Standards of Business Conduct

We at 360 Strategic Partners are committed to conducting our business affairs in accordance with the highest standards of integrity and ethical behavior. Honesty, fairness, respect, and integrity are guiding principles in all our business dealings and in our interactions with each other.

Our ability to achieve the challenging performance targets we have set for ourselves depends on each and every one of us, including all senior level executives and financial officers, being committed to these values, and practicing them in every action we take. Moreover, these values apply wherever we do business around the world, in conjunction with local laws and regulations.

If an issue arises that you cannot answer, or if you know of or believe there might be violations of the company’s policies, talk to any Managing Partner.

The reputation for integrity of 360 Strategic Partners depends on every one of us continuing to make and keep our commitments to business conduct standards in all we do. As such, please be diligent in reporting any fraud, misconduct, or abuse that you may encounter. It is up to each and every one of us to maintain the company’s standing in upholding the highest standards of conduct and ethics in all its business and professional dealings. Let’s keep up the good work.

Sincerely,

Managing Partners

Standards of Business Conduct, 11-10-2005