Code of Ethics

METRO ONE DEVELOPMENT, INC.
CORPORATE CODE OF CONDUCT AND ETHICS

This Corporate Code of Conduct and Ethics, referred to as the "Code," is intended
to provide our associates, as defined below, with an understanding of the principles of
business conduct and ethics that are expected of them. The standards set forth in the
Code apply to us all. Every associate of METRO ONE DEVELOPMENT, INC. is expected to comply
with the Code as a condition of his or her relationship with the company. The term
"associate" means every full and part-time employee of the company and its subsidiaries,
all members of the company's senior management, including the company's Chief Executive
Officer, and every member of the company's Board of Directors, even if such member is not
employed by the company. The Code does not replace the company's existing Employee
Handbook. The Code, the Handbook and the other company policies referenced herein set
forth our mutual expectations regarding ethical standards and company procedures. The
company has made the Code publicly available on its web site.

If any breach of the Code is known to you, you should report violations to the
Corporate Compliance Officer (who is Ralph Magid), as described in more detail below.
Reports may be made anonymously and we have adopted a specific non-retaliation policy
described herein to protect associates who make reports of potential violations.

While it is impossible for this Code to describe every situation that may arise,
the standards explained in this Code are guidelines that should govern our conduct. If
you have questions regarding the matters that are addressed in the Code, you are urged to
consult with the Corporate Compliance Officer, or another member of management.

The provisions of the Code regarding the actions the company will take are
guidelines which the company intends to follow. There may be circumstances, however, that
in the company's judgment require different measures or actions and in such cases it may
act accordingly while still attempting to fulfill the principles underlying this Code.

Table of Contents

Page

I. IMPLEMENTATION OF THE CODE

The following questions and answers address the company's implementation
of the Code. The company has attempted to design procedures that ensure maximum
confidentiality, anonymity, and, most importantly, freedom from the fear of
retaliation for complying with and reporting violations under the Code.

Q: Who is responsible for administering, updating and enforcing the Code?

A: The company's Board of Directors has appointed a Corporate Compliance Officer
to administer, update and enforce the Code. Ultimately, the Board of Directors of the
company must ensure that the Corporate Compliance Officer fulfill his responsibilities.
The Corporate Compliance Officer has overall responsibility for overseeing the
implementation of the Code.

Q: How can I contact the Corporate Compliance Officer?

A: The name and phone number of the Corporate Compliance Officer is listed below. This
individual can assist you in answering questions or reporting violations or suspected
violations under the Code.

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Ralph Magid
905 760 2987 ext 302
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II. GENERAL REQUIREMENTS

Each associate of the company is expected to be honest in all business
dealings and obligations, and to try to ensure:

o the ethical handling of conflicts of interest between personal and
professional relationships;

o accurate, timely and understandable disclosure in the reports
required to be filed by the company with the Securities and Exchange
Commission and in other public communications made by the company;
and

o compliance with applicable governmental laws, rules and regulations.

III. CONFLICTS OF INTEREST

Associates should be cautious in any situation that may involve, or even
appear to involve, a conflict between their personal interests and the interests
of the company. An actual or potential conflict of interest arises when an
associate is in a position to influence a decision that may result in personal
gain for that associate or for a relative of that associate as a result of the
company's business dealings. For the purposes of this policy, a relative is any
person who is related by blood or marriage, or whose relationship with the
associate is similar to that of persons who are related by blood or marriage. In
dealings with current or potential customers, suppliers, contractors, and
competitors, each associate should act in the best interests of the company to
the exclusion of personal advantage. In addition, business dealings with outside
firms should not result in unusual gains for those firms, such as bribes,
product bonuses, special fringe benefits, unusual price breaks, and other
windfalls. For purposes of this section, a "significant" amount or interest
shall be deemed to be any amount in excess of $5,000. Associates are prohibited
from any of the following activities which could represent an actual or
perceived conflict of interest:

o No associate or relative of an associate shall have a significant
financial interest in, or obligation to, any outside enterprise
which does or seeks to do business with the company or which is an
actual or potential competitor of the company, without prior
approval of the Compliance Officer, or in the case of executive
officers or members of the Board of Directors, the full Board of
Directors or a committee thereof.

