CODE OF
CONDUCT

Build Trust and Credibility

The success of our business is dependent on the trust and confidence we earn from our employees, customers, and stakeholders. We gain credibility by adhering to our commitments, displaying honesty and integrity, and reaching Company goals solely through honorable conduct.

Treat Others with Respect

We will not tolerate discrimination, harassment or any behavior or language that is abusive, offensive, or unwelcome. All employees are expected to support an inclusive workplace by adhering to the following:

1. Treat others with dignity and respect always.
2. Address and report inappropriate behavior and comments that are discriminatory, harassing, abusive, offensive, or unwelcome.
3. Seek out insights from employees with different experiences, perspectives, and backgrounds.

Avoid Conflicts of Interest

You should avoid any situation which involves or may involve a conflict between your personal interest and the interest of the Company. As in all other facets of your duties, when dealing with customers, suppliers, contractors, competitors, or any person doing or seeking to do business with the Company, you are expected to act in the best interest of the Company. You shall make prompt and full disclosure in writing to your supervisor of any potential situation which may involve a conflict of interest. Such conflicts include:

1. You or a close family member being employed by, or acting as a consultant to, a competitor or potential competitor, supplier, or contractor, regardless of the nature of the employment, while you are employed with BRG.
2. Hiring or supervising family members or closely related persons.
3. Serving as a director, officer, partner, consultant, or in a managerial or technical capacity with an outside enterprise which does or is seeking to do business with or is a competitor of the Company. Exceptions to this can be approved by the President of BRG.
4. Acting as a broker, finder, go-between or otherwise for the benefit of a third party in transactions involving or potentially involving the Company or its interests.
5. Any other arrangements or circumstances, including family or other personal relationships, which might dissuade the associate from acting in the best interest of the Company.

Gifts, Favors, and Payments

Gifts, favors, and payments may be given to others at Company expense, if they meet all the following criteria:

1. They are consistent with accepted business practices
2. They are of sufficiently limited value and in a form that will not be construed as a bribe or payoff
3. They are not in violation of applicable law and generally accepted ethical standards; and Public disclosure of the facts will not embarrass the BRG or its clients

Employees who negotiate or award contracts, or who can influence the allocation of business, must be particularly careful to avoid actions that create the appearance of favoritism or that may adversely affect the Company’s reputation for impartiality and fair dealing. The prudent course is to refuse a courtesy from a supplier when BRG is involved in choosing or reconfirming a supplier or under circumstances that would create an impression that offering courtesies is the way to obtain BRG’s business.

Protect Confidential Information

Employees must not disclose any confidential information, purposefully or inadvertently through casual conversation, to any unauthorized person inside or outside of BRG. The revelation or use of any confidential product information, data on decisions, plans, or any other information which might be contrary to the interest of BRG without prior authorization, is prohibited. Employees who are unsure about the confidential nature of specific information must ask their supervisor for clarification. Employees will be subject to appropriate disciplinary action, up to and including termination, for knowingly or unknowingly revealing information of a confidential nature.

Report Results Accurately

We will make sure that all disclosures made in financial reports and public documents are full, fair, accurate, timely, and understandable. No business goal of any kind is ever an excuse for misrepresenting facts or falsifying records. Inform management if you learn that information in any filing or public communication was untrue or misleading at the time it was made.

Do the Right Thing

When considering an action, ask yourself the following questions to help identify whether a situation may be unethical, inappropriate, or illegal:

• Does what I am doing comply with BRG policies?
• Have I been asked to misrepresent information or deviate from normal procedure?
• Would I feel comfortable describing my decision at a staff meeting?
• How would it look if it made the headlines?
• Am I being loyal to the Company?
• Is this the right thing to do?