This Code of Ethics ("this Code") ought to be read in combination with the Statement of General Business Principles ("SGBP") of Standard & General, which governs how Standard & General conducts its affairs.  

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Key requirements

 

• a. act following the highest standards of honesty, fairness, and integrity and expect the same in their relationships with others while maintaining a business and work climate promoting such standards; and
   

• b. adhere to the SGBP and any applicable code of conduct on dealing with provisions for the avoidance of conflicts of interest specified in relevant terms of employment; and

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• c. excuse himself from making any decisions about issues in which conflicts of interests could arise and, in such event, disclose the relevant facts in writing explaining the circumstances that could create the conflict of interest to (a) the chairman of the Audit Committee in the case of (i) the Executive Directors of Standard & General, (ii) the Chief Financial Officer, (iii) the Chief Internal Auditor and (iv) the Executive Vice President Controller, and (b) to the Executive Vice President Controller of Standard & General, in the case of any other COE; and

 

• d. avoid having any financial interests in work or contracts awarded by a Standard & General company or a company associated with a Standard & General company, or in services rendered or supplies effected by such a company where immediate family members have a financial interest, or it is otherwise unavoidable, such interests shall be disclosed in writing as set out in paragraph c.; and

 

• e. not accept or seek from third parties to his advantage any favor in any form however described in connection with the business of any Standard & General company or his duties (except for the acceptance of such things as working lunches, dinners, gifts of nominal value and entertainment of reasonable value, duration, and frequency, in the appropriate circumstances, and always subject to the standards of paragraph a.); and

 

• f. not hold jobs or positions or engage in outside interests or other businesses that could have an adverse impact on the performance of duties owed to any Standard & General company or its interests; and

 

• g. avoid any relationship with a supplier, partner, or customer that could compromise the ability to transact business on an impartial, competitive, and professional basis or influence decisions to be made by any Standard & General company; and

 

• h. consistent with the range of his job responsibilities, ensure fair, full, timely, accurate, and understandable disclosure in regulatory filings and other public communications made by Standard & General.