I. Introduction

This Code of Ethics for Senior Officers and Directors is applicable to the Corporation's Senior Officers and Directors. References in this Code of Ethics to the Corporation means the Corporation or any of its subsidiaries.

While we expect honest and ethical conduct in all aspects of Corporation business from all employees, we expect the highest possible standards from our Senior Officers and Directors whom set an example for other employees and we expect them to foster a culture of transparency, integrity and honesty.

II. Conflicts of Interest

A conflict of interest occurs when a Senior Officer's or Director's private interests interfere, or appear to interfere, in any way, with the interests of the Corporation as a whole. A conflict situation can arise when Senior Officers or Directors take action or have interests that may make it difficult for them to perform their work effectively. Conflicts of interest also arise when Senior Officers or Directors, or a member of their families, receive improper personal benefits as a result of their position in the Corporation. Loans to, or guarantees of obligations of, any employees, officers, directors or any of their family members are likely to pose conflicts of interest, as are transactions of any kind between the Corporation and any other organization in which Senior Officers or Directors or any member of their families have an interest.

Engaging in any conduct that represents a conflict of interest are prohibited

Senior Officers or Directors of the Corporation must avoid any investment, interest or association which interferes, might interfere, or might be thought to interfere, with their independent exercise of judgment in the Corporation's best interest. Any potential conflicts of interests must be reported immediately to the Corporation's Chief Executive Officer.

III. Accurate Periodic Reports

Full, fair, accurate, timely and understandable disclosure in our periodic reports is required by securities regulators and essential to the success of our business. Senior Officers and Directors must exercise the highest standard of care in preparing such reports in accordance with the guidelines set forth below.

• All Corporation accounting records, as well as reports produced from those records, must be kept and presented in accordance with the laws of each applicable jurisdiction.
• All records must fairly and accurately reflect the transactions or occurrences to which they relate.
• All records must fairly and accurately reflect in reasonable detail the Corporation's assets, liabilities, revenues and expenses.
• The Corporation's accounting records must not contain any false or intentionally misleading entries.
• No transactions will be intentionally misclassified as to accounts, departments or accounting periods.
• All transactions must be supported by accurate documentation in reasonable detail and recorded in the proper account and in the proper accounting period.
• No information will be concealed from the internal auditors or the independent auditors.
• Compliance with Generally Accepted Accounting Principles and the Corporation's system of internal accounting controls is required at all times.

IV. Compliance with Laws

Senior Officers and Directors are expected to comply with both the letter and spirit of all applicable governmental rules and regulations. If they fail to comply with this Code, the Code of Business Conduct and Ethics and applicable laws they will be subject to disciplinary measures, up to and including discharge from the Corporation.