o No associate shall conduct a significant amount of business on the
company's behalf with an outside enterprise which does or seeks to
do business with the company if a relative of the associate is a
principal or officer of such enterprise, or an employee of such
enterprise who will play a significant role in the business done or
to be done between the company and such enterprise, without prior
approval of the Compliance Officer, or in the case of executive
officers or members of the Board of Directors, the full Board of
Directors or a committee thereof.

o No executive officer or employee, or a relative of an executive
officer or an employee, shall serve as a director, officer or in any
other management or consulting capacity of any actual competitor of
the company.

o No director, or a relative of a director, shall serve as a director,
officer or in any other management or consulting capacity of any
actual competitor of the company, without the prior approval of the
full Board of Directors or a committee thereof.

o No associate shall engage in activities that are directly
competitive with those in which the company is engaged.

o No associate shall divert a business opportunity from the company to
such individual's own benefit. If an associate becomes aware of an
opportunity to acquire or profit from a business opportunity or
investment in which the company is or may become involved or in
which the company may have an existing interest, the associate
should disclose the relevant facts to the Corporate Compliance
Officer. The associate may proceed to take advantage of such opportunity only
if the company is unwilling or unable to take advantage of such opportunity
as notified in writing by the Compliance Officer.

o No associate or relative of an associate shall receive any loan or
advance from the company, or be the beneficiary of a guarantee by
the company of a loan or advance from a third party, except for
advances in connection with the company's tuition reimbursement
plan, other customary advances or corporate credit in the ordinary
course of business or otherwise approved by the Compliance
Officer. Please see Section IV.E. below, "Corporate Advances", for
more information on permitted corporate advances.

In addition, the Board of Directors will review and approve, in advance, all
related-party transactions, as required by the Securities and Exchange Commission or any
other regulatory body to which the company is subject.

Each associate should make prompt and full disclosure in writing to the
Corporate Compliance Officer of any situation that may involve a conflict of interest.
Failure to disclose any actual or perceived conflict of interest is a violation of the
Code.

IV. PROTECTION AND PROPER USE OF COMPANY ASSETS

Proper protection and use of company assets and assets entrusted to it by
others, including proprietary information, is a fundamental responsibility of
each associate of the company. Associates should comply with security programs
to safeguard such assets against unauthorized use or removal, as well as against
loss by criminal act or breach of trust. The provisions hereof relating to
protection of the company's property also apply to property of others entrusted
to it (including proprietary and confidential information).

A. Proper Use of Company Property

The removal from the company's facilities of the company's property is
prohibited, unless authorized by the company. This applies to furnishings,
equipment, and supplies, as well as property created or obtained by the company
for its exclusive use - such as client lists, files, personnel information,
reference materials and reports, computer software, data processing programs and
data bases. Neither originals nor copies of these materials may be permanently
removed from the company's premises or used for purposes other than the
company's business without prior written authorization from the Compliance
Officer.

The company's products and services are its property; contributions made
by any associate to their development and implementation are the company's
property and remain the company's property even if the individual's employment
or directorship terminates.

Each associate has an obligation to use the time for which he or she
receives compensation from the company productively. Work hours should be
devoted to activities directly related to the company's business.

B. Confidential Information

The company provides its associates with confidential information relating
to the company and its business with the understanding that such information is
to be held in confidence and not communicated to anyone who is not authorized to
see it, except as may be required by law. The types of information that each
associate should safeguard include (but are not limited to):

o account balances,
o customer finances and credit,
o anticipated changes in management,
o patents,
o new products under development,
o compensation data,
o customer lists,
o customer preferences,
o company financial information,
o marketing strategies,
o new materials research,
o pending projects and proposals, and
o all other sensitive information regarding company affairs.

These are costly, valuable resources developed for the exclusive benefit
of the company.

C. Accurate Records and Reporting

Under law, the company is required to keep books, records and accounts
that accurately reflect all transactions, dispositions of assets and other
events that are the subject of specific regulatory record keeping requirements,
including generally accepted accounting principles and other applicable rules,
regulations and criteria for preparing financial statements and for preparing
periodic reports filed with the Securities and Exchange Commission. All company
reports, accounting records, sales reports, expense accounts, invoices, purchase
orders, and other documents should accurately and clearly represent the relevant
facts and the true nature of transactions. Reports and other documents should
state all material facts of a transaction and not omit any information that
would be relevant in interpreting such report or document. No payment
on behalf of the company may be approved or made with the intention,
understanding or awareness that any part of the payment is to be used for any
purpose other than that described by the documentation supporting the payment.
In addition, intentional accounting misclassifications (e.g., expense versus
capital) and improper acceleration or deferral of expenses or revenues are
unacceptable reporting practices that are expressly prohibited.

