EXHIBIT 11.1

Le Gaga Holdings Limited

Code of Business Conduct and Ethics

INTRODUCTION

Purpose

This Code of Business Conduct
and Ethics contains general guidelines for conducting the business of the Company consistent with the highest standards of business ethics. To the extent this Code requires a higher standard than required by commercial practice or applicable laws,
rules or regulations, we adhere to these higher standards.

This Code applies to all of the directors, officers and employees of the Company
and its subsidiaries (which, unless the context otherwise requires, are collectively referred to as the Company in this Code). We refer to all persons covered by this Code as Company employees or simply employees.
We also refer to our Chief Executive Officer and our Chief Financial Officer as our principal financial officers.

Seeking Help
and Information

This Code is not intended to be a comprehensive rulebook and cannot address every situation that you may face. If you feel
uncomfortable about a situation or have any doubts about whether it is consistent with the Companys ethical standards, seek help. We encourage you to contact your supervisor for help first. If your supervisor cannot answer your question or if
you do not feel comfortable contacting your supervisor, contact the Compliance Officer of the Company. The compliance email address for the Company regarding the reporting of any compliance cases is Compliance@landvchina.com. You may remain
anonymous and will not be required to reveal your identity in your communication to the Company.

Reporting Violations of the Code

All employees have a duty to report any known or suspected violation of this Code, including any violation of the laws, rules, regulations
or policies that apply to the Company. If you know of or suspect a violation of this Code, immediately report the conduct to your supervisor. Your supervisor will contact the Compliance Officer, who will work with you and your supervisor to
investigate the matter. If you do not feel comfortable reporting the conduct to your supervisor or you do not get a satisfactory response, you may contact the Compliance Officer directly. Employees making a report need not leave their name or other
personal information and reasonable efforts will be used to conduct the investigation that follows from the report in a manner that protects the confidentiality and anonymity of the employee submitting the report. All reports of known or suspected
violations of the law or this Code will be handled sensitively and with discretion. Your supervisor, the Compliance Officer and the Company will protect your confidentiality to the extent possible, consistent with law and the Companys need to
investigate your concern.



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It is Company policy that any employee who violates this Code will be subject to appropriate discipline,
which may include termination of employment. This determination will be based upon the facts and circumstances of each particular situation. An employee accused of violating this Code will be given an opportunity to present his or her version of the
events at issue prior to any determination of appropriate discipline. Employees who violate the law or this Code may expose themselves to substantial civil damages, criminal fines and prison terms. The Company may also face substantial fines and
penalties and may incur damage to its reputation and standing in the community. Your conduct as a representative of the Company, if it does not comply with the law or with this Code, can result in serious consequences for both you and the Company.

Policy against Retaliation

The Company prohibits retaliation against an employee who, in good faith, seeks help or reports known or suspected violations. Any reprisal or retaliation
against an employee because the employee, in good faith, sought help or filed a report will be subject to disciplinary action, including potential termination of employment.

Waivers of the Code

Waivers of this Code for employees may be made only by an executive
officer of the Company. Any waiver of this Code for our directors, executive officers or other principal financial officers may be made only by our Board of Directors and will be disclosed to the public as required by law or the rules of the NASDAQ
Global Market.

CONFLICTS OF INTEREST

Identifying Potential Conflicts of Interest

A conflict of interest can occur when an
employees private interest interferes, or appears to interfere, with the interests of the Company as a whole. You should avoid any private interest that influences your ability to act in the interests of the Company or that makes it difficult
to perform your work objectively and effectively.

