WhiteHorse Finance, Inc.

Weexpect each of our officers and directors, as well asany person affiliated with our operations, to act in accordance with the highest standards of personal and professional integrityat alltimes and to comply with the Company’s policies and procedures and all laws, rules and regulations of any applicable international, federal, provincial, state or local government. Tothis effect, the Company has adopted a Code of Conduct (the “Code of Conduct”), which is posted on the Company’s website at www.whitehorsefinance.com. The Code of Conduct applies to the Company’sdirectors, executive officers, officers and their respective staffs. Weand WhiteHorse Advisers have each adopted and maintain a code of ethics pursuant to Rule 17j-1 of the 1940 Act. Our code of ethics, which we maintain with WhiteHorse Advisers (the “Joint Code of Ethics”), establishes procedures that apply to our directors, executive officers, officers, their respective staffs and the employees of WhiteHorse Advisers with respect to their personal investments and investment transactions. Personnel subject to the Joint Code of Ethicsmay invest in securitiesfor their personal investment accounts, including securities that may be purchased or held by us, so long as such investments are made in accordance with the Joint Code of Ethics’ requirements. In addition, the Joint Code of Ethics does not expressly prohibit directors, officers or employees of the Company or WhiteHorse Advisers from purchasing financial instruments (including prepaid variable forward contracts, equity swaps, collars, and exchange funds), or from otherwise engaging in transactions, that hedge or offset, or are designed to hedge or offset, any decrease in the market valueof our Common Stock.

Youmay access the Joint Code of Ethics via the Internetatthe website of the SECatwww.sec.govor our website at www.whitehorsefinance.com. We intend to disclose any material amendments to or waivers of required provisions of the Joint Code of Ethics on a current report on Form 8-K.