Introduction to our Ethics

Our Code of Ethics has been adopted to discourage wrongdoing and promote honest and ethical conduct, proper disclosure in compliance with applicable laws, rules, and regulations by the Company’s principal executive officer, president, principal financial officer, principal accounting officer and controller.

Who does it Apply To?

This Code of Ethics applies to our entire company and our employees.

What Principles do we Value?

In performing his or her duties, each employee must:

(1) Maintain high standards of honest and ethical conduct in all dealings with other employees, customers, and suppliers of the Company and with other third parties, including the Company’s independent auditors, on behalf of the Company;

(2) Avoid any actual or apparent conflict of interest between personal and professional relationships as defined in the Company’s Code of Conduct;

(3) Report any conflict of interest that may arise and any material transaction or relationship that reasonably could be expected to give rise to a conflict;

(4) Take reasonable measures to protect the confidentiality of non-public information about the Company or its customers or suppliers and prevent the unauthorized disclosure of such information unless required by applicable law or regulation or legal or regulatory process;

(5) Maintain all Company accounting records and reports derived from them in accordance with applicable laws, in a manner that fairly and accurately reflects the transactions or occurrences to which they relate and assures that they fairly and accurately reflect in reasonable detail the Company’s assets, liabilities, revenues and expenses and do not contain any false or intentionally misleading entries. In this regard, compliance with the Company’s system of internal controls is required at all times;

(6) Assure full, fair, accurate, timely, and understandable disclosure in reports and documents that the Company files.

(7) Comply and take reasonable action to cause others to comply with applicable governmental laws, rules, and regulations; and

(8) Promptly report suspected violations of this Code of Ethics.

Compliance and Accountability

Our executives will regularly assess compliance with this Code, report material violations and take appropriate action to assure accountability for violation of this Code by any employee.