Code of Ethics

McCormick Capital Management Inc. ("MCM") and The Elite Group (the "Trust") recognize they have a fiduciary responsibility to place the interests of their client, the Elite Mutual Funds, before their own personal interest.

The Code of Ethics is intended to provide guidance to all persons covered under the Code ("access persons") with respect to the purchase and/or sale of securities in the personal accounts of access persons, or in those accounts in which access persons may have a direct or indirect beneficial interest.

The Code is based on the principle that access persons of MCM and the Trust have a fiduciary duty to avoid conflicts of interest with regards to the conduct of personal securities transactions, and establishes guidelines such as:

No trading of a security by access persons on the same day a Fund is trading the same security.

Prior approval must be given before investing in an IPO or Private Placement.

Quarterly reporting of personal security transactions and annual reporting of security holdings.

Prohibition against the use of inside information to make security transactions.

A copy of the complete Code of Ethics can be obtained without charge by contacting McCormick Capital Management, Inc.