RYDEX SERIES FUNDS
RYDEX DYNAMIC FUNDS
RYDEX VARIABLE TRUST
RYDEX ETF TRUST
FINANCIAL OFFICER CODE OF ETHICS
I. INTRODUCTION
The reputation and integrity of Rydex Series Funds, Rydex Dynamic
Funds, Rydex Variable Trust and Rydex ETF Trust (each a "Trust" and,
collectively, the "Trusts") are valuable assets that are vital to the Trusts'
success. The Trusts' senior financial officers ("SFOs,") are responsible for
conducting the Trusts' business in a manner that demonstrates a commitment to
the highest standards of integrity. The Trusts' SFOs are set forth on APPENDIX A
of this Code, as may be amended from time to time, and include the principal
executive officer, the principal financial officer, comptroller or principal
accounting officer, and any person who performs a similar function.
The Sarbanes-Oxley Act of 2002 (the "Act") effected sweeping corporate
disclosure and financial reporting reform on public companies, including mutual
funds, to address corporate malfeasance and assure investors that the companies
in which they invest are accurately and completely disclosing financial
information. Under the Act, all public companies (including the Trusts) must
either have a code of ethics for their SFOs, or disclose why they do not. The
Act was intended to foster corporate environments which encourage employees to
question and report unethical and potentially illegal business practices. The
Trusts have chosen to adopt this Financial Officer Code of Ethics (the "Code")
to encourage its SFOs to act in a manner consistent with the highest principles
of ethical conduct.
II. PURPOSES OF THE CODE
The purposes of this Code are:
o To promote honest and ethical conduct by the Trusts' SFOs,
including the ethical handling of actual or apparent conflicts of
interest between personal and professional relationships;
o To assist the Trusts' SFOs in recognizing and avoiding conflicts
of interest, including disclosing to an appropriate person any
material transaction or relationship that reasonably could be
expected to give rise to such a conflict;
o To promote full, fair, accurate, timely, and understandable
disclosure in reports and documents that the Trusts file with, or
submit to, the SEC and in other public communications made by the
Trusts;
o To promote compliance with applicable laws, rules and
regulations;
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o To encourage the prompt internal reporting to an appropriate
person of violations of this Code; and
o To establish accountability for adherence to this Code.
III. QUESTIONS ABOUT THIS CODE
Each Trust's compliance officer designated to oversee the Trust's Code
of Ethics adopted pursuant to Rule 17j-1 shall serve as Compliance Officer for
the implementation and administration of this Code. You should direct your
questions about this Code to the Compliance Officer.
IV. CONDUCT GUIDELINES
Each Trust has adopted the following guidelines under which the Trust's
SFOs must perform their official duties and conduct the business affairs of the
Trust.
1. ETHICAL AND HONEST CONDUCT IS OF PARAMOUNT IMPORTANCE. Each
Trust's SFOs must act with honesty and integrity and avoid
violations of this Code, including the avoidance of actual or
apparent conflicts of interest with the Trust in personal and
professional relationships.
2. SFOS MUST DISCLOSE MATERIAL TRANSACTIONS OR RELATIONSHIPS. Each
Trust's SFOs must disclose to the Compliance Officer any actual
or apparent conflicts of interest the SFO may have with the Trust
that reasonably could be expected to give rise to any violations
of this Code. Such conflicts of interest may arise as a result of
material transactions or business or personal relationships to
which the SFO may be a party. If it is not possible to disclose
the matter to the Compliance Officer, it should be disclosed to
the Trust's Chief Financial Officer, Chief Executive Officer or
another appropriate person. In addition to disclosing any actual
or apparent conflicts of interest in which an SFO is personally
involved, the Trust's SFOs have an obligation to report any other
actual or apparent conflicts which they discover or of which they
otherwise become aware. If you are unsure whether a particular
fact pattern gives rise to a conflict of interest, or whether a
particular transaction or relationship is "material," you should
bring the matter to the attention of the Compliance Officer
3. STANDARDS FOR QUALITY OF INFORMATION SHARED WITH TRUST SERVICE
PROVIDERS. Each Trust's SFOs must at all times seek to provide
information to the Trust's service providers (advisor,
administrator, outside auditor, outside counsel, custodian, ETC.)
that is accurate, complete, objective, relevant, timely, and
understandable.
4. STANDARDS FOR QUALITY OF INFORMATION INCLUDED IN PERIODIC
REPORTS. Each Trust's SFOs must at all times endeavor to ensure
full, fair, timely, accurate, and understandable disclosure in
the Trust's periodic reports.
