SEABOARD TCC
TRANSCONTINENTAL CAPITAL CORP. (BERMUDA LTD.
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Seaboard’s Commitment

Seaboard’s Code of Ethics -The successful operation and reputation of Seaboard Corporation and its subsidiaries and affiliates (collectively, the "Company") depend upon the principles of fairness and ethical conduct of its directors, officers and employees. The Company's reputation for integrity and excellence requires careful compliance with the spirit and letter of all laws and regulations, as well as a commitment to the highest standards of personal and professional conduct.

The success and survival of this organization depends upon wise business decisions and an attitude of trust and respect between the Company and its customers, vendors and suppliers, employees, and shareholders. That trust must be preserved. Directors, officers and employees have a duty to support the goals and objectives of the Company, and to act in a way that will always merit the continued trust and confidence of the Company's customers, vendors and suppliers, employees, and shareholders.

Accordingly, the Company adopts this Code of Ethics requiring its directors, officers, managers, employees and vendors to comply with the provisions outlined below. As all other subsidiaries of Seaboard Corporation, Seaboard Power has adopted this Code of Ethics as a policy. If you have any questions pertaining to specific aspects of our Code of Ethics, please contact the Manager of the Human Resources Department, at 687-0101.