Exhibit 14.1



POLAR
POWER, INC.



CODE OF BUSINESS CONDUCT AND ETHICS



Dated: December 6, 2016



Introduction



Purpose



This Code of Business
Conduct and Ethics (the “Code”) contains general guidelines for conducting the business of Polar Power, Inc.
(the “Company”) consistent with the highest standards of business ethics. To the extent this Code requires a
higher standard than required by commercial practice or applicable laws, rules or regulations, the Company adheres to these higher
standards.



This Code applies to
all of our directors, officers and other employees. We refer to all officers and other employees covered by this Code as “Company
employees” or simply “employees,” unless the context otherwise requires. In this Code, we refer to our principal
executive officer, principal financial officer, principal accounting officer and controller, or persons performing similar functions,
as our “principal financial officers.”



Seeking Help and Information



This Code is not intended
to be a comprehensive rulebook and cannot address every situation that you may face. If you feel uncomfortable about a situation
or have any doubts about whether it is consistent with the Company’s ethical standards, seek help. We encourage you to contact
your supervisor for help first. If your supervisor cannot answer your question or if you do not feel comfortable contacting your
supervisor, contact the Company’s Chief Financial Officer (or the Company’s Acting Chief Financial Officer, as the
case may be). The Company has also established an Ethics Hotline that is available 24 hours a day, 7 days a week by calling (424)
286-4122, or emailing the Chief Financial Officer. You may remain anonymous and will not be required to reveal your identity in
calls to the Ethics Hotline, although providing your identity may assist the Company in addressing your questions or concerns.



Reporting Violations of the Code



All employees and directors
have a duty to report any known or suspected violation of this Code, including violations of the laws, rules, regulations or policies
that apply to the Company. If you know of or suspect a violation of this Code, immediately report the conduct to your supervisor
or the Company’s Chief Financial Officer (or the Company’s Acting Chief Financial Officer, as the case may be). The
Company’s Chief Financial Officer (or the Company’s Acting Chief Financial Officer, as the case may be) will work with
you and your supervisor or other appropriate persons to investigate your concern. If you do not feel comfortable reporting the
conduct to your supervisor or you do not get a satisfactory response, you may contact the Company’s Chief Financial Officer
(or the Company’s Acting Chief Financial Officer, as the case may be) directly. You may also report known or suspected violations
of the Code on the Ethics Hotline that is available 24 hours a day, 7 days a week by calling (424) 286-4122, or emailing Chief
Financial Officer (or the Company’s Acting Chief Financial Officer, as the case may be). You may remain anonymous and will
not be required to reveal your identity in calls to the Ethics Hotline, although providing your identity may assist the Company
in investigating your concern. All reports of known or suspected violations of the law or this Code will be handled sensitively
and with discretion. Your supervisor, the Company’s Chief Financial Officer (or the Company’s Acting Chief Financial
Officer, as the case may be) and the Company will protect your confidentiality to the extent possible, consistent with applicable
laws and the Company’s need to investigate your concern.











It is Company policy
that any employee or director who violates this Code will be subject to appropriate discipline, which may include termination of
employment or removal from the Board of Directors, as appropriate. This determination will be based upon the facts and circumstances
of each particular situation. If you are accused of violating this Code, you will be given an opportunity to present your version
of the events at issue prior to any determination of appropriate discipline. Employees and directors who violate the law or this
Code may expose themselves to substantial civil damages, criminal fines and prison terms. The Company may also face substantial
fines and penalties and may incur damage to its reputation and standing in the community. Your conduct as a representative of the
Company, if it does not comply with the law or with this Code, can result in serious consequences for both you and the Company.



Policy Against Retaliation



The Company prohibits
retaliation against an employee or director who, in good faith, seeks help or reports known or suspected violations. Any reprisal
or retaliation against an employee because the employee, in good faith, sought help or filed a report will be subject to disciplinary
action, including potential termination of employment.



Waivers of the Code



Any waiver of this
Code for our directors, executive officers or other principal financial officers may be made only by our Board of Directors and
will be disclosed to the public as required by law or the rules of The NASDAQ Stock Market, when applicable. Waivers of this Code
for other employees may be made only by our Chief Executive Officer or Chief Financial Officer and will be reported to our Audit
Committee.



