The Board has adopted a Code of Business Conduct and Ethics (“Code of Conduct”) that applies to all directors, officers and employees of Axos Financial, Inc. and its subsidiaries. Among other things, the Code of Conduct requires compliance with laws and regulations, avoidance of conflicts of interest and insider trading, and reporting of illegal or unethical behavior. A copy of the Code of Conduct will be made available via written request sent to Axos Financial, Inc., 9205 West Russell Road, Suite 400, Las Vegas, NV 89148, Attention: Corporate Secretary.