Pre-Effective Amendment to Registration Statement of an Open-End Management Investment Company — Form N-1A
Filing Table of Contents
Document/Exhibit Description Pages Size
1: N-1A/A Pre-Effective Amendment to Registration Statement 66± 288K
of an Open-End Management Investment
Company
2: EX-99.A(III) Written Instrument Fixing 1 8K
3: EX-99.A(IV) Written Instrument Establishing 2± 12K
4: EX-99.B(I) Amendment to Bylaws 1 8K
5: EX-99.D Advisory Agreement 6± 26K
6: EX-99.D(I) Expense Waiver and Reimbursement Agreement 2± 10K
7: EX-99.E Distribution Agreement 7± 30K
8: EX-99.G Custody Agreement 27± 90K
9: EX-99.H(I) Admistration Agreement 8± 31K
10: EX-99.H(II) Transfer Agent Servicing Agreement 8± 31K
11: EX-99.H(III) Fund Accounting 8± 32K
12: EX-99.H(IV) Shareholder Services Agreement 4± 19K
13: EX-99.H(V) Fullfilment Agreement 4± 16K
14: EX-99.I Opinion and Consent of Counsel 1 11K
15: EX-99.L Agreement Relating to Initial Capital 1 8K
16: EX-99.M Rule 12B-1 Plan 8± 35K
17: EX-99.N Rule 18F-3 Plan 3± 14K
18: EX-99.P Code of Ethics 16± 56K
ALLIED ASSET ADVISORS FUNDS
ALLED ASSET ADVISORS, INC.
JOINT CODE OF ETHICS
SECTION I STATEMENT OF GENERAL FIDUCIARY PRINCIPLES
This Code of Ethics (the "Code") has been approved by the Board of
Trustees of Allied Asset Advisors Funds (the "Trust"), including a majority of
the Trustees who are not "interested persons" of the Trust ("Independent
Trustees"), as defined by the Investment Company Act of 1940 (the "1940 Act").
The Code has been adopted by the Trust and Allied Asset Advisors, Inc. (the
"Advisor"), the investment advisor of the Trust, in compliance with Rule 17j-1
under the 1940 Act. The purpose of the Code is to establish standards and
procedures for the detection and prevention of activities by which persons
having knowledge of the investments and investment intentions of the Trust may
abuse their fiduciary duties to the Trust and otherwise to deal with the types
of conflict of interest situations to which Rule 17j-1 is addressed.
The Code is based on the principle that the trustees and officers of
the Trust and the personnel of the Advisor who provide services to the Trust,
owe a fiduciary duty to the Trust to conduct their personal securities
transactions in a manner that does not interfere with the Trust's transactions
or otherwise take unfair advantage of their relationship with the Trust. All
such trustees, officers and personnel of the Trust and the Advisor ("Trust
Employees") are expected to adhere to this general principle as well as to
comply with all of the specific provisions of this Code that are applicable to
them.
Technical compliance with the Code will not automatically insulate any
Trust Employee from scrutiny of transactions that show a pattern of compromise
or abuse of the individual's fiduciary duties to the Trust. Accordingly, all
Trust Employees must seek to avoid any actual or potential conflicts between
their personal interests and the interests of the Trust and its shareholders. In
sum, all Trust Employees shall place the interests of the Trust before their own
personal interests.
Every Trust Employee must read and retain this Code of Ethics, and
should recognize that he or she is subject to its provisions.
The Trust and the Advisor shall use reasonable diligence and institute
procedures reasonably necessary to prevent violations of this Code.
SECTION II DEFINITIONS
(A) "Access Person" means any trustee, director, general partner, officer,
or Advisory Person (as defined below) of the Trust or of the Advisor.
(B) An "Advisory Person" of the Trust or of the Advisor means: (i) any
employee of the Trust or the Advisor, or of any company in a control
relationship to the Trust or the Advisor, who in connection with his or her
regular functions or duties makes, participates in, or obtains current
information regarding the purchase or sale of any Security by the Trust, or
whose functions relate to the making of any recommendations with respect to such
purchases or sales; and (ii) any natural person in a control relationship to the
Trust or the Advisor who obtains information concerning current recommendations
made to the Trust with regard to the purchase or sale of any current Security.
