CODE OF CONDUCT & ETHICS

Preamble

As Oakwell, we strive to uphold the Group’s high standards of credibility, integrity and achievements, and in addition thereto, recognize our obligations to one another, as expressed in this Code.

This document – the Oakwell Holdings’ Code of Conduct & Ethics – addresses the ways in which associate partner members of this private investment group are expected to conduct themselves to bring into practice its vision, mission and goals.

As associate partner members of Oakwell, we aim to create a climate and opportunities for associate partner members to voice genuine concerns about actions or decisions they perceive to be unethical.

Oakwell’s Chief Executive Officer is responsible for initiating and supervising the investigation of all breaches of this Code as well as ensuring, where necessary, that the appropriate disciplinary steps are taken.

Group Interaction

As associate partner members of Oakwell, we shall at all times:

• Deal fairly, honestly and with utmost integrity.
• Promote and maintain a high ethical standard of conduct.
• Contribute to creating a climate that will enable us to achieve our respective goals and objectives.
• Refrain from any business activity that is not consistent with Oakwell’s Code of Corporate Practices.
• Conduct business in a manner that is professional and in accordance with good corporate governance and sound entrepreneurial practices.
• Introduce and accept individuals and corporates as associate partner members only if they comply with Oakwell’s stringent associate partner membership criteria.
• Accept venture capital only from certified subscribed sources.
• Accept and participate only in certified and quantifiable projects for investment and development purposes.
• Respect information from associate partner members as being confidential – in order to maintain and build trust and confidence in one another.
• Contribute to associate partner members’ growth by sharing valuable information, experience, resources and strategic alliances.
• Refrain from taking improper advantage of our position to the disadvantage of others under any circumstances.
• Promote Oakwell in the global community.
• Contribute to Oakwell’s collective objectives and growth.

Global Corporate Relations

As associate partner members of Oakwell, we shall at all times:

• Respect the traditions, cultures and laws of each country in which we operate.
• Act responsibly in all international trade, project developments and investments.
• Be able to objectively justify all project developments and investments.
• Favor consistent procedures among agencies and associate partner members when operating in countries where business practices differ from our own.
• Work for multilateral action aimed at achieving common goals.
• Refrain from any unlawful business activities or practices.

Environmental & Social Development and Training & Educational Sponsorships

As associate partner members of Oakwell, we shall at all times:

• Concern ourselves with the conservation of the environment in the broadest sense.
• Recognize that certain natural resources are finite and must be used responsibly and sustainably.
• Limit the use of finite resources in all business ventures.
• Responsibly manage the buildings and the land we occupy, manage waste responsibly, and use energy efficiently.
• Contribute to the economic well-being and social development of the countries and communities in which we conduct business.
• Where viable and appropriate, support communities by involving associate partner members of those communities in training and educational sponsorships.