The company has developed and maintains a system of internal controls to
provide reasonable assurance that transactions are executed in accordance with
management's authorization, are properly recorded and posted, and are in
compliance with regulatory requirements. The system of internal controls within
the company includes written policies and procedures, budgetary controls,
supervisory review and monitoring, various other checks and balances, and
other safeguards.

The company has also developed and maintains a set of disclosure controls
and procedures to ensure that all of the information required to be disclosed by
the company in the reports that it files or submits under the Securities
Exchange Act is recorded, processed, summarized and reported within the time
periods specified by the Securities and Exchange Commission's rules and forms.
Associates are expected to be familiar with, and to adhere to, these internal
controls and disclosure controls and procedures.

Responsibility for compliance with these internal controls and disclosure
controls and procedures rests not solely with the company's accounting
personnel, but with all associates involved in approving transactions, supplying
documentation for transactions, and recording, processing, summarizing and
reporting of transactions and other information required by periodic reports
filed with the Securities and Exchange Commission. Any associate who believes
the company's books and records are not in accord with these requirements should
immediately report the matter to the Corporate Compliance Officer. The company has
adopted explicit non-retaliation policies with respect to these matters, as described in
Section VIII below.

D. Document Retention

Numerous federal and state statutes require the proper retention of many
categories of records and documents that are commonly maintained by companies.
In consideration of those legal requirements and the company's business needs,
all associates must maintain records in accordance with applicable law and
policies adopted by the company from time to time.

In addition, any record, in paper or electronic format, relevant to a
threatened, anticipated or actual internal or external inquiry, investigation,
matter or lawsuit may not be discarded, concealed, falsified, altered, or
otherwise made unavailable, once an associate has become aware of the existence
of such threatened, anticipated or actual internal or external inquiry,
investigation, matter or lawsuit.

When in doubt regarding retention of any record, an associate must not
discard or alter the record in question and should seek guidance from the
Corporate Compliance Officer. Associates should also direct all questions regarding
issues of document retention and related procedures to the Corporate Compliance Officer.

E. Corporate Advances

Under law, the company may not loan money to associates except in limited
circumstances. It shall be a violation of the Code for any associate to advance
company funds to any other associate or to himself or herself except for
advances in connection with the company's tuition reimbursement plan or other
usual and customary business advances for legitimate corporate purposes which
are approved by a supervisor or pursuant to a corporate credit card for usual
and customary, legitimate business purposes. It is the company's policy that any
advance to an associate over $5,000, other than in connection with the company's
tuition reimbursement plan, be approved in advance by the Compliance Officer.

Company credit cards are to be used only for authorized, legitimate
business purposes. An associate will be responsible for any unauthorized charges
to a company credit card.

V. FAIR DEALING WITH CUSTOMERS, SUPPLIERS, COMPETITORS, AND ASSOCIATES

The company does not seek to gain any advantage through the improper use
of favors or other inducements. Offering, giving, soliciting or receiving any
form of bribe to or from an employee of a customer or supplier to influence that
employee's conduct is strictly prohibited.

A. Improper Influence

The company expects all of its associates to refrain from any illegal
conduct to achieve improper influence. Among other types of improper influence
which are prohibited are the following:

1. No associate of the company shall make illegal contributions,
bribes, kick-backs, or any type of illegal payment to anyone in
connection with the obtaining of orders or favored treatment.

2. The accepting of gifts, entertainment, or any other personal favor
or preferment from anyone with whom the company has or is likely to
have any business dealings, other than a Holiday gift of nominal
value (under $15), is forbidden.

If a situation should arise in which you are unable to discern whether a
course of conduct would violate these rules, please contact the
Compliance Officer to discuss the situation in advance of any course of
action.

B. Unfair Competition

Although the free enterprise system is based upon competition, rules have
been imposed stating what can and what cannot be done in a competitive
environment. The following practices can lead to liability for "unfair
competition" and should be avoided. They are violations of the Code.

Disparagement of Competitors. It is not illegal to point out weaknesses in
a competitor's service, product or operation; however, associates may not spread
false rumors about competitors or make misrepresentations about their
businesses. For example, an associate may not pass on anecdotal or unverified
stories about a competitor's products or services as the absolute truth (e.g.,
the statement that "our competitors' diagnostic testing procedures have poor
quality control").

