SEI Code of Conduct

SEI’s Code of Conduct sets forth the Company’s expectations that its employees conduct business in accordance with the Sumitomo Spirit and high ethical standards.  The Company encourages employees and contractors to report suspected violations of the Code and company policies and provides several avenues for reporting. One example is SEI’s Hotline, which anyone may use to anonymously report suspected policy violations.   External Point of Contact:     Expolink Europe Ltd. Telephone No.:         1-877-533-5310 Email address: Address: Expolink Europe Ltd.

 1 Greenways Business Park, Bellinger Close,

 Chippenham, SN15 1BN

United Kingdom

  Whether reporting is made to a manager/supervisor, Human Resources, a Compliance Liaison, the Legal Department, or the Hotline, SEI’s policies prohibit retaliation, either for reporting in good faith or for cooperating in an investigation of a suspected violation.