Ethics Policy Statement

Axis-Shield plc believes that high standards of business ethics are critical in today's business world and therefore places high priority on compliance with all legislative and regulatory requirements, and on the maintenance of high ethical standards, within each of the territories and jurisdictions in which it conducts its business.

Axis-Shield plc, its Divisions and businesses ("The Group") commits to conducting itself, and expects all employees to conduct themselves, in an honest, ethical manner in all dealings on its behalf and to behave professionally and with integrity and fairness at all times. The Group applies these same standards to all dealings with customers, suppliers, stakeholders, and public officials. These standards also apply to associates or intermediaries of any party involved in company business activities.

The Group's policy is that businesses should compete enthusiastically and fairly in the marketplace and must comply with the relevant competition laws of each country in which it operates. No employee may, either directly or indirectly, offer, solicit, pay or accept a bribe, or other such advantage that may be construed as such, in any form. Any approach from an external party soliciting a bribe or other advantage must be reported through line management or directly to the Group Director QA and Regulatory Affairs whose contact details are via e-mail: simon.richards@axis-shield.com. Corporate hospitality may only be offered to or accepted from a third party if it is modest in value and in compliance with any applicable law. Company contributions to political parties, organisations or their representatives that are related, either directly or indirectly, to the Group's business dealings are prohibited. All Group employees must maintain the confidentiality of price sensitive and commercial information and not use such information for their personal gain. Reporting of business performance should be undertaken in such a way that reflects the businesses' true performance and the risks and opportunities that business may face.

The Group recognises that it is important that all employees feel confident that they may freely and confidentially voice genuine concerns relating to possible business malpractice or breaches in ethical behaviour to the appropriate management level. You are encouraged to make your disclosure to your team leader/manager, or if this matter concerns your team leader/manager, then site HR individual, divisional senior manager or the Group Director QA and Regulatory Affairs whose contact details are given above. However, if you believe it is inappropriate to make your disclosure to an employee of the Company you may speak to the senior independent non-executive director, Bay Green whose e-mail address is: whistleblowing@axis-shield.com. In such circumstances the Group will respect the confidential nature of any communication and ensure the protection of any individuals acting in good faith from harassment or victimisation.

The Board of Directors of Axis-Shield plc is ultimately responsible for this Policy. The Group's executive management are responsible for ensuring that the Policy is enacted through integration into the Group's normal management systems; Divisional and business unit management are responsible for implementing and communicating this policy within their own Divisions and business units.

Against a background of evolving business and legal requirements Axis-Shield plc and each unit will regularly review and adapt their activities where necessary to comply with applicable laws and regulations and be consistent with maintaining the Group's high standards of ethics.

This policy will be reviewed on a regular basis and is published on the Group's web-site.