I. Statement of Policy

It is MJ Hughes Construction’s policy to maintain the highest ethical standards and comply with all applicable laws, rules, and regulations. We believe that adherence to this policy will ensure our continued success as well as earn and maintain the confidence of our customers and the community in which we live. In order to ensure MJ Hughes Construction operates pursuant to this policy, we have established this Code of Ethical Conduct. The following general rules apply to the implementation of this Code of Ethical Conduct:

  1. All employees must comply this Code of Conduct. Any officer, director, or employee violating this Code is subject to discipline, which may include demotion or dismissal.
  2. All employees have a duty to report all suspected violations of the Code or other potentially unethical behavior by anyone, including officers, directors, employees, agents, customers, subcontractors, suppliers, and prime contractors, to the Corporate Compliance Officer.
  3. Employees in management positions are personally accountable for their own conduct and the conduct of those reporting to them. Each management employee is expected to inform those reporting to them about this Code of Conduct and take all necessary steps to ensure compliance with this Code.
  4. No employee has the authority to direct, participate in, approve, or tolerate any violation of this Code by anyone.
  5. Any employee who has questions about the application of this Code should consult with the designated Corporate Compliance Officer.

II. Definitions

Code of Ethical Conduct: The written statement of acceptable behavior by MJ Hughes Construction’s officers, directors, and employees that ensures MJ Hughes Construction operates according to the highest ethical standards.

Code: The Code of Ethical Conduct.

Corporate Compliance Officer: The company official designated by the President to be responsible for implementing and administering the Code of Ethical Conduct. In the case where there is no Corporate Compliance Officer, or the Corporate Compliance Officer is not available, the Company President will be responsible for implementing and administering the Code of Ethical Conduct.

Corporate Compliance Program: The written procedures and policies used by MJ Hughes Construction are designed to ensure that all officers, directors, and employees are aware of the Code of Ethical Conduct and adhere to its standards. The Corporate Compliance Program is implemented and administered by the Corporate Compliance Officer.

Employee: Any person employed by MJ Hughes Construction, including employees, foremen, managers, officers, directors, and persons authorized to act on behalf of the Company.

Program: Corporate Compliance Program.

III. Standards of Conduct

A. Equal Employment and Nondiscrimination

The continued success of our company is dependent upon employing the most qualified people and establishing a work environment that is free of discrimination, harassment, intimidation or coercion related to race, color, religion, sex, age, national origin, disability, or sexual orientation. This policy extends to all phases of employment, including hiring, placement, promotion, transfer, compensation, benefits, training and the use of facilities. MJ Hughes is committed to complying with all applicable laws related to equal employment opportunities and to ensure that there is no unlawful discrimination by any officer, director, or employee. MJ Hughes Construction is committed to a work environment in which everyone is treated with respect, trust, honesty, fairness, and dignity.

B. Environmental Compliance

MJ Hughes Construction is committed to full compliance with all federal, state and local environmental laws, standards, and guidelines. Not only is environmental compliance legally necessary, but it is also an important component of our obligation to the community and our good reputation. It is essential that each employee involved with regulated air emissions, water discharges, hazardous materials, or other regulated pollutants know and comply with all applicable environmental laws and guidelines. No one at MJ Hughes Construction may participate in concealing an improper discharge, disposal, or storage of hazardous materials or other pollutants. Any person who has reason to believe that there may have been violations of any aspect of MJ Hughes Construction’s environmental compliance policy shall report immediately to the Company’s environmental compliance officer or Corporate Compliance Officer. Moreover, in addition to compliance with all environmental laws and guidelines, MJ Hughes Construction is also committed to utilizing energy and materials in a manner that will minimize the impact on the environment. MJ Hughes Construction will also consider using recycled materials whenever feasible.

C. Safety & Health

MJ Hughes Construction considers employee safety and health as one of the highest priorities. Many of the job activities, products, and materials handled by our employees require strict adherence to safety procedures, rules and regulations. Each employee must be aware of the Company’s safety program that incorporates all of the applicable health and safety laws and guidelines and follow all applicable procedures. Also, supervisors are responsible for ensuring that all reasonable safeguards and precautions are taken in the workplace including ensuring compliance with the Company’s procedures and guidelines, promoting safe work practices, and the use of personal protective equipment. If any employee has any safety related concerns, he or she should report these concerns to the Company’s safety compliance officer.

D. Drugs and Alcohol

MJ Hughes Construction is firmly committed to providing its employees with a safe and productive work environment to the extent possible and promoting high standards of employee health. Accordingly, MJ Hughes Construction expects all of its employees to report to work and be able to perform his or her duties productively and safely. Drug and alcohol abuse by employees is regarded as unsafe by creating an increased risk to the safety of themselves, their fellow employees, and the general public and contrary to the Company’s interests in maximizing its productivity. Therefore, drug and alcohol abuse in MJ Hughes Construction will not be tolerated and the company will take appropriate action to ensure compliance with this policy. Additionally, anyone caught using drugs or alcohol in the workplace will be subject to discipline, including termination.

E. Conflicts of Interest

Employees must avoid situations in which their personal interests could conflict with, or even appear to conflict with, the interests of the Company. Conflicts of interest arise when an individual’s position or responsibilities with the Company present an opportunity for personal gain of profit separate and apart from that individual’s earnings from the Company or where the employee’s interests are otherwise inconsistent with the interests of the Company. A conflict of interest may arise in any number of situations and it is impossible to describe each and every instance. As a general matter, if you think that any situation may be a potential conflict of interest, you should consult with the Corporate Compliance Officer. However, the following situations have a great potential for conflicts of interest:

1. Outside Employment

As a matter of company policy, employees may pursue outside employment opportunities. However, such opportunities must not interfere with the employee’s job responsibilities with the Company. Any outside employment that interferes with the employee’s job responsibilities or conscientious performance of his or her duties are deemed to be a conflict of interest is not permitted. Likewise, an employee’s participation in civic, charitable, or professional organizations or activities that interferes with the employee’s job responsibilities or conscientious performance of his or her job is deemed to be an impermissible conflict of interest. Additionally, employees may not use company time or resources to further non-company