Imperial Holdings Limited // Code Of Ethics
Purpose

It is a core value of IMPERIAL to act with uncompromising honesty and integrity. This Code of Ethics provides guidance to all staff, management and directors of IMPERIAL and its subsidiaries to ensure adherence to this core value.

While the Code provides a broad range of guidance, no Code can address every situation that individuals are likely to encounter. As a result, this Code is not a substitute for our responsibility and accountability to exercisegood judgment and obtain guidance on appropriate business conduct.

The Code

At all times we shall:
  1. Respect others and avoid any form of discrimination.
  2. Abide by the laws of the country in which we operate and comply withthe code of conduct of all professional and industry bodies to which we belong.
  3. Avoid any waste, damage and private use of company assets and resources, (including time)
  4. Not give or receive any bribes.
  5. At the earliest opportunity, disclose in writing to the appropriate level of management all gifts which are not of a token value received from clients or suppliers.
  6. Not divulge any confidential information to any party, or otherwise make improper use of company and client information.
  7. Market our products and services accurately and charge the agreed fee, or where no fee was agreed, a fair fee.
  8. Not seek to advance our personal interests at the expense of the company or our clients.
  9. Not engage in any activity, whether directly or indirectly, which results or might result in a conflict of individual interests with the interests of the group.
  10. Not partake in, or involve the company in any way with any scheme that would cause embarrassment to the company or harm its reputation. If we feel that the public disclosure of any action would be detrimental to the company then this action should be avoided.

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Latest Results
Audited Preliminary Results for the year ended 30 June 2010

Unaudited Results December 2009
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