INSIDER TRADING POLICY & US FEDERAL SECURITIES LAWS

The purpose of this policy is to govern activities concerning employee trading in securities. It is the policy of Emergence Global Inc. (the “Company”) that its directors, officers, employees (full time, part-time, contract and temporary) and associates including those of all subsidiary companies (collectively, the “Company Employees”), and all others who act on the Company’s behalf, observe the spirit and letter of all laws governing the Company’s operations, and conduct the Company’s affairs in keeping with the highest legal and ethical standards.

This policy, which has been approved by the Audit Committee of the Company’s Board of Directors, has been designed to assist Company Employees in understanding and complying with the Company’s policies and The Securities and Exchange Commission rules and regulations with respect to the trading of the Company’s securities. The policies set forth below may not cover every situation. If there is ever any doubt as to a proper course of action, Company Employees should consult with the Company’s Chief Executive Officer, the Company’s Corporate Secretary, or the Chief Financial Officer (each, a “Senior Officer”).