CODE OF CONDUCT

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It is the policy of SBJ Military, to apply the highest standards of courtesy, professionalism, honesty, and integrity in our interactions with customers, suppliers, co-workers, and the community. To that end, SBJ Military has established this Code of Business Ethics & Conduct (the “Code”). This Code intends to require a higher standard than required by commercial practice or applicable laws, rules, or regulations. This code applies to our directors, officers, employees, agents, and business associates, and we expect all to comply. We refer to all persons covered by this Code as “SBJ MILITARY employees” or simply “employees.”

SBJ Military has a simple and straightforward policy on the rules of conduct and behavior that are expected from employees when conducting SBJ Military business. It is a commitment to do what is right, obey all laws, behave with integrity and honesty, treat people fairly, respect diversity, accept accountability, communicate openly, and always behave in a way that is above reproach. Generally, these requirements are referred to as ethics. Each employee is required to maintain the highest ethical standards at all times, even though doing so may result in the loss of business to SBJ Military. No employee of SBJ Military should feel that a compromising or unethical situation is justified by any possible business result.

SBJ Military employees must comply with all applicable laws and regulations, including applicable worldwide laws in addition to those mentioned in this Code. If a local custom or policy presents a conflict, consult Human Resources or the Legal Department before taking any action.