CODE OF ETHICS AND COMPLIANCE

The Beaver Excavating Company is committed to providing a work environment that is professional, respectful, and free from discrimination, harassment, violence, criminal, or unethical behavior.

The Beaver Excavating Company has established a Code of Ethical Conduct and Corporate Compliance Program which is intended to identify the standards our employees, vendors, and subcontractors are expected to follow whenever conducting business. It is everyone’s responsibility to promptly report any concerns or incidents to which he/she is subject, that he/she witnesses, or to which he/she becomes aware.

Reports and concerns will be promptly investigated, and the Company will maintain confidentiality during the investigation to the maximum extent possible under the circumstances.

Where a violation has been substantiated, the Company will act promptly to eliminate the conduct and impose appropriate corrective action. For violations involving non-associates such as contract workers, guests, customers, vendors, and consultants, the Company reserves the right to terminate any contract or other legal relationship with the offending third party or deny that third party continued access to Company premises.

The Company prohibits any form of actual or attempted retaliation against any person for making a report in good faith about a potential violation or concern or for assisting in any investigation.

Reports and concerns can be addressed to the attention of the Corporate Compliance Officer at The Beaver Excavating Company, P.O. Box 6059, Canton, Ohio 44706.