CADIZ INC

The Company has adopted a code of conduct and ethics that applies to all of our employees, including the CEO, CFO and COO. A copy of the code of conduct and ethics may be found on the Company’s website at* *http://investors.cadizinc.com/.

The code of conduct and ethics defines and prohibits conflicts of interest and provides means for communicating potential conflicts. It also prohibits using corporate opportunities, property, information, or position for personal gain. The code of conduct and ethics also includes confidentiality restrictions, rules for protection and proper use of Company assets, fair dealing requirements for interactions with customers, suppliers, and competitors and requirements for compliance with applicable law, including insider trading laws.

Any employee who becomes aware of any existing or potential violation of the code of conduct and ethics is required to report it. Any waivers from and amendments to the code of ethics granted to directors or executive officers will be promptly disclosed on the Company’s website athttp://www.cadizinc.com. There are no waivers from the code of conduct and ethics applicable to any employee at this time.