bingzhu@chemspeccomcn.pdf

CHEMSPEC INTERNATIONAL LIMITED CODE OF BUSINESS CONDUCT AND ETHICS INTRODUCTION Purpose This Code of Business Conduct and Ethics contains general guidelines for conducting the business of the Company consistent with the highest standards of business ethics. To the extent this Code requires a higher standard than required by commercial practice or applicable laws, rules or regulations, we adhere to these higher standards. This Code applies to all of the directors, officers and employees of the Company and its subsidiaries (which, unless the context otherwise requires, are collectively referred to as the “Company” in this Code). We refer to all persons covered by this Code as “Company employees” or simply “employees”. We also refer to our Chief Executive Officer, our Chief Financial Officer, our principal accounting officer and our controller as our “principal financial officers.” Seeking Help and Information This Code is not intended to be a comprehensive rulebook and cannot address every situation that you may face. If you feel uncomfortable about a situation or have any doubts about whether a situation is consistent with the Company’s ethical standards, seek help. We encourage you to contact your supervisor for help first. If your supervisor cannot answer your question or if you do not feel comfortable contacting your supervisor, contact one the Compliance Officers of the Company, who has been appointed by the Board of Directors of the Company. Compliance Officers Bing Zhu has been appointed by the Board of Directors of the Company as the Compliance Officer for the Company. Bing Zhu can be reached at +86 21 5270-2636 and bing.zhu@. The Company will notify you if the Board of Directors appoints different Compliance Officers. You may also seek help from or submit information to the Company by writing to the Company at the email address “bing.zhu@”. You may remain anonymous and will not be required to reveal your identity in your communica