EXHIBIT (a)(1)
CLAYMORE FUNDS
CODE OF ETHICS
FOR
CHIEF EXECUTIVE AND SENIOR FINANCIAL OFFICERS
Each of the registered investment companies listed in Appendix A hereto
(each a "Trust") is committed to conducting business in accordance with
applicable laws, rules and regulations and the highest standards of business
ethics, and to full and accurate financial disclosure in compliance with
applicable law. This Code of Ethics, applicable to the Trust's Chief Legal and
Executive Officer, Chief Financial Officer and Treasurer (or persons performing
similar functions) (together, "Senior Officers"), sets forth specific policies
to guide you in the performance of your duties.
As a Senior Officer, you must comply with applicable law. You also have
a responsibility to conduct yourself in an honest and ethical manner; and you
have leadership responsibilities that include creating a culture of high ethical
standards and commitment to compliance, maintaining a work environment that
encourages employees to raise concerns, and promptly addressing employee
compliance concerns.
The Code of Ethics of the Trust pursuant to Rule 17j-1(c) under the
Investment Company Act of 1940, as amended (the "1940 Act") (the "1940 Act Code
of Ethics"), which this Code of Ethics is intended to supplement, sets forth the
fundamental principles and key policies and procedures that govern the conduct
of all of us in our business as registered investment companies. You are also
bound by the requirements and standards set forth in this Code of Ethics and
other applicable laws and regulations and other policies and procedures adopted
by the Trust from time to time.
COMPLIANCE WITH LAWS, RULES AND REGULATIONS
You are required to comply with the laws, rules and regulations that
govern the conduct of our business and to report any suspected violations in
accordance with the section below entitled "Compliance with Code of Ethics."
CONFLICTS OF INTEREST
Senior Officers are expected to dedicate their best efforts to
advancing the Trust's interests and to use objective and unbiased standards when
making decisions that affect the Trust, keeping in mind that you are subject to
inherent conflicts of interest because you are an officer of Claymore Advisors,
LLC (the "Adviser") as well as the Trust. Your obligation to conduct the Trust's
business in an honest and ethical manner includes the ethical handling of actual
or apparent conflicts of interest between personal and business relationships. A
conflict of interest for the purpose of this Code of Ethics occurs when your
private interests interfere in any way, or even appear to interfere, with the
interests of the Trust. The 1940 Act Code of Ethics,
the Advisers' and the Trust's allocation procedures and the other policies of
the Trust are designed to ensure the ethical handling of such conflicts. As a
result, it is incumbent on you to be familiar with the 1940 Act Code of Ethics,
the Adviser's and Trust's allocations procedures and other rules and regulations
under the 1940 Act as well as the policies of the Trust. When making any
investment, accepting any position or benefits, participating in any transaction
or business arrangement or otherwise acting in a manner that creates or appears
to create a conflict of interest where you are receiving a personal benefit, you
should act in accordance with the letter and the spirit of the 1940 Act Code of
Ethics and/or the Trust's or the Advisor's other applicable policies and
procedures. If you are in doubt as to the application or interpretation of any
of these, you should make full disclosure of all facts and circumstances to, and
obtain the prior written approval of the Chairman of the Audit Committee of the
Trust or, in his absence, any Independent Trustee of the Trust(1).
DISCLOSURES
It is the policy of the Trust to make full, fair, accurate, timely and
understandable disclosure in compliance with all applicable laws and regulations
in all reports and documents that the Trust files with, or submits to, the
Securities and Exchange Commission and in all other public communications made
by the Trust. As a Senior Officer, you are required to promote compliance with
this policy by all employees and to abide by the Trust's standards, policies and
procedures designed to promote compliance with this policy.
COMPLIANCE WITH CODE OF ETHICS
If you know of or suspect a violation of this Code of Ethics or other
laws, regulations, policies or procedures applicable to the Trust, you must
immediately report that information to the Chairman of the Audit Committee of
the Trust or, in his absence, any Independent Trustee of the Trust. No one will
be subject to retaliation because of a good faith report of a suspected
violation.
The Trust will follow these procedures in investigating and enforcing
this Code of Ethics, and in reporting on this Code of Ethics:
o the Chairman of the Audit Committee of the Trust will take all
appropriate action to investigate any actual or potential
violations reported to him;
o violations and potential violations will be reported to the
Independent Trustees after such investigation;
o if the Independent Trustees determine that a violation has
occurred, they will take, or shall designate appropriate persons
to determine, appropriate action in response to violations of
this Code of Ethics; and
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(1) An "Independent Trustee" is any Trustee who is not an "interested person"
of the Trust within the meaning of the 1940 Act.
o appropriate action may include a letter of censure, suspension,
dismissal or, in the event of criminal or other serious
violations of law, notification of the Securities and Exchange
Commission or other appropriate law enforcement authorities.
Senior Officers must make this Code of Ethics known to persons who
might know of potential conflicts of interest, including any "whistle blower"
policies that the Trust may adopt from time to time.
WAIVERS OF CODE OF ETHICS
Except as otherwise provided in this Code of Ethics, the Chairman of
the Audit Committee of the Trust is responsible for applying this Code of Ethics
to specific situations in which questions are presented to the Chairman of the
Audit Committee of the Trust and has the authority to interpret this Code of
Ethics in any particular situation. The Chairman of the Audit Committee of the
Trust shall take action he or she considers appropriate to investigate any
actual or potential violations reported under this Code of Ethics.
The Chairman of the Audit Committee of the Trust is authorized to
consult, as appropriate, with the Chairman of the Board of Trustees of the
Trust, the Independent Trustees or the Board of Trustees and with counsel to the
Trust, Claymore or the Independent Trustees, and is encouraged to do so.
The Independent Trustees are responsible for granting waivers of this
Code of Ethics, as appropriate. Any changes to or waivers of this Code of Ethics
will, to the extent required, be disclosed on Form N-CSR as provided by
Securities and Exchange Commission rules.
NO RIGHTS CREATED
This Code of Ethics is a statement of certain fundamental principles,
policies and procedures that govern the Trust's Senior Officers in the conduct
of the Trust's business. It is not intended to and does not create any rights in
any employee, investor, supplier, competitor, shareholder or any other person or
entity.
APPENDIX A
Claymore Exchange-Traded Fund Trust
Claymore Exchange-Traded Fund Trust 2
Claymore/Guggenheim Strategic Opportunities Fund
Claymore/Raymond James SB-1 Equity Fund
Dreman/Claymore Dividend & Income Fund
Fiduciary/Claymore Dynamic Equity Fund
Fiduciary/Claymore MLP Opportunity Fund
Madison/Claymore Covered Call & Equity Fund
Old Mutual/Claymore Long-Short Fund
TS&W/Claymore Tax Advantaged Balanced Fund