Himalayan Investments’ Code of Ethics is in alignment with its values and commitments. The essence of this code is that all Company employees, including all officers, as well as Himalayan Investments Board of Directors should conduct the Company’s business in a way that upholds its values and commitments and shall endeavor to deal fairly with the Company’s customers, suppliers and competitors. At Himalayan Investments we strive to maintain a culture where our ideas and concerns are acknowledged and considered. This gives us the freedom to be at our best, extend trust, demonstrate ethical leadership and pursue our Vision and Purpose.

It is expected that all employees and directors be conscientious and loyal in representing the Company and in using and conserving its resources; conflicts of interest will never be tolerated. All employees should protect the Company’s assets and ensure their efficient use for legitimate business purposes. Proper management of confidential information by employees and directors is very important to the Company. Loyalty to the Company includes a commitment not to use or give to others trade secrets or confidential information belonging to the Company or belonging to others with whom the Company does business.

Employees and directors will be held accountable for adherence to this Code. Employees who violate the Code will be subject to disciplinary action, including potential termination of employment.