Employee Adherence to the Code

Employees are required annually to sign off on their acceptance and compliance with the Code. Additionally, as part of its annual re-training program, the Company conducts online training relating to its Code of Business Conduct and Ethics including specific modules on Navigating the Work Environment, Handling Company Resources and Managing Company Relationships. In addition to the Code, the Company?s Corporate Manual (available online at polarisrei.com) also addresses other aspects of ethical business practices including Insider Trading, Diversity among others.