Identifying potential conflicts of interest may not always be clear-cut. The following
situations are examples of conflicts of interest:



| |  ̈ | Outside Employment. No employee should be employed by, serve as a director of, or provide any services to, a company that is a customer, supplier or competitor of the
Company.
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| |  ̈ | Improper Personal Benefits. No employee should obtain any material (as to him or her) personal benefits or favors because of his or her position with the Company.
Please see Gifts and Entertainment below for additional guidelines in this area.
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| |  ̈ | Financial Interests. No employee should have a significant financial interest (ownership or otherwise) in any company that is a customer, supplier or competitor of the
Company. A significant financial interest means (i) ownership of greater than 1% of the equity of a customer, supplier or competitor or (ii) an investment in a customer, supplier or competitor that represents more than 5% of
the total assets of the employee.
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| |  ̈ | Loans or Other Financial Transactions. No employee should obtain loans or guarantees of personal obligations from, or enter into any other personal financial
transaction with, any company that is a customer, supplier or competitor of the Company. This guideline does not prohibit arms-length transactions with banks, brokerage firms or other financial institutions.
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| |  ̈ | Service on Boards and Committees. No employee should serve on a board of directors or trustees or on a committee of any entity (whether profit or not-for-profit) whose
interests reasonably would be expected to conflict with those of the Company.
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| |  ̈ | Actions of Family Members. The actions of family members outside the workplace may also give rise to the conflicts of interest described above because they may
influence an employees objectivity in making decisions on behalf of the Company. For purposes of this Code, family members include your spouse or life-partner, brothers, sisters and parents, in-laws and children whether such
relationships are by blood or adoption.
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Disclosure of Conflicts of Interest

The Company requires that employees disclose any situations that reasonably would be expected to give rise to a conflict of interest. If you suspect that
you have a conflict of interest, or something that others could reasonably perceive as a conflict of interest, you must report it to your supervisor or the Compliance Officer. Your supervisor and the Compliance Officer will work with you to
determine whether you have a conflict of interest and, if so, how best to address it. Although conflicts of interest are not automatically prohibited, they are not desirable and may only be waived as described in Waivers of the Code
above.

CORPORATE OPPORTUNITIES

As an employee of the Company, you have an obligation to advance the Companys interests when the opportunity to do so arises. If you discover or are presented with a business opportunity through the
use of corporate property, information or because of your position with the Company, you should first present the business opportunity to the Company before pursuing the opportunity in your individual capacity. No employee may use corporate
property, information or his or her position with the Company for personal gain or should compete with the Company.

You should disclose to
your supervisor the terms and conditions of each business opportunity covered by this Code that you wish to pursue. Your supervisor will contact the Compliance Officer and the appropriate management personnel to determine whether the Company wishes
to pursue the business opportunity. If the Company waives its right to pursue the business opportunity, you may pursue the business opportunity on the same terms and conditions as originally proposed and consistent with the other ethical guidelines
set forth in this Code.

CONFIDENTIAL INFORMATION

Employees have access to a variety of confidential information while employed at the Company. Confidential information includes all non-public information that might be of use to competitors, or, if
disclosed, harmful to the Company or its customers. Every employee has a duty to respect and safeguard the confidentiality of the Companys information and the information of our suppliers and customers, except when disclosure is authorized or
legally mandated. In addition, you must refrain from using any confidential information from any previous employment if, in doing so, you could reasonably be expected to breach your duty of confidentiality to your former employers. An
employees obligation to protect confidential information continues after he or she leaves the Company. Unauthorized disclosure of confidential information could cause competitive harm to the Company or its customers and could result in legal
liability to you and the Company.



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Employees also have a duty to protect the Companys intellectual property and other business assets.
The intellectual property, business systems and the security of Company property are critical to the Company.

Any questions or concerns
regarding whether disclosure of Company information is legally mandated should be promptly referred to the Compliance Officer.

Safeguarding Confidential Information and Company Property

Care must be taken to safeguard and protect confidential information and Company property. Accordingly, the following measures should be adhered to:



| |  ̈ | The Companys employees should conduct their business and social activities so as not to risk inadvertent disclosure of confidential information. For example, when
not in use, confidential information should be secretly stored. Also, review of confidential documents or discussion of confidential subjects in public places (e.g., airplanes, trains, taxis, buses, etc.) should be conducted so as to prevent
overhearing or other access by unauthorized persons.
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| |  ̈ | Within the Companys offices, confidential matters should not be discussed within hearing range of visitors or others not working on such matters.
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| |  ̈ | Confidential matters should not be discussed with other employees not working on such matters or with friends or relatives, including those living in the same household
as a Company employee.
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| |  ̈ | Company employees are only to access, use and disclose confidential information that is necessary for them to have in the course of performing their duties. They are
not to disclose confidential information to other employees or contractors at the Company unless it is necessary for those employees or contractors to have such confidential information in the course of their duties.
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| |  ̈ | The Companys files, personal computers, networks, software, internet access, internet browser programs, e-mails, voice mails and other business equipment (e.g.
desks and cabinets) and resources are provided for business use and they are the exclusive property of the Company. Misuse of such Company property is not tolerated.
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COMPETITION AND FAIR DEALING

All employees are obligated to deal fairly with fellow
employees and with the Companys customers, suppliers and competitors. Employees should not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other
unfair-dealing practice.

Relationships with Customers

Our business success depends upon our ability to foster lasting customer relationships. The Company is committed to dealing with customers fairly, honestly and with integrity. Specifically, you should
keep the following guidelines in mind when dealing with customers:



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 ̈ Information we supply to customers should
be accurate and complete to the best of our knowledge. Employees should not deliberately misrepresent information to customers.

 ̈ Employees should not refuse to sell, service, or maintain products the Company has
produced simply because a customer is buying products from another supplier.

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Customer entertainment should not exceed reasonable and customary business practice. Employees should not provide entertainment or other benefits that could be viewed as an inducement to or a reward for, customer purchase decisions. Please see
Gifts and Entertainment below for additional guidelines in this area.

Relationships with Suppliers

The Company deals fairly and honestly with its suppliers. This means that our relationships with suppliers are based on price, quality, service and
reputation, among other factors. Employees dealing with suppliers should carefully guard their objectivity. Specifically, no employee should accept or solicit any personal benefit from a supplier or potential supplier that might compromise, or
appear to compromise, their objective assessment of the suppliers products and prices. Employees can give or accept promotional items of nominal value or moderately scaled entertainment within the limits of responsible and customary business
practice. Please see Gifts and Entertainment below for additional guidelines in this area.

Relationships with Competitors

The Company is committed to free and open competition in the marketplace. Employees should avoid actions that would be contrary to laws
governing competitive practices in the marketplace, including antitrust laws. Such actions include misappropriation and/or misuse of a competitors confidential information or making false statements about the competitors business and
business practices.

PROTECTION AND USE OF COMPANY ASSETS

Employees should protect the Companys assets and ensure their efficient use for legitimate business purposes only. Theft, carelessness and waste have a direct impact on the Companys
profitability. The use of Company funds or assets, whether or not for personal gain, for any unlawful or improper purpose is prohibited.

To
ensure the protection and proper use of the Companys assets, each employee should:

 ̈ Exercise reasonable care to prevent theft, damage or misuse of Company property.

 ̈ Report the actual or suspected theft, damage or misuse of Company property
to a supervisor.

 ̈ Use the Companys telephone system, other electronic
communication services, written materials and other property primarily for business-related purposes.

 ̈ Safeguard all electronic programs, data, communications and written materials from inadvertent access by others.

 ̈ Use Company property only for legitimate business purposes, as authorized in connection with your job responsibilities.

Employees should be aware that Company property includes all data and communications transmitted or received to or by, or contained in, the
Companys electronic or telephonic systems.



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Company property also includes all written communications. Employees and other users of Company property
should have no expectation of privacy with respect to these communications and data. To the extent permitted by law, the Company has the ability, and reserves the right, to monitor all electronic and telephonic communications. These communications
may also be subject to disclosure to law enforcement or government officials.

GIFTS AND ENTERTAINMENT

The giving and receiving of gifts (including meals, entertainment, transportation costs, sponsorship expenses, festivities subsidy and red packets) is a
common business practice. Appropriate business gifts and entertainment are welcome courtesies designed to build relationships and understanding among business partners. However, gifts and entertainment should not compromise, or appear to compromise,
your ability to make objective and fair business decisions.