Conflicts of Interest



Employees, officers
and directors must act in the best interests of the Company. You must refrain from engaging in any activity or having a personal
interest that presents a “conflict of interest” and should seek to avoid even the appearance of a conflict of interest.
A conflict of interest occurs when your personal interest interferes with the interests of the Company. A conflict of interest
can arise whenever you, as an employee, officer or director, take action or have an interest that prevents you from performing
your Company duties and responsibilities honestly, objectively and effectively.



2







The Company requires
that employees and directors disclose any situation that reasonably would be expected to give rise to a conflict of interest. If
you suspect that you have a situation that could give rise to a conflict of interest, or something that others could reasonably
perceive as a conflict of interest, you must report it in writing to your supervisor or the Company’s Chief Financial Officer
(or the Company’s Acting Chief Financial Officer, as the case may be), or if you are a director or executive officer, to
the Board of Directors. The Company’s Chief Financial Officer (or the Company’s Acting Chief Financial Officer, as
the case may be) or the Board of Directors, as applicable, will work with you to determine whether you have a conflict of interest
and, if so, how best to address it. All transactions that would give rise to a conflict of interest involving a director, executive
officer or principal financial officer must be approved by the Board of Directors, and any such approval will not be considered
a waiver of this Code.



Identifying potential
conflicts of interest may not always be clear-cut. The list below contains examples of situations that may be deemed to constitute
a conflict of interest requiring disclosure:



| | · | Outside Employment. An employee being employed by, serving as a director of, or providing
any services to a company that the individual knows or suspects is a customer, supplier or competitor of the Company (other than
services to be provided as part of an employee’s job responsibilities for the Company).
| | - | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | · | Improper Personal Benefits. An employee or director obtaining any material (as to him or
her) personal benefits or favors because of his or her position with the Company. Please see “Gifts and Entertainment”
below for additional guidelines in this area.
| | - | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | · | Financial Interests. An employee having a “material interest” (ownership or
otherwise) in any company that the individual knows or suspects is a customer, supplier or competitor of the Company and using
his or her position to influence a transaction with such company. Whether an employee has a “material interest” will
be determined by the Board of Directors in light of all of the circumstances, including consideration of the relationship of the
employee to the customer, supplier or competitor, the relationship of the employee to the specific transaction and the importance
of the interest to the employee having the interest.
| | - | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | · | Loans or Other Financial Transactions. An employee or director obtaining loans or guarantees
of personal obligations from, or entering into any other personal financial transaction with, any company that the individual knows
or suspects is a customer, supplier or competitor of the Company. This guideline does not prohibit arms-length transactions with
banks, brokerage firms or other financial institutions.
| | - | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | · | Service on Boards and Committees. An employee or director serving on a board of directors
or trustees or on a committee of any entity (whether profit or not-for-profit) whose interests reasonably would be expected to
conflict with those of the Company.
| | - | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



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| | · | Actions of Family Members. The actions of family members outside the workplace may also
give rise to the conflicts of interest described above because they may influence an employee’s or director’s objectivity
in making decisions on behalf of the Company. For purposes of this Code, “family members” include your spouse or life-partner,
brothers, sisters, parents, in-laws and children whether such relationships are by blood or adoption.
| | - | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



Corporate Opportunities



As an employee or director
of the Company, you have an obligation to advance the Company’s interests when the opportunity to do so arises. If you discover
or are presented with a business opportunity through the use of corporate property or information or because of your position with
the Company, you should first present the business opportunity to the Company before pursuing the opportunity in your individual
capacity. No employee may use corporate property, information or his or her position with the Company for personal gain or compete
with the Company while employed by us.



You should disclose
to your supervisor the terms and conditions of each business opportunity covered by this Code that you wish to pursue. Your supervisor
will contact the Company’s Chief Financial Officer (or the Company’s Acting Chief Financial Officer, as the case may
be) and the appropriate management personnel to determine whether the Company wishes to pursue the business opportunity. If the
Company waives its right to pursue the business opportunity, you may pursue the business opportunity on the same terms and conditions
as originally proposed and consistent with the other ethical guidelines set forth in this Code.