(C) "Beneficial Ownership" has the meaning set forth in paragraph (a)(2) of
Rule 16a-1 under the Securities Exchange Act of 1934, except that the
determination shall apply to all securities which an Access Person has or
acquires. For purposes of this Code, Beneficial ownership shall be deemed to
include, but not be limited to, any interest by which an Access Person or any
member of his or her immediate family (i.e., a person who is related by blood or
marriage to, and who is living in the same household as, the Access Person) can
directly or indirectly derive a monetary or other economic benefit from the
purchase, sale (or other acquisition or disposition) or ownership of a Security,
including for this purpose any such interest that arises as a result of: a
general partnership interest in a general or limited partnership; an interest in
a trust; a right to dividends that is separated or separable from the underlying
Security; a right to acquire equity Securities through the exercise or
conversion of any derivative Security (whether or not presently exercisable);
and a performance related advisory fee (other than an asset based fee).1
(D) "Compliance Officer" means the chief compliance officer of the
Advisor.
(E) "Control" shall have the same meaning as that set forth in Section
2(a)(9) of the 1940 Act.
(F) "Covered Security" means any Security (as defined below) other than a
Security that is: (i) a direct obligation of the Government of the United
States; (ii) a banker's acceptance, certificate of deposit, commercial paper, or
high quality short-term debt security, including a repurchase agreement; or
(iii) a share of an open-end investment company registered under the 1940 Act.
(G) "Independent Trustee" means a trustee of the Trust who is not an
"interested person" of the Trust within the meaning of Section 2(a)(19) of the
1940 Act.
(H) "Initial Public Offering" means an offering of securities registered
under the Securities Act of 1933, the issuer of which, immediately before the
registration, was not subject to the reporting requirements of Section 13 or
Section 15(d) of the Securities Exchange Act of 1934.
(I) "Investment Personnel" means: (i) any employee of the Trust or the
Advisor (or of any company controlling, controlled by or under common control
with the Trust or the Advisor) who, in connection with his or her regular
functions or duties, makes or participates in making recommendations regarding
the purchase or sale of Securities by the Trust; and (ii) any natural person who
controls the Trust or the Advisor and who obtains information concerning current
recommendations made regarding the purchase or sale of Securities by the Trust.
(J) "Limited Offering" means an offering of Securities that is exempt from
registration under the Securities Act of 1933 pursuant to Section 4(2) or
Section 4(6) thereof or Rule 504, Rule 505 or Rule 506 thereunder.
(K) "Security" includes all stock, debt obligations and other securities
and similar instruments of whatever kind, including any warrant or option to
acquire or sell a security. References to a Security in this Code (e.g., a
prohibition or requirement applicable to the purchase or sale of a Security)
shall be deemed to refer to and to include any warrant for, option in, or
Security immediately convertible into that Security, and shall also include any
instrument (whether or not such instrument itself is a Security) which has an
investment return or value that is based, in whole or part, on that Security
(collectively, "Derivatives"). Therefore, except as otherwise specifically
provided by this Code: (i) any prohibition or requirement of this Code
applicable to the purchase or sale of a Security shall also be applicable to the
purchase or sale of a Derivative relating to that Security; and (ii) any
prohibition or requirement of this Code applicable to the purchase or sale of a
Derivative shall also be applicable to the purchase or sale of a Security
relating to that Derivative.
(L) A Security is "being considered for purchase or sale" when a
recommendation to purchase or sell that Security has been made or communicated
and, with respect to the person making the recommendation, when such person
seriously considers making such a recommendation.
(M) "Trust Employee" means any person who is a trustee, director, officer
or employee of the Trust or the Advisor.
SECTION III OBJECTIVE AND GENERAL PROHIBITIONS
Although certain provisions of this Code apply only to Access Persons,
all Trust Employees must recognize that they are expected to conduct their
personal activities in accordance with the standards set forth in Sections I,
III and VII of this Code. Therefore, a Trust Employee may not engage in any
investment transaction under circumstances where the Trust Employee benefits
from or interferes with the purchase or sale of investments by the Trust. In
addition, Trust Employees may not use information concerning the investments or
investment intentions of the Trust or their ability to influence such investment
intentions, for personal gain or in a manner detrimental to the interests of the
Trust. Disclosure by a Trust Employee of such information to any person outside
of the course or scope of the responsibilities of the Trust Employee to the
Trust and the Advisor will be deemed to be a violation of this prohibition.
