Outlook, with its affiliated corporations (together, the Company), expects all of its officers, directors and associates to maintain high ethical standards and to adhere to the policies described in the Associate Handbook that are based on our “Basic Principles” and “Values.”

Basic Principles
Principles are the personality of the Company. They are:

• Focus on the situation, issue, or behavior - not the person.

• Maintain self-confidence and self-esteem of others.

• Maintain constructive relationships.

• Take initiative to make things better.

• Lead by example.

  - Achieve Global™

Values
Values are the behaviors we give while living those principles out loud. They are:

• Clients: Building a foundation to achieve dynamic growth through client focus.

• Improvement: Continuously improve the quality and timing of everything we do.

• Integrity: Commit to mutual trust and conduct consistent with the highest ethical standards in all relationships.

• People: Create the environment and opportunities for Associates to maximize talents and contributions/recognize and celebrate successes.

• Performance: Pursue ambitious performance and profit goals with relentless determination.

• Safety: Safety will not be compromised.

• Teamwork: Work together to achieve shared goals.

• Learning: Aggressively seek out and implement best practices and learn from one another.

• Risk Taking: Challenge established practices; take calculated risks.

• This Code of Ethics (the Code) is intended to supplement and enhance the policies which are included in the Associate Handbook. The Code is designed to deter wrongdoing and to promote:

• Honest and ethical conduct;

• Full, fair, accurate, timely and understandable disclosure;

• Compliance with applicable laws and regulations;

• Timely internal reporting of violations of the code; and

• Accountability for adherence to the code.

Conduct
The Company expects all of its officers, directors and associates to conduct themselves in accordance with the highest possible standards.

• All conduct by Company officers, directors and associates with Company stakeholders is to be characterized by honesty, integrity and dignity.

• Honesty is complete and full adherence to the truth; integrity includes the dissemination of truthful information and full disclosure of relevant facts, irrespective of the consequences; dignity relates to treating all stakeholders in a fair, ethical and respectful manner.

• Stakeholders of the Company include its shareholders, other associates, customers, vendors, geographic neighbors, business partners and regulators.

• Directors and officers in particular are to serve as a role model of honest and ethical behavior for other Company associates and for the community as a whole. In a similar manner, all associates are expected to maintain the same kind of honest and ethical behaviors.

Conflicts
All officers, directors and associates of the Company owe a high degree of loyalty to the Company. In conducting Company affairs, it is critical that they look at the interest of the Company, not their personal interests.

• Actual conflicts of interest are to be avoided. A conflict of interest may incur any time when you or a family member, or an organization in which you or a family member have an ownership stake or another financial or employment interest, does business with the Company.

• Actions that could be perceived to be a conflict of interest are also to be avoided.

• All other associates should disclose any situations, and discuss such actions, with the Chief Executive Officer, Chief Operating Officer or Chief Financial Officer and obtain pre-approval from one of them, if it is deemed necessary. All associates are encouraged to discuss any items they might question.

• Gifts

• Some of the companies that supply goods and services to us have a practice of providing gifts to their clients as a token of their appreciation for the business that we provide to them. We recognize that such a practice is common, but do not feel that it is fair that some of our associates should be able to benefit from such a practice and not others.

• We require that any gifts with more than a nominal value that are received as representatives of the Company must be turned over to the Company. The Company will redistribute any such gifts at Company sponsored social events so that each and everyone might have an equal chance to share these gifts.

• Similarly, if you are invited to an event that is not directly business related and more than a nominal value, your participation should be pre-cleared under the rules applying to other conflicts of interest.

• The Company is committed to providing full and fair disclosure to shareholders, the securities marketplace and potential investors, in compliance with the letter and spirit of securities laws and the rules of the exchange on which our securities trade.

• The Chief Financial Officer and Chief Executive Officer are primarily responsible for initiating, maintaining, assessing and periodically reviewing the continued adherence to necessary internal controls to assure that transactions of the Company are properly authorized, reviewed and reported in the accounts and that assets are safeguarded from improper use. All other officers, directors and associates are to assist the Chief Financial Officer and Chief Executive Officer as their duties require and as requested to help assure full and fair disclosure.

• Transactions are to be reported in conformance with generally accepted accounting principles on a basis consistent with prior years. Any exceptions are to be properly and completely disclosed. All associates are required to comply with these controls and practices.

Confidentiality and Inside Information
The Company takes very seriously its obligation of confidentiality, both as to internal information and customer information.

• If you are aware of material non-public information relating to the Company, you are prohibited by Company policy from directly or indirectly disclosing such information to any other persons.

• It is difficult to describe exhaustively what constitutes “material” information, but you should assume that any information, positive or negative, which might be of significance to an outsider. Examples include a potential business acquisition, internal financial information, important product developments, the acquisition or loss of a major client, or an important financing transaction. This list is merely illustrative.

• Confidentiality of our information. Serious problems could be caused for the Company by unauthorized disclosure of internal information about the Company.

• Officers, directors and associates should not discuss internal Company matters or developments with anyone outside of the Company, except as required in the performance of regular corporate duties. This prohibition includes inquiries about the Company, which may be made by the financial press or others in the financial community.

• It is important that all these communications on behalf of the Company be through an appropriately designated officer. Unless you are expressly authorized to the contrary, if you receive any inquiries of this nature, you should decline any comment and refer the inquirer to the Chief Financial Officer.

• Confidentiality of customer information. Similarly, we often have access to confidential information of our customers, and we are frequently under a legal or contractual obligation to safeguard that information. Officers, directors and associates must keep that information confidential, as if it were our own confidential information.

• Questions? Associates with questions regarding the confidentiality of information should discuss the questions and obtain pre-approval, if needed, from the Chief Financial Officer, Chief Operating Officer. Directors and Executive officers should discuss any such questions with the Audit Committee or with the independent Directors and obtain pre-approval, if needed. Do not try to resolve uncertainties on your own.

Compliance
The Company takes compliance with its legal obligations very seriously, and we expect our officers, directors and associates to do the same.

• All officers, directors and associates shall comply with all legal obligations when conducting Company business.

• Directors and officers, who are to set an example for compliance, shall themselves comply with the appropriate requirements of federal, state and local governments and other private and public regulatory agencies and communicate requirements to all affected associates.

• All associates are required to comply with all appropriate rules and regulations applicable to their jobs.

• Reporting Violations

• The matters which we cover in this Code of Ethics are very important. We therefore need the cooperation of all officers, directors and associates to make sure that the Company lives up to the highest ethical standards.

• Associates should promptly report any perceived violations, or any situation that could reasonably be expected to result in a violation, of this code, Company policy, governmental laws, regulatory requirements or business ethics to the Chief Financial Officer or the Chief Executive Officer.

• No action shall be taken against any individual who in good faith reports a violation or a perceived violation, even if the reporting is ultimately determined to be incorrect.

• To help us follow up on relevant information, reports which include your name are helpful to the Company. However, if you do not feel that you can or want to identify yourself when making your report, you may provide anonymous reports by contacting a professional representative from Outlook-CAP (Confidential Assistance Program) at 800-236-7605, which will pass information on an anonymous basis to appropriate management representatives.

Accountability
The Company expects strict compliance with this Code of Ethics and with other Company policies. Failure to comply with this Code of Ethics, or failure to report a potential violation by others will be considered a matter of extreme seriousness and may result in disciplinary action, including termination and/or legal action.