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CENTURA FUNDS, INC.
AND
ASSET MANAGEMENT GROUP
CENTURA FUNDS ACCESS PERSONS
CODE OF ETHICS
Governing Purchase and Sale of Securities by Each Access Person
Effective February 24, 2000
This Code of Ethics is adopted in accordance with Rule 17j-1 under the
Investment Company Act of 1940 ("1940 Act") by Centura Funds, Inc. ("Company")
and by Centura Bank with respect to the Asset Management Group. This rule makes
it unlawful for employees identified as "access persons" in connection with the
purchase and sale by such person of a security "held or to be acquired by the
Company's series ("Funds"):
1. To employ any device, scheme or artifice to defraud the Company or a
Fund;
2. To make to the Company or a Fund an untrue statement of a material fact
or omit to state to the Company or a Fund a material fact necessary in
order to make the statement made, in light of the circumstances under
which they are made, not misleading;
3. To engage in any act, practice or course of business which operates or
would operate as fraud or deceit upon the Company or a Fund; or
4. To engage in any manipulative practice with respect to the Company or a
Fund.
A security is "held or to be acquired" if within the most recent 15 days it (i)
is or has been held by a Fund, or (ii) is being considered by a Fund or by the
Asset Management Group for purchase by a Fund.
To ensure compliance with these restrictions Centura Funds, Inc. and the Asset
Management Group adopt and agree to be governed by the provisions contained in
this Code of Ethics and each person identified as an "Access Person" agrees to
be governed by the provisions in this Code of Ethics, provided that Access
Persons who are affiliated with the Company's Administrator and Distributor will
be subject to the Code of Ethics of BISYS Fund Services, Inc.
The trading restrictions and reporting requirements of this Code of Ethics shall
not apply to any director of the Company who is not an "interested person" of
the Company (as defined in Section 2(a) (19) of the 1940 Act) except with
respect to securities transactions where such director knew; or in the course of
ordinary business or fulfilling his or her official duties as a director of the
Company should have known that such security was being purchased or sold by a
Fund or that purchase or sale of such security was being considered by or with
respect to a Fund.
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1. General Principles
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The Company and Asset Management Group shall be governed by the following
principles and shall apply them to their "Access Persons", as applicable.
A. No "Access Person" shall engage in any act, practice or course of
conduct that would violate the provisions of Rule 17j-1 set forth.
B. The interest of the Funds and their shareholders are paramount and come
before the interest of any "Access Person" or employee.
C. Personal investing activities of all "Access Persons" and employees
shall be conducted in a manner that shall avoid actual or potential
conflicts of interest with the Funds and their shareholders.
D. "Access Persons" shall not use such positions, or any investment
opportunities presented by virtue of such positions, to the detriment
of the Funds and their shareholders.
II. Substantive Restrictions
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A. The price paid or received by a Fund for any security should not be
affected by a buying or selling interest on part of an "Access Person",
or otherwise result in an inappropriate advantage to the "Access
Person". To that end;
(a) no "Access Person" shall enter an order for the purchase or sale of
a security which a Fund is, or is considering, purchasing or selling
until the day after the Fund's transaction in that security has been
completed.
(b) a Portfolio Manager of a Fund may not buy or sell a security within
seven days before or after a Fund trades in the security.
B. No "Access Person" may acquire any securities issued as part of an
initial public offering of the issuer.
C. Each "Access Person" must seek prior approval from the individual
designated as Compliance Officer for the Asset Management Group
(Compliance Officer) for private placement transactions. The Compliance
officer will approve or disapprove the transactions based on conflicts
of interest with the Funds or this Code of Ethics.
D. An "Access Person" must not accept gifts in excess of the limits
contained in Section 2830(1) of the Conduct Rules of the National
Association of Securities Dealers from any entity doing business with
or on behalf of a Fund.
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E. An "Access Person" shall not serve on the boards of directors of
publicly traded companies, or in any similar capacity, absent the prior
approval of such service by the Compliance Officer following the
receipt of a written request for such approval.
F. Any profits derived from securities transactions in violation of
paragraphs A, B or C above, shall be forfeited and paid to the
appropriate Fund or Funds for the benefit of its or their shareholders.
