Core expectations and code of ethics

The Company is committed to upholding high standards of business integrity, honesty and transparency in all its business dealings.  We will comply with local laws and international good practice and will not become involved in any way in the offering, payment, soliciting or acceptance of bribes in any form.

All Directors and appointed advisers are expected to:

• Behave honestly, be trustworthy and set a good example;
• Make sure that their behaviour complies with the policies of MedicX Fund;
• Use the resources of the Company in the best interest of the Company, and not to misuse those resources;
• Not to pay or accept bribes or kickbacks, whether in the public or the commercial sector;
• Make a clear distinction between the interests of the Company, the interests of the organisation that they are employed by, and their individual private interests, and avoid possible conflicts of interest.  Gifts, invitations or other advantages which could contradict this principle are not accepted;
• Ensure that they comply with UK and applicable international anti-corruption laws; and
• Report incidents, risks and issues which deviate from our policies.

In accordance with these commitments, and to support the above behaviours, the Company has developed this policy for countering corruption and bribery.

Application of this policy

This policy applies to MedicX Fund Ltd ("the Fund" or "the Company") and all subsidiary companies over which it exercises control (together, "the Group").  It also applies to all directors of the Company (including those of subsidiaries), and those employees of the Investment Adviser and Administrator (which for these purposes includes temporary or contract staff and consultants) (the "Agents").  In addition, the Group expects its business partners to comply with the prohibitions on bribery set out in this policy.

All Directors and Agents are required to comply with this policy.

The Board of Directors is committed to supporting this policy.  The Board is responsible for establishing and implementing this policy.  Questions in relation to this policy should be directed to the Audit Committee Chairman.