On November 27, 2012, Vantage Drilling Company (the "Company") adopted revisions to its Code of Business Conduct and Ethics that applies to all of the Company's directors, officers and employees (the "Code of Conduct").

The revisions amend to the Code of Conduct to (i) expressly prohibit the undue or fraudulent influence of auditing or accounting functions, (ii) require directors, officers and employees to disclose any error in the Company's financial records of which they are aware, (iii) prohibit directors, officers and employees from holding an interest in private companies with which the Company does business, and require reporting to the Chief Compliance Officer of certain interests in public companies with which the Company does business and
(iv) clarify certain requirements with respect to director, officer, and employee transactions in Company securities.

The newly adopted Code of Conduct is attached hereto as Exhibit 14.1 and is also available at www.vantagedrilling.com on the "Corporate Governance" page under the link "Vantage Code of Conduct and Ethics."

(d) Exhibits

   Exhibit
   Number    Exhibit Description

   14.1      Code of Business Conduct and Ethics as amended November 27, 2012.