This Code of Conduct and Ethics helps to ensure compliance with legal United States requirements and the
standards of business conduct of L&L International Holdings, Inc. (the “Company”). All directors, officers and
employees of the Company are expected to read and understand this Code of Business Conduct and Ethics, uphold
these standards in day-to-day activities, comply with all applicable policies and procedures, and ensure that all
agents and contractors are aware of, understand and adhere to these standards.

This Code of Ethics and Business Conduct seeks to deter wrongdoing and to promote:

  • Honest and ethical conduct, including the ethical handling of actual or apparent  conflicts of interest
    between personal and professional relationships;

  • Full, fair, accurate, timely, and understandable disclosure in reports and documents that the Company files
    with, or submits to, the U.S. Securities and Exchange Commission (the “SEC”) and in other public
    communications made by the Company;

  • Compliance with applicable U.S. Government laws, rules and regulations;

  • Timely internal reporting of violations of this Code of Ethics and Business Conduct to an appropriate person
    or persons identified in this Code of Ethics and Business Conduct; and

  • Accountability for adherence to this Code of Ethics and Business Conduct.

We are continuously reviewing and updating our policies and Ethics as well as this Code of Business Conduct and
Ethics. Therefore, it is subject to modification. This Code of Business Conduct and Ethics supersedes all other such
codes, policies, procedures, rules, written and/or verbal representations to the extent they are inconsistent. For
detailed information, feel free to contact L&L.
Code of Conduct and Ethics