CODE OF ETHICS
(as amended on August 1, 2016)

     Nicholas Limited Edition, Inc., an investment company registered under the Investment Company Act of 1940, as amended, hereby adopts the following Code of Ethics governing the conduct of personal trading by persons associated with it. The purpose of this Code of Ethics is to foster compliance with applicable federal regulatory requirements and to eliminate transactions suspected of being in conflict with the best interests of the Fund.

1	.	Definitions.
		A.	Access Person. As used in this Code, the term "Access Person" shall mean any
			director or officer of the Fund, or any employee of the investment adviser to the
			Fund who, in connection with his or her regular functions or duties, makes,
			participates in, or obtains information regarding the purchase or sale of a security by
			the Fund, or whose functions relate to the making of any recommendation with
			respect to such purchases or sales.
		B.	Fund. As used in this Code, the term "Fund" shall mean Nicholas Limited Edition,
			Inc.
		C.	Beneficial Ownership. As used in this Code, the term "beneficial ownership" 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, as
			amended ("Exchange Act"), and the rules and regulations thereunder. Pursuant to
			Rule 16a-1(a)(2) under the Exchange Act, the term "beneficial owner" shall mean
			any person who, directly or indirectly, through any contract, arrangement,
			understanding, relationship, or otherwise, has or shares: (1) a direct or indirect

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		pecuniary interest in a security; (2) voting power, which includes the power to vote,
		or to direct the voting of, such security; and/or (3) investment power, which includes
		the power to dispose, or to direct the disposition of, such security. For example,
		close family or business relationships may give rise to a degree of influence of one
		person over the voting or investment decisions of another such as to result in shared
		beneficial ownership. Typically, ownership of securities by a spouse, minor child or
		a trust of which an Access Person is grantor, beneficiary or trustee, will be deemed
		beneficial ownership of those securities by the related Access Person.
	D.	Security. As used in this Code, except as otherwise provided herein, the term
		"security" shall mean a "Covered Security" as defined in Section 2(a)(36) of the
		Investment Company Act, except that it shall not include: (1) direct obligations of
		Government of the United States; (2) bankers' acceptances, bank certificates of
		deposit, commercial paper and high quality short-term debt instruments, including
		repurchase agreements; and (3) shares issued by open-end investment companies
		registered under the Investment Company Act.
2.	Prohibited Activities.
	A.	Unlawful Actions: No Access Person shall in connection with the purchase or sale
		of a "Security Held or To Be Acquired" by the Fund:
		(1	)	Employ any device, scheme or artifice to defraud the Fund;
		(2	)	Make to the Fund any untrue statement of a material fact or omit to state to
				the Fund any material fact necessary in order to make the statements made,
				in light of the circumstances under which they are made, not misleading;

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	(3)	Engage in any act, transaction, practice, or course of business which operates
		or would operate as a fraud or deceit upon the Fund; or
	(4)	Engage in any manipulative practice with respect to the Fund.
	For purposes of this Section 2A, a "Security Held or to Be Acquired" by the Fund
	shall mean any Covered Security which, within the most recent 15 days: (a) is or
	has been held by the Fund; or (b) is being or has been considered by the Fund or its
	investment adviser for purchase by the Fund. In addition, the securities subject to
	the foregoing anti-fraud provisions include any option to purchase or sell, and any
	security that is exchangeable for or convertible into, any Covered Security that is
	held or to be acquired by the Fund.
B.	Blackout Period for Security Transactions. No Access Person shall purchase or
	sell, directly or indirectly, for his/her own account, or acquire any beneficial
	ownership in, any security which has been purchased or sold within the preceding
	fifteen (15) days by the Fund or which to his/her knowledge will be purchased or
	sold within the succeeding fifteen (15) days by the Fund unless such purchase or sale
	is approved in writing by Albert O. Nicholas, David O. Nicholas or Jennifer R.
	Kloehn, or a person delegated by either of the foregoing, prior to the effectuation of
	such purchase or sale. A copy of such written approval shall be retained for a period
	of at least five (5) years.
C.	No Access Person shall purchase any security from, or sell any security to, the Fund,
	unless the sale or purchase involves solely securities of which the issuer is the Fund.

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3	.	Pre-approval of Investments in IPOs and Limited Offerings.
			All Fund Investment Personnel must obtain approval from the Fund's investment
		adviser, Nicholas Company, Inc. (either Albert O. Nicholas, David O. Nicholas or Jennifer
		R. Kloehn, or a person delegated by any of the foregoing) before directly or indirectly
		acquiring beneficial ownership in any securities in an Initial Public Offering or in a Limited
		Offering. For purposes of this requirement, the following definitions set forth in Rule 17j-1
		shall apply:
		Investment Personnel shall mean (1) any employee of the Fund (or any company in
		control of the Fund) 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 Fund; and (2) any natural person who controls the Fund and who obtains information
		concerning recommendations made to the Fund regarding the purchase or sale of securities
		by the Fund.
		Initial Public Offering shall mean an offering of securities under the Securities Act of
		1933, as amended ("Securities Act"), the issuer of which, immediately before the
		registration, was not subject to the reporting requirements of Sections 13 or 15(d) of the
		Exchange Act.
		Limited Offering shall mean an offering that is exempt from registration under the
		Securities Act pursuant to Section 4(2) or Section 4(6) or pursuant to Rule 504, Rule 505
		and Rule 506 under the Securities Act.
4	.	Reporting.
		A.	Initial Holdings Reports. No later than ten (10) days after a person becomes an
			Access Person of the Fund, he/she must provide an Initial Holdings Report to the
			Fund which contains the following information: (1) the title and type of security,
			and as applicable the exchange ticker symbol or CUSIP number, number of shares,
			and principal amount of each Covered Security in which the Access Person had any
			direct or indirect beneficial ownership when the person became an Access Person;
			(2) the name of any broker, dealer or bank with whom the Access Person

