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The Company’s Board of Directors and Audit Committee have established the standards of business conduct contained in this Code and oversees compliance with this Code.

This Code shall be distributed to each new Employee, officer and Director of the Company upon commencement of his or her employment or other relationship with the Company. It will also be made available via the Company’s Intranet site.

Strict adherence to this Code is vital. Managers are responsible for ensuring that Employees are aware of and understand the provisions of the Code. For clarification or guidance on any point in the Code of Business Conduct & Ethics, please consult a member of the executive team or a Human Resources Manager.