THE DESTINATION FUNDS

                   CODE OF ETHICS FOR PRINCIPAL EXECUTIVE AND
                            SENIOR FINANCIAL OFFICERS

I.   COVERED OFFICERS/PURPOSE OF THE CODE

     The code of ethics (this "Code") for The Destination  Funds (the "Company")
applies to the Company's  Principal  Executive  Officer(s),  Principal Financial
Officer(s) and Principal  Accounting  Officer(s) (the "Covered Officers" each of
whom are set forth in Exhibit A) for the purpose of promoting:

o    honest and ethical  conduct,  including  the ethical  handling of actual or
     apparent   conflicts  of  interest   between   personal  and   professional
     relationships;

o    full, fair, accurate,  timely and understandable  disclosure in reports and
     documents  that a registrant  files with, or submits to, the Securities and
     Exchange Commission ("SEC") and in other public  communications made by the
     Company;

o    compliance with applicable laws and governmental rules and regulations;

o    the prompt  internal  reporting of violations of the Code to an appropriate
     person or persons identified in the Code; and

o    accountability for adherence to the Code.


     Each Covered  Officer  should adhere to a high standard of business  ethics
and should be  sensitive to  situations  that may give rise to actual as well as
apparent conflicts of interest.

II.  COVERED OFFICERS SHOULD HANDLE  ETHICALLY ACTUAL AND APPARENT  CONFLICTS OF
     INTEREST

     OVERVIEW.  A "conflict of interest" occurs when a Covered Officer's private
interest  interferes with the interests of, or his service to, the Company.  For
example, a conflict of interest would arise if a Covered Officer, or a member of
his family, receives improper personal benefits as a result of his position with
the Company.

     Certain  conflicts  of  interest  arise  out of the  relationships  between
Covered Officers and the Company and already are subject to conflict of interest
provisions in the Investment Company Act of 1940 ("Investment  Company Act") and
the Investment  Advisers Act of 1940  ("Investment  Advisers Act"). For example,
Covered Officers may not individually  engage in certain  transactions  (such as
the purchase or sale of securities or other  property) with the Company  because
of their status as  "affiliated  persons" of the Company.  The Company's and the
investment adviser's compliance programs and procedures are designed to prevent,
or identify and correct, violations of these provisions.






This Code does not, and is not intended to, repeat or replace these programs and
procedures, and such conflicts fall outside of the parameters of this Code.

     Although  typically not  presenting an  opportunity  for improper  personal
benefit,  conflicts arise from, or as a result of, the contractual  relationship
between  the  Company  and the  investment  adviser/administrator  of which  the
Covered  Officers  are also  officers  or  employees.  As a  result,  this  Code
recognizes that the Covered  Officers will, in the normal course of their duties
(whether  formally  for the  Company  or for the  adviser/administrator,  or for
both), be involved in establishing policies and implementing decisions that will
have  different  effects  on the  adviser/administrator  and  the  Company.  The
participation  of the  Covered  Officers in such  activities  is inherent in the
contractual relationship between the Company and the  adviser/administrator  and
is consistent  with the  performance by the Covered  Officers of their duties as
officers of the Company. Thus, if performed in conformity with the provisions of
the Investment Company Act and the Investment Advisers Act, such activities will
be deemed to have been handled ethically.  In addition,  it is recognized by the
Company's  Board of Trustees  ("Board")  that the Covered  Officers  may also be
officers  or  employees  of one or more  investment  companies  covered by other
codes.

     Other conflicts of interest are covered by the Code, even if such conflicts
of interest are not subject to provisions in the Investment  Company Act and the
Investment  Advisers Act. The following  list provides  examples of conflicts of
interest  under the Code,  but Covered  Officers  should keep in mind that these
examples  are not  exhaustive.  The  overarching  principle is that the personal
interest  of a Covered  Officer  should  not be  placed  improperly  before  the
interest of the Company.

     Each Covered Officer must:

o    not use his personal  influence  or personal  relationships  improperly  to
     influence  investment  decisions  or  financial  reporting  by the  Company
     whereby the Covered  Officer would  benefit  personally to the detriment of
     the Company;

o    not cause the  Company  to take  action,  or fail to take  action,  for the
     individual  personal benefit of the Covered Officer rather than the benefit
     of the Company;

o    not use material  non-public  knowledge of portfolio  transactions  made or
     contemplated  for the Company to trade  personally or cause others to trade
     personally in contemplation of the market effect of such transactions;

o    report at least annually any affiliations or other relationships related to
     conflicts   of  interest   that  the   Company's   Trustees   and  Officers
     Questionnaire covers.


