Fair Competition and Dealing

The Company seeks to outperform its competition fairly and honestly. The Company seeks competitive advantages through superior performance, never through unethical or illegal business practices. Stealing proprietary information, possessing trade secret information that was obtained without the owner’s consent, or inducing such disclosures from past or present employees of other companies is prohibited. Each employee should endeavor to respect the rights of and deal fairly with the Company’s customers, suppliers, competitors and employees. No employee should 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 is committed to fair and open competition in markets and around the world. Employees are expected to comply with all applicable anti-trust/competition laws. Employees should exercise due care in any situation where competitors may be present to avoid violating these laws. Employees should not discuss with competitors current or future prices, coordination of bidding, margins, costs or profits, terms or conditions of sales, production or sales capacities, dividing sales territories or allocation of customers or product lines, business plans, or distribution strategies for competing products or services.

The purpose of business entertainment and gifts in a commercial setting is to create good will and sound working relationships, not to gain unfair advantage with suppliers and customers. No gift or entertainment should ever be offered, given, provided or accepted by any employee, or the employee’s family member or agent, unless it:

(1) is not a cash gift,

(2) is consistent with customary business practices,

(3) is not excessive in value,

(4) cannot be construed as a bribe or payoff and

(5) does not violate any laws or regulations. Employees should contact a supervisor or Director to discuss any gifts or proposed gifts to be certain that they are appropriate.