Capital Banker

Code of Business Conduct

On March 12, 2007, the Board of Directors adopted a comprehensive Code of Business Conduct applicable to all directors, officers and employees that reaffirms Capital Banker's commitment to high standards of ethical conduct and reinforces Capital Banker's business ethics, policies and procedures. The Code of Business Conduct as amended October 10, 2007 and March 2, 2008, includes Capital Banker's policies, concerning among other things, compliance with laws, rules and regulations (including insider trading laws), conflicts of interest (including corporate opportunities) and protection of corporate assets. The October 10, 2007 amendment added Capital Banker’s Equal Rights Policy to the policies included within the Code of Business Conduct. The Audit Committee is responsible for monitoring compliance with the Code of Business Conduct.