     There are some  conflict  of  interest  situations  that  should  always be
discussed with Counsel for the Company if material. Examples of these include:

o    service as a director on the board of any public company;

o    the receipt of any non-nominal gifts;


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o    the receipt of any  entertainment  from any company  with which the Company
     has current or prospective  business dealings unless such  entertainment is
     business-related, reasonable in cost, appropriate as to time and place, and
     not so frequent as to raise any questions of impropriety;

o    any ownership  interest in, or any  consulting  or employment  relationship
     with,  any of the Company's  service  providers,  other than its investment
     adviser,  principal  underwriter,  administrator  or any affiliated  person
     thereof;

o    a direct or indirect financial interest in commissions, transaction charges
     or spreads paid by the Company for effecting portfolio  transactions or for
     selling or redeeming shares other than an interest arising from the Covered
     Officer's employment, such as compensation or equity ownership.


III. DISCLOSURE AND COMPLIANCE

o    each  Covered  Officer  should  familiarize  himself  with  the  disclosure
     requirements generally applicable to the Company;

o    each Covered Officer should not knowingly misrepresent,  or cause others to
     misrepresent,  facts about the Company to others, whether within or outside
     the Company,  including to the Company's  directors  and  auditors,  and to
     governmental regulators and self-regulatory organizations;

o    each Covered Officer should, to the extent  appropriate  within his area of
     responsibility,  consult with other  officers and  employees of the Company
     and the  adviser/administrator  with  the  goal of  promoting  full,  fair,
     accurate, timely and understandable disclosure in the reports and documents
     the  Company  files  with,  or  submits  to,  the SEC and in  other  public
     communications made by the Company; and

o    it is the responsibility of each Covered Officer to promote compliance with
     the  standards  and  restrictions  imposed by  applicable  laws,  rules and
     regulations.


IV.  REPORTING AND ACCOUNTABILITY

     Each Covered Officer must:

o    upon  adoption of the Code (or  thereafter as  applicable,  upon becoming a
     Covered  Officer),  affirm in writing  to the Board  that he has  received,
     read, and understands the Code;

o    annually  thereafter  affirm to the  Board  that he has  complied  with the
     requirements of the Code;

o    not  retaliate  against any other  Covered  Officer or any  employee of the
     Company or their  affiliated  persons for reports of  potential  violations
     that are made in good faith; and


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o    notify  Counsel for the Company  promptly if he knows of any  violation  of
     this Code. Failure to do so is itself a violation of this Code.


Counsel  for the  Company is  responsible  for  applying  this Code to  specific
situations in which  questions  are presented  under it and has the authority to
interpret  this Code in any  particular  situation.  However,  any  approvals or
waivers  sought by a Covered  Officer will be considered by the Audit  Committee
(the "Committee").

     The Company will follow these  procedures  in  investigating  and enforcing
this Code:

o    Counsel for the Company will take all appropriate action to investigate any
     potential violations reported to him;

o    if,  after such  investigation,  Counsel  believes  that no  violation  has
     occurred, Counsel is not required to take any further action;

o    any matter that  Counsel  believes  is a violation  will be reported to the
     Committee;

o    if the Committee concurs that a violation has occurred,  it will inform and
     make a recommendation to the Board, which will consider appropriate action,
     which may include review of, and appropriate  modifications  to, applicable
     policies  and  procedures;  notification  to  appropriate  personnel of the
     investment  adviser/administrator  or its  board;  or a  recommendation  to
     dismiss the Covered Officer;

o    the Board will be responsible for granting waivers, as appropriate; and

o    any  changes to or waivers of this Code will,  to the extent  required,  be
     disclosed as provided by SEC rules.


V. OTHER POLICIES AND PROCEDURES

     This Code  shall be the sole  code of ethics  adopted  by the  Company  for
purposes  of  Section  406 of the  Sarbanes-Oxley  Act and the  rules  and forms
applicable  to  registered  investment  companies  thereunder.  Insofar as other
policies  or  procedures  of  the  Company,  the  Company's  adviser,  principal
underwriter, or other service providers govern or purport to govern the behavior
or  activities  of the Covered  Officers who are subject to this Code,  they are
superseded  by this Code to the extent that they  overlap or  conflict  with the
provisions  of this  Code.  The  Company's  and  its  investment  adviser's  and
principal  underwriter's  codes of ethics under Rule 17j-1 under the  Investment
Company Act are  separate  requirements  applying to the  Covered  Officers  and
others, and are not part of this Code.


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VI.  AMENDMENTS

     Any  amendments to this Code,  other than  amendments to Exhibit A, must be
approved or ratified  by a majority  vote of the Board,  including a majority of
independent trustees.

VII. CONFIDENTIALITY

     All reports and records  prepared or maintained  pursuant to this Code will
be considered  confidential  and shall be maintained and protected  accordingly.
Except as  otherwise  required by law or this Code,  such  matters  shall not be
disclosed to anyone other than the Board and Counsel for the Company.

VIII. INTERNAL USE

     The Code is intended  solely for the  internal  use by the Company and does
not  constitute  an admission,  by or on behalf of the Company,  as to any fact,
circumstance, or legal conclusion.




Date: April 18, 2005








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                                                                       EXHIBIT A


                     Persons Covered by this Code of Ethics
                     --------------------------------------

                              Michael A. Yoshikami
                                  Mark J. Seger









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