EX-99.CODE ETH

                                VANECK VIP TRUST
                                  VANECK FUNDS
                            VANECK VECTORS ETF TRUST
                   CODE OF ETHICS FOR PRINCIPAL EXECUTIVE AND
                           SENIOR FINANCIAL OFFICERS

I.     COVERED OFFICERS/PURPOSE OF THE CODE

       VanEck's Code of Ethics (this "Code") for the investment companies within
the complex (collectively, "Funds" and each, "Company") applies to the Company's
Principal   Executive   Officer,   Principal  Financial  Officer  and  Principal
Accounting Officer (the "Covered Officers" each of whom are set forth in Exhibit
A) for the purpose of promoting:

o    honest and ethical  conduct,  including  the ethical  handling of actual or
     apparent   conflicts  of  interest   between   personal  and   professional
     relationships;

o    full, fair, accurate,  timely and understandable  disclosure in reports and
     documents  that a registrant  files with, or submits to, the Securities and
     Exchange Commission ("SEC") and in other public  communications made by the
     Company;

o    compliance with applicable laws and governmental rules and regulations;

o    the prompt  internal  reporting of violations of the Code to an appropriate
     person or persons identified in the Code; and

o    accountability for adherence to the Code.

       Each Covered  Officer should adhere to a high standard of business ethics
and should be  sensitive to  situations  that may give rise to actual as well as
apparent conflicts of interest.

II.    COVERED OFFICERS SHOULD HANDLE ETHICALLY ACTUAL AND APPARENT CONFLICTS OF
       INTEREST

       OVERVIEW.  A  "conflict  of  interest"  occurs  when a Covered  Officer's
private  interest  interferes  with the  interests  of, or his  service  to, the
Company.  For example,  a conflict of interest would arise if a Covered Officer,
or a member of his family,  receives  improper  personal benefits as a result of
his position with the Company.

       Certain  conflicts  of interest  arise out of the  relationships  between
Covered Officers and the Company and already are subject to conflict of interest
provisions in the Investment Company Act of 1940 ("Investment  Company Act") and
the Investment  Advisers Act of 1940  ("Investment  Advisers Act"). For example,
Covered Officers may not individually  engage in certain  transactions  (such as
the purchase or sale of securities or other  property) with the Company  because
of their status as  "affiliated  persons" of the Company.  The Company's and the
investment adviser's compliance programs and procedures are designed to prevent,
or identify and correct, violations of these provisions. This Code does not, and
is not intended to, repeat or replace these  programs and  procedures,  and such
conflicts fall outside of the parameters of this Code.



       Although  typically not presenting an opportunity  for improper  personal
benefit,  conflicts arise from, or as a result of, the contractual  relationship
between the Company and the investment adviser of which the Covered Officers are
also officers or employees.  As a result,  this Code recognizes that the Covered
Officers  will, in the normal course of their duties  (whether  formally for the
Company or for the adviser,  or for both), be involved in establishing  policies
and implementing  decisions that will have different  effects on the adviser and
the Company.  The  participation  of the Covered  Officers in such activities is
inherent in the contractual relationship between the Company and the adviser and
is consistent  with the  performance by the Covered  Officers of their duties as
officers of the Company. Thus, if performed in conformity with the provisions of
the Investment Company Act and the Investment Advisers Act, such activities will
be deemed to have been handled ethically.  In addition,  it is recognized by the
Funds'  Boards of  Directors  ("Boards")  that the Covered  Officers may also be
officers or employees of one or more other investment  companies covered by this
or other codes.

       Other  conflicts  of  interest  are  covered  by the  Code,  even if such
conflicts of interest are not subject to  provisions in the  Investment  Company
Act and the  Investment  Advisers Act. The following  list provides  examples of
conflicts of interest under the Code, but Covered  Officers  should keep in mind
that these examples are not exhaustive.  The  overarching  principle is that the
personal  interest of a Covered Officer should not be placed  improperly  before
the interest of the Company.

       Each Covered Officer must:

     o not use his personal  influence or personal  relationships  improperly to
       influence  investment  decisions  or  financial  reporting by the Company
       whereby the Covered Officer would benefit  personally to the detriment of
       the Company;

     o not cause the Company to take  action,  or fail to take  action,  for the
       individual  personal  benefit  of the  Covered  Officer  rather  than the
       benefit the Company;

     o not use material non-public  knowledge of portfolio  transactions made or
       contemplated for the Company to trade personally or cause others to trade
       personally in contemplation of the market effect of such transactions;

       There are some  conflict of  interest  situations  that should  always be
discussed with the Compliance Officer if material. Examples of these include:

o    service as a director on the board of any public or private company;

o    the receipt of any non-nominal gifts;

o    the receipt of any  entertainment  from any company  with which the Company
     has current or prospective  business dealings unless such  entertainment is
     business related, reasonable in cost, appropriate as to time and place, and
     not so frequent as to raise any question of impropriety.

o    any ownership  interest in, or any  consulting  or employment  relationship
     with,  any of the Company's  service  providers,  other than its investment
     adviser,  principal  underwriter,  administrator  or any affiliated  person
     thereof,



o    a direct or indirect financial interest in commissions, transaction charges
     or spreads paid by the Company for effecting portfolio  transactions or for
     selling or redeeming shares other than an interest arising from the Covered
     Officer's employment, such as compensation or equity ownership.

