ETHICS INTRODUCTION:


Hill Brothers Construction Co., Inc. is committed to being an ethical and responsible member of the business communities and has a long reputation for honesty and integrity in business dealings and lawful and ethical behavior. In order to maintain our commitment to integrity, we have established a Code of Ethics and Compliance Program.

The purpose of the Code of Ethics and Compliance (“the Code” or “this Code”) is intended to ensure that all of its employees abide by the Code and to follow in dealings of Hill Brothers Construction Co., Inc. and all its related business entities with the Government, the general public, customers, suppliers, vendors and employees, and to outline the requirements of its Ethics an Compliance Program (“the Program”). All officers, managers and supervisors are responsible for making this Code known and regularly stressing its importance to employees over whom they have supervision and, where applicable, to subcontractors to the extent of applicability. As an employee, you are expected to read both the Code and the Program and to certify your commitment to complying fully. No employee may take an action, on behalf of Hill Brothers Construction Co., Inc. that the employee knows or reasonably should know, would violate any law or regulation.

This Code provides guidelines of business practice, for both professional and personal conduct; all company employees are obligated and expected to adopt and uphold and to immediately report any violation or apparent violation of this Code or the Program. Employees may report violations to Hill Brothers Construction Co., Inc.’s CEO, to a Hill Brothers Construction Co., Inc.’s supervisor, or to Hill Brothers Construction Co., Inc.’s Corporate Ethics Officer, Sharon Goolsby at phone number 662-512-1225. In addition, employees may report incidents of suspected fraud or any illegal activity on the Fraud Hotline published on Hill Brothers Construction Co., Inc.’s website.

To administer this Program, I have appointed Sharon Goolsby as the Corporate Ethics Officer. She will responsible for implementing appropriate procedures and policies, ensuring that each of you will receive a copy of the Program and providing training on compliance with the Code.

Each of you is expected to alert Sharon Goolsby of any information you may have of unlawful or unethical behavior by any of our employees, prime contractors, subcontractors, suppliers, vendors or customers.

Hill Brothers Construction Co., Inc. determines at all times to maintain a system of internal controls that helps makes timely discovery of improper conduct, easier. And also, to make certain that corrective measures are promptly instituted and carried out in an effective manner.

Upon notice of a violation of this Code, the appropriate responsible supervisory personnel shall promptly initiate corrective measure and will be monitored for effectiveness by the Corporate Ethics Officer, Sharon Goolsby.

Hill Brothers Construction Co., Inc. will investigate all incidents reported to the fullest possible extent and will take appropriate action to address the situation.

Violations of this Code by any employee may result in disciplinary action up to and including discharge from Hill Brothers Construction Co., Inc. HBCC may apply such disciplinary measures to any employee who directs or approves of prohibited activities or who has knowledge of them and does not move promptly to correct and report them. Additional criminal or civil penalties may apply for violation of a federal, state or local regulation governing activities as outlined in this Code.

Supervisors are responsible for ensuring that employees are familiar with and complying with this Code and the Program. All employees with management, administrative or supervisory responsibilities who are employed in a full time position are expected to certify that you read and familiarized yourselves with this Code and with the Program by signing the certification form attached. In addition, all employees who are assigned to work on any Federal Contract in excess of $5,000,000 and with a performance period in excess of 120 days must certify that they have received ethics and compliance training which will include proof that they have received a copy of and have read and understand this Code.

Hill Brothers Construction Co., Inc. will not tolerate any form of unlawful or unethical behavior by any person or entity it is associated. Hill Brothers Construction Co., Inc. stresses that each employee conducts himself or herself in accordance with the laws and regulations that apply to our business and not condone criminal or unethical behavior by others.