EXHIBIT (a)(1)

                     DREMAN/CLAYMORE DIVIDEND & INCOME FUND
                                 CODE OF ETHICS
                FOR CHIEF EXECUTIVE AND SENIOR FINANCIAL OFFICERS

        Dreman/Claymore Dividend & Income Fund (the "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 Executive Officer, President, 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 Secretary of the Trust.

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 applicable laws, regulations,
policies, procedures or this Code of Ethics, you must immediately report that
information to the Chairman of the Trust's Audit Committee. No one will be
subject to retaliation because of a good faith report of a suspected violation.

        Violations of this Code of Ethics may result in disciplinary action, up
to and including discharge. The Board of Trustees shall determine, or shall
designate appropriate persons to determine, appropriate action in response to
violations of this Code.

Waivers of Code of Ethics

        If you would like to seek a waiver of the Code of Ethics you must make
full disclosure of your particular circumstances to the Secretary of the Trust.
Changes in and waivers of this Code of Ethics will be publicly disclosed as
required by applicable law and regulations.

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.

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