The Company’s reputation depends on the reliability of its financial statements and other public disclosure, the absence of conflicted behavior, compliance with law and the integrity of senior management. Conduct that impairs the public trust in the reliability and integrity of the Company’s disclosure or that suggests individual self-dealing not only damages the Company’s standing and recognition, but can also lead to criminal and civil actions that can be costly to the Company, destructive to Company personnel and financially damaging to stockholders and other Company constituencies. This Code is intended to promote high standards of ethical conduct and deter wrongdoing amongst the Company’s senior management with responsibility for the Company’s financial and other public disclosure. The Company’s chief executive officer and the senior financial personnel mentioned above (all of whom are referred to in this Code as covered personnel) are required to adhere to this Code and to enforce compliance with the Code by Company personnel under their control. This Code is supplemental to and not a replacement of the Company’s Code of Business Conduct and Ethics applicable to all employees of the Company, including all covered personnel.