Administration and Distribution

The Company’s Board of Directors and the Audit and Corporate Governance Committee have established the standards of business ethics and conduct contained in the Code, and it is their responsibility to oversee compliance with the Code.  Any change in or waiver of any provision of the Code shall require approval of the Audit and Corporate Governance Committee as applicable, and shall be publicly disclosed in the time period and manner as required by law or regulation.

The Code is to be distributed to each employee, officer and director of the Company. It will also be made available via the Company’s Internet site.  From time to time, the Company, its auditors, or the Company’s legal counsel acting on its behalf, will circulate questionnaires to Company personnel relating to the matters covered by the Code.  All Company personnel are expected to answer such questionnaires fully and frankly.

Strict adherence to the Code is vital.  All managers are responsible for ensuring that employees under their supervision are aware of and understand the provisions of the Code   For clarification or guidance on any point in the Code, please consult the CEO.