Code of Ethics

CODE OF BUSINESS CONDUCT AND ETHICS
OF BABYLON LTD.

Introduction

This Code of Business Conduct and Ethics (the “Code”) of Babylon Ltd. (the "Company") covers a wide range of business practices and procedures. It does not cover every issue that may arise, but it sets out basic principles to guide all Directors, Officers and employees of the Company (the "Company Personnel"). Each of the Company Personnel must conduct themselves accordingly and seek to avoid even the appearance of improper behavior.

It is important to emphasize that the Code is formulated at the level of general principles only and cannot be expected to provide specific answers for every possible occasion. Nor does it replace specific and detailed procedures that the Company has instituted. It is, however, very important for each of the Company Personnel to understand the principles it contains, as well as applicable laws and the policies and procedures that relate to the Company Personnel's work. In case some part of this document is not clear, the Company Personnel are requested to contact our CEO or CFO for clarification.

This Code of Business Conduct is continually evaluated and may be amended, modified or terminated at any time without prior notice to the Company Personnel.

Those who violate the standards in this Code will be subject to disciplinary action, including termination of employment. If you are in a situation that you believe may violate or lead to a violation of this Code, follow the guidelines described in Section 16 of this Code.

Purpose of the Code