CODE OF CONDUCT

Every member at Klein Financial Corporation commits to conduct themselves with integrity and honesty when working with clients, residents, investors and each other; treating everyone with respect and recognizing the value and contribution of each individual. We never sacrifice our commitment to excellence. We always design and structure every development to deliver the highest value to the residents. We, also, respect and honor the goals and interests of our investors and protect their interests and capital with the same intense commitment as our own. We dedicate ourselves to learning everyday how we can improve our products, our business, and our service to the communities in which our residential developments are located. We dedicate ourselves to the health and safety of our residents and of our team members.