Commitment and dedication to ethical professional conduct is expected of all employees in every aspect of our business practices. Our company is judged by how its' employees act. Therefore, upholding the Turner reputation is paramount. This reputation will be upheld only if we act with honesty and integrity in all business practices. Maintaining the trust and confidence of owners, employees, customers and other people with whom we conduct business, as well as the communities in which we work, is crucial to our continued growth and success.

This Code shall serve as a basis for ethical decision-making in the performance of work for this Company. Additionally this code may serve as a basis for judging the merit of a formal complaint pertaining to violations of professional ethical standards contained herein. It is understood that some words and descriptions in a code of ethics and professional conduct are subject to varying personal interpretations, and that any ethical principle may conflict with other ethical principles in specific situations.

Compliance with this Code:

The future of our Company depends on our operational, administrative and ethical excellence. All employees should adhere to the principles of this code as well as encourage and support adherence to these principles by their co-workers. Our compliance policies and this Code are all aimed at avoiding unethical conduct as well as possible violations of laws. Each employee has an obligation to seek clarification and advice whenever a question concerning compliance with this Code arises. Such advice may be sought from management, from the Ethics Committee or from our internal Risk Management, Legal, Audit or Human Resources departments. Our long-term success in this area will depend on each employee’s realizing our Company’s commitment to this Code, seeking advice before engaging in conduct that presents legal or ethical questions, and proceeding with business in a professional and ethical manner.

Reporting Possible Violations of this Code:

If an employee feels that they have a good faith report of behavior that they believe to be a violation of this Code they are required to make such report to the Turner Ethics Committee at 1-800-288-6503. Any attempt at retaliation or intimidation against anyone reporting in good faith, a suspected violation of this Code or against anyone who participates in an investigation of a suspected violation will not be tolerated. Once a report of a possible violation of this Code is made, a prompt investigation will be conducted by the Turner Ethics Committee. Our Company strives to consistently and appropriately enforce this Code. Violators of this Code are subject to disciplinary action up to and including termination. In certain cases, where appropriate, law enforcement officials will be informed of facts discovered by any internal investigation concerning non-compliance with laws.

In addition to this Code, Company and site specific policies and procedures are detailed in your employee handbook. It is the responsibility of every employee to perform his or her job in a manner that is in strict compliance with all Company policies, procedures and Codes.