Confidential Information



Employees and directors
have access to a variety of confidential information regarding the Company. Confidential information includes all non-public information
that might be of use to competitors, or, if disclosed, harmful to the Company or its customers or suppliers. Employees and directors
have a duty to safeguard all confidential information of the Company or third parties with which the Company conducts business,
except when disclosure is authorized or legally mandated. Unauthorized disclosure of any confidential information is prohibited.
Additionally, employees and directors should take appropriate precautions to ensure that confidential or sensitive business information,
whether it is proprietary to the Company or another company, is not communicated within the Company except to employees and directors
who have a need to know such information to perform their responsibilities for the Company. An employee’s and director’s
obligation to protect confidential information continues after he or she leaves the Company. Unauthorized disclosure of confidential
information could cause competitive harm to the Company or its customers and could result in legal liability to you and the Company.



Any questions or concerns
regarding whether disclosure of Company information is legally mandated should be promptly referred to the Company’s Chief
Financial Officer (or the Company’s Acting Chief Financial Officer, as the case may be).



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Competition and Fair Dealing



All employees should
endeavor to deal fairly with fellow employees and with the Company’s collaborators, licensors, customers, suppliers and competitors.
Employees should not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation
of material facts or any other unfair-dealing practice. Employees should maintain and protect any intellectual property licensed
from licensors with the same care as they employ with regard to Company-developed intellectual property. Employees should also
handle the nonpublic information of our collaborators, licensors, suppliers and customers responsibly and in accordance with our
agreements with them, including information regarding their technology and product pipelines.



Gifts and Entertainment



The giving and receiving
of gifts is a common business practice. Appropriate business gifts and entertainment are welcome courtesies designed to build relationships
and understanding among business partners. Gifts and entertainment, however, should not compromise, or appear to compromise, your
ability to make objective and fair business decisions. In addition, it is important to note that the giving and receiving of gifts
are subject to a variety of laws, rules and regulations applicable to the Company’s operations. These include, without limitation,
laws covering the marketing of products, bribery and kickbacks. You are expected to understand and comply with all laws, rules
and regulations that apply to your job position.



It is your responsibility
to use good judgment in this area. As a general rule, you may give or receive gifts or entertainment to or from collaborators,
customers or suppliers only if the gift or entertainment is infrequent, modest, intended to further legitimate business goals,
in compliance with applicable law, and provided the gift or entertainment would not be viewed as an inducement to or reward for
any particular business decision. All gifts and entertainment expenses should be properly accounted for on expense reports.



You should make every
effort to refuse or return a gift that is beyond these permissible guidelines. If it would be inappropriate to refuse a gift or
you are unable to return a gift, you should promptly report the gift to your supervisor. Your supervisor will bring the gift to
the attention of the Chief Financial Officer (or the Company’s Acting Chief Financial Officer, as the case may be), who may
require you to donate the gift to an appropriate community organization. If you have any questions about whether it is permissible
to accept a gift or something else of value, contact your supervisor or a principal financial officer for additional guidance.



Note: Gifts and entertainment
may not be offered or exchanged under any circumstances to or with any employees of the U.S. government or state or local governments.
If you have any questions about this policy, contact your supervisor or the Company’s Chief Financial Officer (or the Company’s
Acting Chief Financial Officer, as the case may be) for additional guidance. For a more detailed discussion of special considerations
applicable to dealing with the U.S., state and local governments, see “Interactions with Governments.”



5







Company Records



Accurate and reliable
records are crucial to our business. Our records are the basis of our earnings statements, financial reports, regulatory submissions
and many other aspects of our business and guide our business decision-making and strategic planning. Company records include financial
records, personnel records, records relating to our technology and product development, customer collaborations, regulatory submissions
and all other records maintained in the ordinary course of our business.



All Company records
must be complete, accurate and reliable in all material respects. Company records and communications often become public, and we
should avoid exaggeration, derogatory remarks, guesswork or inappropriate characterizations of people and companies that can be
misunderstood. This applies equally to e-mail, internal memos and formal reports. Each employee and director must follow any document
retention policy of the Company with respect to Company records within such employee’s or director’s control.



Protection and Use of Company Assets



Employees should protect
the Company’s assets and ensure their efficient use for legitimate business purposes only and not for any personal benefit
or the personal benefit of anyone else. Theft, carelessness and waste have a direct impact on the Company’s financial performance.
The use of Company funds or assets, whether or not for personal gain, for any unlawful or improper purpose is prohibited.



