The Founding and Governing Code of Ethics of The Alvan Ikoku Group LLC (the “Code of Ethics” and the “Ethics”) shall ethically guide, inform, and govern any and all activity involving, relating, referring, or otherwise pertaining to The Ikoku Group.

Therefore, persons engaged in any such activity are expected to uphold the principles delineated below.

— first, with respect to the Agreement you enter into with The Ikoku Group via the Founding and Governing Code of Ethics, the Codes and Polices, and The Ikoku Group User Agreement and Code of Conduct, you understand and adhere to the following:

— second, with respect to the Founding and Governing Code of Ethics, you understand and adhere to the following:

— third, given the aforementioned, your commitment to this understanding of ethics, of ethics principles, of ethics rights, and of their protections shall entail the following:

— and furthermore, by engaging in any activity involving, referring to, relating to, or otherwise pertaining to The Ikoku Group, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of The Ikoku Group, any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the divisions, series, subsidiaries, or affiliates, as well as any activities, affairs, areas, assets, offices, parts, properties, sections, or equivalent of the Products or Services, you accept and agree to the statements, terms, conditions, and requirements described in this section and in the Codes and Policies, regarding the Founding and Governing Code of Ethics of The Ikoku Group, in their entirety without modification, including as amended and updated from time to time by The Ikoku Group, and you further accept and agree to fully inform The Ikoku Group in writing of any knowledge you have regarding any activity subject to this Policy.

Along with the above principles, the Code of Ethics requires your adherence to correlative principles 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.

Humanity. To have as core, central and essential to The Ikoku Group robust notions of humanity and the humane. To refrain from acts of cruelty and indignity to human beings. To ensure that the welfare of an individual person is not diminished, imperiled or sacrificed for the interests of the community, group, or state. And, for the above, to therefore abide by spiritual commitments and principles defined and delineated in the Founder’s Operating Agreement and the Codes and Policies.

Honor. To conduct and imbue with honor all activities within, with and with respect to The Ikoku Group. To serve The Ikoku Group under code of honor as well as ethics. And to promote through any activities relating to The Ikoku Group environments that value honor.

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 foster at The Ikoku Group work 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.

Meaningfulness. To ensure the mission and purposes, as well as activities and operations, of The Ikoku Group are meaningful. To therefore read, interpret and make decisions from codes, policies, communications and documents of The Ikoku Group by following the intent, meaning and purpose as well as the words with which they were written. To not misconstrue them for objectives contrary to those of The Ikoku Group, its founding, or the Founder, Alvan Azinna Chibuzo Ikoku. And to confer — directly, respectfully, in writing — with the Founder where there is conflict, contradiction or question.

Control. To dutifully refrain from diminishing, interfering with or otherwise usurping the control of The Ikoku Group by the sole Founder, Owner and Manager, Alvan Azinna Chibuzo Ikoku. To respect the decisions made by said Founder. And to acknowledge and abide by the ownership of The Ikoku Group by said Founder.

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 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 at The Ikoku Group.

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. And to 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.

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.

Informing, Consenting and Ethical Research and Care. To associate with, engage in, and support only activities that meet the most robust definitions of informing, consenting and ethical research and care. And to have The Ikoku Group associate with, engage in, and support only care, research, and equivalent activity that abide by the most robust and humane interpretations of applicable guidelines, laws, and regulations, including the Belmont Report, the Declaration of Helsinki, the Nuremberg Code, the United Nations Declaration of Bioethics and Human Rights.

Informing, Consenting and Ethical Education and Training. To also associate with, engage in, and support only activities that meet the most robust definitions of informing, consenting and ethical research and care. And to have The Ikoku Group associate with, engage in, and support only care, research, and equivalent activity that abide by the most robust and humane interpretations of applicable guidelines, laws, and regulations.

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.

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.

Accessibility. To endeavor that the sites, spaces, and attendant communities The Ikoku Group creates, benefits, fosters, reaches, and serves become reasonably available to those who abide by this Code of Ethics, and the Codes and Policies, regardless of disability or notions of human, cultural or social difference.

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.

Review and Evaluation. To periodically review and evaluate for mission alignment and effectiveness at The Ikoku Group. To develop consenting, policy-abiding and lawful means for such review and report — expressly approved and administered by the Founder, Alvan Azinna Chibuzo Ikoku. And to in this manner distill and incorporate lessons learned.

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.

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 Violation or Incompatibility — 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 engaging in any activity engaging, involving, referring to, relating to, or otherwise pertaining to 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 the 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.