Why do we need a Code of Conduct?

Ethical behavior is an essential part of your position with CFR and is a personal responsibility that should be taken very seriously. We need and expect each employee to be accountable for their work and behavior and to support the values, principles, and standards upon which CFR business reputation rests. This Code of Conduct (the "Code") is a guide to help you live up to CFR values, abide by CFR policies and respect the best interest of our customers and shareholders. The purpose of the Code is to describe principles of business conduct and to provide guidance in ethical decision making. Many sections of the Code reference matters for which specific policies exist; this is because the Code encompasses standards of behavior set forth in other CFR policies. The Code is especially important for CFR to ensure the laws, rules and regulations are in place, which govern the disclosure of information about the business of the companies. The Code outlines the basic legal obligations of all CFR employees. CFR Asset’s affairs will be under close scrutiny by shareholders, regulators and the investment community. We must be aware of our obligations and conduct ourselves in accordance with the highest ethical and moral standards.

Although the Code lays out fundamental principles of ethical and legal conduct, it cannot anticipate every ethical dilemma or situation you may encounter in performing the task. If at any time you are unsure about the proper course of action discuss your concerns.

Application of the Code

The Code applies to all employees, stakeholders, contractors and the members of the Board, which for purposes of the Code are referred to as "Interested Parties". Contractors include any consultants, suppliers’ vendors or service providers who are required to have access to CFR’s confidential, business and proprietary information in order to perform their duties.

Compliance

Compliance with the Code is mandatory. You are expected to be familiar and comply with the Code in the performance of your duties. As well, you are expected to understand your obligations under CFR policies. On an annual basis all employees and members of the Board are required to sign an Annual Acknowledgement of Corporate Policies form. Those of us who fail to abide by the Code and CFR’s policies will be subject to disciplinary action, up to and including dismissal or prosecution.

Responsibilities to Report

It is the responsibility of everybody at CFR to report any known or suspected unethical conduct, which includes any violation of the Code, by other Interested Parties or anyone in any way associated with the corporation. CFR Asset is committed to protecting all Employees who report unethical conduct from reprisal as well as offering any necessary support to individuals who make reports. When an Employee makes a report of unethical conduct they should do so in good faith.

Insider trading and tipping

CFR’s Securities Trading and Insider Reporting Policy applies to all the interested parties. Applicable securities laws prohibit all Employees with access to or knowledge of material non-public information from or about CFR from buying, selling or otherwise trading in CFR securities or from informing or tipping others about material non-public information.

Conduct when representing CFR

Conduct yourself professionally and with personal integrity, both in and out of the workplace, reflective of CFR values. Communicate and negotiate with honesty with all Employees, customers, partners, stakeholders, suppliers, associates, and other members of the public. Our obligation to act with integrity and within the spirit of this Code continues while traveling, whether domestically or abroad.

Legal and social responsibility

Ensure that your actions comply with and are within the meaning and intent of all applicable laws and regulations. Ensure that your actions are free from suspicion and criticism and have no unfavorable effects on society.

Conduct with Clients

Serving clients is the focal point of our business. Our clients deserve the highest quality service and standards in all transactions. We provide our clients with value and deal fairly, act with integrity and do everything possible to provide great services to our clients, either directly or by supporting the work of other individuals or business units.

Use of Corporate Information and Property

Do not disclose information about CFR activities or our customers’ activities to non-authorized parties within the workplace, or anyone outside the workplace unless in accordance with CFR’s Disclosure Policy. All information held by CFR is confidential and the property of CFR. This includes information relating to CFR business, property, Employees, customers, partners, consultants, or others that is not generally available to the public. In our business, we become aware of confidential information about our customers’ business and personal ventures. We have a responsibility to uphold the trust of our customers. Do not discuss or disclose confidential customer information outside the workplace and ensure that uses of confidential customer information within CFR are consistent with the purposes for which it was collected. Our obligation to keep corporate information confidential continues post-assignment also. For further information about the privacy of client’s personal information, consult the Company’s Privacy Policy.

CFR Code of Conduct Policy ensure that corporate property under our control is used in accordance with CFR’s acceptable use of Information Technology Policy and CFR Security Policy and is protected from use by unauthorized individuals. Employees are responsible for ensuring that:

• CFR’s assets are protected and not used for personal use unless otherwise authorized;
• CFR’s intellectual property is subject to copyright and is not reproduced, distributed or altered without authorization;
• As far as practicable, contracts are put in writing; and
• Unless otherwise authorized CFR’s name or purchasing power is not used to obtain personal benefits, discounts or rebates.

Use of computer systems and software

Our computer systems and Software form the backbone of our services and our operations infrastructure. Every effort should be made to protect CFR systems and associated software from various threats to their security such as accidental or deliberate destruction of data or equipment, interruption of service, disclosure of confidential information, theft or corruption of data. Any security concerns with respect to our systems or software, or any viruses or data network attacks, weaknesses or unexplained system changes should immediately be reported to the Management.