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	maintained an account in which any securities (not limited solely to Covered
	Securities) were held for the direct or indirect benefit of the Access Person as of the
	date the person became an Access Person; and (3) the date that the report is
	submitted by the Access Person. The information in the Initial Holdings Report
	must be current as of a date no more than forty-five (45) days prior to the individual
	becoming an access person.
B.	Quarterly Transaction Reports. Within thirty (30) days of the end of each
	calendar quarter of the Fund, each Access Person shall submit a Quarterly
	Transaction Report. However, Quarterly Transaction Reports do not need to be
	submitted pursuant to an automatic investment plan.
	The Quarterly Transactions Report shall contain the following information: (1)
	with respect to any transaction during the quarter in a Covered Security in which
	the Access Person had any direct or indirect beneficial ownership:
	(a)	the date of the transaction, the title and as applicable the exchange
		ticker symbol or CUSIP number, the interest rate and maturity date
		(if applicable), the number of shares, and the principal amount of
		each Covered Security involved;
	(b)	the nature of the transaction (i.e., purchase, sale or any other type of
		acquisition or disposition);
	(c)	the price of the Covered Security at which the transaction was
		effected;
	(d)	the name of the broker, dealer or bank through which the transaction
		was effected; and
	(e)	the date that the report is submitted by an Access Person.
	(2) with respect to any account established by the Access Person in which any
	securities (not limited solely to Covered Securities) were held during the quarter for
	the direct or indirect benefit of the Access Person:

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	(a)	the name of the broker, dealer or bank with whom the Access
		Person established the account;
	(b)	the date the account was established; and
	(c)	the date that the report is submitted by the Access Person.
C.	Annual Holdings Report. Within forty-five (45) days of the end of the calendar
	year, each Access Person shall submit an Annual Holdings Report containing the
	following information: (1) the title and type of security, and as applicable the
	exchange ticker symbol or CUSIP number, number of shares, and principal amount
	of each Covered Security in which the Access Person had any direct or indirect
	beneficial ownership; and (2) the name of any broker, dealer or bank with whom
	the Access Person maintains an account in which any securities (not limited solely
	to Covered Securities) are held for the direct or indirect benefit of the Access
	Person; and (3) the date that the report is submitted by the Access Person.
D.	Exceptions from Reporting Requirements.
	(1) A person who qualifies as an Access Person solely because he is a director of the
	Fund is not required to file the report required by subparagraphs (A) and (C) hereof
	if such person is not an "interested" director of the Fund, as "interested" is defined in
	Section 2(a)(19) of the Investment Company Act of 1940, as amended; and
	(2) A director of the Fund who is not an "interested person" of the Fund (as defined
	above) need not make a Quarterly Transaction Report as required by subparagraph
	(B) hereof if he/she does not know, or in the ordinary course of fulfilling his/her
	official duties as a director is not charged with knowing, that during the 15-day
	period immediately preceding or following a transaction in a Covered Security by

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			such director, the Fund purchased or sold, or the Fund or its investment adviser
			considered purchasing or selling, the same security. Thus, a disinterested director
			only must file a Quarterly Transaction Report if he/she had, or should have had,
			actual or imputed knowledge at the time he/she entered into his/her transaction that
			(i) the Fund had engaged in a transaction in the same security within the last fifteen
			(15) days, or is engaging in such transaction or is going to engage in such transaction
			in the same security in the next fifteen (15) days, or (ii) the Fund or its investment
			adviser has within the last fifteen (15) days considered a transaction in the same
			security or is considering a transaction in the security or within the next fifteen (15)
			days is going to consider a transaction in the security; and
			(3) An Access Person need not make any reports pursuant to this Section 4 with
			respect to transactions in Covered Securities over which the person has no direct or
			indirect influence or control.
5	.	Administration of Code of Ethics.
		A.	The Fund shall adopt procedures reasonably necessary to ensure compliance with
			the provisions of the Code, including procedures regarding Notification of
			Reporting Obligations (as required by Rule 17j-1(d)(4)), Review of Reports (as
			required by 17j-1(d)(3)), and Record Keeping Requirements (as required by Rule
			17j-1(f)).
		B.	At least once a year, management of the Fund shall provide the Board of Directors
			of the Fund with an Annual Issues and Certification Report as required by Rule 17j-
			1(c)(2)(ii) of the Investment Company Act.

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6	.	Sanctions. Jennifer R. Kloehn, or another person designated by the Board of Directors,
		shall review all reports submitted, and shall determine if any violations of the Code of Ethics
		have occurred. If a violation of this Code of Ethics occurs, Albert O. Nicholas, David O.
		Nicholas or the Board of Directors of the Fund may impose such sanctions as they deem
		appropriate in the circumstances, including termination of employment of the violator.

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