Principles of trust law require that the Trustees, Chief Executive Officer, and Executives of the Estate of Bernice Pauahi Bishop (the Kamehameha Schools or "KS") maintain the highest standards of integrity, ethics and business morals and demonstrate their undivided loyalty to the persons intended to benefit from the charitable purposes expressed in the Will of Bernice Pauahi Bishop.

To achieve this goal, each Trustee, Chief Executive Officer, and Executive 1) avoids knowing participation in any transaction which may be an actual or potential Conflict of Interest, 2) discloses information about personal financial interests or external activities which present potential or actual Conflicts of Interest, and 3) adheres to prescribed, on-going disclosure and review procedures developed specifically to avoid actual or potential Conflicts of Interest.

In general, the Trustees, Chief Executive Officer, and Executives may not deal with the trust property individually nor hold a position of conflicting interest with KS. The Trustees', Chief Executive Officer's, and Executives' duty of loyalty requires that they administer the trust solely with a view to the accomplishment of the purposes of the trust and not with a view to promoting their own interests.

Corporate and partnership opportunities, knowledge, directorships, member-ships and other benefits accruing to KS or its Trustees, Chief Executive Officer, and Executives by reason of KS' ownership of an interest in the entity, contractual rights or voting strength shall belong to and be the property of KS and any compensation, benefit, option or opportunity inuring to any Trustee, Chief Executive Officer, or Executive in connection with such entities shall belong to and be the property of KS.

The Board of Trustees, together with KS' Chief Legal Officer, shall review and update this policy and these procedures on a periodic basis to ensure adherence to the highest standards of integrity, ethics and business morals by each Trustee, Chief Executive Officer, and Executive.