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JIMMY CHAKART SEANCHAN

President and Chief Executive Officer

Discussions of ethics and integrity have become increasingly important in today’s business environment and operating with a strong sense of ethics and integrity is critical to maintaining trust and credibility with our employees, customers, vendors, partners, stockholders and the community.

This Code of Business Conduct reflects our commitment to ethical business practices and compliance with the law. The Code summarises some important principles and standards to guide our actions in business. All at Leadway are responsible for fully understanding and complying with the letter and spirit of this Code of Business Conduct as well as other Company policies and the laws and regulations that apply to our work. This Code outlines the broad principles of legal and ethical business conduct, it is not intended to be all encompassing. Rather, it is intended to serve as a guide to the most critically relevant areas.

We earn the trust and respect of the people and companies we associate with every day through the actions of every employee. Each of us must be committed to acting with integrity and honesty in everything we do, we must treat the people and companies with whom we associate with respect and fairness. We rely on everyone to uphold this commitment. Doing so will ensure that Leadway will remain a great place to work together with a well respected company to do business with.

Additional resources are available to help us meet our compliance obligations. Copies of some of the Company's other policies are available on the Leadway web-site or from the Human Resources Department. If anyone has any questions about the applicability or interpretation of the Code or any Company policy, they should seek advice from their supervisor, senior management, or the Company's Human Resources or Legal Departments.