Regular Member Code of Ethics

As a regular member of the National Investor Relations Institute, I will:

1. Maintain my integrity and credibility by practicing investor relations in accordance with the highest legal and ethical standards.
2. Avoid even the appearance of professional impropriety in the conduct of my investor relations responsibilities.
3. Recognize that the integrity of the capital markets is based on transparency of credible financial and non-financial corporate information, and will to the best of my ability and knowledge work to ensure that my company or client fully and fairly discloses this important information.
4. Provide analysts, institutional and individual investors and the media fair access to corporate information.
5. Honor my obligation to serve the interest of shareholders and other stakeholders.
6. Discharge my responsibilities completely and competently by keeping myself abreast of the affairs of my company or client as well as the laws and regulations affecting the practice of investor relations.
7. Maintain the confidentiality of information acquired in the course of my work for my company or client company.
8. Not use confidential information acquired in the course of my work for my personal advantage nor for the advantage of related parties.
9. Exercise independent professional judgment in the conduct of my duties and responsibilities on behalf of my company or client.
10. Avoid any professional/business relationships that might affect, or be perceived to potentially affect, my ethical practice of investor relations.
11. Report to appropriate company authorities if I suspect or recognize fraudulent or illegal acts within the company.
12. Represent myself in a reputable and dignified manner that reflects the professional stature of investor relations.

Enforcement and Communication of the NIRI Code of Ethics
NIRI urges compliance with its Code of Ethics by positively communicating the ideals of professional ethics and practice rather than through negative sanctions. However, members of NIRI who are sanctioned by an appropriate governmental agency or judicial body for violating laws or regulations affecting their professional activities may, upon recommendation of the NIRI Ethics Council, have their membership terminated by the NIRI Board of Directors following procedures in the institute's bylaws.
Revised 3/11/02

Ethics Council and Charter