Phoenix Aviation Managers is committed to conducting its business in compliance with applicable laws and regulations and in accordance with high standards of business conduct. In managing its business, the Company is mindful of the public trust with which it is vested. The Company strives to maintain high standards of accuracy, completeness and disclosure in its financial dealings, records and reports. These standards are intended to protect and serve the multiple interests of policyholders and the beneficiaries of their insurance policies, as well as those of the Company's employees, Parent Company and other stakeholders. To these ends, Phonenix Aviation Managers adheres to the Code of Conduct and Ethics adopted by all members of the Old Republic International Corporation family of companies.