Administration

The Code of Business Conduct and Ethics of the Company shall be administered as follows:

The President has overall responsibility to oversee compliance with this Code of Business Conduct and Ethics. Each manager is responsible for the enforcement of this policy by the employees under his or her supervision.

The Company shall exercise due care, based on the due diligence conducted prior to hiring or promoting any individual to whom it will be delegating discretionary authority, in order to ensure that such individual does not have a propensity to engage in illegal or improper activities. To ensure the continued compliance the Company must take, or cause to be taken, reasonable steps to communicate effectively the standards and procedures included in the Code of Business Conduct and Ethics to employees and agents of the Company. Such steps will include mandatory attendance at training sessions, web-based training, periodic notices and reminders to employees and publication of the Code.

The Company is to monitor and audit compliance with the Code of Business Conduct and Ethics, on a regular basis as instructed by the Company President.

The Company will enforce its Code of Business Conduct and Ethics through appropriate means of discipline. The disciplinary measures, which may be invoked at the discretion of the Company, include, but are not limited to, counseling, oral or written reprimands, warnings, probation or suspension without pay, demotions, reductions in salary, or termination of employment.

Persons subject to disciplinary measures may include, in addition to the violator, others involved in the wrongdoing such as (i) persons who fail to use reasonable care to detect a violation, (ii) persons who if requested to divulge information withhold material information regarding a violation, and (iii) supervisors who approve or condone the violations or attempt to retaliate against employees or agents for reporting violations or violators.