This Code of Business Conduct and Ethics (the "Code") sets forth legal and ethical standards of conduct for all officers, directors and consultants of the Company.

The Code applies the Company’s core values to the day-to-day business situations and demonstrates how its business standards are applied through interactions with customers, investors and government agencies.

This Code is intended to promote ethical conduct in all Company affairs in accordance with high standards of integrity, and to deter wrongdoing in compliance with all applicable laws and regulations.

The Company maintains numerous policies and procedures that provide specific direction across many functions of its business. Each associate is responsible for knowing and following the policies and procedures that are relevant to individual business activities.

Many of those policies are referenced in this Code and are available on the Company intranet.

1. 3.1 Insider Trading - Stock transactions conducted by associates, officers, directors and consultants who have material non-public information about the Company (or other companies) whose stock is being traded.
2. 3.2 Gifts & Gratuities - The use of Company funds or assets for gifts, or receipt of same from others.
3. 3.3 Officer - All Section 16 officers, the Chief Executive Officer, Chief Financial Officer, Principal Accounting Officer, and any other financial or operating officer that the Company may employ from time to time.
4. 3.4 Corporate Compliance Officer (CCO) - An officer of the Company, appointed by the Compensation & Organization Committee of the Board of Directors in accordance with the Corporate Compliance Program Manual.

1. 4.1 Officers and Directors - All officers, directors and consultants are responsible for following the various guidelines and requirements of this policy, and for conducting themselves in all Company affairs in accordance with high standards of integrity and in compliance with all applicable laws and regulations.
2. 4.2 Corporate Compliance Officer (CCO) - The CCO will have responsibility to oversee and monitor compliance with this Code of Business Conduct and Ethics.

1. 5.1 Honest and Ethical Conduct and Fair Dealing - Associates, officers, directors and consultants should endeavor to deal honestly and ethically with the Company’s suppliers, customers, competitors and fellow associates.
2. 5.2 Compliance with Laws, Rules, Regulations and Policies - Each officer, director and consultant is expected to use good judgment and common sense to comply with all applicable laws, rules, regulations and policies, and to ask for advice when uncertain about them.
3. 5.3 Employment Practices - The Company works to ensure that all associates and applicants for employment are given consideration and treated without regard to their race, color, religion, national origin, gender, age, marital status, disability or other characteristics protected by law.
4. 5.4 Environmental, Health and Safety - The Company provides a safe and healthy workplace, promoting environmental excellence in our operations. The Company complies with government legislation and regulations and accepted industry standards.
5. 5.5 Conflicts of Interest - Officers, directors and consultants should always act in the best interests of the Company, and refrain from any activity or personal interest that might appear as a "conflict of interest."
6. 5.6 Insider Trading - Officers, directors and consultants who are in possession of material non-public information about the Company or other companies, including competitors, suppliers and customers as a result of their relationship with the Company, are prohibited by law and Company policy from trading or gifting in securities of the Company or such other companies and are further prohibited from communicating such information to others who might trade on the basis of that information.
7. 5.7 Confidentiality - Officers, directors and consultants will maintain the security of confidential information entrusted to them by the Company or other companies, including suppliers and customers, except when disclosure is authorized by a supervisor or is legally mandated.
8. 5.8 Protection and Proper Use of Corporate Assets and Opportunities - Associates, officers, directors and consultants should seek to protect all Company assets. Fraud and waste have a direct impact on financial performance.
9. 5.9 Gifts, Gratuities and Business Entertainment - The use of Company funds or assets for gifts, gratuities or other favors to associates or government officials is prohibited, except to the extent such gifts are in compliance with applicable law, are customary and reasonable under the circumstances, and are not given in consideration or expectation of any action by the recipient.
10. 5.10 Health Care Laws and Regulations - All associates and officers are responsible for knowing and following the policies and procedures regarding activities and interactions with Health Care Professionals.
11. 5.11 Anti-Corruption Statutes - The consequences for violating anti-corruption laws can be serious. The payment of illegal bribes can subject both the Company and individuals engaging in the illegal conduct to significant criminal and civil fines and possibly even imprisonment.
12. 5.12 Accuracy of Books and Records and Public Reports - Officers, directors and consultants will honestly and accurately report all business transactions. Accurate information is essential in maintaining the Company’s ability to meet legal and regulatory obligations.
13. 5.13 Reporting and Compliance Procedures - Every officer, director and consultant has a responsibility to ask questions, seek guidance, report suspected violations and express concerns regarding compliance with this Code.
14. 5.14 Dissemination, Training and Amendment - This Code shall be given to each new officer, director and consultant of the Company upon commencement of employment or other membership with the Company, and will be available at all times on the Company’s intranet and external website to each officer, director and consultant of the Company.