TURNER INVESTMENT DISTRIBUTORS, INC.
                   (Principal Underwriter of the Turner Funds)

                     PERSONAL TRADING POLICY/CODE OF ETHICS

                                December 1, 2001

A.   When  used in  this  Personal  Trading  Policy/Code  of  Ethics,  the  term
     "employee" includes any director,  officer or employee of Turner Investment
     Distributors, Inc. (TID), or any independent contractor or other person who
     is licensed  with the National  Association  of  Securities  Dealers,  Inc.
     (NASD) as a registered representative or principal of, with or through TID.

B.   Beneficial  ownership:  An employee should consider  himself the beneficial
     owner of those  securities held by him, his spouse,  his minor children,  a
     relative  who  shares his  house,  or  persons  by reason of any  contract,
     arrangement,  understanding or relationship  that provides him with sole or
     shared voting or investment power.

C.   Employees are barred from  purchasing  any  securities  (to include  Common
     Stock and related Options,  Convertible securities,  Options, or Futures on
     Indexes) in which TID, any of its affiliated companies or any of the mutual
     funds for  which TID acts as  principal  underwriter  has  either a long or
     short position. If an employee owns a position in any security, he must get
     written pre-clearance from the President or Chief Compliance Officer to add
     to or sell the position.  ALL SECURITY  TRANSACTIONS  (BUY OR SELL) REQUIRE
     WRITTEN CLEARANCE IN ADVANCE. Approval is good for 48 hours; if a trade has
     not been executed,  subsequent  approvals are necessary  until the trade is
     executed. The Exception Committee (the President, Vice President, and Chief
     Compliance Officer) must approve any exceptions to this rule.

D.   Employees   may   not   purchase   initial   public   offerings.    Private
     placements/Limited partnerships require written pre-clearance.  Mutual fund
     holdings are excluded from pre-clearance and reporting. IRA's, and Rollover
     IRA's that are self-directed  (i.e. stocks or bonds, not mutual funds), and
     ESOP's (Employee stock ownership plans) require pre-clearance.

E.   Blackout Restrictions:  Employees are subject to the following restrictions
     when  their  purchases  and sales of  securities  coincide  with  trades of
     clients of TID  (including  any mutual fund for which TID acts as principal
     underwriter) or trades of clients (including  investment  companies) of any
     affiliated companies of TID:

     1.   Purchases  and sales  within  three  days  following  a client  trade.
          Employees  are  prohibited  from  purchasing  or selling any  security
          within three calendar days after a client  transaction in the same (or
          a related) security.  The Exception Committee must approve


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          exceptions.  If an employee makes a prohibited  transaction without an
          exception the employee must unwind the  transaction and relinquish any
          gain from the transaction to charity.

     2.   Purchases within seven days before a client purchase.  An employee who
          purchases  a  security  within  seven  calendar  days  before a client
          purchases the same (or a related)  security is prohibited from selling
          the security of a period of six months  following the client's  trade.
          The Exception Committee must approve exceptions.  If an employee makes
          a prohibited  sale without an exception  within the six month  period,
          the employee must relinquish any gain from the transaction to charity.

     3.   Sales within seven days before a client sale.  An employee who sells a
          security  within  seven  days  before  a client  sells  the same (or a
          related)  security must  relinquish to charity the difference  between
          the  employee's  sale price and the client's sale price  (assuming the
          employee's sale price is higher).

F.   Short Term Trading Rule - Employees may not take profits in any security in
     less than 60 days  (includes  Options,  Convertibles  and  Futures).  If an
     individual  must trade within this period,  the  Exception  Committee  must
     grant approval or the employee must relinquish such profits to charity. The
     closing of positions at a loss is not  prohibited.  Options that are out of
     the money may be exercised in less than 60 days.

