Code of Ethical Conduct
At Putney, we believe that the ethical and legal conduct of our business, in accordance with our Core Values, is essential to our success. The ethical conduct of our business is not only a legal necessity but in and of itself a Core Value of our company. We place an exceedingly high value in conducting our affairs in an ethical manner and further believe that the ethical conduct of our business is fundamental to our growth, our ability to create value for our shareholders and customers and to the creation of opportunities for each of us to grow individually as members of the Putney team. All of us, whether officers, employees or members of the Board of Directors of Putney, are required to comply with the law and to conduct Putney's business in an ethical manner that is consistent with our Core Values as a company.