BBNC Code of Ethics Code of Ethics_Light_final_joomag 2 | Page 4

Message from Jason Metrokin Bristol Bay Native Corporation (BBNC) was established by the Alaska Native Claims Settlement Act (ANCSA) of 1971 with the mission: Enriching Our Native Way of Life. With headquarters in Anchorage, Alaska, BBNC has worked to deliver value to the Native people of Southwest Alaska through economic development, cultural enhancement and preservation, stewardship of our lands and educational scholarships. Theses benefits are made possible by the hard work and dedication of our subsidiaries and employees. As of 2019, BBNC employs approximately 4,500 employees in subsidiaries throughout Alaska and beyond. Alaska will always be our home, but today we are a global company, with diversified and successful business operations around the world. As an Alaska Native Corporation, no matter where we work or how large we grow, our values are at the core of our operations and actions. They shape how we treat each other as well as how we conduct our business around the world. These values have been our foundation, and they are also our future. While BBNC‘s success depends on these values, along with delivery of high-quality products and services, our employees are our most valuable resource as a company. We rely on each of you to ensure that BBNC’s Culture of Integrity is infused into daily activities and operations. BBNC is committed to integrity in everything we do — and we believe that is a shared responsibility. Each BBNC 2 employee is a champion for our corporation and our values. I ask that you take the time to closely review the BBNC Code of Ethics and Business Conduct (Code). The Code sets out BBNC’s standards for conducting business and our expectations for all. This Code provides specific guidance applicable to all BBNC subsidiaries, directors, officers, employees and agents and to all business activities conducted by the corporation. While it is as comprehensive as possible, it is not possible to include answers to every question. If you are faced with a situation that is not clearly addressed by this Code, or if you have questions of any kind, please reach out to your supervisor, company leader or use the other resources available to you, including the BBNC Compliance Department, or the BBNC Ethics Hotline. I am proud to work for BBNC and to represent the values and integrity that BBNC is associated with in our communities. Thank you for all that you do, and for being a BBNC leader. Best Regards, Jason Metrokin BBNC President & CEO BBNC Code of Ethics | Ethics Hotline: 1.866.513.7078 | Effective May 17, 2019 | www.bbnc.net