Overview

We are committed to serving our customers and employing individuals with personal standards consistent with that of our values. This Code is designed to deter wrongdoing and to promote:

• Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships.
• Full, fair, accurate, timely, and understandable disclosure in reports and documents we file with regulatory agencies and in our other public communications.
• Compliance with applicable laws, rules, and regulations.
• The prompt internal reporting of violations of this Code.
• Accountability for adherence to this Code.

Our Code applies to all directors, officers, employees, and contractors and our affiliates and subsidiaries. Agents and vendors are also expected to read, understand, and abide by this Code.

This Code should help guide your conduct in the course of our business. Many of the principles described in this Code are general in nature, and the Code does not cover every situation that may arise. Use common sense and good judgment in applying this Code. If you have any questions about applying the Code, please seek guidance. Not all information regarding the conduct of our business is found in this Code. Please review the applicable policies and procedures in specific areas as they apply as found in our Handbook

The Code of Conduct will be reviewed on an annual basis to ensure compliance with applicable laws and industry standards.

Complying with the Code

To maintain the highest standards of integrity, we must dedicate ourselves to complying with this Code, company policies and procedures, and applicable laws and regulations. Violations of this Code not only damage our company’s standing in the communities we serve, they may also be illegal. Team members involved in violating this Code will likely face negative consequences. We will take the appropriate disciplinary action in response to each case, up to and including termination. In addition, team members involved may be subject to government fines, or criminal or civil liability.

Reporting Violations

If you think this Code or any policy is being violated, or if you have an ethics question, you have several options:

• Discuss the issue with your supervisor or manager.
• Discuss the issue with another supervisor or manager.
• Contact a member of the executive team

All reports (formal or informal) made to a supervisor, manager or executive should be promptly escalated to the CEO. We will then review the report promptly and thoroughly to determine if an investigation is warranted, including if outside counsel and support need to be involved.

Commitment to Non-Retaliation

Any employee or contractor who reports a violation will be treated with dignity and respect and will not be subjected to any form of discipline or retaliation for reporting in good faith. Retaliation against anyone who provides information or otherwise assists in an investigation or proceeding will be treated as a violation of this Code.