Disrupting a Competitor's Business. This includes bribing a competitor's
employees or using deceptive practices such as enticing away employees in order
to obtain secrets or destroy a competitor's organization.

C. Unfair Practices in International Business

Under the Foreign Corrupt Practices Act ("FCPA"), associates of the
company are prohibited from making certain gifts to foreign officials. "Foreign
officials" include not only persons acting in an official capacity on behalf of
a foreign government, agency, department or instrumentality, but also
representatives of international organizations, foreign political parties and
candidates for foreign public office. The gift is "corrupt" under the FCPA if it
is made for the purpose of:

o Influencing any act or decision of a foreign official in his
official capacity;

o Inducing a foreign official to do or omit to do any act in violation
of his lawful duty;

o Inducing a foreign official to use his position to affect any
decision of the government; or

o Inducing a foreign official to secure any "improper advantage."

A gift is still "corrupt" even when paid through an intermediary. Any
associate who has any questions whatsoever as to whether a particular gift might
be "corrupt" under the FCPA, please contact the Corporate Compliance Officer.

VI. COMPLIANCE WITH LAWS, RULES AND REGULATIONS

A. Insider Trading Policy

The company expressly forbids any associate from trading on material
nonpublic information or communicating material nonpublic information to others
in violation of the law. This conduct is frequently referred to as "insider
trading." This policy applies to every associate of the company and extends to
activities both within and outside their duties to the company, including
trading for a personal account.

Trading on inside information is not a basis for liability unless the
information is material. This is information that a reasonable investor would
consider important in making his or her investment decisions, or information that is
likely to have a significant effect on the price of a company's securities.

Information is nonpublic until it has been effectively communicated to the
marketplace. Tangible evidence of such dissemination is the best indication that
the information is public. For example, information found in a report filed with
the Securities and Exchange Commission or appearing in a national newspaper
would be considered public.

Each associate should be familiar with and abide by the company's Insider
Trading Policy. A copy of this policy is given to all new associates of the
company and is available from the Corporate Compliance Officer.

B. Regulation FD

The company is subject to the securities laws of the United States and the
regulations adopted by the Securities and Exchange Commission, including
Regulation FD, with respect to the disclosure of material information to the
public. The company is committed to fair disclosure to investors in compliance
with the law. The company's policy, which reflects these legal requirements, is
that no one associated with the company may make any disclosure of material
nonpublic information about the company to anyone outside of the company who
trades in or may be expected to trade in our securities, unless we disclose such
information to the public at the same time.

Only the Chief Executive Officer or other individuals expressly authorized by the
Chief Executive Officer may discuss material information with analysts, financial
professionals, stockholders and other members of the public.

No other company personnel are authorized to discuss material information
relating to the company with analysts, financial professionals, stockholders and
other members of the public. Any requests for such information regarding the
company must be forwarded to one of the officers listed above.

C. Equal Employment Opportunity

The company is committed to a policy of nondiscrimination and equal
opportunity in employment decisions for all employees and qualified applicants
without regard to race, color, creed, religion, sex, age, ancestry, national
origin, sexual orientation, marital status, veteran's status, physical or mental
handicap or disability or any other characteristic protected by law. "Employment
decisions" generally mean decisions relating to hiring, recruiting, training,
promotions and compensation, but the term may encompass other employment actions
as well.

Each associate should be familiar with and abide by the company's Equal
Employment Opportunity policy, as described in the Employee Handbook. A copy of
the Handbook is made available to all new associates of the company and can also
be obtained from the Corporate Compliance Officer.

The company encourages its associates to bring any problem, complaint or
concern regarding any alleged employment discrimination to the attention of the
Corporate Compliance Officer.

D. Sexual and Other Unlawful Harassment Policy

The company is committed to maintaining a working environment that is free
of unlawful discrimination. In keeping with this commitment, we will not
tolerate harassment of our employees, directors and officers by anyone,
including any coach, co-worker, vendor, client or customer.

Harassment consists of unwelcome conduct, whether verbal, physical or
visual, that is based upon a person's protected status, such as race, color,
creed, religion, sex, age, ancestry, national origin, sexual orientation,
marital status, veteran's status, physical or mental handicap or disability or
any other characteristic protected by law.

