Lycopodium Corporate Code of Conduct

This Code of Conduct has been established by the Board of Directors of the Company and sets out the principals, practices and standards of personal conduct expected from all directors, executives and employees of the Company. The Company is committed to complying with all applicable laws and regulations and to delivering strong returns and shareholder value whilst acting ethically and responsibly when dealing with third parties.

The objectives of this Code of Conduct are to ensure that:

• high standards of corporate and individual behaviour are observed by all personnel;
• personnel are aware of their responsibilities to the Company; and
• all persons dealing with the Company, whether it be personnel, shareholders, clients or suppliers can be guided by the stated values and practices of the Company.

The Company is committed to complying with this Code of Conduct and requires all personnel to comply with it. Personnel should always use care and diligence when fulfilling their role or representing the Company and should not engage in any conduct likely to bring discredit upon the Company.