The Company is committed to conducting business in accordance with the highest standards of ethics, integrity, and quality and has adopted a Code of Business Ethics (the “Code”) to promote ethical standards and deter wrongdoing. The Code addresses matters including: (i) conflicts of interest, (ii) corporate opportunities, (iii) confidentiality, (iv) fair dealing, (v) protection and proper use of Company assets, (vi) compliance with laws, rules, and regulations, and (vii) such other matters as the Board deems appropriate. The Code applies to all directors, officers and employees of the Company. The Code requires all covered persons to avoid conflicts of interest that may be to the detriment of the Company. No waiver of the Code with respect to any director will be granted except by a vote of the Board or the Audit Committee, which will determine whether a waiver is appropriate and ensure that the waiver is accompanied by appropriate controls designed to protect the Company.