The Company has adopted a Business Ethics Policy applicable to all directors, officers, and employees of the Company and its subsidiaries. (A European Addendum supplements the Business Ethics Policy for employees located within the European Union.)

The Company has also adopted a Code of Ethics for the Chief Executive Officer, the Chief Financial Officer and Controller.

The Board of Directors has designated the Audit Committee of the Board of Directors as the Company's "Qualified Legal Compliance Committee" pursuant to the rules of the Securities and Exchange Commission with respect to Section 307 of the Sarbanes-Oxley Act.