As Revised and Updated April 1, 2007

As a fiduciary, Harman Investment Advisors (the firm) has an affirmative duty to act in the best interests of clients.

Supervised persons are also expected to act in the best interests of clients and place clients' interests before their own interests.

•  They have an obligation to protect the firm's reputation by conducting business with the honesty and integrity expected of an investment professional.

•  They should use particular care in determining the applicable fiduciary duty and shall comply with such duty as to those persons and interests to whom the duty is owed.

Therefore, supervised persons shall not engage in any conduct involving dishonesty, fraud, deceit, or misrepresentation, or commit any act that reflects adversely on their honesty, trustworthiness, or professional competence.

All supervised persons are expected to:

•  Place the interests of clients first.

•  Avoid (a) actual or potential conflicts of interest, (b) abusing a client's trust, or (c) taking inappropriate advantage of their position with the firm when making personal securities transactions.

•  Maintain the confidentiality of information (a) concerning client's financial circumstances, the identity of their security holdings, etc. and (b) regarding the firm's research, recommendations, and portfolio holdings.

•  Use reasonable care and judgment to achieve and maintain independence and objectivity when making investment recommendations or taking investment actions.

Supervised persons are required to report any violations of the Code of Ethics (or suspected violations thereof) promptly to the firm's Chief Compliance Officer.

Failure to comply with the firm's Compliance Policies, including the firm's Code of Ethics (Code of Ethics and Standards of Business Conduct), may result in disciplinary action, including termination of employment.