Each associate should be familiar with and abide by the company's Sexual
and Other Unlawful Harassment Policy, as included in the Employee Handbook. The
policy sets forth specific examples of harassment that our associates must avoid
and provides guidelines for the reporting of violations. A copy of the Handbook
is made available to all associates of the company and can also be obtained from
the Corporate Compliance Officer.

E. Health, Safety & Environment Laws

Health, safety, and environmental responsibilities are fundamental to the
company's values. Associates are responsible for ensuring that the company
complies with all provisions of the health, safety, and environmental laws of
the United States and of other countries where the company does business.

The penalties that can be imposed against the company and its associates
for failure to comply with health, safety, and environmental laws can be
substantial, and include imprisonment and fines.

VII. REPORTING CONCERNS UNDER THE CODE: NON-RETALIATION POLICY

Reporting Concerns/Receiving Advice

Communication Channels

Be Proactive. Every employee is encouraged to act proactively by asking
questions, seeking guidance and reporting suspected violations of the Code and
other policies and procedures of the Company, as well as any violation or
suspected violation of applicable law, rule or regulation arising in the conduct
of the Company's business or occurring on the Company's property. If any
employee believes that actions have taken place, may be taking place, or may be
about to take place that violate or would violate the Code, he or she should
bring the matter to the attention of the Company.

Seeking Guidance. The best starting point for an officer or employee
seeking advice on ethics-related issues or reporting potential violations of the
Code will usually be his or her supervisor. However, if the conduct in question
involves his or her supervisor, if the employee has reported the conduct in
question to his or her supervisor and does not believe that he or she has dealt
with it properly, or if the officer or employee does not feel that he or she can
discuss the matter with his or her supervisor, the employee may raise the matter
with the Compliance Officer.

Communication Alternatives. Any officer or employee may communicate with
the Compliance Officer by any of the following methods:

o In writing (which may be done anonymously as set forth below under
"Reporting; Anonymity; Retaliation"), addressed to the Compliance
Officer, either by facsimile to 905 660 5738 or by U.S. mail to 85 corstate
Ave unit #1 Concord Ontario L4K 4Y2 ; or

o By e-mail addressed to the Compliance Officer at his e-mail address noted
above on page 3 (anonymity cannot be maintained)

Misuse of Reporting Channels. Employees must not use these reporting
channels in bad faith or in a false or frivolous manner.

Reporting; Anonymity; Retaliation

When reporting suspected violations of the Code, the Company prefers that
officers and employees identify themselves in order to facilitate the Company's
ability to take appropriate steps to address the report, including conducting
any appropriate investigation. However, the Company also recognizes that some
people may feel more comfortable reporting a suspected violation anonymously.

If an officer or employee wishes to remain anonymous, he or she may do so,
and the Company will use reasonable efforts to protect the confidentiality of
the reporting person subject to applicable law, rule or regulation or to any
applicable legal proceedings. In the event the report is made anonymously,
however, the Company may not have sufficient information to look into or
otherwise investigate or evaluate the allegations. Accordingly, persons who make
reports anonymously should provide as much detail as is reasonably necessary to
permit the Company to evaluate the matter(s) set forth in the anonymous report
and, if appropriate, commence and conduct an appropriate investigation.

No Retaliation

The Company expressly forbids any retaliation against any officer or
employee who, acting in good faith, reports suspected misconduct. Any person who
participates in any such retaliation is subject to disciplinary action,
including termination.

VIII. QUESTIONS UNDER THE CODE AND WAIVER PROCEDURES

Associates are encouraged to consult with the Corporate Compliance Officer
about any uncertainty or questions they may have under the Code.

If any situation should arise where a course of action would likely result
in a violation of the Code but for which the associate thinks that a valid
reason for the course of action exists, the associate should contact the
Corporate Compliance Officer to obtain a waiver prior to the time the action is taken. No
waivers will be granted after the fact for actions already taken. Except as noted below,
the Compliance Officer will review all the facts surrounding the proposed course of
action and will determine whether a waiver from any policy in the Code should be
granted.

Waiver Procedures for Executive Officers and Directors. Waiver requests by
an executive officer or member of the Board of Directors shall be referred by
the Compliance Officer, with his recommendation, to the Board of Directors or
a committee thereof for consideration. If either (i) a majority of the
independent directors on the Board of Directors, or (ii) a committee comprised
solely of independent directors agrees that the waiver should be granted, it
will be granted. The company will disclose the nature and reasons for the waiver
on a Form 8-K to be filed with the Securities and Exchange Commission within
four days. If the Board denies the request for a waiver, the waiver will not be
granted and the associate may not pursue the intended course of action.

