The Code defines the ethical and regulatory standards applicable to all directors, officer and employees (the Representatives) of Bankers Petroleum Ltd. and its subsidiaries and affiliates, to promote:

• honest and ethical conduct;
• avoidance of conflicts of interest, whether actual or potential;
• full, fair, accurate, timely and understandable disclosure in financial statements, reports and documents that the Company files with, or submits to, shareholders and securities authorities, as well as in other public communications made by the Company;
• compliance with various legislation and regulations applicable to the Company;
• prompt internal disclosure of any violation of the Code; and
• accountability for any failure to respect the Code.

The Code is not a comprehensive guide to all of the Company's policies or to all of the responsibilities of the Representatives under applicable laws and regulations governing the Company and its operations.

The Code is intended to provide general parameters and expectations of the Company with respect to the conduct of the Company's Representatives. Violations of law or of the Company's policies, including this Code may lead to disciplinary action, including, but not limited to, dismissal.

• Code of Ethics