INTRODUCTION
The mission of North Star Marketing (NSM) is to be a leading marketing services company focused on providing outstanding marketing solutions for our clientele. We seek to produce value in our business and sustainable returns for our owners as we provide opportunities for growth and enrichment to our employees, our business partners and the communities in which we operate. In everything we do, we strive to act with honesty, fairness and integrity and to obey the laws and regulations of the countries wherein we do business.

RESPECT FOR OUR EMPLOYEES
We believe our most important strength is our employees. We seek to provide a work environment where all employees have the opportunity to reach their full potential and contribute to NSM’s success. We emphasize personal integrity and believe long-term results are the best measure of an employee’s performance.

NSM respects the human rights and the dignity of all employees. We endeavor to treat our employees fairly and honestly. We strive to maintain a safe, secure and healthy workplace and it is against our policy to use forced or child labor. We also strive to follow all applicable employment laws and regulations.

We are committed to equal opportunity in all aspects of employment for employees and applicants. This means providing a workplace free from any form of discrimination or harassment, including sexual harassment. We seek to create a work environment where people feel comfortable and respected, regardless of individual differences, talents or personal characteristics. Our objective is for the diversity of our employees to reflect the diversity of the population wherever we operate and for the performance of all employees to be judged fairly and based on their contribution to our results.
NSM encourages an inclusive culture, which enables all employees to do their best. We recognize the needs of individuals to achieve professional and personal balance in their lives. We also respect employee privacy and will acquire and retain only that employee personal information that is required for operation of the Company’s business or required by law.

CONSUMERS, CUSTOMERS, SUPPLIERS AND COMPETITORS
We are committed to the continuation of free enterprise and the legal and regulatory frameworks that support it. Therefore, we recognize the importance of laws that prohibit restraints of trade, predatory economic activities and unfair, deceptive or unethical business practices.

In all of our business dealings with consumers, customers, suppliers and competitors, we will:
Avoid any unfair or deceptive practice and always present our services and products in an honest and forthright manner.

Treat all customers and suppliers honestly, fairly and objectively.

Select suppliers based on merit, and make clear to all suppliers that we expect them to compete fairly and vigorously for our business.

Compete vigorously and with integrity.

Comply with all competition laws.

BUSINESS GIFTS AND ENTERTAINMENT
Our business decisions are made on merit. Therefore, we will never give or offer, directly or indirectly, anything of value to a third party, including a government official, political party or candidate, to corruptly influence that person’s business decision or gain an unfair advantage. Giving gifts or entertainment to governmental officials is highly regulated and often prohibited. Gifts or entertainment given to or received from customers or suppliers must never influence, or appear to influence, business decisions. There must be a legitimate business purpose for any business gift or entertainment, it must be in good taste and it must be consistent with the law, with the giver’s and receiver’s policies, and NSM’s policies. Customer and supplier meals and entertainment must be reasonable in cost and frequency and consistent with guidelines established by NSM.

HEALTH AND SAFETY
NSM is committed to providing safe and healthy work environments at its facilities for all its employees, visitors, contractors and vendors. It is our policy to provide employees with a drug-free workplace. In order to create an environment free from threats, violence and intimidation, we are committed to a policy of zero tolerance for violence.

ENVIRONMENT
NSM is committed to being an environmentally responsible corporate citizen. We are committed to minimizing the impact of our businesses on the environment with methods that are socially responsible, scientifically based and economically sound. We encourage conservation, recycling and energy use programs that promote clean air and water, reduce landfill wastes and replenish the planet’s natural resources. We will follow applicable environmental laws and regulations in the countries where we operate.

POLITICAL AND COMMUNITY ACTIVITIES AND CONTRIBUTIONS
NSM believes in contributing to society and encourages employees to participate in community activities.

We will continue to communicate information and opinions on issues of public concern that may affect NSM. Decisions by our employees whether or not to contribute time, money or resources of their own to any political or community activity are entirely personal and voluntary.

We will obey all laws in promoting the Company’s position to government authorities and in making political contributions. Contributions by the Company to political candidates may be prohibited or regulated.

CONFLICTS OF INTEREST
NSM’s conflicts of interest policy is straight-forward: Don’t compete with NSM businesses, and never let your business dealings on behalf of any of our businesses be influenced, or appear to be influenced, by personal or family interests.

ACCOUNTS AND RECORD-KEEPING
We will continue to observe the most stringent standards in the keeping of our financial records and accounts. Our books and records must reflect all components of transactions, as well as our own standard of insisting upon an honest and forthright presentation of the facts.

RESPONSIBILITY FOR COMPLIANCE
All employees are expected to display responsible and ethical behavior, to follow consistently both the meaning and intent of this Code and to act with integrity on a daily basis. This Code cannot provide definitive answers to all questions. For that, we must rely on each person’s judgment and integrity.

Last Revision: April 2011