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 accessing, communicating, engaging, monitoring, transmitting, or otherwise using or visiting, in any way, The Ikoku Group, any areas, offices, parts, sections, or assets or properties of The Ikoku Group, any areas, offices, parts, sections, or assets or properties of the divisions, series, subsidiaries, or affiliates, as well as any areas, offices, parts, sections, or assets or properties of the Products or Services, 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 accessing, communicating, engaging, monitoring, transmitting, or otherwise using or visiting, in any way, The Ikoku Group, any areas, offices, parts, sections, or assets or properties of The Ikoku Group, any areas, offices, parts, sections, or assets or properties of the divisions, series, subsidiaries, or affiliates, as well as any areas, offices, parts, sections, or assets or properties of the Products or Services, 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 attestation, your commitment to this understanding of ethics shall entail the following:

And furthermore, by accessing, communicating, engaging, monitoring, transmitting, or otherwise using or visiting, in any way, The Ikoku Group, any areas, offices, parts, sections, or assets or properties of The Ikoku Group, any areas, offices, parts, sections, or assets or properties of the divisions, series, subsidiaries, or affiliates, as well as any areas, offices, parts, sections, or assets or properties of the Products or Services, you accept and agree to the terms, conditions, and requirements described above, and in these Codes and Policies, in their entirety without modification.

— You represent, warrant, and covenant that, given the above attestation about your consent to the Code of Ethics, the Codes and Policies, and The Ikoku Group User Agreement and Code of Conduct, you ensure that your abiding by and adhering to their conditions, policies, principles, requirements, and rights shall further remain in accordance with the founding mission and purposes of The Ikoku Group, without incompatibility, as described and delineated in the Codes and Policies and the Founder’s Agreement.

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 section and other communications regarding the Founding Code of Ethics, as well as the Codes and Policies. The Ikoku Group takes your continued access, activity, communication, engagement, operation, participation, and other use or visiting of the Products and Services, as active indication of your knowledge, understanding, and legally binding acceptance of and agreement to this Policy as well as the Codes and Policies.

And you further legally accept and agree that no application, interpretation, judgment, or other compliance, proceeding, or reading from, of, with, or otherwise relating to the Founding Ethics, the Codes and Policies, or any equivalent code, policy, or other document or material shall, in any way, entail any abrogation, diminishment, interference, or violation pertaining to any of the terms, conditions, principles, requirements, rights — including the attendant properties and protections — of company and organizational integrity.

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

If you detect, notice, become aware of, 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 — to be addressed to and 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 section. 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:

Mission. To carry out the founding mission and purposes of The Ikoku Group in pursuit of private and public interest. 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 and be of value to the society at large.

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 any official work for The Ikoku Group a working environment that values integrity.

Respect. To hold the fullest and most humane understanding of respect for persons to be essential to the formation, management, and operations of The Ikoku Group. To treat people of The Ikoku Group as individual persons and human beings fully enjoying respect and its substantive ethical benefits, including autonomy, dignity, humanity, integrity, and reciprocity. To also have the communities of The Ikoku Group — particularly those they help create, develop, foster, and support — emanate from and be informed by the above understanding of respect.

Governance. To have a governing structure — appointed, approved and administered by the Founder, Alvan Azinna Chibuzo Ikoku — 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 Operating Agreement of The Alvan Ikoku Group LLC, and in fiduciary duties delineated in the constituting and governance documents of The Ikoku Group and the divisions, series, subsidiaries, and affiliates. And to also guide the official persons and communities of The Ikoku Group in accordance with this Founding and Governing Code of Ethics.

Independence. To hold independence to be crucial to the fulfillment of the founding mission and purposes of The Ikoku Group. And to have independence be central to the development, role, and understanding of private and public benefit commerce to be shared by The Ikoku Group and the divisions, series, subsidiaries, and affiliates.

Nongovernmental, Nonpartisan, Nonpolitical, Nonreligious, Private. To hold the nongovernmental, nonpartisan, nonpolitical, nonreligious and private nature and status of The Ikoku Group to be essential to fulfilling the founding mission and purposes of The Ikoku Group. To have such nature and status entail following faith-based commitments and principles delineated and described in the Founder’s Agreement and the Codes and Policies. And to also have such nature and status be a central basis for efforts to promote the private and public interest across the complex affiliations, associations, states, and nations that constitute Africa, its global diasporas, and its connected or shared societies in which the communities of The Ikoku Group reside.

Confidentiality and Privacy. To foreground the most robust protections of confidentiality and privacy as central inspirations for the formation of The Ikoku Group. To consider the confidentiality and privacy of personal biospecimens, data, and information as basic, civil and fundamental rights, and to further consider the privacy of personal life, including but not limited to aspects of life pertaining to body, conversation, home, mind, and thought, as absolute basic, fundamental and natural freedoms, liberties, and rights — all of which are to be guaranteed, safeguarded as well as essential to the fulfillment of the founding mission and purposes of The Ikoku Group.

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 also hold as centrally important the recognition and safeguarding of autonomy, dignity, humanity, and respect as well as the basic, fundamental and natural freedoms, liberties, and rights accorded to all human beings. And to furthermore hold the robust protection of minority rights to be essential to the fulfillment of the founding mission and purposes of The Ikoku Group.

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 of 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 or notions of human, cultural or social difference.

Duty to Report and Inform. To ensure that the work of The Ikoku Group reflect its founding mission and purposes by honorably carrying out a duty to promptly report and fully inform the Founder, Alvan Azinna Chibuzo Ikoku, of any apparent violation of or incompatibility with the founding mission or purposes, the Code of Ethics, the Codes and Policies, or equivalent codes, policies, or instruments of The Ikoku Group.

No Conflict or Inconsistency — Finally, under no circumstances shall any action, activity, decision, operations, resolution, or their equivalent of or with The Ikoku Group, including any conducted while meeting any fiduciary duties or standards of care or conduct, be in intentional violation of or incompatible with the following:

And furthermore, by accessing, communicating, engaging, monitoring, transmitting, or otherwise using or visiting, in any way, The Ikoku Group, any part or section of The Ikoku Group, any part or section of the divisions, series, subsidiaries, or affiliates, as well as any part or section of the 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.