CODE OF ETHICS

CODE OF ETHICS
Pursuant to Section 17(j) of the
Investment Company Act of 1940


Bexil Corporation

Foxby Corp.

Global Income Fund, Inc.

Midas Dollar Reserves, Inc.

Midas Fund, Inc.

Midas Special Equities Fund, Inc.

Tuxis Corporation

CEF Advisers, Inc.

Investor Service Center, Inc.

Midas Management Corporation


The object of this Code of Ethics (the "Code") is to provide rules designed
to avoid conflicts of interest involving persons associated with the above
companies. Conflicts of interest may arise when a person has obligations to more
than one person or entity or has a personal interest in a situation which might
permit him to show preference or advantage to one person or entity at the
expense of another, or to himself at the expense of another. In view of the
fiduciary obligations of both the Funds' and their investment advisers'
employees, officers and directors, it is important not only to avoid violations
of law and regulatory rules, but also to avoid activities or practices which
have the appearance of or may give rise to a charge of a violation.

All employees are required to have a working familiarity with this Code. A
violation of the Code may result in penalties including censure, suspension or
dismissal.

If you have any questions about the applicability of the Code to any
particular transaction or account, please contact Monica Pelaez.


A. Definitions.

(1) "Security" shall have the same meaning as set forth in Section 2(a)(36) of
the Investment Company Act of 1940, as amended (the "1940 Act"), but shall not
include securities issued by the Government of the United States, bankers'
acceptances, bank certificates of deposit, commercial paper and shares of


registered open-end investment companies. The 1940 Act definition of "security"
is quite broad and includes any option, futures contract, warrant or right to
purchase any security.

(2) Persons subject to this Code ("Covered Persons" or individually "Covered
Person") shall include:

(a) all directors and officers of CEF Advisers, Inc., Midas
Management Corporation, and the Funds;

(b) any employee of CEF Advisers, Inc., Midas Management Corporation,
or any of the Funds (or of a company in a control relationship
with any of the foregoing) (i) who, in connection with his or her
regular functions or duties, makes or participates in, or obtains
information regarding the purchase or sale of a Security
(including the writing of an option to purchase or sell a
Security) by a Fund, or (ii) whose functions relate to the making
of any recommendation with respect to the purchase or sale of a
Security (including the writing of an option to purchase or sell
a Security) by a Fund;

(c) directors and officers of Investor Service Center, Inc. (i) who,
in the ordinary course of business make, participate in, or
obtain information regarding the purchase or sale of a Security
(including the writing of an option to purchase or sell a
Security) by a Fund, or (ii) whose functions or duties in the
ordinary course of business relate to the making of any
recommendation to a Fund with respect to the purchase or sale of
a Security (including the writing of an option to purchase or
sell a Security); and

(d) any natural person in a control relationship with respect to CEF
Advisers, Inc. or Midas Management Corporation or any of the
Funds who obtains information concerning recommendations made to
any Fund with respect to the purchase or sale of a Security
(including the writing of an option to purchase or sell a
Security).

(3) "Control" shall have the same meaning as that set forth under Section 2(a)
(9) of the 1940 Act.

(4) "Beneficial Ownership" for purposes of this Code shall be interpreted in
the same manner as it would be in determining whether a person is subject
to the provisions of Section 16 of the Securities Exchange Act of 1934 and
the rules and regulations thereunder, except that the determination of
direct or indirect beneficial ownership shall apply to all Securities which
the person has or acquires. Beneficial Ownership is broadly interpreted to
include securities in which a Covered Person holds an ownership interest or
the power to vote. Examples include securities owned by a Covered Person's
spouse or minor children, held in a trust in which a Covered Person is a
trustee or beneficiary, owned by a partnership in which a Covered Person is
a partner or by a corporation in which a Covered Person is an officer,
director or major stockholder.



(5) An "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 sections
13 or 15(d) of the Securities Exchange Act of 1934.

(6) A "Limited Offering" means an offering that is exempt from registration
under the Securities Act of 1933 pursuant to section 4(2) or section 4(6)
or pursuant to rule 504, rule 505, or rule 506 thereunder.

B. Prohibited Activities.

(1) No Covered Person shall, in connection with the purchase or sale (including
the writing of an option to purchase or sell), directly or indirectly, of
any Security by such person (or involving a Security in which such person
has a direct or indirect Beneficial Ownership interest) which, within the
most recent 15 days is or has been held by any Fund, or is being or has
been considered by any Fund or its investment adviser for purchase by such
Fund:

(a) employ any device, scheme or artifice to defraud any Fund;

(b) make to any Fund any untrue statement of a material fact or omit
to state to any Fund a material fact necessary in order to make
the statements made, in light of the circumstances under which
they are made, not misleading;

(c) engage in any act, practice, or course of business which operates
or would operate as a fraud or deceit upon any Fund; or

(d) engage in any manipulative practice with respect to any Fund.

(2) No Covered Person shall purchase or sell, directly or indirectly, any
Security if he knows at the time of such purchase or sale that the Security
(i) is being considered for purchase or sale by a Fund, (ii) is being
purchased or sold by a Fund, or (iii) was purchased or sold by the Fund
within the most recent fifteen days if such Covered Person participated in
the recommendation to, or the decision by, the Fund to purchase or sell
such Security.

