as that term is
defined in the Code, in such accounts and/or transactions;
b. Such accounts are not Mr. Daftary's "own accounts", as that term is
defined in the Code;
c. Transactions in such accounts are not considered to be "personal
securities transactions", as that term is defined in the Code.
Accordingly, Mr. Daftary shall have no reporting requirements with respect to
accounts of DG Capital Management, Inc. and transactions relating to such
accounts.
Executed this ________ day of April, 2000.
_____________________________ ______________________________
By: _____________________ By: __________________________
Clearing Officer Clearing Officer
<PAGE>
SCHEDULE A
CONFIDENTIAL TRANSACTION CLEARANCE
REQUEST FORM
Pursuant to the requirements of Section V of the Code of Ethics of Quaker
Investment Trust (the "Trust"), I, ______________________, being an Access
Person of the Trust, as that term is defined in the Code, hereby request that
the Trust approve the following transaction in Covered Securities:
Name of Security: _____________________________________________________________
Number of shares/Principal amount:______________________________________________
Nature of transaction: ___________________________________
(i.e., purchase, sale or other type of acquisition or disposition);
Name of broker/dealer or bank executing transaction: ___________________________
Yes No
___ ___ The security described above represents an investment in an initial
public offering.
___ ___ The security described above represents an investment in a private
placement.
By my signature below, I swear and affirm that I have not engaged in any
transactions in the above-described securities in violation of the Trust's Code
of Ethics, that I will invest in the above-described securities only after
obtaining clearance to do so from authorized officers of the Trust, will report
all such transactions in accordance with the requirements of the Trust's Code of
Ethics, and if I receive clearance to engage in the above-described security, I
will execute the transaction not later than three (3) days after receiving
clearance or will obtain a new clearance prior to executing the transaction.
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Signature of Applicant Printed Name of Applicant
_____ After due consideration, the proposed transaction described above is
APPROVED.
_____ After due consideration, the proposed transaction is DENIED.
_____ (Check only if approving a transaction that represents an investment in an
initial public offering or in a private placement). We, the undersigned,
in the exercise of our obligations to the Trust under the Trust's Code of
Ethics, have found that the above-described transaction is not a
transaction that should be reserved to the Trust, and we further find that
the transaction is not being offered to the Applicant as a result of
his/her position with the Trust, Adviser or Underwriter.
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Signature of Clearing Officer Date Signature of Clearing Officer Date
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Printed Name Printed Name
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SCHEDULE B
CONFIDENTIAL INITIAL
HOLDINGS REPORT
The following lists all holdings in Covered Securities in which I had any
direct or indirect beneficial ownership as of ________________________. (If no
transactions took place write "None".) Sign and return to the Secretary of the
Trust not later than the 10th day after you qualify as an Access Person. Use
reverse side if additional space is needed.
HOLDINGS IN COVERED SECURITIES
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Description Number of Per Unit Total Broker executing
Transaction Date of Security Shares/Units Price Amount Transaction
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The following lists all accounts established by me as of _______________________
in which I had any direct or indirect beneficial ownership in any Securities.
(If no accounts were established, write "None".) Sign and return to the
Secretary of the Trust not later than the 10th day after you qualify as an
Access Person. Use reverse side if additional space is needed.
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Name of Broker, Dealer or Bank Date Account Established
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Name:
Date: Signature:
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<PAGE>
SCHEDULE C
QUARTERLY SECURITIES TRANSACTIONS
CONFIDENTIAL REPORT
The following lists all transactions in Covered Securities in which I
had any direct or indirect beneficial ownership during the last calendar
quarter. (If no transactions took place write "None".) Sign and return to the
Secretary of the Trust not later than the 10th day of the month following the
end of the calendar quarter. Use reverse side if additional space is needed.
PURCHASES/SALES AND OTHER DISPOSITIONS
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<TABLE>
<CAPTION>
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Purchase (P),
Sale(S), or Number of
Transaction Description Other Disposition Shares/ Per Unit Total Broker executing
Date of Security (Describe) Units Price Amount Transaction
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<S> <C> <C> <C> <C> <C> <C>
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</TABLE>
The following lists all accounts established by me during the last calendar
quarter in which I had any direct or indirect beneficial ownership in any
Securities. (If no accounts were established, write "None".) Sign and return to
the Secretary of the Trust not later than the 10th day of the month following
the end of the calendar quarter. Use reverse side if additional space is needed.
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Name of Broker, Dealer or Bank Date Account Established
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Name:
Date: Signature:
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<PAGE>
SCHEDULE B
CONFIDENTIAL ANNUAL
SECURITIES HOLDINGS REPORT
The following lists all holdings in Covered Securities in which I had
any direct or indirect beneficial ownership as of ________________________. (If
no transactions took place write "None".) Sign and return to the Secretary of
the Trust not later than the 30th day after the Trust's fiscal year end. Use
reverse side if additional space is needed.
HOLDINGS IN COVERED SECURITIES
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Description Number of Per Unit Total Broker executing
Transaction Date of Security Shares/Units Price Amount Transaction
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The following lists all accounts established by me as of _______________________
in which I had any direct or indirect beneficial ownership in any Securities.
(If no accounts were established, write "None".) Sign and return to the
Secretary of the Trust not later than the 30th day after the Trust's fiscal year
end. Use reverse side if additional space is needed.
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Name of Broker, Dealer or Bank Date Account Established
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I swear and affirm that the foregoing information is true and correct to the
best of my information and belief, and that the information included in this
report is current as of a date not later than thirty (30) days prior to the
filing of this report.
Name:
Date: Signature:
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