CODE OF BUSINESS CONDUCT AND ETHICS

Introduction

This Code of Business Conduct and Ethics (referred to hereinafter as the Code) sets forth the Companys policies with respect to the way we conduct ourselves individually and operate our business.  The provisions of this Code are designed to promote honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships.  All employees, officers and directors of the Company must comply with the provisions of this Code.  References to employees contained in this Code should be understood as referring to officers and directors as well.

In the course of performing our various roles in the Company, each of us will encounter ethical questions in different forms and under a variety of circumstances.  Moments of ethical uncertainty may arise in our dealings with fellow employees, with customers, or with other parties such as government entities or members of our community.  Our employees should never be content with simply obeying the letter of the law, but must also strive to comport themselves in an honest and ethical manner.  This Code provides rules and procedures to help our employees, officers and directors recognize and respond to situations that present ethical issues.  For guidance with respect to issues not addressed in this Code, employees are directed to our Employee Handbook which sets forth the Companys policies on a wide range of issues that arise in the course of employment.

The reputation of the Company is our greatest asset and its value relies on the character of its employees.  In order to protect this asset, the Company will not tolerate unethical behavior by employees, officers or directors.  Those who violate the standards in this Code will be subject to disciplinary action.  If you are concerned about taking an action that may violate the Code or are aware of a violation by another employee, an officer or a director, follow the guidelines set forth in Sections 6 and 7 of this Code.

1.              Compliance with Laws, Rules and Regulations

Company policy requires that all employees, officers and directors of the Company, comply fully with both the spirit and the letter of all laws, rules and regulations.  Whenever an applicable law, rule or regulation is unclear or seems to conflict with either another law or any provision of this Code, all employees, officers and directors are urged to seek clarification from their supervisor, the appropriate compliance official.

2.              Conflicts of Interest

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