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Code of Ethics

Our ethical principles are the values that set the ground rules for all that we do as employees of
Charley Grey. As we seek to achieve responsible success, we will be challenged to balance these
principles, always mindful of our promise to achieve responsible success.

Honesty

We will not say things that are false. We will never
deliberately mislead. We will be as candid as possible,
openly and freely sharing information, as appropriate to
the relationship.

Fairness

We will create and follow a process and achieve outcomes that a reasonable person would call just, evenhanded and non-arbitrary

 Compassion

We will maintain an awareness of the needs of others and act to meet those needs whenever possible. We will also minimize harm whenever possible. We will act in ways that are consistent with our commitment to social responsibility.

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 Respect For Others

We will be open and direct in our communication and receptive to influence. We will honor and value the abilities and contributions of others, embracing the responsibility and accountability for our actions in this regard.

Integrity

We will live up to our ethical principles, even when confronted by personal, professional, and social risks, as well as economic pressures.

Promise Keeping

We will go to great lengths to keep our commitments. We will not make promises that cannot be kept and we will not make promises on behalf of the Company unless we have the authority to do so.