Trust Employees may not engage in conduct which is deceitful,
fraudulent, or manipulative, or which involves false or misleading statements,
in connection with the purchase or sale of investments by the Trust. In this
regard, Trust Employees should recognize that Rule 17j-1 makes it unlawful for
any affiliated person or principal underwriter of the Trust, or any affiliated
person of such a person, directly or indirectly, in connection with the purchase
or sale of a Security held or to be acquired by the investment company to:
(i) employ any device, scheme or artifice to defraud the Trust;
(ii) make any untrue statement of a material fact
to the Trust or omit to state to the Trust a
material fact necessary in order to make the
statements made, in light of the
circumstances under which they are made, not
misleading;
(iii) engage in any act, practice, or course of business which
operates or would operate as a fraud or deceit upon the Trust; or
(iv) engage in any manipulative practice with respect to the Trust.
Trust Employees should also recognize that a violation of this Code or
of Rule 17j-1 may result in the imposition of: (1) sanctions as provided by
Section IX below; or (2) the imposition of administrative, civil and, in certain
cases, criminal fines, sanctions or penalties.
SECTION IV PROHIBITED TRANSACTIONS2
(A) Investment Personnel may not purchase or otherwise acquire direct or
indirect Beneficial Ownership of any Covered Security in an Initial Public
Offering or a Limited Offering unless he or she obtains pre-clearance pursuant
to Section V and reports to the Trust the information described in Section VI of
this Code.
(B) An Access Person may not purchase or otherwise acquire direct or
indirect Beneficial Ownership of any Covered Security, and may not sell or
otherwise dispose of any Covered Security in which he or she has direct or
indirect Beneficial Ownership, if he or she knows or should know at the time of
entering into the transaction that: (1) the Trust has purchased or sold the
Covered Security within the last 15 calendar days, or is purchasing or selling
or is going to purchase or sell the Covered Security in the next 15 calendar
days; or (2) the Advisor has within the last 15 calendar days considered
purchasing or selling the Covered Security for the Trust or is considering
purchasing or selling the Covered Security for the Trust within the next 15
calendar days, unless such Access Person:
(i) obtains pre-clearance of such transaction pursuant to Section V;
and
(ii) reports to the Trust the information described in Section VI of
this Code.
For purposes of administering this Code, Access Persons who are Advisory
Persons shall be presumed to have the requisite knowledge of the Trust's
transactions so as to require pre-clearance, regardless of whether such persons
actually have such knowledge. Accordingly, all Advisory Persons shall obtain
pre-clearance of all transactions in Covered Securities in accordance with this
Section IV(B) except in the case of a transaction as to which one of the
exceptions from pre-clearance set forth in Section IV(C) below applies.
Because investment recommendations and decisions made for the Trust are
made by persons who are associated with the Advisor, Access Persons who are not
associated with the Advisor will, in the absence of evidence to the contrary, be
presumed not to have the requisite knowledge of the Trust's transactions so as
to generally require pre-clearance of transactions. Accordingly, Access Persons
who are Independent Trustees shall not be required to obtain pre-clearance of a
transaction unless at the time of the transaction they have actual knowledge of
the matters described in (B) above.
(C) The prohibitions of this Section IV and the preclearance requirements
of Section V do not apply to:
(1) Purchases that are made by reinvesting cash dividends pursuant to
an automatic dividend reinvestment program ("DRIP") (however, this
exception does not apply to optional cash purchases pursuant to a
DRIP);
(2) Purchases of rights issued by an issuer pro rata to all holders of
a class of its Securities, if such rights are acquired from such
issuer, and the exercise of such rights;
(3) Involuntary (I.E., non-volitional) purchases, sales and transfers
of Securities;
(4) Transactions in exchange traded futures contracts;
(5) Transactions in common stock of large capitalization companies
(companies that comprise the S&P 500 Index), if the amount of the
transaction or a series of related transactions is less than $ 10,000
or 100 shares;
(6) Transactions in an account over which the Access Person does not
exercise, directly or indirectly, any influence or control; provided,
however, that such influence or control shall be presumed to exist in
the case of the account of an immediate family member of the Access
Person who lives in the same household as the Access Person, absent a
written determination by the Compliance Officer to the contrary; and
(7) Transactions in Securities that are not permissible investments
for the Trust, other than securities purchased or sold in an
Initial Public Offering or Limited Offering.
