Welcome to the Founding and Governing Code of Ethics of The Alvan Ikoku Group LLC (the “Code of Ethics” and the “Ethics”), which shall ethically guide, inform and govern any and all your activity with, within, for, on behalf of, in relation to or otherwise pertaining to The Ikoku Group.

Please take the time to read the Code of Ethics below carefully.

— With respect to the Agreement you enter into with The Ikoku Group via the Code of Ethics, you understand and adhere to the following:

And furthermore, by using or visiting, in any way, The Ikoku Group, any area, part, section or properties of The Ikoku Group, any area, part, section or properties of its divisions, series, subsidiaries or affiliates, as well as any of the Products or Services, including the Sites, you accept and agree to the terms, conditions and requirements described above, and in these Codes and Policies, in their entirety without modification.

— With respect to your ability to agree and consent to the Code of Ethics, you represent and warrant the following:

And furthermore, by using or visiting, in any way, The Ikoku Group, any area, part, section or properties of The Ikoku Group, any area, part, section or properties of its divisions, series, subsidiaries or affiliates, as well as any of the Products and Services, including the Sites, you accept and agree that your consent meets the conditions, principles and requirements for consent, as delineated and described in a these Codes and Policies — for the specific purpose of consenting to this Policy, the Agreement and the Codes and Policies.

— You represent, warrant and covenant that, given the above attestation about your consent to the Code of Ethics, you have read, understood, consented to and agreed to be legally bound by and abide by the Code of Ethics and the Codes and Policies, as they are amended from time to time, and in their entirety without modification.

— You represent, warrant and covenant that, given the above attestation about your consent and adherence to the Code of Ethics, you have also read, understood, consented to and agreed to be legally bound by and abide by understandings of ethics as defined in all applicable guidelines, law and regulation, by The Ikoku Group in the Codes and Polices, and as specifically delineated below, which expressly emphasize provisions for the most rigorous and robust conceptions of dignity, humanity, independence and respect, and the most rigorous and robust protections for privacy, confidentiality, civil liberties and minority rights.

— You also represent, warrant and covenant that, given the aforementioned, your commitment to this understanding of ethics shall entail its basis for any activity you engage in with respect to The Ikoku Group — including its divisions, series, subsidiaries and affiliates, as well as its Products and Services — and that any such actions and decisions you engage in shall be free of any incompatibility with, inconsistency with or violation of this Code of Ethics.

The Ikoku Group strongly recommends you develop and maintain your knowledge of all the Codes and Policies, and so asks that you read, understand and regularly visit this page and other communications regarding the Founding Code of Ethics, as well as the Codes and Policies. The Ikoku Group takes your continued visiting and use of its Products and Services, including its Sites, as active indication of your knowledge, understanding, legally binding acceptance and agreement.

To protect the company and organizational integrity of The Ikoku Group — as well as the properties, rights and protections of the company and its official persons — The Ikoku Group requires all natural and legal persons concerned to read, understand, abide by and, where applicable, sign contracts and agreements delineated and described in the Policy on Company Integrity.

The Ikoku Group reminds you that the Policy on Company Integrity forms part of The Ikoku Group User Agreement and Code of Conduct. Thus, The Ikoku Group takes your continued visiting and use of its Products and Services, including its Sites, as active indication of your legally binding acceptance of this Policy as well as the Codes and Policies.

Please contact policies@ikokugroup.com with any feedback, issues or questions — which will be addressed by the President, CEO and Chair, Alvan Azinna Ikoku.

If you detect, notice or are informed of a possible breach or violation of this Policy or any of these Codes and Policies, please contact policies@ikokugroup.com with any details you have — which will be addressed by the President, CEO and Chair, Alvan Azinna Chibuzo Ikoku.

As with all official documents, materials, policies and statements of The Ikoku Group, definitions for terms used here can be found in the main Codes and Policies page. Please do continue with the Code of Ethics via further reading below.

Along with the above key principles, the Code of Ethics requires your adherence to correlative requirements delineated below:

Integrity. To act with integrity in all activities within, with and with respect to The Ikoku Group. To ensure the organizational integrity of The Ikoku Group. And to promote at The Ikoku Group a working environment that values integrity.

