Whistleblower Policy

General

Majestic Capital, Ltd. Code of Business Conduct and Ethics requires employees, officers and directors of CRM Holdings and each of its wholly-owned subsidiaries (collectively, the "Company") to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As Company employees, officers and directors we must practice honesty and integrity in fulfilling our responsibilities and complying with all applicable laws and regulations. Pursuant to this Whistleblower Policy, any employee, officer or director of the Company or its subsidiaries may submit a good faith complaint regarding (i) violations of law, including any rule of the U.S. Securities and Exchange Commission, federal law, state law, Bermuda law, and the laws and regulation of any jurisdiction in which the Company operates; (ii) violations of the Company's Code of Business Conduct and Ethics or other Company policies or requirements for good corporate governance; (iii) any other matter which could cause harm to the business or public position of the Company; or (iv) accounting or auditing matters including but not limited to financial statement disclosure issues, internal accounting controls and auditing matters.

The purpose of this policy is also to establish procedures for (i) the submission of such complaints on a confidential and anonymous basis; (ii) the receipt, retention and treatment of such complaints; and (iii) the protection of employees, officers and directors reporting any such complaints.

Reporting Responsibility

It is the responsibility of all directors, officers and employees to comply with the Code of Business Conduct and Ethics and to report violations or suspected violations in accordance with this Whistleblower Policy.

Policy of Non-Retaliation

It is the Company's responsibility to comply with all applicable laws that protect its employees, officers or directors against unlawful discrimination or retaliation as a result of their lawfully reporting information regarding, or their participation in investigations involving alleged misconduct by the Company or its agents. Therefore, the purpose of this policy is to state clearly and unequivocally that the Company prohibits discrimination, harassment, retaliation, and/or adverse employment consequences against any employee, officer or director for the following:

(i) Disclosing information to a government or law enforcement agency or a representative of the Company, where the employee, officer or director has a good faith, reasonable belief that the information demonstrates a violation or possible violation of a law, rule or regulation of any jurisdiction in which the Company operates;

(ii) Providing information, filing, testifying or participating in a proceeding filed or about to be filed, or otherwise assisting in an investigation or proceeding regarding any conduct that the employee reasonably believes involves a violation or possible violation of a law, rule or regulation of any jurisdiction in which the Company operates; or

(iii) Providing information to the Company's representatives or other persons where the employee has a good faith, reasonable belief that the information discloses a violation or possible violation of the Code of Business Conduct and Ethics.

The Company will not discharge, demote, suspend, threaten, harass or in any manner discriminate against any employee in the terms and conditions of employment based upon any lawful actions of such employee with respect to good faith reporting of complaints regarding alleged misconduct (including accounting, internal accounting controls, auditing matters or otherwise as specified in Section 806 of the Sarbanes-Oxley Act of 2002). Any employee, officer or director who retaliates against someone who has reported a violation in good faith is subject to disciplinary action up to and including termination of employment.

Reporting of Complaints

Any employee, officer or director of the Company who in good faith believes that he or she has knowledge or concerns regarding violations of any laws or regulations of any jurisdictions in which the Company operates, violations of the Company's Code of Business Conduct and Ethics, financial statement disclosure issues, accounting, internal accounting controls, auditing matters or any other matter that could cause harm to the business or public position of the Company is strongly encouraged to report immediately the facts forming the basis of that knowledge or those concerns to the anonymous incident reporting hotline (the "Hotline") maintained by the Company through The Network Inc. This incident report line is available twenty-four hours a day, seven days a week at the number and email address set out at the end of this policy. Any employee, officer or director who witnesses any conduct which they legitimately and in good faith believe may be prohibited by this policy must immediately call the Hotline.

Treatment of Complaints

All complaints will be communicated by The Network Inc. to the General Counsel and Chief Executive Officer. Complaints relating to accounting or auditing matters including but not limited to the following, will be reviewed by the Audit Committee:

• accounting and auditing irregularities, including financial statement disclosure issues and internal auditing controls



• breaches of securities laws



• breaches of environmental laws



• falsification of Company records



• fraud or violations of laws regarding fraud



• fraudulent insurance and benefit claims



• improper loans to Company executives



• insider trading



• kickbacks



• retaliation against whistleblowers



• theft of cash



• theft of goods or services



• workplace violence or threats



• violations of the Company's Code of Business Conduct and Ethics



• commission or possible commission of criminal offenses

It is the obligation of all employees, officers and directors to cooperate in any investigation conducted by the General Counsel and/or Audit Committee. Confidentiality will be maintained to the fullest extent possible, consistent with the need to conduct a full and impartial investigation, remedy any violations or monitor compliance with the Company's policies. Prompt and appropriate corrective action will be taken when and as warranted in the judgment of the General Counsel or, with respect to accounting or auditing matters, in the judgment of the Audit Committee.

Reporting and Retention of Complaints and Investigations

The General Counsel will maintain a log of all complaints, tracking their receipt, investigation and resolution and shall prepare a periodic summary report thereof for the Audit Committee. Copies of complaints and such log will be maintained in accordance with the Company's document retention policy.

WHISTLEBLOWER POLICY
The Network Inc. Anonymous Incident Reporting Hotline: For North America call:
1-877-571-9754
Fax number: 770-409-5008, include the following in the fax cover sheet: The Network, Attn: CRM Holdings, Ltd.
Email: reportline@tnwinc.com
Web Address: www.tnwinc.com/webreport

Revised and Adopted: August 5, 2009

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