QCA Code Principle 8

The Board requires that the Company’s strategy of building a portfolio of underwriting capacity at Lloyd’s through the purchase of corporate members is carried out in a manner that is ethical and sustainable. This is achieved by focussing on syndicate portfolios comprising quality syndicates which are managed by leading managing agents at Lloyd’s.

The Directors and the Board determine, support and will observe the Company’s ethical values in order to promote and preserve the Company’s reputation. It is the policy of the Company to conduct business in an honest and ethical manner and steps taken by the Company to prevent modern slavery, human rights violations or trafficking in its business and supply chains are detailed in the Company’s Modern Slavery Statement. Furthermore, the Company takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships, wherever it operates, and implementing and enforcing effective systems to counter bribery. How this is ensured is detailed in the Company’s Anti-Corruption and Bribery Policy which, together with the Company’s Modern Slavery Statement, is available in the Documents and Papers section of the Company’s website.

The Board has adopted a Share Dealing Code and Disclosure Policy that any Director, employee or person engaged by the Company who is in possession of ‘inside information’ must comply with. All such persons are prohibited from trading in the Company’s securities if they are in possession of ‘inside information’. The Directors will also comply with Rule 21 of the AIM Rules relating to Directors’ dealings.

In addition, in the interests of openness and transparency, a record is kept of Directors’ interests and of persons closely associated with them to ensure they have no conflicts or possible conflicts with the interests of the Company. The Board also reviews whether there are relationships or circumstances which do, or are likely to, affect independence of the Non-Executive Directors.