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Code of Ethics

1. Application and Purpose
2. Honest and Ethical Conduct
3. Full, Fair, Accurate, Timely and Understandable Disclosure
4. Internal Reporting of Code Violations
5. No Retaliation
6. Consequences for Non-Compliance with this Code
7. Publication of this Code; Amendments and Waivers
Adopted by the Audit Committee on December 9, 2003.
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