This Code of Ethics for Financial Professionals (the “Code of Ethics”) applies to the Chief Executive Officer, Chief Financial Officer and all professionals worldwide serving in finance, accounting, treasury, tax or investor relations role atABC Enterprises, Inc. (“ABC”).ABC expects all of its employees to act in accordance with the highest standards of personal and professional integrity in all aspects of their activities. ABC therefore has existing Codes of Ethics and Business Conduct applicable to all directors, officers and employees of ABC. In addition to the Codes of Ethics and Business Conduct, the CEO, CFO and all other financial professionals are subject to the following additional specific policies: As the Chief Executive Officer, Chief Financial Officer, or another financial professional, I agree to:

a. Engage in and promote honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;

b. Avoid conflicts of interest and to disclose to the General Counsel any material transaction or relationship that reasonably could be expected to give rise to such a conflict;

c. Take all reasonable measures to protect the confidentiality of non-public information about ABC or its subsidiaries and their customers obtained or created in connection with my activities and to prevent the unauthorized disclosure of such information unless required by applicable law or regulation or legal or regulatory process;

d. Produce full, fair, accurate, timely, and understandable disclosure in reports and documents that ABC or its subsidiaries files with, or submits to, the Securities and Exchange Commission and other regulators and in other public communications made by ABC or its subsidiaries;

e. Comply in all material respects with applicable governmental laws, rules, and regulations, as well as the rules and regulations of the New York Stock Exchange and other appropriate private and public regulatory agencies; and

f. Promptly report any possible violation of this Code of Ethics to the General Counsel or any of the parties or through any of the channels described in ABC’s Whistleblower Policy.

I understand that I am prohibited from directly or indirectly taking any action to fraudulently influence, coerce, manipulate or mislead ABC or its subsidiaries’ independent public auditors for the purpose of rendering the financial statements of ABC or its subsidiaries misleading.

I understand that I will be held accountable for my adherence to this Code of Ethics. My failure to observe the terms of this Code of Ethics may result in disciplinary action, including termination of employment. Violations of this Code of Ethics may also constitute violations of law and may result in civil and criminal penalties against me, my supervisors, and/or ABC.

Any questions regarding the best course of action on a particular situation should be directed to the General Counsel. Please be aware that ABC’s Whistle blower Policy provides the option to remain anonymous in reporting any possible violation of the Code of Ethics.

Questions

1. ABC Enterprises has created multiple codes of conduct applicable to different groups of employees. Why wouldn’t they create just one code of conduct, applicable to everyone in the company?

2. Who, specifically, has agreed to follow the “Code of Ethics for Financial Professionals”?

3. How is ABC helping to prevent white-collar crime within its company by defining and clarifying appropriate and inappropriate behavior in its codes of conduct?