As an associate member of the National Investor Relations Institute, I will:

1.  Maintain my integrity and credibility in accordance with the highest legal and ethical standards.

2.  Keep myself abreast of the laws and regulations affecting the practice of investor relations to the extent necessary to fulfill my duties.

3.  During the course of my work, support, study, research, reporting, and/or practice of investor relations:

• Maintain the confidentiality of information acquired.
  
• Not use confidential information acquired for personal advantage nor for the advantage of other parties.
  
• Exercise independent judgment and avoid conflicts of interest.

4.  Support and promote maintaining the highest level of ethical standards for investor relations professionals.

5.  Report to appropriate authorities if I strongly suspect or recognize fraudulent or illegal acts are being conducted.

6.  Represent myself in a reputable and dignified manner that reflects on the professional stature of investor relations.

7.  Honor my obligation to serve the interest of shareholders and other stakeholders by recognizing that the integrity of the capital markets is based on transparency of credible financial and non-financial corporate information.

8.  Avoid any professional/business relationships that might affect, or be perceived to potentially affect, the ethical practice of investor relations or its professional stature.

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