Our Code of Ethics applies to senior management and key financial and accounting personnel. It has been designed to deter wrongdoing and to promote:

• Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest;

• Fair, accurate, timely, and understandable disclosure in our public communications;

• Compliance with applicable governmental laws, rules, and regulations;

• Prompt internal reporting of violations of the Code to an appropriate person or persons identified in the Code; and

• Accountability to ensure adherence to the Code.

The Code requires each covered person to deal ethically and honestly with the company and to avoid business, financial, or other direct or indirect interests or relationships that conflict with those of the company or divide the covered person’s loyalty to the company. Each covered person is required to sign an Attestation of Compliance with the Code at the end of each fiscal year.