Conflict of Interest

Goodwind Development Corporation expects all employees to conduct themselves and
 company business in a manner that reflects the highest standards of ethical conduct and in
 accordance with all federal, state, and local laws and regulations. This includes avoiding real and
 potential conflicts of interests.

Exactly what constitutes a conflict of interest or an unethical business practice is both a moral
 and a legal question. Goodwind Development Corporation recognizes and respects the
 individual employee’s right to engage in activities outside of employment that are private in
 nature and do not in any way conflict with or reflect poorly on the company.

It is not possible to define all the circumstances and relationships that might create a conflict of
 interest. If a situation arises in which there is a potential conflict of interest, the employee should
 discuss this with a manager for advice and guidance on how to proceed. The list below suggests
 some of the types of activities that indicate improper behavior, unacceptable personal integrity,
 or unacceptable ethics:
1. Simultaneous employment by another firm that is a competitor of or supplier to
 Goodwind Development Corporation;
2. Carrying on company business with a firm in which the employee, or a close relative of
 the employee, has a substantial ownership or interest;
3. Holding a substantial interest in, or participating in the management of, a firm to which
 the company makes sales or from which it makes purchases;
4. Borrowing money from customers or firms, other than recognized loan institutions, from
 which our company buys services, materials, equipment, or supplies;
5. Accepting substantial gifts or excessive entertainment from an outside organization or
 agency;
6. Speculating or dealing in materials, equipment, supplies, services, or property purchased
 by the company;
7. Participating in civic or professional organization activities in a manner that divulges
 confidential company information;
8. Misusing privileged information or revealing confidential data to outsiders;
9. Using one’s position in the company or knowledge of its affairs for personal gains; and
10. Engaging in practices or procedures that violate antitrust laws, commercial bribery laws,
copyright laws, discrimination laws, campaign contribution laws, or other laws regulating
 the conduct of company business.