SECTION V PRE-CLEARANCE PROCEDURES
(A) Obtaining Pre-Clearance.
Pre-clearance of a personal transaction in a Covered Security required to
be approved pursuant to Section IV above must be obtained from the Compliance
Officer or a person who has been authorized by the Compliance Officer to
pre-clear transactions. Each of these persons is referred to in this Code as a
"Clearing Officer." A Clearing Officer seeking pre-clearance with respect to his
or her own transaction shall obtain such pre-clearance from another Clearing
Officer.
(B) TIME OF CLEARANCE.
(1) An Access Person may pre-clear trades only in cases where such
person has a present intention to effect a transaction in the
Security for which pre-clearance is sought. It is not appropriate for
an Access Person to obtain a general or open-ended pre-clearance to
cover the eventuality that he or she may buy or sell a Security at
some future time depending upon market developments. Consistent with
the foregoing, an Access Person may not simultaneously request
pre-clearance to buy and sell the same Security.
(2) Pre-clearance of a trade shall be valid and in effect only for a
period of 72 hours from the time pre-clearance is given; provided,
however, that a pre-clearance expires upon the person becoming aware
of facts or circumstances that would prevent a proposed trade from
being pre-cleared were such facts or circumstances made known to a
Clearing Officer. Accordingly, if an Access Person becomes aware of
new or changed facts or circumstances that give rise to a question
as to whether pre-clearance could be obtained if a Clearing Officer
was aware of such facts or circumstances, the person shall be required
to so advise a Clearing Officer before proceeding with such
transaction.
(C) FORM.
Pre-clearance must be obtained in writing by completing and signing the
form attached as Schedule A, and obtaining the signature of a Clearing Officer.
If an Access Person has responsibility regarding the determination by the
Advisor of Covered Securities to be purchased or sold for the Trust and is
requesting approval to purchase or sell a Covered Security that is owned by the
Trust or is purchasing a Covered Security that is a permissible investment for
the Trust, but has not purchased such Covered Security for the Trust, the Access
Person shall inform the Clearing Officer of that fact at the time pre-clearance
to purchase or sell the Covered Security is sought.
(D) FILING.
Copies of all completed pre-clearance forms, with the required signatures,
shall be retained by the Compliance Officer.
(E) FACTORS CONSIDERED IN PRE-CLEARANCE OF PERSONAL TRANSACTIONS.
A Clearing Officer may refuse to grant pre-clearance of a personal
transaction in his or her sole discretion without being required to specify any
reason for the refusal. Generally, a Clearing Officer will consider the
following factors in determining whether or not to pre-clear a proposed
transaction:
(1) Whether the amount or nature of the transaction or person making
it is likely to affect the price or market for the Security; and
(2) Whether the person making the proposed purchase or sale is likely
to benefit from purchases or sales being made or being considered on
behalf of the Trust; and
(3) Whether the transaction is likely to adversely affect the Trust.
(F) MONITORING OF PERSONAL TRANSACTIONS AFTER PRE-CLEARANCE.
After pre-clearance is given to an Access Person, the Compliance Officer
shall periodically monitor each Access Person's transactions to ascertain
whether pre-cleared transactions have been executed within 72 hours and whether
such transactions were executed in the specified amounts.
SECTION VI CERTIFICATIONS AND REPORTS BY ACCESS PERSONS3
(A) Initial Certifications and Initial Holdings Reports
Within 10 days after a person becomes an Access Person, except as provided
in Section VI (D), such person shall complete and submit to the Compliance
Officer an Initial Certification and Holdings Report on the form attached as
Schedule C.
