The compliance commitment in this Code extends to all matters, including decisions relating to trade, investment, subcontracting, supplying, business development, and in all other business and employment relationships. TWL Corporation's approach to implementing this Code of Conduct will be active, open and ethically sound. Although difficult questions of interpretation may arise in specific instances, particularly regarding the need to sensitively balance local customs and requirements with global standards and guidelines, Trinity recognizes that the above commitment means that TWL Corporation will do its utmost to identify ethical, legal, environmental, employment, and human rights issues and resolve matters consistent with this Code of Conduct.

It is the responsibility of each TWL Corporation employee to promote this Code. Questions about the application or meaning of any provisions of this Code, or potential violations of the Code are to be reported to superiors. Where serious allegations are concerned, fair and comprehensive investigations will be conducted by those human resource personnel, security and line management closest to the issue. If this is inappropriate, more senior managers or global heads of these functions should be notified. Acts inconsistent with this Code must be promptly corrected and are subject to disciplinary action up to and including termination of employment. TWL Corporation will ensure that there will be no adverse work-related consequences as a result of an employee bringing complaints of violations of this Code.

Any complaints or concerns about violation of this code can be voiced by leaving a message at the toll-free number below for our independent Audit Committee Chairman, with assurance of confidentiality.

Audit Contact: auditchair@twlk.com