THE MIDLANDS COMPANIES

Statement of Ethics

As employees of Midlands, its subsidiaries and affiliates we hereby recognize that the overall corporate ethics of Midlands is to be "beyond reproach" in all of our dealings with our clients, community, vendors and fellow employees. In keeping with this ethical mandate we agree to the following:

• We will act in the utmost good faith while dealing fairly and equitably with all parties involved in any transaction.
• We will maintain confidentiality of all business transactions and information held in trust on behalf of our clients and fellow employees.
• We will communicate with clients any potential conflict situations and at all times avoid situations whereby the interest of our clients and the interest of Midlands do not coincide.
• We will continue to enhance our technical skills essential to the individual employees position within the Midlands Group through continuing education programs fully supported by Midlands.
• We will strictly adhere to all statutory and regulatory requirements within our industry and keep fully informed of revisions regarding same.
• We will treat all parties with respect, fairness and honesty while pursuing an ideal of service that transcends self interest.