Employees should be
aware that Company property includes all data and communications transmitted or received to or by, or contained in, the Company’s
electronic or telephonic systems. Company property also includes all written communications. Employees and other users of this
property should have no expectation of privacy with respect to these communications and data. To the extent permitted by law, the
Company has the ability, and reserves the right, to monitor all electronic and telephonic communication. These communications may
also be subject to disclosure to law enforcement or government officials.



Accuracy of Financial Reports and Other Public Communications



As a public company
we are subject to various securities laws, regulations and reporting obligations. Both federal law and our policies require the
disclosure of accurate and complete information regarding the Company’s business, financial condition and results of operations.
Inaccurate, incomplete or untimely reporting will not be tolerated and can severely damage the Company and result in legal liability.



The Company’s
principal financial officers and other employees working in the finance department have a special responsibility to ensure that
all of our financial disclosures are full, fair, accurate, timely and understandable. These employees must understand and strictly
comply with generally accepted accounting principles and all standards, laws and regulations for accounting and financial reporting
of transactions, estimates and forecasts. In addition, employees and directors are prohibited from directly or indirectly taking
any action to fraudulently influence, coerce, manipulate or mislead the Company’s independent registered public accounting
firm for the purpose of rendering the financial statements of the Company misleading.



6







Compliance with Laws and Regulations



Each employee and director
has an obligation to comply with all laws, rules and regulations applicable to the Company’s operations. These include, without
limitation, laws covering bribery and kickbacks, the marketing and sale of our products and services, copyrights, trademarks and
trade secrets, information privacy, insider trading, illegal political contributions, antitrust prohibitions, foreign corrupt practices,
offering or receiving gratuities, environmental hazards, employment discrimination or harassment, occupational health and safety,
false or misleading financial information or misuse of corporate assets. You are expected to understand and comply with all laws,
rules and regulations that apply to your job position. If any doubt exists about whether a course of action is lawful, you should
seek advice from your supervisor or the Company’s Chief Financial Officer (or the Company’s Acting Chief Financial
Officer, as the case may be).



Interactions with the Government



The Company may conduct
business with the U.S. government, state and local governments and the governments of other countries. The Company is committed
to conducting its business with all governments and their representatives with the highest standards of business ethics and in
compliance with all applicable laws and regulations, including the special requirements that apply to communications with governmental
bodies that may have regulatory authority over our products and operations, such as government contracts and government transactions.



If your job responsibilities
include interacting with the government, you are expected to understand and comply with the special laws, rules and regulations
that apply to your job position as well as with any applicable standard operating procedures that the Company has implemented.
If any doubt exists about whether a course of action is lawful, you should seek advice immediately from your supervisor and the
Company’s Chief Financial Officer (or the Company’s Acting Chief Financial Officer, as the case may be).



In addition to the
above, you must obtain approval from the Company’s Chief Executive Officer or Chief Financial Officer (or the Company’s
Acting Chief Financial Officer, as the case may be) for any work activity that requires communication with any member or employee
of a legislative body or with any government official or employee. Work activities covered by this policy include meetings with
legislators or members of their staffs or with senior executive branch officials on behalf of the Company. Preparation, research
and other background activities that are done in support of lobbying communication are also covered by this policy even if the
communication ultimately is not made. If any doubt exists about whether a given work activity would be considered covered by this
provision, you should seek advice immediately from your supervisor and the Company’s Chief Financial Officer (or the Company’s
Acting Chief Financial Officer, as the case may be).



7







Political Contributions and Volunteer Activities



The Company encourages
its employees and directors to participate in the political process as individuals and on their own time. However, federal and
state contribution and lobbying laws severely limit the contributions the Company can make to political parties or candidates.
It is Company policy that Company funds or assets not be used to make a political contribution to any political party or candidate,
unless prior approval has been given by the Company’s Chief Executive Officer or the Company’s Chief Financial Officer
(or the Company’s Acting Chief Financial Officer, as the case may be). The Company will not reimburse you for personal political
contributions. When you participate in non-Company political affairs, you should be careful to make it clear that your views and
actions are your own, and not made on behalf of the Company. Please contact the Company’s Chief Financial Officer (or the
Company’s Acting Chief Financial Officer, as the case may be) if you have any questions about this policy.



