3.1.1 - Code of Conduct and Ethics

October 2003


Code of Conduct

A Message About the Code from the Chairman and CEO:

To All Officers, Directors and Employees of [COMPANY NAME]:

One of most valuable assets of [COMPANY NAME] (the “Company”) is its integrity. Protecting this asset is the job of everyone in the Company. To that end, the Board of Directors has established a Code of Business Conduct and Ethics to help all of us, including the Board, comply with the law and maintain the highest standards of ethical conduct. The Code does not cover every issue that may arise, but sets out basic principles and a methodology to help guide all of us in the attainment of this common goal. The Company’s reputation is upheld and enhanced or diminished by each person’s decisions, actions, and sense of business ethics. We expect our agents and representatives to have similar standards of ethics and codes of conduct.

Please read this document carefully, understand its contents and then apply the principles it states in the course of your work. Such conduct is not only the right thing to do, it is the law. If you are in a situation that you believe may violate or lead to a violation of this Code, follow the procedures described in Section 17 of the Code.

As you all know, our reputation is integral to our success, and reputation comes from our actions on a continuous basis. Your performance in conducting our business in a manner that is consistent with the principles contained in the Code will enable us to keep and enhance that reputation.

Thank you,

Chairman and Chief Executive Officer

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