SHANGRI-LA PAZHOUHUMAN RESOURCES POLICY & PROCEDURE MANUALSUBJECT CODE OF ETHICSPREPARED BY:FRANK ZHANGREVIEWED BY:DATE PREPARED:Sept. 28, 2005EFFECTIVE DATE:August 08, 2005 APPROVED BY:ROBERT A. BORMESPOLICY NO.:HR / P / 007DISTRIBUTION:DIVISION HEADSPAGE NO.:1 OF 1 DEFINITION- The Code of Ethics is a document outlining Shangri-Las requirements and expectations with regard to the conduct and ethics to be adopted in dealing with our customers, employees, suppliers, owners and communities. GUIDELINES1. It is required that all Management employees, and others as appropriate will sign a copy of the Code of Ethics upon commencement of employment, or upon promotion or transfer to a covered position. 2. The original dated copy should be retained on the employees personal file, with the employees signature on the last page, and initials on the other pages. A photocopy should be issued to the employee for reference. 3. The Code of Ethics should be signed by the below eligible employees on a yearly basis.4. The eligible employees are:- General Manager- All Management Staff (Level 1 Level 3)- All other employees in Finance / Purchasing / Receiving department.- All other employees in Reception / Concierge / Transportation.