G.   Reporting:  For purposes of the  provisions of Rule 17j-1 of the Investment
     Company Act of 1940, all employees will be treated as "access  persons" and
     must submit the following:

     1.   Initial  Holdings  Report -  within  ten  (10)  days of hire,  all new
          employees  are required to file a signed and dated  Initial and Annual
          Accounts and Holdings  Report,  setting forth the title, the number of
          shares,  and the  principal  amount of each covered  security in which
          they have any direct or indirect beneficial ownership; and the name of
          any  broker,  dealer,  or bank with whom an account is  maintained  in
          which any  covered  securities  are held for their  direct or indirect
          benefit.

     2.   Annual  Holdings  Report  - on an  annual  basis,  all  employees  are
          required  to file  within  thirty  (30) days of  year-end a signed and
          dated  Initial and Annual  Accounts  and Holdings  Report  listing all
          securities beneficially owned as of December 31st. Within this Report,
          all  employees  must list the title,  the  number of  shares,  and the
          principal amount of each covered security in which they had any direct
          or indirect beneficial ownership;  and the name of any broker, dealer,
          or bank with  whom an  account  was  maintained  in which any  covered
          securities were held for their direct or indirect benefit.

     3.   Quarterly  Transaction  Reports - All employees must submit within ten
          (10) days  following  the end of each  calendar  quarter a signed  and
          dated report listing all  transactions  executed during that preceding
          calendar quarter, along with duplicate


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          statements/confirmations. For each transaction, employees are required
          to list the date, the title,  the interest rate (if  applicable),  the
          number of shares and the  principal  amount of each  covered  security
          involved;  the nature of the  transaction  (i.e.,  purchase,  sale, or
          other  type  of  acquisition/disposition);  the  price  at  which  the
          transaction was effected;  and the name of any broker, dealer, or bank
          through which the transaction was effected. Statements are reviewed by
          one of the firm's Series 24  principals.  Brokerage,  IRA's,  Rollover
          IRA's  (which are  self-directed),  ESOP's,  private  placements,  and
          limited partnerships must all be reported as personal trading.

     4.   Annual  Certification - All employees are required to certify annually
          to the Compliance  Department  that: (i) they have read and understand
          the Personal  Trading  Policy/Code of Ethics;  (ii) they have complied
          with all requirements of the Personal  Trading  Policy/Code of Ethics;
          and (iii) they have reported all transactions  required to be reported
          under the Personal Trading Policy/Code of Ethics.

H.   Violation  of this  Personal  Trading  Policy/Code  of Ethics may result in
     disciplinary action, up to and including termination of employment.

I.   Exclusion:  So long as an  employee  of TID is  also a  director,  officer,
     employee or other person  subject to a personal  trading  policy or code of
     ethics adopted by a registered  investment adviser,  such employee shall be
     excluded from the following:

     (1)  the  requirements  under  Sections C, D, E and F above to pre-clear or
          obtain approval of specified transactions;

     (2)  all trading bars, limits and restrictions under Sections C, D, E and F
          above and all provisions  requiring the unwinding of transactions  and
          the relinquishment of proceeds under those sections; and

     (3)  the reporting,  filing and certification  requirements under Section G
          above;

     provided that such adviser:

     (i)  certifies  to TID that its personal  trading  policy or code of ethics
          was adopted pursuant to Rule 17j-1 under the Investment Company Act of
          1940 and is sufficient to satisfy the requirements of that rule; and

     (ii) agrees to provide TID the following:

          (a)  at  least  once a year,  upon  request,  a  written  report  that
               describes any issues(s)  that arose during the previous 12 months
               under  the  adviser's  policy  or code,  including  any  material
               violations, and any resulting sanctions;

          (b)  an immediate report,  without request, of all material violations
               of such policy or code by any person who is a TID employee;

          (c)  prompt written  notice of all material  amendments to such policy
               or code.


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J.   Acknowledgment:   By  signing  the  TID,  Inc.   Acknowledgment  form,  you
     acknowledge  that  you have  read and  understand  the  foregoing  Personal
     Trading  Policy/Code  of Ethics and will comply in all  respects  with such
     policy/code.


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