It is your responsibility to use good judgment in this area. As a general rule,
you may give or receive gifts or entertainment to or from customers or suppliers only if the gift or entertainment would not be viewed as an inducement to or reward for any particular business decision. All gifts and entertainment expenses should be
properly accounted for on expense reports. The following specific examples may be helpful:



| |  ̈ | Meals and Entertainment. You may occasionally accept or give meals, refreshments or other entertainment if:
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| |  |  | The items are of reasonable value;
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| |  |  | The purpose of the meeting or attendance at the event is business related; and
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| |  |  | The expenses would be paid by the Company as a reasonable business expense if not paid for by another party.
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Entertainment of reasonable value may include food and tickets for sporting and cultural events if they are generally offered to other customers,
suppliers or vendors.

 ̈ Advertising and Promotional Materials. You may
occasionally accept or give advertising or promotional materials of nominal value.

 ̈ Personal Gifts. You may accept or give personal gifts of reasonable value that are
related to recognized special occasions such as a graduation, promotion, new job, wedding, retirement or a holiday. A gift is also acceptable if it is based on a family or personal relationship and unrelated to the business involved between the
individuals.

 ̈ Gifts Rewarding Service or Accomplishment. You may accept a
gift from a civic, charitable or religious organization specifically related to your service or accomplishment.

You must be particularly
careful that gifts and entertainment are not construed as bribes, kickbacks or other improper payments. See The Foreign Corrupt Practices Act for a more detailed discussion of our policies regarding giving or receiving gifts related to
business transactions.

However, on top of taking the above factors into consideration, under no circumstances can the monetary value of the
gifts or entertainment to be given to third parties exceed RMB5,000 per one instance.



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You should make every effort to refuse or return a gift that is beyond these permissible guidelines. If it
would be inappropriate to refuse a gift or you are unable to return a gift, you should promptly report the gift to your supervisor. Your supervisor will bring the gift to the attention of the Compliance Officer, who may require you to donate the
gift to an appropriate community organization. If you have any questions about whether it is permissible to accept a gift or something else of value, contact your supervisor or the Compliance Officer for additional guidance. In any case, the
monetary value of a gift to be received cannot exceed RMB500.

COMPANY RECORDS

Accurate and reliable records are crucial to our business. Our records are the basis of our earnings statements, financial reports and other disclosures to the public and guide our business
decision-making and strategic planning. Company records include booking information, payroll, timecards, travel and expense reports, e-mails, accounting and financial data, measurement and performance records, electronic data files and all other
records maintained in the ordinary course of our business. All Company records must be complete, accurate and reliable in all material respects. Undisclosed or unrecorded funds, payments or receipts are inconsistent with our business practices and
are prohibited. You are responsible for understanding and complying with our record keeping policy. Ask your supervisor if you have any questions.

ACCURACY OF FINANCIAL REPORTS AND OTHER PUBLIC COMMUNICATIONS

As a public company we are
subject to various securities laws, regulations and reporting obligations. These laws, regulations and obligations and our policies require the disclosure of accurate and complete information regarding the Companys business, financial
condition and results of operations. Inaccurate, incomplete or untimely reporting will not be tolerated and can severely damage the Company and result in legal liability. It is essential that the Companys financial records, including all
filings with the Securities and Exchange Commission (SEC) be accurate and timely. Accordingly, in addition to adhering to the conflict of interest policy and other policies and guidelines in this Code, the principal financial officers
and other senior financial officers must take special care to exhibit integrity at all times and to instill this value within their organizations. In particular, these financial officers must ensure their conduct is honest and ethical that they
abide by all public disclosure requirements by providing full, fair, accurate, timely and understandable disclosures, and that they comply with all other applicable laws and regulations. These financial officers must also understand and strictly
comply with International Financial Reporting Standards and all standards, laws and regulations for accounting and financial reporting of transactions, estimates and forecasts.

