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Our Code of Ethics 

Employees of Bavaria Gulf Real Estate shall:

Act with honesty and integrity, avoiding actual or apparent conflicts of interest in personal and professional relationships.

Avoid transactions that involve potential conflicts of interest, or which have not been appropriately processed in accordance with company policy; employees shall disclose to at least one of the individuals designated in item 11 below any material transaction or relationship that reasonably could be expected to give rise to such a conflict.

Provide full, fair, accurate, timely and understandable disclosure in reports and documents filed with the company, or submitted through any other public communication statements made by the company.

Comply in good faith with applicable laws, rules and regulations of local governments, and of other appropriate private and public regulatory agencies.

Act in good faith, responsibly, with due care, competence and diligence, without misrepresenting material facts or allowing his or her independent judgment to be subordinated.

Respect the confidentiality of information acquired in the course of his or her work, except when authorized or otherwise legally obligated to disclose. Confidential information acquired in the course of his or her work shall not be used for personal advantage.

Maintain skills important to his or her constituents’ needs.

Promote ethical behavior as a responsible partner among peers in his or her work environment.

Achieve responsible use of and control over all assets and resources employed or entrusted to him or her.

Be accountable for adherence to this Code.

Promptly report any violations of this Code to the Chairman.

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(c) 2008 Bavaria Gulf Real Estate LLC, P.O. Box 214970, Dubai, UAE All rights reserved.