(3) No Covered Person shall cause or attempt to cause any Fund to purchase,
sell or hold any Security in a manner calculated to create any personal
benefit to the Covered Person. A Covered Person who participates in any
research or investment decision concerning a particular Security must
disclose to those persons with authority to make investment decisions for
the Fund (or to the Administrator of the Code if the Covered Person is a
person with authority to make investment decisions for the Fund), any
personal or beneficial interest that the Covered Person has in that
Security or any Related Security, or in the issuer thereof, where such
decisions could create a material benefit to the Covered Person. The person
to whom the Covered Person properly reports such interest, in consultation
with the Administrator, shall determine whether or not the Covered Person
will be restricted in pursuing the research or recommendation.


(4) All Covered Persons are expressly prohibited from taking personal advantage
of any opportunity properly belonging to any Fund.

(5) The following persons must obtain approval from the Administrator of this
Code, on behalf of the Fund, CEF Advisers, Inc., or Midas Management
Corporation, as applicable, before directly or indirectly acquiring
beneficial ownership in any securities in an Initial Public Offering or
Limited Offering:

(a) Any employee of a Fund, CEF Advisers, Inc., or Midas Management
Corporation (or of any company in a control relationship with any
of the foregoing) 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 a
Fund; and

(b) Any natural person who controls a Fund, CEF Advisers, Inc., or
Midas Management Corporation and who obtains information
concerning recommendations made to a Fund regarding the purchase
or sale of Securities.

C. Confidentiality.

Information about Securities transactions being undertaken or considered for
recommendation for a Fund shall be treated as confidential and may not be
communicated to other persons who are not involved in the decision-making
process.

D. Administrator.

The Boards of Directors of the Funds shall from time to time appoint an
Administrator of this Code who shall receive and review the report hereinafter
described and who shall:

(1) Identify and inform each Covered Person of the existence of this Code,
deliver a copy to such person, and inform such person of their reporting
obligations hereunder; and

(2) Maintain in an easily accessible place at the offices of the Funds a copy
of this Code together with copies of all reports made pursuant hereto, a
record of any violations hereof and of any action taken as a result of such
violations during the prior five years, a list of all Covered Persons
during the prior five years, and a record of any decision, and the reasons
supporting the decision, to approve the acquisition by a Covered Person of
any securities in an initial public offering or a limited offering during
the past five years.

E. Reporting.

(1) Upon designation as a Covered Person, such person shall provide to the
Administrator of the Code, on or before the tenth day after such person
becomes a Covered Person, an initial holdings report with respect to any
Security in which the Covered Person had any direct or indirect beneficial
ownership when the person became a Covered Person. Any such report shall
include the title, number of shares and principal amount of each Security,
the name of any broker, dealer, or bank with whom the Covered Person


maintained an account as of the date the person became a Covered Person and
the date that the report is submitted by the Covered Person.

(2) All Covered Persons shall provide to the Administrator of the Code, on or
before the tenth day after the end of each calendar quarter in which the
transaction to which the report relates was effected; (1) with respect to
any transactions in any Security in which such person has a direct or
indirect Beneficial Ownership interest, the date of the transaction, the
title, the interest rate and maturity date (if applicable), the number of
shares and the principal amount of each Security involved, the nature of
the transaction (purchase, sale or any other type of acquisition or
disposition), the price at which the transaction was effected, and the name
of the broker, dealer or bank with or through whom the transaction was
effected and the date the report is submitted by the Covered Person; and
(2) with respect to any new account established by such person in which any
securities were held during the quarter for the direct or indirect benefit
of such person, the name of the broker, dealer or bank with whom the
Covered Person established the account, the date the account was
established, and the date the report is submitted by the Covered Person.
Any such report may contain a statement that the report shall not be
construed as an admission by the person that the person making the report
that he or she has any direct or indirect Beneficial Ownership in the
Security to which the report relates.

(3) All Covered Persons shall provide on an annual basis to the Administrator
of the Code, with respect to any security in which such person has a direct
or indirect Beneficial Ownership interest, the title, number of shares and
principal amount of each Security involved, the name of any broker, dealer,
or bank with whom the Covered Person maintains an account in which any
securities are held for the direct or indirect benefit of the Covered
Person and the date that the report is submitted by the Covered Person.
Such information must be current as of a date no more than thirty days
before the report is submitted.

(4) Notwithstanding the foregoing:

(a) no Covered Person shall be required to make a report with respect
to transactions affected for any account over which such person
does not have any direct or indirect influence or control; and

(b) if such person is an "independent" director of any of the Funds,
and would be required to make a report solely by reason of being
a director, such person need not make an initial holdings report
or an annual holdings report, and except where such director knew
or, in the ordinary course of fulfilling his official duties as a
director, should have known that during the fifteen days
immediately preceding or after a transaction in a Security by the
director, such Security is or was purchased or sold by such Fund
or such purchase or sale by such Fund is or was considered by
such Fund or its investment adviser, such director shall not be
required to make the quarterly transaction report.



F. Penalties.

If the Administrator determines that a violation of this Code has occurred, he
or she shall report the relevant facts and conclusions to the Board of Directors
of any affected Fund(s), and to the Chief Executive Officer of each entity
employing the person responsible for the violation. The applicable Board of
Directors and Chief Executive Officer shall each have the power to censure,
suspend or dismiss such person or require that a trade be reversed.

G. Amendments.

Any material changes to this Code must be approved by the Board of Directors,
including a majority of independent directors, of each Fund, no later than six
months after adoption of such material change. Before approving any such
amendment to this Code, the Board of Directors of each Fund must receive a
certification from the Funds, CEF Advisers, Inc., Midas Management Corporation,
or Investor Service Center, Inc., that it has adopted procedures reasonably
necessary to prevent Covered Persons from violating the Code.