Business Conduct & Ethics

KRU OVERSEAS LIMITED and its subsidiaries (collectively, referred to as the “Company”) are committed to the highest standards of ethical conduct. Outlined in this Standard of Business Conduct and Ethics Policy (hereinafter the “Standard, Policy”) is the foundation of the Company’s outstanding reputation for integrity, ethics and respect for the law. This Policy contains the moral and ethical standards by which each employee, officer and director of the Company and its subsidiaries is to conduct the business activities of the Company. Every employee, officer and director needs to understand and adhere to these standards.

This Standard cannot and is not intended to cover every applicable law or Company policy, nor does it provide answers to all questions that might arise in the performance of your duties. You must rely on your good sense of what is right, including a recognition of when it is appropriate to seek guidance from others as to the proper conduct for a given situation. Because our business depends upon the reputation of the Company and its directors, officers, and employees for integrity and honest business conduct, in many instances this Standard goes beyond the requirements of the law.

The Company expects you to acquire and maintain a working knowledge of the laws and the Company’s ethical standards that are applicable to your responsibilities with the Company. In addition, every supervisor and manager is responsible for helping employees understand and comply with this standard. If you have any questions about the application of this Standard or about what is required by law in a particular situation, you should consult with your Departments, Chief Financial Officer or Legal Counsel.