III.   DISCLOSURE AND COMPLIANCE

o    Each  Covered  Officer  should  familiarize  himself  with  the  disclosure
     requirements generally applicable to the Company;

o    Each Covered Officer should not knowingly misrepresent,  or cause others to
     misrepresent,  facts about the Company to others, whether within or outside
     the Company,  including to the Company's  directors  and  auditors,  and to
     governmental regulators and self-regulatory organizations;

o    Each Covered Officer should, to the extent  appropriate  within his area of
     responsibility,  consult with other officers and employees of the Funds and
     the adviser with the goal of promoting  full,  fair,  accurate,  timely and
     understandable disclosure in the reports and documents the Funds file with,
     or submit to, the SEC and in other public communications made by the Funds;
     and

o    It is the responsibility of each Covered Officer to promote compliance with
     the  standards  and  restrictions  imposed by  applicable  laws,  rules and
     regulations.

IV.    REPORTING AND ACCOUNTABILITY

Each Covered Officer must:

o    report at least annually all affiliations or other relationships related to
     conflicts  of  interest   that  the   Company's   Directors   and  Officers
     Questionnaire covers;

o    upon  adoption of the Code (or  thereafter as  applicable,  upon becoming a
     Covered  Officer),  affirm in writing  to the Board  that he has  received,
     read, and understands the Code;

o    annually  thereafter  affirm to the  Board  that he has  complied  with the
     requirements of the Code;

o    not  retaliate  against any other  Covered  Officer or any  employee of the
     Funds or their affiliated persons for reports of potential  violations that
     are made in good faith, and

o    notify the Compliance Officer promptly if he knows of any violation of this
     Code. Failure to do so is itself a violation of this Code.

       The Compliance  Officer or other  designated  senior legal officer of the
Funds'  investment  adviser is  responsible  for applying  this Code to specific
situations in which  questions  are presented  under it and has the authority to
interpret  this Code in any  particular  situation.  However,  any  approvals or
waivers  sought by the  Principal  Executive  Officer will be  considered by the
Governance Committee.



       The Company will follow these procedures in  investigating  and enforcing
this Code:

o    the Compliance  Officer or other designated  senior legal officer will take
     all appropriate action to investigate any potential  violations reported to
     him;

o    if, after such  investigation,  the  Compliance  Officer  believes  that no
     violation has occurred,  the Compliance Officer is not required to take any
     further action;

o    any matter that the  Compliance  Officer  believes  is a violation  will be
     reported to the Committee;

o    if the Committee concurs that a violation has occurred,  it will inform the
     Board, which will consider appropriate action, which may include review of,
     and  appropriate  modifications  to,  applicable  policies and  procedures;
     notification  to  appropriate  personnel of the  investment  adviser or its
     board; or a recommendation to dismiss the Covered Officer;

o    the Committee will be responsible for granting waivers, as appropriate; and
     any  changes to or waivers of this Code will,  to the extent  required,  be
     disclosed as provided by SEC rules.

V.     OTHER POLICIES AND PROCEDURES

This Code shall be the sole code of ethics  adopted by the Funds for purposes of
Section  406 of the  Sarbanes-Oxley  Act and the rules and forms  applicable  to
registered  investment  companies  thereunder.  Insofar  as  other  policies  or
procedures of the Funds,  the Funds' adviser,  principal  underwriter,  or other
service  providers govern or purport to govern the behavior or activities of the
Covered  Officers who are subject to this Code, they are superseded by this Code
to the extent that they overlap or conflict  with the  provisions  of this Code.
The Funds' and their investment  adviser's and principal  underwriter's codes of
ethics under Rule 17j-1 under the Investment  Company Act and the adviser's more
detailed  policies and procedures  set forth in the Van Eck Employee  Manual are
separate  requirements  applying to the Covered Officers and others, and are not
part of this Code.

VI.    AMENDMENTS

       Any amendments to this Code,  other than amendments to Exhibit A, must be
approved or ratified by a majority vote of the Board.

VII.   CONFIDENTIALITY

       All reports and records prepared or maintained pursuant to this Code will
be considered  confidential  and shall be maintained and protected  accordingly.
Except as  otherwise  required by law or this Code,  such  matters  shall not be
disclosed to anyone other than the appropriate Board and its counsel.



VIII.  INTERNAL USE

The Code is  intended  solely  for the  internal  use by the  Funds and does not
constitute  an  admission,  by or on  behalf  of any  Company,  as to any  fact,
circumstance, or legal conclusion.



                                   EXHIBIT A

                                COVERED OFFICERS



Jan F. van Eck, Chief Executive Officer, VanEck Funds, VanEck VIP Trust and
VanEck Vectors ETF Trust

John J. Crimmins, Treasurer & Chief Financial Officer