| -      | Act      with honesty and integrity, avoiding actual or actual conflicts of      interest in personal and professional relationships.                                                                                                                                                                                                 |
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| -      | Provide      information that is accurate, complete, objective, relevant, timely and      understandable to ensure full, fair, accurate, timely, and understandable      disclosure in the reports and documents that Universal Holdings files      with, or submits to, government agencies and in other public      communications. |
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| -      | Comply      with the rules and regulations of federal, state and local governments,      and other appropriate private and public regulatory    agencies.                                                                                                                                                                             |
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| -      | Act      in good faith, responsibly, with due care, competence and diligence,      without misrepresenting material facts or allowing one’s independent      judgment to be subordinated.                                                                                                                                       |
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| -      | Respect      the confidentiality of information acquired in the course of one’s work,      except when authorized or otherwise legally obligated to disclose.      Confidential information acquired in the course of one’s work will not be      used for personal advantage.                                            |
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| -      | Share      job knowledge and maintain skills important and relevant to stakeholders      needs.                                                                                                                                                                                                                                       |
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| -      | Proactively      promote and be an example of ethical behavior as a responsible partner      among peers, in the work environment and in the  community.                                                                                                                                                                              |
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| -      | Achieve      responsible use of, and control over, all Universal Holdings assets and      resources employed by, or entrusted to yourself, and your      department.                                                                                                                                                                  |
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| -      | Receive      the full and active support and cooperation of Universal Holdings’      Officers, Sr. Staff, and all employees in the adherence to this Financial      Code of Ethics.                                                                                                                                             |
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| -      | Promptly      report to the CEO or CFO any conduct believed to be in violation of law or      business ethics or in violation of any provision of this Code of Ethics,      including any transaction or relationship that reasonably could be      expected to give rise to such aconflict.                                          |