In addition, U.S. federal securities law requires the Company to maintain proper internal books and records and to devise and maintain an adequate system of internal accounting controls. The SEC has
supplemented the statutory requirements by adopting rules that prohibit (1) any person from falsifying records or accounts subject to the above requirements and (2) officers or directors from making any materially false, misleading, or
incomplete statement to an accountant in connection with an audit or any filing with the SEC. These provisions reflect the SECs intent to discourage officers, directors, and other persons with access to the Companys books and records
from taking action that might result in the communication of materially misleading financial information to the investing public.



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COMPLIANCE WITH LAWS AND REGULATIONS

Each employee has an obligation to comply with all laws, rules and regulations applicable to the Companys operations. These include, without limitation, laws covering bribery and kickbacks,
copyrights, trademarks and trade secrets, information privacy, insider trading, illegal political contributions, antitrust prohibitions, foreign corrupt practices, offering or receiving gratuities, environmental hazards, employment discrimination or
harassment, occupational health and safety, false or misleading financial information or misuse of corporate assets. You are expected to understand and comply with all laws, rules and regulations that apply to your job position. If any doubt exists
about whether a course of action is lawful, you should seek advice from your supervisor or the Compliance Officer.

COMPLIANCE WITH INSIDER
TRADING LAWS

The Company has an insider trading policy, which may be obtained from the Compliance Officer. The following is a summary of
some of the general principles relevant to insider trading, and should be read in conjunction with the aforementioned specific policy.

Company employees are prohibited from trading in shares or other securities of the Company while in possession of material, nonpublic information about
the Company. In addition, Company employees are prohibited from recommending, tipping or suggesting that anyone else buy or sell shares or other securities of the Company on the basis of material, nonpublic information. Company employees
who obtain material nonpublic information about another company in the course of their employment are prohibited from trading in shares or securities of the other company while in possession of such information or tipping others to trade
on the basis of such information. Violation of insider trading laws can result in severe fines and criminal penalties, as well as disciplinary action by the Company, up to and including termination of employment.

Information is non-public if it has not been made generally available to the public by means of a press release or other means of widespread
distribution. Information is material if a reasonable investor would consider it important in a decision to buy, hold or sell stock or other securities. As a rule of thumb, any information that would affect the value of stock or other
securities should be considered material. Examples of information that is generally considered material include:

 ̈ Financial results or forecasts, or any information that indicates the Companys financial results may exceed or fall short of forecasts or expectations;

 ̈ Important new products or services;

 ̈ Pending or contemplated acquisitions or dispositions, including mergers, tender offers
or joint venture proposals;

 ̈ Possible management changes or changes of
control;

 ̈ Pending or contemplated public or private sales of debt or equity
securities;

 ̈ Acquisition or loss of a significant customer or contract;

 ̈ Significant write-offs;



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 ̈ Initiation or settlement of significant
litigation; and

 ̈ Changes in the Companys auditors or a notification
from its auditors that the Company may no longer rely on the auditors report.

The laws against insider trading are specific and
complex. Any questions about information you may possess or about any dealings you have had in the Companys securities should be promptly brought to the attention of the Compliance Officer.

PUBLIC COMMUNICATIONS AND PREVENTION OF SELECTIVE DISCLOSURE

Public Communications Generally

The Company places a high value on its credibility and
reputation in the community. What is written or said about the Company in the news media and investment community directly impacts our reputation, positively or negatively. Our policy is to provide timely, accurate and complete information in
response to public requests (media, analysts, etc.), consistent with our obligations to maintain the confidentiality of competitive and proprietary information and to prevent selective disclosure of market-sensitive financial data. To ensure
compliance with this policy, all news media or other public requests for information regarding the Company should be directed to the Companys Investor Relations Department. The Investor Relations Department will work with you and the
appropriate personnel to evaluate and coordinate a response to the request.

Prevention of Selective Disclosure

Preventing selective disclosure is necessary to comply with United States securities laws and to preserve the reputation and integrity of the Company as
well as that of all persons affiliated with it. Selective disclosure occurs when any person provides potentially market-moving information to selected persons before the news is available to the investing public generally. Selective
disclosure is a crime under United States law and the penalties for violating the law are severe.

