Any employee who requests an exception to this Code of Conduct should obtain the exception, in writing, in advance, from the Chief Risk and Compliance Officer. No others are authorized to allow an exception.

Nothing in the Code of Conduct or other Winrock Policies and Procedures is intended to create an express or implied contract of employment. In the U.S. and other applicable countries, the maintenance of this Code does not modify the employment-at-will relationship that may exist between Winrock and its employees. Nothing in this Code creates a contractual obligation on the part of Winrock, nor does it expand any third party or employee legal rights or Winrock’s legal obligations.

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