Lazard Ltd has a Code of Business Conduct and Ethics applicable to all directors, Officers and employees of Lazard Ltd and its subsidiaries and affiliates (“Lazard”). The CEO, and all senior financial officers, including the CFO and principal accounting officer, are bound by the provisions set forth therein relating to ethical conduct, conflicts of interest and compliance with law. In addition to the Code of Business Conduct and Ethics, the CEO and senior financial officers are subject to the following additional specific policies:

1. The CEO and all senior financial officers are responsible for full, fair, accurate, timely and understandable disclosure in the periodic reports required to be filed by Lazard with the SEC. Accordingly, it is the responsibility of the CEO and each senior financial officer promptly to bring to the attention of the Disclosure Committee any material information of which he or she may become aware that affects the disclosures made by Lazard in its public filings or otherwise assist the Disclosure Committee in fulfilling its responsibilities as specified in Lazard’s policies relating to financial reporting and disclosure, and to controls and procedures.
   
   
2. The CEO and each senior financial officer shall promptly bring to the attention of the Disclosure Committee and the Audit Committee any information he or she may have concerning (a) significant deficiencies in the design or operation of internal controls which could adversely affect Lazard’s ability to record, process, summarize and report financial data or (b) any fraud, whether or not material, that involves management or other employees who have a significant role in Lazard’s financial reporting, disclosures or internal controls.
   
   
3. Each senior financial officer shall promptly bring to the attention of the General Counsel or the CEO and to the Audit Committee, and the CEO or General Counsel shall promptly bring to the attention of the Audit Committee, any information he or she may have concerning any violation of Lazard’s Code of Business Conduct and Ethics, including any actual or apparent conflicts of interest between personal and professional relationships, involving any management or other employees who have a significant role in Lazard’s financial reporting, disclosures or internal controls.
   
   
4. Each senior financial officer shall promptly bring to the attention of the General Counsel or the CEO and to the Audit Committee, and the CEO or General Counsel shall promptly bring to the attention of the Audit Committee, any information he or she may have concerning evidence of a material violation of the securities or other laws, rules or regulations applicable to Lazard and the operation of its business, by Lazard or any agent thereof, or of violation of the Code of Business Conduct and Ethics or of these additional procedures.
   
   
5. The Board of Directors shall determine, or designate appropriate persons to determine, appropriate actions to be taken in the event of violations of the Code of Business Conduct and Ethics or of these additional procedures by the CEO and Lazard’s senior financial officers. Such actions shall be reasonably designed to deter wrongdoing and to promote accountability for adherence to the Code of Business Conduct and Ethics and to these additional procedures, and shall include written notices to the individual involved advising such individual potentially among other things the Board’s determination that there has been a violation, any censure by the Board, any demotion or re-assignment of the individual involved, any suspension with or without pay or benefits (as determined by the Board) and any termination of the individual’s employment. In determining what action is appropriate in a particular case, the Board of Directors or such designee shall take into account all relevant information, including the nature and severity of the violation, whether the violation was a single occurrence or repeated occurrences, whether the violation appears to have been intentional or inadvertent, whether the individual involved had been advised prior to the violation as to the proper course of action and whether or not the individual involved had committed other violations in the past.