The following guidelines have been
established to avoid improper selective disclosure. Each employee is required to follow these procedures:

 ̈ All contact by the Company with investment analysts, the press and/or members of the media must be made through the Chief Executive Officer, Chief Financial Officer or persons designated by them
(collectively, the Media Contacts).

 ̈ Other than the Media
Contacts, no officer, director or employee can provide any information regarding the Company or its business to any investment analyst or member of the press or media.

 ̈ All inquiries from third parties, such as industry analysts or members of the media, about the Company or its business should be directed to a Media
Contact. All presentations to the investment community regarding the Company will be made by us under the direction of a Media Contact.



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 ̈ Other than the Media Contacts, any
employee who is asked a question regarding the Company or its business by a member of the press or media must respond with No comment and forward the inquiry to a Media Contact.

These procedures do not apply to the routine process of making previously released information regarding the Company available upon inquiries made by investors, investment analysts and members of the
media.

Please contact the Compliance Officer if you have any questions about the scope or application of the Companys policies
regarding selective disclosure.

THE FOREIGN CORRUPT PRACTICES ACT

Foreign Corrupt Practices Act

The Foreign Corrupt Practices Act (the FCPA)
prohibits the Company and its employees and agents from offering or giving money or any other item of value to win or retain business or to influence any act or decision of any governmental official, political party, candidate for political office
or official of a public international organization. Stated more concisely, the FCPA prohibits the payment of bribes, kickback or other inducements to foreign officials. This prohibition also extends to payments to a sales representative or agent if
there is reason to believe that the payment will be used indirectly for a prohibited payment to foreign officials. Violation of the FCPA is a crime that can result in severe fines and criminal penalties, as well as disciplinary action by the
Company, up to and including termination of employment.

Certain small facilitation payments to foreign officials may be permissible under the
FCPA if customary in the country or locality and intended to secure routine governmental action.

Governmental action is routine
if it is ordinarily and commonly performed by a foreign official and does not involve the exercise of discretion. For instance, routine functions would include setting up a telephone line or expediting a shipment through customs. To
ensure legal compliance, all facilitation payments must receive prior written approval from the Compliance Officer and must be clearly and accurately reported as a business expense.

ENVIRONMENT, HEALTH AND SAFETY

The Company is committed to providing a safe and healthy
working environment for its employees and to avoiding adverse impact and injury to the environment and the communities in which we do business. Company employees must comply with all applicable environmental, health and safety laws, regulations and
Company standards. It is your responsibility to understand and comply with the laws, regulations and policies that are relevant to your job. Failure to comply with environmental, health and safety laws and regulations can result in civil and
criminal liability against you and the Company, as well as disciplinary action by the Company, up to and including termination of employment. You should contact the Compliance Officer if you have any questions about the laws, regulations and
policies that apply to you.



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Environment

All Company employees should strive to conserve resources and reduce waste and emissions through recycling and other energy conservation measures. You have a responsibility to promptly report any known or
suspected violations of environmental laws or any events that may result in a discharge or emission of hazardous materials. Employees whose jobs involve manufacturing have a special responsibility to safeguard the environment. Such employees should
be particularly alert to the storage, disposal and transportation of waste, and handling of toxic materials and emissions into the land, water or air.

Health and Safety

The Company is committed not only to comply with all relevant health and
safety laws, but also to conduct business in a manner that protects the safety of its employees. All employees are required to comply with all applicable health and safety laws, regulations and policies relevant to their jobs. If you have a concern
about unsafe conditions or tasks that present a risk of injury to you, please report these concerns immediately to your supervisor or the Human Resources Department.

EMPLOYMENT PRACTICES

The Company pursues fair employment practices in every aspect of its
business. The following is intended to be a summary of our employment policies and procedures. Copies of our detailed policies are available from the Human Resources Department. Company employees must comply with all applicable labor and employment
laws, including anti-discrimination laws and laws related to freedom of association, privacy and collective bargaining. It is your responsibility to understand and comply with the laws, regulations and policies that are relevant to your job. Failure
to comply with labor and employment laws can result in civil and criminal liability against you and the Company, as well as disciplinary action by the Company, up to and including termination of employment. You should contact the Compliance Officer
or the Human Resources Department if you have any questions about the laws, regulations and policies that apply to you.