(B) Quarterly Transaction Reports
(1) Within 10 days after the end of each calendar quarter, each Access
Person shall make a written report to the Compliance Officer of all
transactions in Covered Securities occurring in the quarter in
which he or she had any direct or indirect Beneficial Ownership. Such
report is hereinafter called a "Quarterly Transaction Report."
Such report is hereinafter called a "Quarterly Transaction Report."
(2) Except as provided in Section VI (D), a Quarterly Transaction
Report shall be on the form attached as Schedule B and must contain
the following information with respect to each reportable transaction:
(a) Date and nature of the transaction (purchase, sale or any
other type of acquisition or disposition);
(b) Title, number of shares, interest rate and maturity (if
applicable) or principal amount of each Covered Security and the price
at which the transaction was effected; and
(c) Name of the broker, dealer or bank with or through whom the
transaction was effected.
(3) A Quarterly Transaction Report may contain a statement that the
report is not to be construed as an admission that the person making
it has or had any direct or indirect Beneficial Ownership of any
Security to which the report relates.
(C) Annual Certifications and Annual Holdings Reports
Annually, by January 30 of each year, except as provided in Section VI(D),
each Access Person shall complete and submit to the Compliance Officer an
Annual Certification and Holdings Report on the form attached as Schedule D.
(D) Exceptions from Reporting Requirements
(1) Transactions in an account over which the Access Person does not
exercise, directly or indirectly, any influence or control provided,
however, that such influence or control shall be presumed to exist in
the case of the account of an immediate family member of the Access
Person who lives in the same household as the Access Person, absent a
written determination by the Compliance Officer to the contrary.
(2) Notwithstanding the quarterly reporting requirement set forth in
Section VI(B), an Independent Trustee is not required to file a
Quarterly Transaction Report unless he or she was actually aware of
the Trust's trading activity at any time during the 15 day period
immediately preceding or after such Independent Trustee engaged in a
Securities transaction.
(3) Independent Trustees are not required to file Initial Holdings
Reports or Annual Holdings Reports.
(4) In lieu of submitting a Quarterly Transaction Report, an Access
Person may arrange for the Compliance Officer to be sent duplicate
confirmations and statements for accounts through which transactions
in Covered Securities in which the Access Person has any direct or
indirect Beneficial Ownership are effected. However, a Quarterly
Transaction Report must be submitted for any quarter during which the
Access Person has acquired or disposed of direct or indirect
Beneficial Ownership of any Covered Security if such transaction was
not in an account for which duplicate confirmations and statements are
being sent. Access Persons who are associated persons of the Advisor
and who provide duplicate confirmations and statements for their
accounts to the Advisor will be deemed to satisfy the requirement to
submit a Quarterly Transaction Report if such confirmations and
statements reflect all transactions in Covered Securities required to
be reported by them hereunder. The Advisor shall deliver such
confirmations and statements or analysis thereof to permit the
Compliance Officer to ascertain compliance with this Code. Any Access
Person relying on this Section VI(D)(3) shall be required to certify
as to the identity of all accounts through which Covered Securities in
which they have direct or indirect Beneficial Ownership are purchased,
sold and held.
(5) An Access person need not make a separate transaction report under
this Code where the report would duplicate information recorded by the
Advisor pursuant to Rule 204-2(a)(12) under the Investment Advisers
Act of 1940
(E) It is the responsibility of each Access Person to take the initiative
to comply with the requirements of this Section VI. Any effort by the Trust or
by the Advisor to facilitate the reporting process does not change or alter that
responsibility.
SECTION VII ADDITIONAL PROHIBITIONS
(A) CONFIDENTIALITY OF TRUST TRANSACTIONS.
Until disclosed in a public report to shareholders or to the SEC in the
normal course, all information concerning the Securities "being considered for
purchase or sale" by the Trust shall be kept confidential by all Trust Employees
and disclosed by them only on a "need to know" basis. It shall be the
responsibility of the Compliance Officer to report any inadequacy found in this
regard to the trustees of the Trust.
(B) OUTSIDE BUSINESS ACTIVITIES, RELATIONSHIPS AND DIRECTORSHIPS.
