Code of Conduct

The Company’s Code of Conduct is intended to provide a broad overview of basic ethical principles that govern our conduct and that of our directors, officer, employees, agents and representatives. Leaders in our Company have a special obligation regarding compliance with the Code and are responsible for building and maintaining a culture of compliance and working to prevent, detect and appropriately respond to compliance problems.  The Code’s coverage includes:  HSSE, compliance with laws, conflicts of interest, record keeping and reporting, corporate opportunities, competition, fair dealing, business entertainment, employment practices, confidentiality, computer use, protection of Company asset and anti-corruption.  Anyone subject to the Code is required to report violations of which they are aware, and the Company has a strict non-retaliation policy protecting the reporter.  The Company has established a dedicated hotline address for reporting Code violations to the Chief Compliance Officer, and all directors, officers and employees are required to annually certify compliance with the Code and participate in online training programs.