GENERAL POLICY

ABX is proud of those who work for us, and you can be proud of the position of trust you hold. The reputation of the company in the community and business world depends on the actions of those who work here. It is expected that you will maintain the highest degree of integrity, honesty, and professional manner in dealing with all customers and any other outside parties such as suppliers, contractors, competitors, or any person doing business or seeking to do business with ABX.

PURPOSE

This policy outlines ABX’s expectations with regard to receiving or giving gifts, favors, or entertainment, along with other potential conflicts of interest.

DEFINITIONS

Conflict of Interest - situations in which personal considerations or financial gain may compromise, or have the appearance of compromising, your professional judgment and result in actions or choices that conflict with the best interest of the company.

Relatives - parents, siblings, children, spouses, grandparents, aunts, uncles, nieces, nephews, first cousins, in-laws, or step-relations.

CORE REQUIREMENTS

• Act in the best interest of the company when dealing with customers, suppliers, contractors, competitors, or any person doing or seeking to do business with ABX.

• Tell management immediately if you own or have significant interest in, or any member of your family owns or has significant interest in, any outside company which does business or seeks to do business with ABX or is a competitor.

• Tell management immediately if you become aware of any situation that may involve a conflict of interest for yourself or others.

• Please direct any questions related to this policy to your management or the Vice President, Corporate Secretary & General Counsel.

EMPLOYEE ROLE & RESPONSIBILITIES

• You are expected to conduct the company’s business with integrity and in a manner that excludes any personal advantage or gain.

• Your conduct with all outside parties should be in a strictly professional, business-like manner to avoid any potential or actual conflict of interest or favoritism.

With regard to gifts, favors, and entertainment you are offered:

• Do not seek gifts, favors, or entertainment for yourself or for others.

• It is never permissible to accept a gift of cash or cash equivalent such as stocks or other forms of marketable securities of any amount.

• ANY gifts, favors, or entertainment offered MUST be reported to the next level of management who will assist in deciding how the offers should be handled. In most cases, gifts that can be shared with co-workers should be shared.

• Examples of gifts, favors, or entertainment situations that commonly come up and are acceptable include, but are not limited to:

1. Lunch and/or dinner with vendors, sometimes including spouses.

2. Gifts of small value from vendors such as calendars, pens, pads, knives, etc.

3. Tickets to events (such as sports, arts, etc.).

4. Overnight outings are acceptable under the condition that either individuals from other companies or the vendor also attends.

5. Receipt of gifts of alcoholic beverages is discouraged.

6. Gifts of perishable items usually given during the holidays such as hams, cookies, nuts, etc., are acceptable. You are encouraged to share with co-workers if you receive them.

7. Day outings such as golf, fishing, and hunting are acceptable if the vendor attends.

8. Use of vendor’s facilities (vacation homes, etc.) by employees or families for personal use is prohibited.

• Management should not accept gifts of more than limited value from those under their supervision.

GIFTS, FAVORS, AND ENTERTAINMENT OFFERED BY EMPLOYEES

You may give gifts, favors, and entertainment to others at Company expense, only if they meet all of the following criteria:

• They are of limited value and will not be construed as a bribe or payoff;

• They are not in violation of applicable law and generally accepted ethical standards; and public disclosure of the facts will not embarrass the company;

• Your Vice President approves the gift.

OTHER POTENTIAL EMPLOYMENT CONFLICTS

Other potential conflicts of interest include, but are not limited to the following:

• Employment outside ABX - If you are employed outside ABX, it should not interfere, compete, or conflict with the company’s best interests or hinder your ability to meet your responsibilities at ABX.

• Volunteer Activities/Community Involvement -You are encouraged to be involved in community, industry, and charitable activities, including directorships in non-profit community organizations, as long as they do not compete with or create demands that interfere with your job.

• Employment of Relatives - ABX permits the employment and promotions of qualified relatives of employees as long as such employment does not, in the opinion of ABX, create actual or perceived conflicts of interest.

ACCESS TO CONFIDENTIAL INFORMATION

Revealing or using any confidential, personal information; trade secrets; product information; information used to make decisions or future plans; or any other information that might be contrary to the best interests of the Company without prior authorization is forbidden. The misuse, unauthorized access to, or mishandling of confidential information, particularly personnel information, is strictly prohibited and will subject an employee to disciplinary action up to and including termination.

MANAGEMENT ROLE & RESPONSIBILITIES; BEYOND THOSE AS EMPLOYEES

• Respond to employees’ concerns and provide guidance regarding potential or actual conflict of interest issues.

• Investigate immediately if you become aware of any situation that may involve a potential or actual conflict of interest and take appropriate action.

• Take time to examine situations involving relatives to see if the potential for conflict of interest does exist and, if so, how it will affect the employee’s productivity in the job and the productivity of the department. If a potential for conflict of interest does exist, discuss the situation with your management and Human Resources to evaluate the appropriate steps to take.

• Your department may establish procedures to provide additional guidance to you.