It is the company's policy only to grant waivers from the Code in limited
and compelling circumstances.

IX. FREQUENTLY ASKED QUESTIONS AND ANSWERS

The following questions and answers address each associate's obligation to
comply with the Code. The company has attempted to design procedures that ensure
maximum confidentiality and, most importantly, freedom from the fear of
retaliation for complying with and reporting violations under the Code.

Q: Do I have a duty to report violations under the Code?

A: Yes, participation in the Code and its compliance program is mandatory.
You must immediately report any suspected or actual violation of the Code to the
Corporate Compliance Officer. The company will keep reports confidential to the fullest
extent required by applicable law. Failure to report suspected or actual violations is
itself a violation of the Code and may subject you to disciplinary action, up to and
including termination of employment or legal action.

Q: I'm afraid of being fired for raising questions or reporting violations
under the Code. Will I be risking my job if I do?

A: The Code contains a clear non-retaliation policy, meaning that if you
in good faith report a violation of the Code by the company, or its agents
acting on behalf of the company, to the Corporate Compliance Officer, the company will
undertake to protect you from being fired, demoted, reprimanded or otherwise harmed for
reporting the violation, even if the violation involves you, your supervisor, or senior
management of the company. You are entitled to make the report on a confidential
and anonymous basis. To the extent an investigation must be initiated, the
company will keep confidential any report you make to the Corporate Compliance
Officer to the extent required by applicable law.

In addition, if you report a suspected violation under the Code which you
reasonably believe constitutes a violation of a federal statute by the company,
or its agents acting on behalf of the company, to a federal regulatory or law
enforcement agency, you may not be reprimanded, discharged, demoted, suspended,
threatened, harassed or in any manner discriminated against in the terms and
conditions of your employment for reporting the suspected violation, regardless
of whether the suspected violation involves you, your supervisor or senior
management of the company.

Q: How are suspected violations investigated under the Code?

A: When a suspected violation is reported to the Corporate Compliance
Officer, the Compliance Officer will gather information about the allegation by
interviewing the associate reporting the suspected violation (if permissible, in the case
of a non-anonymous report), the associate who is accused of the violation and/or any co-
workers or associates of the accused associates to determine if a factual basis
for the allegation exists. The reporting associate's immediate supervisor will
not be involved in the investigation if the reported violation involved that
supervisor. The company will keep the identity of the reporting associate
confidential to the fullest extent required by applicable law.

If the report is not substantiated, the reporting associate will be
informed and at that time will be asked for any additional information not
previously communicated. If there is no additional information, the Corporate
Compliance Officer will close the matter as unsubstantiated.

If the allegation is substantiated, the Compliance Officer will make a
judgment as to the degree of severity of the violation and the appropriate
disciplinary response. In more severe cases, the Compliance Officer will make
a recommendation to the Board of Directors of the company for its approval. The
Board's decision as to disciplinary and corrective action will be final.

The Compliance Officer shall provide a summary of all matters considered
under the Code to the Board of Directors or a committee thereof at each regular
meeting thereof, or sooner if warranted by the severity of the matter.

Q: Do I have to participate in any investigation under the Code?

A: Your full cooperation with any pending investigation under the Code is
a condition of your continued relationship with the company. The refusal to
cooperate fully with any investigation is a violation of the Code and grounds
for discipline, up to and including termination.

Q: What are the consequences of violating the Code?

A: As explained above, associates who violate the Code may be subject to
discipline, up to and including termination of employment. Associates who
violate the Code may simultaneously violate federal, state, local or foreign
laws, regulations or policies. Such associates may be subject to prosecution,
imprisonment and fines, and may be required to make reimbursement to the
company, the government or any other person for losses resulting from the
violation. They may be subject to punitive or treble damages depending on the
severity of the violation and applicable law.

Q: What if I have questions under the Code or want to obtain a waiver
under any provision of the Code?

A: The Corporate Compliance Officer can help answer questions you may have under
the Code. In addition, Section IX of the Code provides information on how you may
obtain a waiver from the Code; waivers will be granted only in very limited
circumstances. You should never pursue a course of action that is unclear under
the Code without first consulting the Corporate Compliance Officer, and if necessary,
obtaining a waiver from the Code.