Pytheas' Code of Ethics and Business Conduct

The purpose of this Code of Ethics and Business Conduct is to set forth basic principles to guide you in your day-to-day activities as an employee, officer or director of Pytheas. It should be read together with other Firm policies and procedures, including the officer and employee Code of Conduct. It does not cover every legal or ethical issue that you may confront at the Firm. Indeed, no Code can attempt to anticipate the myriad issues that arise in a business as diverse and dynamic as Pytheas'. However, by following this Code and other Firm policies and procedures, by adhering to the letter and the spirit of all applicable laws and regulations, and above all by applying sound judgment to your activities, you can demonstrate your commitment to the Firm's five core values-integrity, excellence, respect for individuals and cultures, entrepreneurial spirit and teamwork.

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