Statement of Integrity 
Burley Stabilization Corporation ("BSC") is committed to conducting business according to the highest standards of ethical integrity and legal compliance and in a financially accountable manner. This document outlines the commitment to which all persons and institutions affiliated with BSC are expected to comply. This document is a foundation from which to operate rather than a detailed set of guidelines. As laws and rules change, BSC provides additional training and education to all in its organization to ensure that we can continue to maintain these highest standards. Our reputation and future is based on our conducting all transactions with our stakeholders and customers in an open, responsive manner in accordance with these standards. 

Mission 
BSC's mission is to support producer sustainability by operating a financially efficient organization engaged in the development of reliable markets by supplying quality tobacco at a price value to customers worldwide. 

Core Values 

• Honesty and Integrity: Doing what we say.

• Willing to Act: Responding to grower and customer needs.

• Flexibility: Changing to adapt.

• Strong Relationships: Focusing on those activities that make our customers and growers successful.

• Reliability: Providing stability and opportunity to our customers and growers. 

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Focused Business Strategies 

• Striving for consistent and fair treatment of our grower suppliers. 

• Implementation of good agricultural practices that result in a high quality product, ensure worker safety and protect and enhance the environment.

• Maintaining systems that allow product traceability from the farm to the end user with a concurrent focus on product cleanliness.

• Supplying a product of consistent quality. 

Responsibility 
BSC maintains accountability and a responsibility to all segments of the industry we are associated with, from the growers we contract with to the customer base we serve. Our trained staff maintains participation with organizations such as International Tobacco Growers Association (ITGA), Tobacco Merchants Association (TMA), Coresta, Tobacco Workers Conference (TWC), Tobacco Science Research Conference (TSRC), and GAP Connections to keep involved and informed of developments in all segments of the industry. This enables us to ensure that our growers are informed and in compliance with changing needs of the industry. We conduct in-house training of personnel as well as conduct grower meetings to ensure that our suppliers are informed and using the best agricultural practices to provide the highest quality leaf. Additionally we support and collaborate with University Research and Extension personnel in meetings and educational programs that reach out to all tobacco growers. Many issues confronting the tobacco leaf industry are community concerns rather than unique to BSC; we are as committed to dealing with community wide production issues as we are to those directly affecting us. 

The value of our company is not based on our holdings, sales, or financial statement but rather on our relationships with our farmer/suppliers, employees, customers and the positive ways we can interact within our local communities. "Good corporate citizen" is the foundational tenet in all our interactions. 

Ethics 
The success of our business is dependent on the trust and confidence we earn from our employees, customers and shareholders. We gain credibility by practicing honesty and integrity and reaching company goals solely through honorable conduct. 

Commitment to integrity begins with complying with all laws, rules and regulations where we do business. 

BSC strives to create an environment where everyone feels comfortable to share ideas and concerns with management, particularly with respect to ethics concerns. BSC management and employees have a responsibility to create an open and supportive environment where employees feel comfortable raising such questions. We encourage employees to exercise their ability to prevent mistakes or wrongdoing by asking the right questions to the appropriate individuals. 

BSC will investigate all reported instances of questionable or unethical behavior. In every instance where improper behavior is found to have occurred, BSC will take appropriate action. We will not tolerate retaliation against employees who raise genuine ethics concerns in good faith. 

BSC is committed to competing solely on the merit of our products and services. We are dedicated to ethical and fair competition in the marketplace. We will sell the highest quality tobacco based on its merit, superior quality and competitive pricing. We will not offer or solicit improper payments or gratuities in connection with the purchase of goods or services. 

We must avoid any relationship or activity that might impair, or even appear to impair, our ability to make objective and fair decisions when performing our jobs. 

We should avoid any actions that create a perception that favorable treatment of outside entities by BSC was sought, received or given in exchange for personal business courtesies. Business courtesies include gifts, gratuities, hospitality, meals, or entertainment or other benefits from persons or companies with whom BSC does or may do business. We will neither give nor accept business courtesies that constitute, or could reasonably be perceived as constituting, unfair business inducements that would violate law, regulation or polices of BSC or customers, or would cause embarrassment or reflect negatively on BSC's reputation. 

Equal Opportunity 
BSC is committed to equal employment opportunity to the extent required by law for all individuals, without regard to race, religion, color, national origin, sex, disability/handicap, age, genetic information, or any other characteristic protected by law. This applies to all employment practices, including hiring, promotions, training, disciplinary action, termination, and benefits. BSC will make reasonable accommodations for qualified individuals with disabilities as defined by the ADA. 

All employees are expected to show respect and sensitivity toward all other employees, and to demonstrate a commitment to BSC's equal opportunity objectives. Employees can raise concerns and make reports without fear of reprisal. 

BSC is committed to providing a work environment that is free of unlawful discrimination and harassment. The Company expressly prohibits any form of unlawful discrimination and/or harassment based on an individual's race, color, religion, national origin, sex, disability/handicap, age, genetic information, or any other characteristic protected by law. All employees of BSC will be expected to comply with this policy. 

Health and Safety 
Safety training is provided by certified and trained personnel for all tasks performed by employees. Provisions are in place for supervisors to monitor expected safety standards. Part of the employee training includes providing the person to contact and procedure to follow if there is a situation an employee may consider unsafe or what to do in the event of an accident. Any employee concern or accident is investigated and appropriate remediation is taken if necessary. 

Our safety concerns extend to our farmer suppliers. We conduct and/or fund meetings and programs which address safety issues for farmers and their employees. GAP Connections has taken a strong initiative in this area and our working through the formation of that organization as well as becoming a Charter Member demonstrates our commitment to this aspect of grower safety. 

Green Tobacco Sickness ("GTS") has been a recurring problem on tobacco farms. Through educational programs farmers are more aware of the potential seriousness of GTS for some employees. Growers receive training as part of their annual GAP educational meetings on how to implement practices to minimize employee exposure to the risk of GTS and how to identify and handle those cases where an employee may suffer the symptoms. 

Environment 
Environmental responsibility extends beyond legal compliance with all laws, rules and regulations. On the farm, our supplier level, all growers are expected to comply with all applicable laws regarding land conservation, crop protective agents (CPAs) and any other hazardous materials used on the farm (not just those laws applying to tobacco production.) Audits, both internal and third party and informal farm visits are used to ensure compliance. Violations are identified and if not properly remediated are grounds for production contract termination. 

We strongly encourage the use of Integrated Pest Management practices to minimize unnecessary practices or CPA usage that would take away from the high standards of land stewardship we expect. We work collaboratively with University and USDA personnel as well as independently to support and conduct the types of educational programs that provide our farmer suppliers the tools they need to meet the same high standards we maintain.