Encouraging the Reporting of any Illegal or Unethical Behavior

The Company is committed to operating according to the highest standards of business conduct and ethics and to maintaining a culture of ethical compliance. Directors and officers should promote an environment in which the Company:

• encourages directors, officers and employees to talk to supervisors, managers, and other appropriate personnel when in doubt about the best course of action in a particular situation;
• encourages directors, officers and employees to report violations of laws, rules, and regulations to appropriate personnel; and
• informs directors, officers, and employees that the Company will not allow retaliation for reports made in good faith.

If an employee, officer or director believes that he or she has been discharged, disciplined or otherwise penalized for reporting a violation in good faith, he or she should immediately report that belief in writing to J. Kent’s President.  Reporting the violation will be treated as confidential. Violations of this Code will be investigated by a person or persons designated by J. Kent’s President, and appropriate disciplinary action will be taken in the event of a violation.

An employee, officer or director who is unsure of whether a situation violates this Code should discuss the situation with J. Kent’s President to prevent possible misunderstandings at a later date. Any director, employee or officer who becomes aware of any existing or potential violation of laws, rules, regulations or this Code is required to notify J. Kent’s President promptly. Failure to do so is itself a violation of this Code. To encourage directors, officers and employees to report any violations, the Company will not allow retaliation for reports made in good faith of any violations of this Code, up to and including termination.