ETHICAL PRINCIPLES

ICU Venture Capital Trust’s management, employees and suppliers adhere to the following ethical principles in their conduct of business.

ICU VENTURE CAPITAL TRUST

All activities are carried out in accordance with internationally accepted corporate governance principles. Dealings between management, employees, partners, suppliers, affiliates and 3rd parties take place within legal and ethical rules and standards.

Competition rules are strictly adhered to and competitors treated in an honest manner.

All activities that might cause financial damage to investors and other stakeholders are avoided, and necessary measures are deployed to prevent conflicts of interest. Best efforts are made to make information available to investors on a timely and cost effective basis.

Institutionalization and its enforcement are ensured through procedures and internal policies produced in written form.

An honest, transparent, humane and environmentally friendly approach to management is enforced. Legal and human rights of all employees are protected, and a fair working environment is ensured where everyone is treated equally. Diverse backgrounds, profiles and assets are sought in both recruitment and partnerships.

EMPLOYEES and SUPPLIERS

ICU Venture Capital Trust accepts responsibility for ensuring adherence to ethical standards.

They act in accordance with the laws, regulations and internal company regulations under all circumstances. Any activity or relationship serving personal interests or causing conflict of interest is avoided. All employees are required to report every unethical undertaking.

They are aware of their obligation to carefully keep all confidential information of the company and its subsidiaries. Allocation and use of assets of the firm and its affiliates are to be treated as if they were personal assets.