Simply put, we seek to employ people who believe that honest and ethical behavior is not only good business, but also the right thing to do personally.

As employees, officers and directors of our Company, each of us is responsible for safeguarding our business reputation by respecting others, acting with honesty and integrity, and engaging in fair and ethical business practices. Of course, doing the right thing is not always easy. Many situations will involve subtleties and complexities that lead to difficult choices. When in doubt, take a step back to ask yourself whether the situation feels right, and consider whether you feel confident that your actions would withstand scrutiny. If necessary, take another careful look at the Code for guidance and seek advice. Your actions should not have even the appearance of impropriety. You should be able to feel comfortable that your actions would not embarrass yourself, your colleagues or our investors should it turn out that your conduct becomes ‘front page’ news.

Any employee who ignores or violates any provision of the Code, and any manager or supervisor who penalizes a subordinate for trying to follow the Code, will be subject to appropriate disciplinary action consistent with relevant laws and regulations.