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5. COMPLIANCE WITH LAWS. Each Trust's SFOs must comply with the
federal securities laws and other laws and rules applicable to
the Trusts, such as the Internal Revenue Code.
6. STANDARD OF CARE. Each Trust's SFOs must at all times act in good
faith and with due care, competence and diligence, without
misrepresenting material facts or allowing your independent
judgment to be subordinated. Each Trust's SFOs must conduct the
affairs of the Trust in a responsible manner, consistent with
this Code.
7. CONFIDENTIALITY OF INFORMATION. Each Trust's SFOs must respect
and protect the confidentiality of information acquired in the
course of their professional duties, except when authorized by
the Trust to disclose it or where disclosure is otherwise legally
mandated. You may not use confidential information acquired in
the course of your work for personal advantage.
8. SHARING OF INFORMATION AND EDUCATIONAL STANDARDS. Each Trust's
SFOs should share information with relevant parties to keep them
informed of the business affairs of the Trust, as appropriate,
and maintain skills important and relevant to the Trust's needs.
9. PROMOTE ETHICAL CONDUCT. Each Trust's SFOs should at all times
proactively promote ethical behavior among peers in your work
environment.
10. STANDARDS FOR RECORDKEEPING. Each Trust's SFOs must at all times
endeavor to ensure that the Trust's financial books and records
are thoroughly and accurately maintained to the best of their
knowledge in a manner consistent with applicable laws and this
Code.
V. WAIVERS OF THIS CODE
You may request a waiver of a provision of this Code by submitting your
request in writing to the Compliance Officer for appropriate review. For
example, if a family member works for a service provider that prepares a Trust's
financial statements, you may have a potential conflict of interest in reviewing
those statements and should seek a waiver of this Code to review the work. An
executive officer of each Trust, or another appropriate person (such as a
designated Board or Audit Committee member), will decide whether to grant a
waiver. All waivers of this code must be disclosed to the applicable Trust's
shareholders to the extent required by SEC rules.
VI. AFFIRMATION OF THE CODE
Upon adoption of the Code, each Trusts' SFOs must affirm in writing
that they have received, read and understand the Code, and annually thereafter
must affirm that they have complied with the requirements of the Code. These
affirmations may be made electronically via the RYDEX.STARCOMPLIANCE.COM
website. To the extent necessary, each Trusts' Compliance Officer will provide
guidance on the conduct required by this Code and the manner in which violations
or suspected violations must be reported and waivers must be requested.
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VII. REPORTING VIOLATIONS
In the event that an SFO discovers or, in good faith, suspects a
violation of this Code, the SFO MUST immediately report the violation or
suspected violation to the Compliance Officer. The Compliance Officer may, in
his or her discretion, consult with another member of the Trusts' senior
management or the Board in determining how to address the suspected violation.
For example, a Code violation may occur when a Trust periodic report or
financial statement omits a material fact, or is technically accurate but, in
the view of the SFO, is written in a way that obscures its meaning.
SFOs who report violations or suspected violations in good faith will
not be subject to retaliation of any kind. Reported violations will be
investigated and addressed promptly and will be treated as confidential to the
extent possible.
VIII. VIOLATIONS OF THE CODE
Dishonest or unethical conduct or conduct that is illegal will
constitute a violation of this Code, regardless of whether this Code
specifically refers to such particular conduct. A violation of this Code may
result in disciplinary action, up to and including removal as an SFO of the
Trusts. A variety of laws apply to the Trusts and their operations, including
the Securities Act of 1933, the Investment Company Act of 1940, state laws
relating to duties owed by Trust officers, and criminal laws. The Trusts will
report any suspected criminal violations to the appropriate authorities, and
will investigate, address and report, as appropriate, non-criminal violations.
ADOPTED: AUGUST 25, 2003
By: /S/ CARL G. VERBONCOUER
-------------------------
Carl G. Verboncouer
President
Date: OCTOBER 5, 2006
By: /S/ NICK BONOS
-------------------------
Nick Bonos
Treasurer
Date: OCTOBER 5, 2006
By: /S/ MIKE BYRUM
-------------------------
Mike Byrum
Chief Investment Officer
Date: OCTOBER 5, 2006
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APPENDIX A
SENIOR FINANCIAL OFFICERS
As of June 1, 2006 each Trust's senior financial officers are:
Carl Verboncoeur
Nick Bonos
Mike Byrum
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