Except for business relationships with not-for profit organizations, access
Persons may not engage in any outside business activities or maintain a business
relationship with any person or company that may give rise to conflicts of
interest or jeopardize the integrity or reputation of the Trust. Similarly, no
such outside business activities or relationship may be inconsistent with the
interests of the Trust. Access Persons who are officers or employees of the
Advisor may not serve as a director of any public or private company, except
with the prior approval of the Compliance Officer, and all directorships held by
such Access Persons shall be reported to the Compliance Officer.
(C) GRATUITIES.
Trust Employees shall not, directly or indirectly, take, accept, receive or
give gifts or other consideration in merchandise, services or otherwise, except:
(i) customary business gratuities such as meals, refreshments, beverages and
entertainment that are associated with a legitimate business purpose, reasonable
in cost, appropriate as to time and place, do not influence or give the
appearance of influencing the recipient and cannot be viewed as a bribe,
kickback or payoff; and (ii) business related gifts of nominal value.
SECTION VIII CERTIFICATION BY ACCESS PERSONS
The certifications of each Access Person required to be made pursuant
to Section VI shall include certifications that the Access Person has read and
understands this Code and recognizes that he or she is subject to it. Access
Persons shall also be required to certify in their annual certifications that
they have complied with the requirements of this Code.
SECTION IX SANCTIONS
Any violation of this Code shall be subject to the imposition of such
sanctions by the Trust as may be deemed appropriate under the circumstances to
achieve the purposes of Rule 17j-1 and this Code. The sanctions to be imposed
shall be determined by the Board of Trustees, including a majority of the
Independent Trustees; provided, however, that with respect to violations by
personnel of the Advisor (or of a company which controls the Advisor, the
sanctions to be imposed shall be determined by the Advisor (or the controlling
person thereof), as applicable. Sanctions may include, but are not limited to,
suspension or termination of employment, a letter of censure and/or restitution
of an amount equal to the difference between the price paid or received by the
Trust and the more advantageous price paid or received by the offending person.
SECTION X ADMINISTRATION AND CONSTRUCTION
(A) The administration of this Code shall be the responsibility of the
Compliance Officer.
(B) The duties of the Compliance Officer are as follows:
(1) Maintaining current lists of the names of all Trust Employees and
Access Persons with an appropriate description of their title or
employment, including a notation of any directorships held by Access
Persons who are partners, officers, or employees of the Advisor or of
any company which controls the Advisor, and the date each such person
became an Access Person;
(2) On an annual basis, providing each Trust Employee with a copy of
this Code and informing such persons of their duties and obligations
hereunder;
(3) Obtaining the certifications and reports required to be submitted
by Access Persons under this Code (except that the Compliance Officer
may presume that Quarterly Transaction Reports need not be filed by
Independent Trustees in the absence of facts indicating that a report
must be filed), and reviewing the reports submitted by Access Persons.
(4) Maintaining or supervising the maintenance of all records and
reports required by this Code;
(5) Reviewing securities transactions and holdings reported by Access
Persons against transactions effected by the Trust;
(6) Issuing, either personally or with the assistance of counsel as
may be appropriate, any interpretation of this Code which may appear
consistent with the objectives of Rule 17j-1 and this Code;
(7) Conducting such inspections or investigations as shall reasonably
be required to detect and report, with recommendations, any apparent
violations of this Code to the Board of Trustees of the Trust; and
(C) The Compliance Officer shall maintain and cause to be maintained in an
easily accessible place, the following records:
(1) A copy of this Code and any other codes of ethics adopted pursuant
to Rule 17j-1 by the Trust and the Advisor for a period of 5 years;
(2) A record of each violation of this Code and any other code
specified in (C)(1) above, and of any action taken as a result of
such violation for a period of not less than 5 years following the end
of the fiscal year of the Trust in which the violation occurred;
(3) A copy of each report made pursuant to this Code and any other
code specified in (C)(1) above, by an Access Person or the Compliance
Officer, for a period of not less than 5 years from the end of the
fiscal year of the Trust in which such report or interpretation was
made or issued, the most recent 2 years of which shall be kept in a
place that is easily accessible;
(4) A list of all persons, currently or within the past 5 years, who
are or were required to make reports pursuant to Rule 17j-1 and this
Code or any other code specified in (C)(1) above, or who are or were
responsible for reviewing such reports;
(5) A record of any decision, and the reasons supporting the decision,
to approve any investment in an Initial Public Offering or a Limited
Offering by Investment Personnel, for at least 5 years after the end
of the fiscal year in which such approval was granted; and
(6) A copy of each report made to the Trustees pursuant to Section
4(D), for at least five years after the end of the fiscal year in
which it was made, the first 2 years in an easily accessible place.