Mission. To carry out the mission and purposes of The Ikoku Group. To have all activities and operations support the mission and purposes. To have all who work for or on behalf of The Ikoku Group understand and be loyal to said mission and purposes. And to have the mission and purposes be responsive to the communities served by The Ikoku Group.

Governance. To have an active governing body that is responsible for setting the strategic directions of The Ikoku Group as well as oversight of its finances, operations and policies.

Responsible Stewardship. To manage all assets and properties of The Ikoku Group both responsibly and prudently — as described in the Founder’s Agreement, and in fiduciary duties delineated in the constituting and governance documents of The Ikoku Group and its divisions, series and subsidiaries. And to guide the official persons and communities of The Ikoku Group in accordance with the Code of Ethics’ principles and requirements.

Independence. To hold independence to be crucial to the fulfillment of the mission and purposes of The Ikoku Group.

Nongovernmental, Nonpartisan, Nonreligious, Private. To hold the nongovernmental, nonpartisan, nonreligious and private nature and status of The Ikoku Group to be essential to fulfilling the mission and purposes of The Ikoku Group.

Privacy and Confidentiality. To foreground the most robust protections of privacy and confidentiality as central inspirations for the establishment of The Ikoku Group. And to consider the privacy of personal life, conversation, thought as well as personal data as absolute rights, essential to the fulfillment of The Ikoku Group’s mission and private and public purposes.

Ethics, Freedoms, Liberties. To take as centrally important the practice of ethics as the examination and analysis of how to determine and do good. To hold as equally important the recognition of autonomy, dignity, humanity and respect as well as civil liberties and minority rights. And to furthermore consider rigorous attention to the question of minority rights to be essential to the fulfillment of The Ikoku Group’s mission and private and public purposes.

Reasonable Transparency. To also provide, where required, reasonable and timely information to the communities served by The Ikoku Group. To be responsive in a timely manner to reasonable requests for information. And to have such published information accurately and honestly reflect policies and practices. Solicitation materials and financial, organizational and program reports will be accurate and complete in all required respects.

Inclusiveness and Diversity. To maintain a founding policy of promoting inclusiveness and diversity in the working environments and communities The Ikoku Group. To take genuine and meaningful steps to promote inclusion in recruitment, hiring, promotion and retention, and in the communities to be reached, served and benefitted by The Ikoku Group.

Program Evaluation. To regularly and respectfully review program effectiveness, to develop lawful, respectful, and previously and expressly consented mechanisms to do so, and to in this manner incorporate lessons learned into existing and future programs.

Informed, Consented and Ethical Research and Care. To associate with, engage in and support only activities that meet the most robust definitions of informed, consented and ethical research and care. And to have The Ikoku Group associate with, engage in and support only care, research and equivalent work that abide by the most humane and most respectful interpretations of the Belmont Report, the Declaration of Helsinki, the Nuremberg Code, the United Nations Declaration of Bioethics and Human Rights, and applicable guidelines, laws and regulation.

Legal Compliance. To remain knowledgeable of and comply with all applicable laws, regulations and international conventions, subject to full access to and benefit of legal, financial and other professional counsel that is not compromised by the efforts of any individual or entity, private, governmental or otherwise.

Accessibility — To endeavor that the communities The Ikoku Group benefits, fosters, reaches and serves become available to all who abide by this Code of Ethics, regardless of disability, and notions of human, cultural and social difference.

Duty to Report and Inform. To ensure that the work of The Ikoku Group reflect its originating inspiration, intent, mission, and company purposes by honorably carrying out a duty to promptly report and fully inform the Founder, Alvan Azinna Chibuzo Ikoku, and partners of any departure from or violation of the Code of Ethics.

No Conflict or Inconsistency — Finally, under no circumstances shall any action, activity, decision, operations, or resolution of or with The Ikoku Group, including any conducted while meeting any fiduciary duties or standards of care or conduct, appear to be inconsistent with or come into conflict with the following:

And furthermore, by using or visiting, in any way, The Ikoku Group, any part or section of The Ikoku Group, any part or section of its divisions, series, subsidiaries or affiliates, as well as any part or section of its Products or Services, you accept and agree to the terms, conditions and requirements described above, in the Code of Ethics, and in these Codes and Policies, in their entirety without modification.

Please send any questions or concerns you may have concerning the Founding and Governing Code of Ethics to policies@ikokugroup.com.