Code of Business Ethics and Compliance

Mission

The mission of CIRI is to promote the economic and social well-being and Alaska Native heritage of our shareholders, now and into the future, through prudent stewardship of the Company's resources, while furthering self-sufficiency among CIRI shareholders and their families. We will continue to achieve this mission by staying true to our values.

CIRI's Business Ethics and Compliance Program and our Code of Business Ethics and Compliance have been developed to provide a clear and common understanding of our values and the legal and ethical expectations that we have for the conduct of CIRI's business activities. The Code has been written to help us put those values into action. Although we know that no written document can ever guarantee anyone's individual behavior, acting ethically and with integrity is a decision all of us must make and demonstrate each day in every one of our activities and interactions.

While our Code cannot cover every situation we may encounter, it is a guide, along with our more detailed policies and procedures, for our daily conduct at CIRI. If you have questions about business ethics or a compliance concern, I encourage you to discuss the issue openly and candidly with your manager, any member of CIRI management, the Legal Compliance Manager, or by calling our Business Ethics and Compliance Assistance Line at (888) 228-7798.

I have great confidence that we will continue to conduct our business with the highest ethical and legal standards. This is a commitment we must continue to keep for ourselves, our business and, most importantly, for our shareholders.

Sincerely,

Margaret L. Brown

President and CEO