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CODE OF ETHICS for Hennessy Funds Trust and Hennessy Advisors, Inc. February 2016 Code of Ethics February 2016 TABLE OF CONTENTS Page I. GENERAL .......................................................................................................
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How to Fill Out Code of Ethics:

01
Begin by reviewing your organization's mission statement and values. Understand the core principles and beliefs that guide your organization's actions and decision-making processes.
02
Identify the key ethical issues that your organization commonly faces. These may include conflicts of interest, bribery and corruption, confidentiality, fair competition, environmental responsibility, or employee welfare, among others.
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Consult relevant laws, regulations, and industry standards that pertain to your organization. Ensure that your code of ethics aligns with legal requirements and complies with industry best practices.
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Involve key stakeholders, such as employees, managers, executives, and board members, in the development and review process. Seek their input and perspectives to ensure a comprehensive and inclusive code of ethics.
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Clearly define and articulate the expected behavior and standards of conduct for all individuals associated with your organization. Include guidelines on ethical decision-making, reporting unethical behavior, and the consequences for violating the code of ethics.
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Use clear and concise language that is easily understood by all individuals within your organization. Avoid jargon or complex terms that may hinder comprehension or interpretation.
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Provide examples and scenarios that showcase proper ethical behavior. This can help individuals understand how the code of ethics applies to their specific roles and responsibilities.
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Include a mechanism for ongoing review and updates to the code of ethics. Ethical dilemmas and societal norms change over time, and it is essential to ensure that your code of ethics remains relevant and effective.

Who needs a Code of Ethics:

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Organizations of all sizes and industries need a code of ethics. From multinational corporations to small businesses and non-profit organizations, having a code of ethics promotes responsible and ethical behavior among employees and stakeholders.
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Employees and individuals associated with the organization can benefit from a code of ethics as it provides a clear framework for decision-making and sets expectations for conduct. It helps create a positive and respectful work environment where everyone understands and adheres to ethical standards.
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Society as a whole benefits from organizations having a code of ethics. Ethical behavior positively impacts communities and fosters trust and transparency between organizations and the public. A code of ethics can help prevent unethical practices and promote social responsibility.
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Code of ethics is a set of principles and guidelines designed to help professionals conduct themselves with honesty, integrity, and respect for others.
Certain professionals, such as government employees, corporate executives, and members of professional associations, may be required to file a code of ethics.
Filling out a code of ethics typically involves reviewing the guidelines and principles outlined, and then signing a statement acknowledging that you understand and will abide by them.
The purpose of a code of ethics is to promote ethical behavior, maintain trust and confidence in the profession, and protect the interests of clients or the public.
Information such as conflicts of interest, gifts or gratuities received, financial interests, and other relevant information must be reported on a code of ethics.
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