From the company’s inception, Hawk associates and its employees have been committed to the highest standards of ethical behavior. Daily business decisions are made on the basis of five values:

Should there ever be any conflict in these values, integrity takes precedence.

Company policy and applicable laws prohibit disclosure of material inside information about Hawk Associates or any of its clients to anyone outside of Hawk Associates without a specific business reason for them to know. It is unlawful and against company policy for anyone possessing inside information about Hawk Associates or any of the company’s clients to use such information for personal gain.

Company policy prohibits employees from disclosing confidential or proprietary information about Hawk Associates or any of its clients outside the company, either during or following employment, without company authorization to do so.

Company policy prohibits conflicts between the interests of its employees and the company. A conflict of interest exists when an employee’s personal interest interferes or may interfere with the interests of the company. Conflicts of interest may not always be clear, so if an employee has a concern that a conflict of interest may exist, that employee should consult with the CEO or the president.

Company policy prohibits commercial bribes, kickbacks and other similar payoffs and benefits paid to any suppliers or customers.

Hawk Associates will conduct its investor relations business in accordance with the NIRI Code of Ethics.