Compliance with Antitrust Laws



Antitrust laws of the
United States and other countries are designed to protect consumers and competitors against unfair business practices and to promote
and preserve competition. Our policy is to compete vigorously and ethically while complying with all antitrust, monopoly, competition
or cartel laws in all countries, states or localities in which the Company conducts business. Violations of antitrust laws may
result in severe penalties against the Company and its employees, including potentially substantial fines and criminal sanctions.
You are expected to maintain basic familiarity with the antitrust principles applicable to your activities, and you should consult
the Company’s Chief Financial Officer (or the Company’s Acting Chief Financial Officer, as the case may be) with any
questions you may have concerning compliance with these laws.



Meetings with Competitors



Employees should exercise
caution in meetings with competitors. Any meeting with a competitor may give rise to the appearance of impropriety. As a result,
if you are required to meet with a competitor for any reason, you should obtain the prior approval of an executive officer of the
Company. You should try to meet with competitors in a closely monitored, controlled environment for a limited period of time. You
should create and circulate agendas in advance of any such meetings, and the contents of your meeting should be fully documented.



Professional Organizations and Trade
Associations



Employees should be
cautious when attending meetings of professional organizations and trade associations at which competitors are present. Attending
meetings of professional organizations and trade associations is both legal and proper, if such meetings have a legitimate business
purpose and are conducted in an open fashion, adhering to a proper agenda. At such meetings, you should not discuss the Company’s
pricing policies or other competitive terms or any other proprietary, competitively sensitive information. You are required to
notify your supervisor or the Company’s Chief Financial Officer (or the Company’s Acting Chief Financial Officer, as
the case may be) prior to attending any meeting of a professional organization or trade association.



8







Compliance with Insider Trading Laws



Consistent with the
Company’s Insider Trading Policy, the Company’s employees and directors are prohibited from trading in the stock or
other securities of the Company while in possession of material nonpublic information about the Company. In addition, Company employees
and directors are prohibited from recommending, “tipping” or suggesting that anyone else buy or sell the Company’s
stock or other securities on the basis of material non-public information. Employees and directors who obtain material non-public
information about another company in the course of their duties are prohibited from trading in the stock or securities of the other
company while in possession of such information or “tipping” others to trade on the basis of such information. Violation
of insider trading laws can result in severe fines and criminal penalties, as well as disciplinary action by the Company, up to
and including termination of employment. You are required to read carefully and observe our Insider Trading Policy, as amended
from time to time. Please contact the Company’s Chief Financial Officer (or the Company’s Acting Chief Financial Officer,
as the case may be) for a copy of the Insider Trading Policy or with any questions you may have about insider trading laws.



Public Communications and Regulation FD



The Company employees
authorized to discuss the Company with the media are the Chief Executive Officer, Acting Chief Financial Officer, Vice President
Operations and any persons delegated by such officers to do so. All other employees must refer all media, analyst and investor
inquiries with respect to the Company to one of these authorized spokespersons. All Company communications shall comply with applicable
law, including SEC Regulation FD. Authorized spokespersons may not provide material information to the media, analysts or investors
unless such information has been, or is simultaneously, disclosed in a manner intended to provide broad, non-exclusionary distribution
to the public. In the event of an inadvertent disclosure of non-public information that may be material, the disclosing spokesperson
must immediately contact the Chief Executive Officer who, in consultation with the Company’s outside counsel, will determine
whether prompt public dissemination of such information is required. All employees, officers and directors shall read and be aware
of any information included within any Company policies concerning public communications and compliance with SEC Regulation FD.



Environment, Health and Safety



The Company is committed
to providing a safe and healthy working environment for its employees and to avoiding adverse impact and injury to the environment
and the communities in which it does business. Company employees and directors must comply with all applicable environmental, health
and safety laws, regulations and Company standards. It is your responsibility to understand and comply with the laws, regulations
and policies that are relevant to your job. Failure to comply with environmental, health and safety laws and regulations can result
in civil and criminal liability against you and the Company, as well as disciplinary action by the Company, up to and including
termination of employment. You should contact the Company’s Chief Executive Officer if you have any questions about the laws,
regulations and policies that apply to you.



9







Environment



All Company employees
and directors should strive to conserve resources and reduce waste and emissions through recycling and other energy conservation
measures. You have a responsibility to promptly report any known or suspected violations of environmental laws or any events that
may result in a discharge or emission of hazardous materials.



