Company seeks to gain competitive advantages through superior performance and not through unethical or illegal business practices. Each officer should endeavor to respect the rights of and deal fairly with other officers and other employees of the Company. No one shall take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other intentional unfair-dealing practice.

The Company’s suppliers make significant contributions to our success. To create an environment where o ur suppliers have an incentive to work with the Company, they must be confident that they will be treated lawfully and in an ethical manner. Selection of suppliers is to be made on the basis of merit, price, quality and performance. The Company’s policy is to select significant suppliers or enter into significant supplier agreements through a competitive bid process where ever possible. Under no circumstances should any Company employee, agent or contractor attempt to coerce suppliers in any way. The confidential information of a supplier is entitled to the same protection as that of any other third party.

Every employee of the Company shall, in his or her business conduct, comply with all applicable laws and regulations, both in letter and in spirit, in all the territories in which he or she operates. If the ethical and professional standards set out in the applicable laws and regulations are below that of the code, then the standards of the code shall prevail.

The Company shall compete only in an ethical and legitimate manner. It prohibits all actions that are anti-competitive or otherwise contrary to laws that govern competitive practices in the market place.