Gifts accepted in violation of paragraph D shall be forfeited, if
practicable, and/or dealt with in any manner determined appropriate and
in the best interest of any affected Fund and it shareholders.
G. The restrictions of this Section II shall not apply to the following
transactions unless the Compliance Officer determines that such
transactions violate the General Principles of this Code:
1. reinvestment of dividends pursuant to a plan;
2. transactions in: securities which are the direct obligation of the U.
S. Government; other short-term securities issued or guaranteed by an
agency or instrumentality of the U. S. Government; bankers'
acceptances; U. S. bank certificates of deposits; and commercial paper.
3. transactions in which direst or indirect beneficial ownership is not
acquired or disposed of,
4. transactions in accounts as to which the "Access Person' has no
investment control.
5. transactions in accounts of an "Access Person" for which investment
discretion is not maintained by the "Access Person" but is granted to
any of the following that are unaffiliated with the Investment
Division: a registered broker-dealer, registered investment adviser or
other investment manager acting in a similar fiduciary capacity,
provided the following conditions are satisfied: (a) the terms of the
account agreement ("Agreement") must be in writing and filed with the
Compliance Officer prior to any transaction; (b) any amendments to the
Agreement must be filed with the Compliance Officer prior to its
effective date; (c) the Agreement must require the account manager to
comply with the reporting provisions of this Code; (d) the Agreement
shall prohibit: acquisitions of securities in initial public offerings;
acquisitions of securities in private placements unless prior approval
is obtained by the "Access Person" from the Compliance Officers and (e)
the exemption provided by this section shall not be available for a
transaction or class of transactions which is suggested or directed by
the "Access Person" or to which the "Access Person" has acquired
advanced information; and
6. transactions in securities in connection with an employer sponsored or
other tax qualified plan, such as a 401(k), an IRA or ESOP, in an
amount not exceeding $1,000 in any calendar month.
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III. Procedures
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To enable the Company and Asset Management Group to determine with reasonable
assurance whether the provisions of Rule 17j-1 and the Code of Ethics are being
observed by "Access Persons":
A. Upon being identified as an "Access Person", each "Access Person" shall
within 10 days provide to the designated person a report listing
his/her holdings of all covered securities and annually thereafter.
"Covered securities" include generally all securities and financial
instruments related to securities except: securities that are direct
obligations of the U. S. Government; open-end mutual fund companies,
banker acceptances, bank certificates of deposit, commercial paper, and
high quality short-term instruments including repurchase agreements.
B. Each "Access Person" shall quarterly disclose in writing, in a form
acceptable to the Compliance Officer all direct or indirect "Beneficial
Ownership" interest of such "Access Persons" in "Covered securities".
C. Each "Access Person" shall obtain prior approval for personal
securities transactions in Covered securities as required by policy and
procedures.
D. Each "Access Person" shall notify the Compliance Officer of all
brokerage accounts in which he or she has any beneficial interest (a)
within 10 days of being identified as an "Access Person" or (b)
promptly after the later opening of any such account.
E. Each "Access Person" with respect to each brokerage account in which
such "Access Person" has any beneficial ownership or interest shall
arrange that the broker shall mail directly to the Compliance Officer
duplicate statements.
"Beneficial Ownership" generally means having a direct or indirect
pecuniary interest in a security that is legally defined to be
beneficial ownership. Beneficial ownership is presumed regarding
securities and accounts held in the name of a spouse or any family
member living in the same household. Beneficial ownership also extends
to transactions by entities over which a person has ownership, voting
or investment control, including corporations (and similar entities),
trusts and foundations.
F. Upon notice from the Company or the Asset Management Group that an
employee has been identified as an "Access Person" the Compliance
Officer shall immediately send this person a copy of the Code of Ethics
and the Initial Access Person Acknowledgment Form. The "Access Person"
will be require to complete a written acknowledgment that he/she
understands the restrictions and requirements of the Code.
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G. The Compliance Officer shall implement a system of monitoring personal
investment activity by "Access Persons" which would identify abusive or
inappropriate trading patterns or other practices of "Access Persons".
H. The Compliance Officer will report any questionable personal investment
activities which appear to violate the restrictions and covered
securities transactions to senior management of the Company or the
Asset Management Group, as applicable.
I. The Compliance Officer will provide the Board of Directors a report
noting any violations of this code on an annual basis.