(D) Review of Code by Board of Trustees
(1) On an annual basis, and at such other time as deemed to be
necessary or appropriate by the trustees, the trustees shall review
operation of this Code and shall adopt such amendments thereto as may
be necessary to assure that the provisions of the Code establish
standards and procedures that are reasonably designed to detect and
prevent activities that would constitute violations of Rule 17j-1.
(2) In connection with the annual review of the Code by the Trustees,
the Trust and the Advisor shall each provide to the Board of Trustees,
and the Board of Trustees shall consider, a written report (which may
be a joint report on behalf of the Trust and the Advisor) that:
(a) Describes any issues arising under the Code or related
procedures during the past year, including, but not limited to,
information about material violations of the Code or any procedures
adopted in connection therewith and that describes the sanctions
imposed in response to material violations; and
(b) Certifies that the Trust and the Advisor have each adopted
procedures reasonably necessary to prevent Access Persons from
violating the Code.
(E) This Code may not be amended or modified except in a written form,
which is specifically approved by majority vote of the Independent Trustees
within six months after such amendment or modification. In connection with any
such amendment or modification, the Trust and the Advisor each provide a
certification that procedures reasonably necessary to prevent Access Persons
from violating the Code, as proposed to be amended or modified, have been
adopted.
This Code was approved by the Board of Trustees of the Trust
at a meeting held on May 4, 2000.
/S/ OMAR HAYDAR
---------------
Secretary
SCHEDULE A
ALLIED ASSET ADVISORS FUNDS
ALLIED ASSET ADVISORS, INC.
REQUEST FOR PERMISSION TO ENGAGE IN PERSONAL TRANSACTION
I hereby request permission to effect a transaction in Covered
Securities in which I have or will acquire direct or indirect
Beneficial Ownership.
PURCHASES AND ACQUISITIONS
------------------------- ---------------------- -----------------------
Date No. of Shares or Name of Security
Principal Amount
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SALES AND OTHER DISPOSITIONS
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Date No. of Shares or Name of Security
Principal Amount
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|_| (check if applicable) If I have responsibility for the determination by
the Advisor of Securities to be purchased or sold by the Trust, I have
noted (by means of an asterisk) those Securities noted above which are
owned by the Trust. If I am requesting permission to purchase
Securities that are not presently owned by the Trust, I have included a
statement as to why such securities are not being purchased for the
Trust or being considered by the Trust.
Date: ______________________ Signature: ________________________
Print Name: _______________________
Permission Granted ___ Permission Denied _____
Date and Time: __________________ Signature: ________________________
(Clearing Officer)
SCHEDULE B
ALLIED ASSET ADVISORS FUNDS
ALLIED ASSET ADVISORS, INC.
QUARTERLY TRANSACTION REPORT
The following lists all transactions in Covered Securities, in
which I have or had any direct or indirect Beneficial Ownership, that were
effected during the last calendar quarter and are required to be reported by
Section VI(B) of the Code. (If no such transactions took place write "NONE".)
Please sign and date this report and return it to the Compliance Officer no
later than the 10th day of the month following the end of the calendar quarter.
Use reverse side if additional space is needed.
[Enlarge/Download Table]
PURCHASES AND ACQUISITIONS
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No. of Shares Purchase Price
or Principal Per Share or
Date Amount Name of Security Unit Account Executing Broker
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SALES AND OTHER DISPOSITIONS
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No. of Shares Purchase Price
or Principal Per Share or
Date Amount Name of Security Unit Account Executing Broker
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Date Completed: _______________ Signature:______________________________
Print Name:_____________________________
*Does not apply to Independent Trustees.
