CODE OF PROFESSIONAL CONDUCT AND BUSINESS ETHICS

* We will maintain the highest ethical standards and avoid even the appearance of impropriety.

* Transparency and openness are the cornerstones of strong relationships. We are committed to creating a culture of transparency and accountability.

* Good partnership is good business. We strive to align our interests with our clients and their management teams, be reliable and trustworthy partners to both and work for the best possible outcomes for all concerned.

* Our people are our most valuable assets. We seek to hire and retain professionals who possess and practice the highest business and ethical standards and share our core values.

* Teamwork is an essential element of our success and the foundation of our culture. The interests of the firm come before those of the individual.

* Confidential information received as part of our business will never be disclosed or used improperly.

* We will manage and resolve any actual or perceived conflicts in an upfront and transparent manner.

* We will treat everyone, fellow employees, investors, clients, management teams, financiers, vendors and our competitors with dignity and respect.

* We will endeavor to make the communities we touch better places to live and work. We will attempt to use our influence for positive change and respect the power entrusted in us by our clients and investors.