Code of Business Conduct

Introduction

Since its founding, JCM Solar Capital Ltd.’s (“JCM”) business practices have been governed by integrity, honesty, fair dealing and compliance with all applicable laws. JCM employees worldwide have upheld and lived this commitment in their everyday responsibilities ever since, and JCM’s reputation remains one of the company’s most important assets today.

Our Code of Business Conduct (“Code”) establishes certain non-negotiable minimum standards of behaviour in key areas. The scope of this Code is not meant to cover all possible situations that may occur. Rather, it is designed to provide a frame of reference against which to measure any activities.

Employees should seek guidance from the General Counsel of JCM when they are in doubt about the proper course of action in a given situation, as it is the ultimate responsibility of each employee to “do the right thing”, a responsibility that cannot be delegated. Employees should always be guided by the following basic principles:

For the purposes of this Code, references to “employees” include officers and employees of, and consultants regularly engaged for 10 or more hours per week by, JCM or any of its subsidiaries.

Download JCM's Code of Business Conduct