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.