Morris Capital Advisors, Inc./Manor Investment Funds, Inc.
Code of Ethics



Introduction
This Code of Ethics ("Code") for the Principal Officers of Morris Capital
Advisors, Inc. ("MCA") and Manor Investment Funds, Inc. ("Fund") applies to all
officers of Morris Capital Advisors, Inc. and Manor Investment Funds, Inc.
Honesty and integrity are hallmarks of Morris Capital Advisors, Inc. and Manor
Investment Funds, Inc. We maintain the highest standards of ethics and conduct
in all of our business relationships. This Code of Business Conduct and Ethics
covers a wide range of business practices and procedures and applies to the
officers and Directors of the Fund in their conduct of the business and affairs
of the Fund. It does not cover every issue that may arise, but it sets out basic
principles to guide the officers and Directors of the Fund in discharging their
duties for the Fund. This Code has been adopted by the Directors of the Fund
with the objectives of deterring wrongdoing and promoting (1) honest and ethical
conduct, including the ethical handling of actual or apparent conflicts of
interest between personal and professional relationships, (2) full, fair,
accurate, timely and understandable disclosure in reports and documents which
the Fund files with the Securities and Exchange Commission and in other public
communications made by the Fund, (3) compliance with applicable governmental
laws, rules and regulations, (4) prompt internal reporting of violations of
this Code, and (5) accountability for adherence to this Code.

This Code is intended as a code of ethics under Section 406 of the
Sarbanes-Oxley Act of 2002 and Item 2 of Form N-CSR under the Investment Company
Act of 1940, and is specifically applicable to the principal executive officer,
principal financial officer, and principal accounting officer (or persons
performing similar functions, whether or not as officers or employees of the
Fund) of the Fund (each a "Covered Officer").

All records and reports created or maintained pursuant to this Code are intended
solely for the internal use of the Fund, are confidential, and in no event
constitute an admission by any person as to any fact, circumstance or legal
conclusion.

Compliance with Laws, Rules and Regulations
The Fund expects its officers and Directors to comply with all laws, rules and
regulations applicable to the Fund's operations and business. Officers and
Directors should seek guidance whenever they are in doubt as to the
applicability of any law, rule or regulation regarding any contemplated course
of action. The Fund and its investment adviser hold information and training
sessions to promote compliance with laws, rules and regulations, including
insider-trading laws. Please consult the various guidelines and policies, which
the Fund has prepared in accordance with specific laws and regulations. A good
guideline, if in doubt on a course of action, is "Always ask first, act later --
if you are unsure of what to do in any situation, seek guidance before you
act."

As a registered investment company, we are subject to regulation by the
Securities and Exchange Commission, and compliance with federal, state and local
laws. The Fund and its Directors insist on strict compliance with the spirit
and the letter of these laws and regulations.

Conflicts of Interest
Each officer and Director of the Fund should be scrupulous in avoiding any
conflict of interest with regard to the Fund's interests. A "conflict of
interest" occurs when an individual's private interest interferes with the
interests of the Fund. A conflict situation can arise when an officer or
Director pursues interests that prevent the individual from performing his
duties to the Fund objectively and effectively. Conflicts of interest also arise
when an officer or Director or member of the individual's family receives
undisclosed, improper benefits as a result of the individual's position with
the Fund. Any conflict of interest that arises in a specific situation or
transaction must be disclosed by the individual and resolved before taking any
action.

Matters involving a conflict of interest are prohibited as a matter of Fund
policy, except when approved by the Directors or the Fund's audit committee for
any Covered Officer or Director, or except when approved by the Fund's president
for any other individual. Conflicts of interest may not always be evident, and
individuals should consult with higher levels of management or the Fund's legal
counsel if they are uncertain about any situation. In no event, however, shall
investment in any security made in accordance with the Fund's Policy on
Personal Securities Transactions (or comparable policy or code then in
effect) be considered a conflict of interest with the Fund.

Corporate Opportunities
Officers and Directors shall not take for themselves personally opportunities
that are discovered through the use of their position with the Fund, except with
the approval of the Directors or the Fund's audit committee for any Covered
Officer or Director, or except with the approval by the Fund's president for
any other individual. Officers and Directors owe a duty to the Fund to advance
its legitimate interests when the opportunity to do so arises. In no event,
however, shall investment in any security made in accordance with the Fund's
Policy on Personal Securities Transactions (or comparable policy or code then
in effect) be considered a business opportunity of the Fund.

Confidentiality
Officers and Directors shall exercise care in maintaining the confidentiality of
any confidential information respecting the Fund, except where disclosure is
authorized or legally mandated. Officers and Directors should consult with the
Fund's legal counsel if they believe they have a legal obligation to disclose
confidential information. Confidential information includes non-public
information of the Fund that may be helpful to competitors, or otherwise
harmful to the Fund or its shareholders. The obligation to preserve
confidentiality of this information continues after association with the Fund
ends.

