TURNER INVESTMENT PARTNERS, INC.
                     PERSONAL TRADING POLICY/CODE OF ETHICS

                               Dated July 10, 2003


A.       Personal investments: 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.

B.       Employees are barred from purchasing any securities (to include Common
         Stock and related Options, Convertible securities, Options, or Futures
         on Indexes) in which the firm has either a long or short position. If
         an employee owns a position in any security, he must get written
         pre-clearance from the Chairman or President 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 Chairman, Vice Chairman,
         President, and Director of Compliance) must approve any exceptions to
         this rule.

C.       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.

D.       Blackout Restrictions: Employees are subject to the following
         restrictions when their purchases and sales of securities coincide with
         trades of Turner Clients (including investment companies):

         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
            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).

                                       1



         4. These restrictions do not apply to proprietary investment
            partnerships for which the firm acts as an adviser in which the
            officers and employees of the adviser have an equity interest of
            less than 50%.

E.       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 with in 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. The proprietary partnerships may take profits in less
         than 60 days.

F.       Reporting: Consistent with the requirements of the Investment Advisers
         Act of 1940 - Rules 204-2 (a)(2) and (a)(3), and with the provisions of
         Rule 17j-1 of the Investment Company Act of 1940, all employees are
         considered 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 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 Annual 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 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.

                                       2



G.       Violation of the Personal Investments/Code of Ethics policy may result
         in disciplinary action, up to and including termination of employment.

                                       3


                 TRADING DISCLOSURES AND HOLDINGS REPORT POLICY


As you are aware, Turner must comply with the industry's ethics rules. We may
have taken a broader stance than other companies regarding Trading Disclosures
and Holdings Reporting, but it is this strict code of ethics and attention to
detail that has made Turner what it is today, an employer of choice and leader
within our industry.

As employees of Turner, we agree to abide by internal policies and procedures.
We must be aware that quarterly TRADING DISCLOSURES AND HOLDINGS REPORTING is a
requirement of our employment at Turner.



IT IS YOUR INDIVIDUAL RESPONSIBILITY TO PROVIDE THIS INFORMATION, WITHIN 10 DAYS
OF THE CLOSE OF THE QUARTER END.

WE HOLD SPECIAL APPRECIATION FOR THOSE INDIVIDUALS WHO HAVE COMPLIED STRICTLY
AND CONSISTENTLY, AND SUPPORT THEIR GOOD EFFORTS IN THAT REGARD.

WE WILL NOT TOLERATE A VIOLATION OF THIS POLICY; THEREFORE A PENALTY MUST BE SET
FOR THOSE WHO CONSCIOUSLY DISREGARD THIS POLICY. ANY EMPLOYEE WHO HAS NOT MEET
THE REQUIREMENTS OF THE TRADING DISCLOSURES AND HOLDINGS REPORT POLICY AND
PROVIDED SUCH INFORMATION TO THE COMPLIANCE DEPARTMENT BY THE CLOSE OF BUSINESS
DAY ON THE 10TH DAY AFTER QUARTER END WILL BE SUBJECT TO DISCIPLINARY ACTION.
SUCH DISCIPLINARY ACTION MAY INCLUDE A WRITTEN DISCIPLINARY LETTER TO BE
INCLUDED IN THE EMPLOYEE'S PERMANENT EMPLOYMENT RECORDS OR A REQUIREMENT THAT
THE EMPLOYEE LEAVE THE PREMISES AND STAY AWAY WITHOUT PAY UNTIL THE REPORT HAS
BEEN FILED.



Future disregard of this policy by any individual will result in further
disciplinary action (including the possibility of termination), the severity
depending on the liability such disregard places upon our Firm.

                                       4