James Bond

The Company is committed to promoting the avoidance of actual or apparent conflicts of interest between personal and professional relationships and the ethical handling of any complaints regarding such matters. Separate and apart from complying with applicable laws and regulations governing the Company's operations and Company policies and procedures related thereto, certain of which are described above, each Company employee has a primary business and ethical responsibility to the Company to avoid any activity or relationship that may interfere or conflict with, or have the appearance of interfering or conflicting with, the performance of the employee's duties to the Company, including, without limitation, service as a director, in a loyal, efficient manner to the best of his or her ability and in the Company's best interest. Such activities and relationships, called "conflicts of interest," include any interest, relationship or activity that is incompatible with or has the appearance of being incompatible with the best interests of the Company or which potentially affects, reasonably could be expected to affect, or has the appearance of affecting an interested person's objectivity in performing services for the Company in a loyal, effective manner to the best of his or her ability and in the Company's best interest. A conflict of interest also occurs when an individual's private interests interfere in any way, or even appear to interfere, with the Company's interests as a whole. A conflict of interest situation can arise when an employee has interests that may make it difficult to perform objectively and effectively his or her duties for the Company. Conflicts of interest also arise when an employee or a member of his or her immediate family receives improper personal benefits as a result of his or her position in the Company. Depending upon an employee's particular responsibilities, potential conflict of interest situations may include, but are not limited to: (1) Serving as a director, officer, employee, partner, consultant or agent of an enterprise that is a present or potential supplier, customer or competitor of the Company, or that engages or may engage in any other business with the Company or with a supplier, customer or competitor of the Company; (2) Owning a material stock, creditor or other financial interest in an enterprise described in (1) above (which normally would not include an equity interest which is not greater than 5% of the stock or other equity of a publicly traded company); (3) Receiving from or giving to representatives of an enterprise described in (1) above material gifts, gratuities, special allowances, discounts, loans, guarantees of obligations, or other benefits not generally available (normally not including reasonable and customary meals or entertainment at which both the employee and the business contact are present, or gifts distributed to business associates as customary practice in the industry and which do not exceed a nominal value, directly or indirectly to or from any such representative); (4) Any other significant direct or indirect personal interest in a transaction involving the Company; (5) Obtaining or using for personal benefit confidential or proprietary information of or regarding an enterprise described in (1) above, or providing confidential or proprietary information of or regarding the Company or its business to such an enterprise; (6) Obtaining or using for personal benefit the Company's property or its confidential or proprietary information where it does not advance the legitimate interests of the Company; (7) Appropriating or using for personal benefit a business relationship gained in the course of employment, or a business opportunity that is discovered through an employee's use of corporate property, information or position with the Company or otherwise in the course of employment or performance of services that the Company might reasonably have an interest in pursuing without first making the opportunity available to the Company; (8) Materially speculating or dealing in goods, commodities or products dealt in, used or sold by the Company (including options and futures in such goods, commodities or products); and (9) Outside activities that detract from or interfere with the full and timely performance by an employee of his or her services for the Company. The Company has established detailed conflict of interest policies, including guidelines and reporting requirements, in the Company's Conflicts of Interest Policy, a copy of which may be obtained on the Company's Intranet Website or from facility Human Resources Departments, and which must be followed at all times. Certain of these policies are summarized below.