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Master Halco, Inc. Code of Conduct

Statement of Our Commitment

Message from the President The integrity, reputation and profitability of Master Halco, Inc. ultimately depend on the individual actions of our directors, officers, employees and representatives, all over the world. The Company’s image and reputation for integrity are its most valuable assets, and the conduct of its employees must protect these assets at all times. Accordingly, as an employee of the Company, you have a responsibility to conduct your business on behalf of the Company in accordance with the highest ethical standards and in compliance with all laws. The exercise of common sense and good judgment in applying these to your daily business conduct, and in responding to situations that seem not to be covered by them, is a must for all employees.

In keeping with our standing commitment to integrity, Master Halco, Inc. has adopted MASTER HALCO, INC. International’s Code of Conduct, which follows this message. I am encouraging all of our employees to review the document and I expect all of us to adhere to the principles and direction within it. This new Code of Conduct updates, replaces and enhances Master Halco, Inc.’s Standards of Ethical Conduct. The Company’s Board of Directors and Executive Committee have approved them. This new Code of Conduct is intended to codify the Company’s present policy and to provide guidelines for compliance by all employees with applicable laws and ethical standards of business conduct. They apply to all employees of the Company and all entities directly or indirectly under its control.

Please note that all questions arising in any of the areas covered should be referred to Eric J. Laptook, the Chief Compliance Officer of MASTER HALCO, INC. International (212-818-8031). The Legal Division has responsibility for considering the legal implications of any business activity, and therefore, the time to involve the Legal Division is at the planning stage of a transaction or deal rather than after problems arise. Any question relating to Human Resources points should be addressed to our company’s HR representative.

In addition to the Code of Conduct and existing corporate compliance policies, the Company from time to time issues statements of policy directly on legal or business matters relevant to particular parts of its business and other general policies. The Company’s compliance standards and procedures will be effectively and consistently communicated and enforced. All employees will be required to fulfill routine and mandatory training and education. Please be advised that the Company shall engage in pro-active and routine compliance audits and risk assessments.

Our company also has a set of rules and regulations that specifically reflects Master Halco, Inc.’s values. You can find these on our Intranet or ask your supervisor, who has a copy.

Ethics and compliance are our shared responsibility. Our commitment to integrity must always come first.

About the Code of Conduct

Why Have a Code of Conduct? Our Company’s reputation and its commitment to integrity are critical to our future business success. A failure to live up to ethical and legal standards can expose the Company to serious harm in the marketplace, as well as the risk of legal prosecution and liability.

This new Code of Conduct summarizes our company-wide commitment to obey the law and uphold high ethical standards. This new Code of Conduct replaces our Standards of Ethical Conduct. It explains many of the basic rules and policies that apply to our businesses in a practical and easy to understand manner. It allows all officers and employees to know what is expected, regardless of culture, education or background. This Code of Conduct also lets our suppliers, customers, and other interested stakeholders know what values our Company holds, and what to expect in their relationships with us.

To Whom Does the Code of Conduct Apply? All employees and officers of the Company are required to obey all applicable laws, and to adhere to the high ethical standards outlined in the Code of Conduct. Moreover, employees who engage or handle suppliers, consultants, sales agents and distributors must monitor them to ensure that they act in a manner consistent with the principles of the Code of Conduct. Ethics and compliance are our shared responsibility.

Where to Go for Help

The Company has established a Helpline at 1-888-301-1422 that can be called at any time from anywhere in the US and Canada, to report apparent ethical misconduct. If you wish, calls to the Helpline may be made anonymously. Anonymous calls will receive a tracking number, so that you may still check back to receive a response or provide more information. However, giving your name can help the Company investigate the matter appropriately – and (as noted below) the Company has a firm policy against any retaliation for raising legal or ethical concerns in good faith.

When you call the Helpline, a specialist will listen and make a detailed summary of your call. The information will then be forwarded to the appropriate individual in the Company to look into the matter. If an investigation is undertaken, it will proceed promptly, and corrective action will be taken whenever it is appropriate.

Relationships with Suppliers MASTER HALCO, INC. will deal fairly with its suppliers, in accordance with the contracts agreed with them, and with all applicable laws.

A. Bribery, Kickbacks and Fraud
Any employee found to be receiving, accepting or condoning a bribe, kickback, or other unlawful payment, or attempting to initiate such activities, may have their employment with MASTER HALCO, INC. terminated and may be subject to possible criminal prosecution. Any employee found to be attempting fraud or engaging in fraud may have their employment with MASTER HALCO, INC. terminated and may be subject to possible criminal proceedings. All employees have a responsibility to report any actual or attempted bribery, kickback or fraud to the Company.

Gifts and Entertainment MASTER HALCO, INC. purchases and sells on the basis of quality and price. We expect our customers and suppliers to do the same when dealing with us. All of our business transactions and decisions should be free of improper outside influences.