Harassment and
Discrimination

The Company is committed to providing equal opportunity and fair treatment to all individuals on the basis of merit,
without discrimination because of race, color, religion, national origin, sex (including pregnancy), sexual orientation, age, disability, veteran status or other characteristic protected by law. The Company prohibits harassment in any form, whether
physical or verbal and whether committed by supervisors, non-supervisory personnel or non-employees. Harassment may include, but is not limited to, offensive sexual flirtations, unwanted sexual advances or propositions, verbal abuse, sexually or
racially degrading words, or the display in the workplace of sexually suggestive objects or pictures.

If you have any complaints about
discrimination or harassment, report such conduct to your supervisor or the Human Resources Department. All complaints will be treated with sensitivity and discretion. Your supervisor, the Human Resources Department and the Company will protect your
confidentiality to the extent possible, consistent with law and the Companys need to investigate your concern. Where our investigation uncovers harassment or discrimination, we will take prompt corrective action, which may include disciplinary
action by the Company, up to and including, termination of employment. The Company strictly prohibits retaliation against an employee who, in good faith, files a compliant.



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Any member of management who has reason to believe that an employee has been the victim of harassment or
discrimination or who receives a report of alleged harassment or discrimination is required to report it to the Human Resources Department immediately.

Alcohol and Drugs

The Company is committed to maintaining a drug-free work place. All
Company employees must comply strictly with Company policies regarding the abuse of alcohol and the possession, sale and use of illegal substances. Drinking alcoholic beverages is prohibited while on duty or on the premises of the Company, except at
specified Company-sanctioned events. Possessing, using, selling or offering illegal drugs and other controlled substances is prohibited under all circumstances while on duty or on the premises of the Company. Likewise, you are prohibited from
reporting for work, or driving a Company vehicle or any vehicle on Company business, while under the influence of alcohol or any illegal drug or controlled substance.

Violence Prevention and Weapons

The safety and security of Company employees is vitally
important. The Company will not tolerate violence or threats of violence in, or related to, the workplace. Employees who experience, witness or otherwise become aware of a violent or potentially violent situation that occurs on the Companys
property or affects the Companys business must immediately report the situation to their supervisor or the Human Resources Department.

The Company does not permit any individual to have weapons of any kind in Company property or vehicles, while on the job or off-site while on Company
business. The only exception to this policy applies to security personnel who are specifically authorized by Company management to carry weapons.

DECLARATION OF UNDERSTANDING OF AND COMPLIANCE WITH THE CODE

All staff members are
required to declare their understanding of and compliance with the Code on an annual basis. A declaration form will be distributed to each staff member for signing. The Company has the responsibility to conduct training for all staff members about
the Code on an annual basis and ensure that all staff members have free access to the Code. The Compliance Officer is responsible to review the Code on an annual basis to ensure the Code is up to date with current laws and regulations and common
practices. The Compliance Officer is required to update the Code on an annual basis in response to changes, if any, in laws and regulations and common practices and present the revisions, if any, to the Board of Directors for approval.

CONCLUSION

This Code of Business
Conduct and Ethics contains general guidelines for conducting the business of the Company consistent with the highest standards of business ethics. If you have any questions about these guidelines, please contact your supervisor or the Compliance
Officer. We expect all directors, officers and employees of the Company to adhere to these standards.

This Code of Business Conduct and
Ethics, as applied to the Companys principal financial officers, shall be our code of ethics within the meaning of Section 406 of the Sarbanes-Oxley Act of 2002 and the rules promulgated thereunder.



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This Code and the matters contained herein are neither a contract of employment nor a guarantee of
continuing Company policy. We reserve the right to amend, supplement or discontinue this Code and the matters addressed herein, without prior notice, at any time.