ERHC Energy takes its responsibility to its shareholders seriously and promotes strong ethical conduct to ensure that it conducts its business in the best interest of its shareholders and in full compliance with its legal obligations. At ERHC Energy we strongly believe in maintaining absolute integrity and transparency in our disclosures to the public.

Our Code of Ethics is designed to promote honest and ethical conduct, full, fair, accurate, timely and understandable disclosure of financial information in the periodic reports of ERHC Energy, and compliance with applicable laws, rules, and regulations.

In June 2005, the Board of Directors approved and adopted a policy on compliance with the Foreign Corrupt Practices Act and a Compensation Committee Charter.

Concerns regarding ERHC's accounting, internal controls or auditing matters should be addressed through the Company's General Counsel to the Chairman of the Audit Committee.