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Code of Ethics

Ethics Obligations for Chief Executive Officer and Employees with Financial Reporting Responsibilities

Revised: May 18, 2017

As a public company it is of critical importance that the Company’s reports to the public and filings with the Securities and Exchange Commission be accurate and timely.Depending on their position with the Company, employees may be called upon to provide information to assure that the Company’s public reports are complete, fair and understandable.The Company expects all of its personnel to take this responsibility very seriously and to provide prompt and accurate answers to inquiries related to the Company’s public disclosure requirements.

The Finance Department bears a special responsibility for promoting integrity throughout the organization, with responsibilities to stakeholders both inside and outside of the Company.The Chief Executive Officer and Finance Department personnel have a special role both to adhere to these principles themselves and also to ensure that a culture exists throughout the Company as a whole that ensures the fair and timely reporting of the Company’s financial results and condition.

Because of this special role, the Chief Executive Officer and all members of the Company’s Finance Department are bound by the following Code of Ethics, and by accepting this Code of Ethics, each agrees that he or she will:

  1. Act with honesty and integrity, avoiding actual or apparent conflicts of interest in personal and professional relationships.
  2. Provide information that is accurate, complete, objective, relevant, timely and understandable to ensure full, fair, accurate, timely, and understandable disclosure in reports and documents that the Company files, with, or submits to, government agencies and in other public communications.
  3. Comply with rules and regulations of federal, state, provincial and local governments, and other appropriate private and public regulatory agencies.
    Act in good faith, responsibly, with due care, competence and diligence, without misrepresenting material facts or allowing one’s independent judgment to be subordinated.
  4. Respect the confidentiality of information acquired in the course of one’s work except when authorized or otherwise legally obligated to disclose.Confidential information acquired in the course of one’s work will not be used for personal advantage.
  5. Share knowledge and maintain skills important and relevant to stakeholders’ needs.
  6. Proactively promote and be an example of ethical behavior as a responsible partner among peers, in the work environment and the community.
    Achieve responsible use of and control over all assets and resources employed or entrusted.
  7. Make no offer, promise, payment or authorization to pay anything of value to any foreign government official for the purpose of influencing any act or decision in order to obtain or retain business.
  8. Maintain records in reasonable detail to reflect accurately and fairly transactions and dispositions of assets.

Concerns about actions or circumstances that appear inconsistent with our Code of Conduct should be dealt with as follows:

If the matter is not resolved or if you do not feel comfortable discussing the matter with any of the persons listed above, you can contact the Company’s Integrity Line, which is operated by an independent company, and report the matter, if permitted by local law.

You can contact the Integrity Line:

If the matter involves questionable accounting or auditing matters, you can also contact the Audit Committee of the Board of Directors:

Violations of this Code of Ethics, including failures to report potential violations by others, will be viewed as a severe disciplinary matter that may result in personnel action, including termination of employment.

It is against the Company’s policy to retaliate against any employee for good faith reporting of violations of this Code.

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