1. Conflicts of Interest. A conflict of interest exists when a persons private interest interferes in any way with the interests of the Company. A conflict can arise when a Covered Party takes actions or has interests that may make it difficult to perform his or her work for the Company objectively and effectively. Conflicts of interest may also arise when a Covered Party, or members of his or her family, receive improper personal benefits as a result of his or her position at the Company. oans to, or !uarantees of obli!ations of, Covered Parties and their family members may create conflicts of interest. "t is almost always a conflict of interest for a Covered Party to work simultaneously for a competitor, customer or supplier. Conflicts of interest may not always be clear#cut, so if you have a $uestion, you should consult with your supervisor or mana!er or, if circumstances warrant, the chief financial officer or chief le!al officer of the Company. Any Covered Party who becomes aware of a conflict or potential conflict should brin! it to the attention of a supervisor, mana!er or other appropriate personnel or consult the procedures described in %ection & of this Code. All directors and executive officers of the Company ', and the chief executive officers and chief financial officers of (erkshire )athaways subsidiaries,* shall disclose any material transaction or relationship that reasonably could be expected to !ive rise to such a conflict to the Chairman of the Companys Audit Committee. +o action may be taken with respect to such transaction or party unless and until such action has been approved by the Audit Committee. ,. Corporate Opportunities. Covered Parties are prohibited from takin! for themselves opportunities that are discovered throu!h the use of corporate property, information or position without the consent of the (oard of -irectors of the Company. +o Covered Party may use corporate property, information or position for improper personal !ain, and no employee may compete with the Company directly or indirectly. Covered Parties owe a duty to the Company to advance its le!itimate interests whenever possible. .. Fair Dealing. Covered Parties shall behave honestly and ethically at all times and with all people. /hey shall act in !ood faith, with due care, and shall en!a!e only in fair and open competition, by treatin! ethically competitors, suppliers, customers, and collea!ues. %tealin! proprietary information, possessin! trade secret information that was obtained without the owners consent, or inducin! such disclosures by past or present employees of other companies is prohibited. +o Covered Party should take unfair advanta!e of anyone throu!h manipulation, concealment, abuse of privile!ed information, misrepresentation of material facts, or any other unfair practice. /he purpose of business entertainment and !ifts in a commercial settin! is to create !ood will and sound workin! relationships, not to !ain unfair advanta!e with customers. +o !ift or entertainment should ever be offered or accepted by a Covered Party or any family member of a Covered Party unless it 011 is consistent with customary business practices, 0,1 is not excessive in value, 0.1 cannot be construed as a bribe or payoff and 021 does not violate any laws or re!ulations. /he offer or acceptance of cash !ifts by any Covered Party is prohibited. Covered Parties should discuss with their supervisors, mana!ers or other appropriate personnel any !ifts or proposed !ifts which they think may be inappropriate. 2. Insider Trading. Covered Parties who have access to confidential information are not permitted to use or share that information for securities tradin! purposes 03insider tradin!41 or for any other purpose except the conduct of the Companys business. All non#public information about the Company should be considered confidential information. "t is always ille!al to trade in (erkshire )athaway securities while in possession of material, non#public information, and it is also ille!al to communicate or 3tip4 such information to others. 5hile all Covered Parties are prohibited from insider tradin!, (erkshire has adopted specific 3"nsider /radin! Policies and Procedures4 applicable to the Companys directors, executive officers and key employees 03-irectors and Covered &mployees41. /his document is posted on (erkshires website and is sent periodically to -irectors and Covered &mployees in connection with certification of compliance. 6. Confidentiality. Covered Parties must maintain the confidentiality of confidential information entrusted to them, except when disclosure is authori7ed by an appropriate le!al officer of the Company or re$uired by laws or re!ulations. Confidential information includes all non#public information that mi!ht be of use to competitors or harmful to the Company or its customers if disclosed. "t also includes information that suppliers and customers have entrusted to the Company. /he obli!ation to preserve confidential information continues even after employment ends.