Page 2 - QP code of ethics B

In QP we attach the utmost importance to conducting

business ethically. This is how we earned our reputation

and built a very successful organization over many years.

The world and QP have moved on significantly since we

first introduced the Code of Ethics and Conflict of Interest

Regulations (the “Green Book”) nearly 17 years ago. The

key business principles established under the Green Book

have served us well, but as we grow our business at home

and abroad, we needed to update the Green Book to more

accurately reflect the current business environment. The

Code of Ethics in front of you (the “Code of Ethics” or the

“Code”) is the result of this work and replaces the Green Book.

The Code of Ethics is the foundation for many policies in QP. The

Code provides employees and others with requirements and

guidance on how to behave while conducting QP’s business.

The Code is not optional. Results do matter, but so does the way

in which we achieve those results. I expect everyone to comply

with the Code and speak up if they witness or suspect

unethical or other behavior incompatible with

the provisions and spirit of the Code.