Fair Dealing
Officers and Directors should endeavor to deal fairly with the Fund's
shareholders, service providers and competitors, and shall not seek unfair
advantage through improper concealment, abuse of improperly acquired
confidential information, misrepresentation of material facts when the other
party is known by the officer or Director to rely justifiably on the individual
to disclose those facts truthfully, or improper and unfair dealing.

Business Gifts and Entertainment
The purpose of business entertainment and gifts in a commercial setting is to
create goodwill and sound working relationships, not to gain unfair advantage.
No gift or entertainment should ever be offered, given, provided or accepted by
any officer or Director in connection with the Fund's business unless it (1) is
not a cash gift, (2) is consistent with customary business practices, (3) is not
excessive in value, (4) cannot be construed as a bribe, payoff or kickback and
(5) does not violate any laws or regulations.

Protection and Proper Use of Fund Assets
All officers and Directors should endeavor to protect the Fund's assets and
pursue their efficient investment in accordance with the Fund's business
purposes and declaration of trust. Any suspected incident of fraud or theft
should be immediately reported for investigation as hereinafter described under
the caption "Reporting Illegal or Unethical Behavior."

The obligation of officers and Directors to protect the Fund's assets includes
its proprietary information. Proprietary information includes intellectual
property such as trademarks and copyrights, as well as business, marketing and
service plans, databases, records, salary information and any unpublished
financial data and reports. Unauthorized use or distribution of this information
 violates this Code.

Insider Trading
All officers and Directors should pay particular attention to potential
violations of insider trading laws. Insider trading is both unethical and
illegal and will be dealt with decisively if it occurs. Officers and Directors
are expected to familiarize themselves with the Policy Statement on Insider
Trading, adopted by the Fund's investment adviser. If they have questions about
these guidelines, they should consult with the Fund's president, the investment
adviser's compliance office, or the Fund's legal counsel.

Reporting Illegal or Unethical Behavior
The Directors encourage each officer to talk to senior officers, the investment
adviser's compliance officers, or the Directors about observed illegal or
unethical behavior, or when the officer is in doubt about the best course of
action in a particular situation. Officers should report actual and suspected
violations of laws, rules, regulations or this Code to appropriate personnel.
If an individual does not believe it appropriate or is not comfortable
approaching senior officers or the investment adviser's compliance officers
about their concerns, then the individual may contact any member of the Fund's
audit committee. If the individual's concerns require confidentiality, then this
confidentiality will be protected, subject to applicable law, regulation or
legal proceedings. The Fund will not permit retaliation of any kind by or on
behalf of the Fund or its officers and Directors against good faith reports or
complaints of violations of this Code or other illegal or unethical conduct.

Reporting and Disclosure
As a registered investment company, it is of critical importance that the Fund's
filings with the Securities and Exchange Commission, including specifically
shareholder reports, contain full, fair, accurate, timely and understandable
disclosure. Each officer and Director should become familiar with the
disclosure laws and regulations applicable to the Fund, consistent with the
individual's authority and duties. Depending on the Fund, each officer and
Director may be called upon to provide necessary information to ensure that
the Fund's public reports are complete, fair and understandable. The Directors
expect officers and Directors to take this responsibility very seriously and to
provide prompt and accurate answers to inquiries related to the Fund's public
disclosure requirements. Officers may be asked to certify as to the accuracy
of all responses and information provided for inclusion in the Fund's public
reports and filings.

Recordkeeping
The Fund requires accurate recording and reporting of information in order to
make responsible business decisions. The Directors expect each of the Fund's
officers, consistent with the officer's individual authority and duties, to
maintain the Fund's books, records, accounts and financial statements in
reasonable detail, and to appropriately reflect the Fund's transactions in
conformity with applicable legal requirements and the Fund's system of internal
controls.

Accounting and Financial Reporting Concerns
The Fund seeks to comply with all applicable financial reporting and accounting
regulations applicable to the Fund. Officers who have concerns or complaints
regarding questionable accounting or auditing matters or procedures involving
the Fund are encouraged to submit those concerns or complaints to the Fund's
audit committee which will, subject to its duties arising under applicable law,
regulations and legal proceedings, treat such submissions confidentially. These
submissions may be directed to the attention of the audit committee chairman, or
any Director who is a member of the audit committee, at the principal executive
offices of the Fund or at the Director's residence address.

Waivers of the Code of Business Conduct and Ethics
Any waiver of this Code for any Covered Officer or Director may be made only by
the Directors or the Fund's audit committee and will be promptly disclosed as
required by law or by Securities and Exchange Commission regulations. Waivers of
this Code for any other individual may be made by the president only upon the
individual's making full disclosure in advance of the transaction in question.
This Code may be amended or modified at any time by the Directors.