SCHEDULE C
ALLIED ASSET ADVISORS FUNDS
ALLIED ASSET ADVISORS, INC.
INITIAL CERTIFICATION OF COMPLIANCE WITH CODE OF ETHICS
AND INITIAL HOLDINGS REPORT
This form must be completed by all Access Persons (other than
Independent Trustees) within 10 calendar days after becoming and Access Person.
I have read and I understand the Joint Code of Ethics of Allied Asset
Advisors Funds and Allied Asset Advisors, Inc. (the "Code"). I recognize that
the provisions of the Code apply to me and agree to comply in all respects with
the procedures described therein.
I certify that I have listed below: (1) the title, number of shares and
principal amount of each Covered Security in which I had any Beneficial
Ownership as of the day I became an Access Person; and (2) the name of each
broker, dealer or bank at which an account is maintained through which any
Covered Securities in which I have any Beneficial Ownership are held, purchased
or sold.
TITLE OF COVERED SECURITY NUMBER OF SHARES PRINCIPAL AMOUNT
------------------------- ---------------- ----------------
Name of each broker, dealer or bank:
? Check here if you have attached additional pages of holding in Covered
Securities.
Number of pages attached ______
Date Completed: _______________ Print Name: ___________________
Signature: ____________________
SCHEDULE D
ALLIED ASSET ADVISORS FUNDS
ALLIED ASSET ADVISORS, INC.
ANNUAL CERTIFICATION OF COMPLIANCE WITH CODE
OF ETHICS AND ANNUAL HOLDINGS REPORT
This form must be completed by all Access Person (other than
Independent Trustee) within 10 calendar days after becoming an Access person).
I have read and I understand the Joint Code of Ethics of Allied Asset
Advisors Funds and Allied Asset Advisors, Inc. (the "Code"). I recognize that
the provisions of the Code apply to me and agree to comply in all respects with
the procedures described therein. I certify that I have complied in all respects
with the requirements of the Code as in effect during the past year.
I also certify that all personal holdings, transactions and accounts
that were required to be reported by me pursuant to the Code, during the past
year have been reported in holdings reports that I have submitted to the
Compliance Officer or in confirmations and statements for each account through
which any Covered Securities in which I have any Beneficial Ownership are held,
purchased or sold, that have been sent to the Compliance Officer.
I certify that I have listed below: (1) the title, number of shares and
principal amount of each Covered Security in which I had any Beneficial
Ownership as of December 31 and (2) the name of each broker, dealer or bank at
which an account is maintained through which any Covered Securities in which I
have any Beneficial Ownership are held, purchased or sold.
TITLE OF COVERED SECURITY NUMBER OF SHARES PRINCIPAL AMOUNT
------------------------- ---------------- ----------------
Name of each broker, dealer or bank:
? Check here if you have attached additional pages of holding in Covered
Securities.
Number of pages attached ______
Date Completed:__________________ Print Name: ________________________
Signature: _________________________
--------
1 Beneficial ownership will not be deemed to exist solely as a result of
any indirect interest a person may have in the investment performance
of an account managed by such person, or over which such person has
supervisory responsibility, which arises from such person's
compensation arrangement with the Advisor or any affiliate of the
Advisor under which the performance of the account, or the profits
derived from its management, is a factor in the determination of such
person's compensation.
2 The prohibitions of this Section IV apply to Securities acquired or
disposed of in any type of transaction, including but not limited to
non-brokered transactions, such as purchases and sales of privately
placed Securities and Securities acquired directly from an issuer,
except to the extent that one of the exemptions from the prohibitions
set forth in Section IV(C) is applicable.
3 The reporting requirements of this Section VI apply to Covered
Securities acquired or disposed of in all types of transactions,
including but not limited to non-brokered transactions, such as
purchases and sales of privately placed Securities and Securities
acquired directly from an issuer, except to the extent that one of the
exemptions from the reporting requirements applies.
Dates Referenced Herein
| This ‘N-1A/A’ Filing | | Date | | Other Filings |
|---|
| |  |
| Filed on: | | 5/23/00 | | None on these Dates |
| | 5/4/00 |
| List all Filings |
4 Subsequent Filings that Reference this Filing
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