Health and Safety



The Company is
committed not only to comply with all relevant health and safety laws, but also to conduct business in a manner that protects
the safety of its employees. All employees and directors are required to comply with all applicable health and safety laws,
regulations and policies relevant to their positions. If you have a concern about unsafe conditions or tasks that present a
risk of injury to you, please report these concerns immediately to your supervisor or the Company’s Chief Financial
Officer (or Acting Chief Financial Officer, as the case may be).



Employment Practices



The Company pursues
fair employment practices in every aspect of its business. Company employees must comply with all applicable labor and employment
laws, including anti-discrimination laws and laws related to freedom of association and privacy. It is your responsibility to understand
and comply with the laws, regulations and policies that are relevant to your job. Failure to comply with labor and employment laws
can result in civil and criminal liability against you and the Company, as well as disciplinary action by the Company, up to and
including termination of employment. You should contact the Company’s Human Resources Department if you have any questions
about the laws, regulations and policies that apply to you.



Harassment and Discrimination



The Company is committed
to providing equal opportunity and fair treatment to all individuals on the basis of merit, without discrimination because of race,
color, religion, national origin, sex (including pregnancy), sexual orientation, age, disability, veteran status or other characteristics
protected by law. The Company also prohibits harassment based on these characteristics in any form, whether physical or verbal
and whether committed by supervisors, non-supervisory personnel or non-employees. Harassment may include, but is not limited to,
offensive sexual flirtations, unwanted sexual advances or propositions, verbal abuse, sexually or racially degrading words, or
the display in the workplace of sexually suggestive or racially degrading objects or pictures.



10







If you have any complaints
about discrimination or harassment, report such conduct to your supervisor or the Human Resources Department. All complaints will
be treated with sensitivity and discretion. Your supervisor, the Human Resources Department and the Company will protect your confidentiality
to the extent possible, consistent with law and the Company’s need to investigate your concern. Where our investigation uncovers
harassment or discrimination, we will take prompt corrective action, which may include disciplinary action by the Company, up to
and including, termination of employment. The Company strictly prohibits retaliation against an employee who, in good faith, files
a complaint.



Any member of management
who has reason to believe that an employee has been the victim of harassment or discrimination or who receives a report of alleged
harassment or discrimination is required to report it to the Human Resources Department immediately.



Alcohol and Drugs



The Company is committed
to maintaining a drug-free work place. All Company employees must comply strictly with Company policies regarding the abuse of
alcohol and the possession, sale and use of illegal substances. Drinking alcoholic beverages is prohibited while on duty or on
the premises of the Company, except at specified Company-sanctioned events or as otherwise authorized by management. Possessing,
using, selling or offering illegal drugs and other controlled substances is prohibited under all circumstances while on duty or
on the premises of the Company. Likewise, you are prohibited from reporting for work, or driving a Company vehicle or any vehicle
on Company business, while under the influence of alcohol or any illegal drug or controlled substance.



Violence Prevention and Weapons



The safety and security
of Company employees is vitally important. The Company will not tolerate violence or threats of violence in, or related to, the
workplace. If you experience, witness or otherwise become aware of a violent or potentially violent situation that occurs on the
Company’s property or affects the Company’s business you must immediately report the situation to your supervisor or
the Human Resources Department.



The Company does not
permit any individual to have weapons of any kind on Company property or in vehicles, while on the job or off-site while on Company
business. This is true even if you have obtained legal permits to carry weapons. The only exception to this policy applies to security
personnel who are specifically authorized by Company management to carry weapons.



Conclusion



This Code contains
general guidelines for conducting the business of the Company consistent with the highest standards of business ethics. If you
have any questions about these guidelines, please contact your supervisor or the Company’s Chief Financial Officer (or the
Company’s Acting Chief Financial Officer, as the case may be) or the Ethics Hotline by calling (424) 286-4122, or
emailing Chief Financial Officer (or the Company’s Acting Chief Financial Officer, as the case may be). The Company expects
all of its employees and directors to adhere to these standards.



11







This Code, as applied
to the Company’s principal financial officers, shall be our “code of ethics” within the meaning of Section 406
of the Sarbanes-Oxley Act of 2002 and the rules promulgated thereunder.



This Code and the matters
contained herein are neither a contract of employment nor a guarantee of continuing Company policy. The Company reserves the right
to amend, supplement or discontinue this Code and the matters addressed herein, without prior notice, at any time.



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