JIC Investment Guidelines

In making purchases or sales, we consider the following guidelines:

1. To concentrate our common stock investments in companies which, in our opinion, will outperform the market in the period for which the stock was bought, will have relatively high rates of growth, and will have earnings growth above the rate of inflation;

2. To invest in financially sound companies which generate most of their total cash requirements internally and earn an adequate return on investment within their industry;

3. To emphasize investment in those companies which benefit from proprietary ability or ownership of valuable natural resources;

4. To seek established smaller companies with exceptional potential, relating to the amount of our investment to the appraised risk, but avoiding restricted securities;

5. To weigh carefully the extra risk associated with companies which are heavily dependent on government funding, and generally to avoid companies whose operations and profits are normally subject to intensive government regulation;

6. To consider securities of companies in whose managements we have confidence;

7. To avoid situations where potential conflicts of interest might interfere with our investment decisions;

8. To buy securities in amounts that do not exceed 10% of the market value of the total portfolio at the time(s) of purchase;

9. To create a portfolio where cash should not exceed 40%; bonds, 25%; conservative growth stocks or income stocks, 40%; growth stocks, 80%; and special situations, 10%;

10. To investigate companies thoroughly enough so that the Trustees have three or more different sources (both factual and opinion oriented) on which to judge a company;

11. To invest in bonds that have a potential for an annualized total return greater than the rate of inflation.

Adopted by vote of the
Trustees of the Fund May 7, 1980

Hans H. Jenny Investment Club