Date: May 2008

CODE OF ETHICS AND STANDARDS OF CONDUCT, MAY 2008

Letter from Managing Director on the board of Directors

Ethics and adherence to the highest standards of good conduct are vital to every POLLUX Business company and operating entity around the world (severally and collectively, “POLLUX Business”) and
to all POLLUX Business employees and others acting on behalf of POLLUX Business.

POLLUX Business is committed to compliance with the law, the highest ethical standards, and to conducting its business with the highest level of integrity. Personally, I believe this commitment is
at the core of what makes POLLUX Business successful.

Each POLLUX Business employee is responsible for the consequences of his or her actions.
We must each be honest and ethical in our personal conduct as well as be a guardian of POLLUX Business’s high ethical standards.

Leaders at POLLUX Business have the extra responsibility of setting an example by their personal conduct and performance, and by having an attitude that conveys our ethical values. That example compels us to treat everyone - employees, customers, prospects, suppliers and competitors - with honesty and respect.

With respect to legal compliance, this Code of Ethics and Standards of Conduct also summarizes our legal compliance principles, and it is designed to be used as an important resource in guiding us in our legal compliance decisions and actions.

It is intended to raise and reinforce awareness of laws and regulations that we must abide by,
it sets forth POLLUX Business policy, and serves as a guide in helping us to reach correct compliance decisions.

I appreciate your attention to POLLUX Business’s Code of Ethics and Standrdards of Conduct and your dedication and commitment to doing your part to ensure that POLLUX’s policy of compliance with the law and POLLUX Business’s adherence to the highest standards of ethics and best business practices continue to be carried out.