Preview | Code of Business Conduct and Ethics |

This Code of Business Conduct and Ethics 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 EnergySouth, Inc. and its subsidiaries (collectively referred to as the Company). All of our directors, officers and employees must conduct themselves accordingly and seek to avoid even the appearance of improper behavior. The Code should also be provided to and followed by the Companys agents and representatives, including consultants.

If a law conflicts with a policy in this Code, you must comply with the law; however, if a local custom or policy conflicts with this Code, you must comply with the Code. If you have any questions about these conflicts, you should ask your supervisor how to handle the situation.

Those who violate the standards in this Code will be subject to disciplinary action, up to dismissal for cause. If you are in a situation which you believe may violate or lead to a violation of this Code, follow the guidelines described in Section 14 of this Code Violation of this Code will be enforced by the same mechanisms as other violations of applicable duties or Company standards .

Obeying the law, both in letter and in spirit, is the foundation on which this Companys ethical standards are built. All employees must respect and obey the laws of the cities in which we operate, the State of Alabama and the United States of America. Although not all employees are expected to know the details of these laws, it is important to know enough to determine when to seek advice from supervisors, managers or other appropriate personnel.

The Company holds information and training sessions to promote compliance with laws, rules and regulations, including insider-trading laws.

A conflict of interest exists when a persons private interest interferes in any way with the interests of the Company. A conflict situation can arise when an employee, officer or director takes actions or has interests that may make it difficult to perform his or her Company work objectively and effectively. Conflicts of interest may also arise when an employee, officer or director, or members of his or her family or friends, receive

improper personal benefits as a result of his or her position in the Company. Loans to officers are subject to prohibitions under federal law, and loans by the Company to, or guarantees by the Company of obligations of, directors, officers, employees or their family members may create conflicts of interest.

It is almost always a conflict of interest for a Company officer, director or employee to be simultaneously employed by the Company and a competitor, customer or supplier. As an officer, you are not allowed to work for a competitor as a consultant or board member. The best policy is to avoid any direct or indirect business connection with our customers, suppliers or competitors, except on our behalf.

Conflicts of interest are prohibited as a matter of Company policy, except as approved by the Board of Directors. Conflicts of interest may not always be clear-cut, so if you have a question, you should consult with higher levels of management or the Companys General Counsel. Any employee, officer or director who becomes aware of a conflict or potential conflict must bring it to the attention of a supervisor, manager or other appropriate personnel or consult the procedures described in Section 14 of this Code.

3. Insider Trading

The Companys Board of Directors has formalized the Companys insider trading policy. The policy is described in the EnergySouth, Inc. Policy Statement on Insider Trading dated July 26, 2002, a copy of which is attached as Appendix A.

4. Corporate Opportunities

Employees, officer and directors are prohibited from taking for themselves personally opportunities that are discovered through the use of corporate property, information or position without the consent of the Board of Directors. No officer, director or employee may use corporate property, information, or position for improper personal gain, and no officer, director or employee may compete with the Company directly or indirectly. Employees, officers and directors owe a duty to the Company to advance its legitimate interests when the opportunity to do so arises.

5. Competition and Fair Dealing

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