General

The purpose of the Company’s Code of Business Conduct and Ethics (the “Code”) is to assist all Company personnel in making decisions regarding the affairs of the Company (including its subsidiaries). The Code states basic principles that should guide the affairs of the Company and deals with certain specific situations but is not comprehensive. Personnel are encouraged to consult with the Chair of the Audit Committee for direction of specific issues on conflicts or potential conflicts.

The Code

All directors, officers, employees and consultants (“Members”) of the Company will comply with the following obligations, which reaffirm the Company’s high standards of business conduct:

Any change in or waiver of this Code of Business Conduct and Ethics for directors or officers will be approved only by the Board and such change or waiver will be promptly disclosed.Compliance with the Code It is the responsibility of all Members to be aware of their obligations under and to comply with this Code. All breaches of this Code shall immediately be reported to the Chair of the Audit Committee.

All reports by an individual of violations of this Code shall be kept confidential unless otherwise required by law. Individuals who breach this Code may be subject to disciplinary action including dismissal.

If you have any questions about this Code or what is expected of our Members, please contact the Chair of the Audit Committee.