<h3><strong>Ethics Policy</strong></h3>
<p><strong>PURPOSE:</strong> Company associates will maintain the highest ethical standards in the conduct of Company affairs. Intent of this policy is that each associate will conduct the Company’s business with integrity and comply with all applicable laws in a manner that excludes considerations of personal advantage or gain.</p>
<p>The following is a summary of the Company’s policy with respect to (1) gifts, favors, entertainment and payments given or received by Company associates, (2) potential conflicts of interest and (3) certain other matters:</p>
<p><strong>GENERAL POLICY APPLICATION:</strong></p>
<p>Gifts, Favors, and Payments by the Company: Gifts, favors, and payments may be given to others at Company expense, if they meet all of the following criteria:</p>
<p>1. They are consistent with accepted business practices<br />
2. They are of sufficiently limited value and in a form that will not be construed as a bribe or payoff<br />
3. They are not in violation of applicable law and generally accepted ethical standards; and<br />
4. Public disclosure of the facts will not embarrass the Company</p>
<p>Payments, commissions or other compensation to or for the benefit of associates of customers (or their family members or associates)not required by written contract are contrary to Company policy.</p>