This Conflict of Interest Policy of The International Association of Credit Portfolio Managers, Inc. (the “Association”): (1) defines conflicts of interest; (2) identifies classes of individuals within the Association covered by this policy; (3) facilitates disclosure of information that may help identify conflicts of interest; and (4) specifies procedures to be followed in managing conflicts of interest.

1. Definition of conflicts of interest. A conflict of interest arises when a person in a position of authority over the Association may benefit financially from a decision he or she could make in that capacity, including indirect benefits such as to family members or businesses with which the person or a family member is closely associated, whether by reason of employment, an investment or otherwise. This policy is focused upon material financial interests of, or benefit to, such persons.

2. Individuals covered. Persons covered by this policy are the Association’s officers, directors, and staff. Each person covered by this policy shall annually sign a statement which affirms such person: (a) has received a copy of the conflict of interest policy; (b) has read and understands the policy; (c) has agreed to comply with the policy; and (d) understands that, in order to maintain its Federal tax exemption, the Association must engage primarily in activities which accomplish one or more of its tax exempt purposes.

3. Facilitation of disclosure. In connection with actual or possible conflict of interest involving a person covered by this policy, such person must disclose, in writing, the existence of such conflict and related facts, including any relevant actual or potential ownership, compensation or investment interest of such person or a family member, to the Chairman of the Board of Directors.

4. Procedures to manage conflicts. For each interest disclosed to the Chairman of the Board of Directors, the Chairman will determine whether to: (a) take no action; (b) assure full disclosure to the Board of Directors and other individuals covered by this policy; (c) ask the person to recuse himself or herself from participation in related discussions or decisions within the Association; or (d) ask the person to resign from his or her position in the Association or, if the person refuses to resign, become subject to possible removal in accordance with the Association’s removal procedures.