Code of Ethics

INTRODUCTION

It is the company policy of Tubular King to conduct its business affairs honestly, ethically and in full accordance with the law. Our Core Values form the foundation of our business and should be met at all times. These core values are as followed:

• Honesty and Integrity

• Safety and respect for the Company work force, (officers, employees and contractors), Customers and Suppliers.

• Safety of People, Property and the Environment

• Adherence to all applicable USA and International laws.

• Fair Employment

• Maintaining the highest standards of Business Conduct and Ethics, Anti-Corruption and Business Conduct Policy and Confidential Information Policy, all of which apply to the Tubular King and its Directors and all its work force.

Conduct that may raise questions as to the Company’s or of any of its director’s or Employee’s honesty, integrity, impartiality, or reputation is prohibited. Any activity, conduct, or transaction that is or may appear to be unethical, illegal or improper business conduct must be avoided at all times.

GENERAL BUSINESS PRINCIPLES

BUSINESS ETHICS

It is the policy of Tubular King to comply with all applicable laws, rules and regulations. The workforce are to deal honestly and adhere to the highest level of ethical standards in all business activities at all times in order to earn and then keep the trust of our customers, and everyone we impact in our business activities.

Ethics and compliance training is given to all Company employees and contractors to ensure the highest possible standards are met and that all applicable laws and regulations are complied with wherever we operate. This Code of Business Ethics applies to the Board of Directors, the Company, and all employees, all of whom are required to adhere to its terms. The Code’s standards and requirements will be provided to and followed by the Company’s agents and representatives, including consultants.

QUALITY AND OPERATIONAL REQUIREMENTS

The Company strives to consistently improve safety, asset reliability, operating efficiency, and the environments protection. Our quality management systems serve to document the processes by which we will conduct our daily operations and to provide a means of assuring consistent performance through the management of change. The Company is committed to fulfill the highest possible level of excellence in HSE, operations, engineering, Supply Chain Management, personnel and maintenance. We are committed to improve in all business activities to better serve our customers.

RISK MANAGEMENT

The Company is committed to the highest possible level of safety, environmental, operational and financial performance. To minimize risk the company supplies the most advanced specification of rigs and equipment available, and ensures that they are maintained in good working order. All employees are fully qualified and given the required training when required and all rigs are audited on a regular basis to ensure that policies and procedures are followed and that crew members and contractors use equipment safely and properly.

SUPPLY CHAIN ACTIVITIES

It is Company’s policy to attain the best quality materials and equipment in accordance with the customers schedule requirements, whilst ensuring the highest possible level of safety to personnel and the environment.

The Company ensures that all suppliers meet obligations of the Business code of conduct and Ethics by completing anti-corruption and due diligence checks during tendering. The supplier must demonstrate high standards of ethics and integrity in all business dealings and complying with all applicable laws, regulations and rules. We expect our contractors, suppliers and subcontractors to comply with all applicable Tubular King policies.