Trilogy brings ideas, opportunities and capital together

Purpose

This Code of Ethics applies to all Trilogy directors, officers and employees, as well as to directors, officers and employees of each subsidiary of Trilogy. Such directors, officers and employees are referred to herein collectively as the “Covered Parties”, Trilogy and its subsidiaries are referred to herein collectively as “Trilogy”.

Trilogy has and will continue to uphold highest levels of business ethics in all types of transactions. With this Code of Ethics we aim to emphasize the our commitment to ethics and compliance with the law, document the basic standards of ethical and legal behavior, help prevent and detect wrongdoing and provide reporting tools for suspected ethical or legal violations. This Code of Ethics serves only as a rough guide due to the complexity of ethical questions that arise in the course of business.

Conflicts of interest

A conflict of interest exists when a person’s private interest interferes in any way directly or not with the interests of Trilogy. As conflicts of interest may not always be obvious, it is advised in case of questions to consult a supervisor or the legal department. Every Covered Party should bring to the attention of the legal department or a supervisor any knowledge of a conflict or potential conflict.

Corporate Opportunities

Covered Parties are prohibited from taking for themselves opportunities that are discovered through the use of corporate property, corporate resources or information without the consent of the legal department of Trilogy.

Covered Parties shall always act in good faith, with due care, and shall engage only in fair and open competition, by treating ethically competitors, suppliers, customers, and colleagues. No gift should ever be offered or accepted by a Covered Party or any family member of a Covered Party unless it is consistent with customary business practices, is not excessive in value, cannot be construed as a bribe or payoff and does not violate any laws or regulations. The offer or acceptance of cash gifts by any Covered Party is prohibited.

Insider Trading

Covered Parties who have access to confidential information are not permitted to use or share that information for stock trading purposes or for any other purpose except the conduct of the Trilogy’s business. All non-public information about Trilogy should be considered confidential information.

Confidentiality

Covered Parties have to maintain the confidentiality of confidential information, except when disclosure is authorized by the legal department of Trilogy or required by law. The obligation to preserve confidential information continues even after employment ends.

Protection of Company Assets

All Covered Parties should endeavor to protect Trilogy´s assets. Any suspected incident of fraud or theft should be immediately reported for investigation.

Compliance with Laws, Rules and Regulations

Obeying the law, is the foundation on which Trilogy´s ethical standards are built. In conducting the business of Trilogy, the Covered Parties shall comply with applicable governmental laws, rules and regulations at all levels of government in which Trilogy does business.

Reporting known or suspected violations

Covered Parties should report to supervisors, managers or other appropriate personnel about known or suspected illegal or unethical behavior. No retaliatory action of any kind will be permitted against anyone making such a report in good faith.

Accountability for violations

If Trilogy´s appropriate organes determine that this Code has been violated, either directly, by failure to report a violation, or by withholding information related to a violation, the offending Covered Party may be disciplined for non-compliance with penalties up to and including removal from office or dismissal. Violations of this Code may also constitute violations of law and may result in criminal penalties and civil liabilities for the offending Covered Party and Trilogy. All Covered Parties are expected to cooperate in internal investigations of misconduct.