All Employee and Board of Directors Code of Ethics
Northern Initiatives

Purpose
Each year, Northern Initiatives (the Corporation) employees (collectively, the “Employees”) and Directors have an obligation to the Corporation and themselves to maintain the highest standards of ethical conduct.  These individuals are empowered to ensure that the interests of shareholders, customers, employees, suppliers, and citizens of the communities we serve are appropriately balanced, protected and preserved by the Corporation.

Accordingly, the Board of Directors of the Company has adopted this Code of Ethics (the “Code”).

The Code provides fundamental principles which the Employees and Directors are expected to adhere to and advocate.  These principles are designed to deter wrongdoing and to promote:

• Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;
• Full, fair, accurate, timely and understandable disclosure in reports and documents that the Corporation files with, or submits to regulatory bodies, shareholders or other public communications made by the Corporation;
• Compliance by the Corporation with applicable governmental laws, rules and regulations;
• Good faith, due care, competence, diligence and objectivity, without misrepresenting material facts or allowing independent judgment to be subordinated;
• Respect for the confidentiality of information acquired in the course of employment;
• Avoidance of the use of any of the Corporation’s information or that of its customers for personal advantage;
• The prompt internal reporting of transactions or circumstances believed to be in violation of this Code to an appropriate person or persons identified in the Code;
• The retention or proper disposal of the Corporation’s records in accordance with established records retention policies and applicable legal and regulatory requirements;
• Accountabilityfor adherence to the Code;
• Achieve responsible use of and control over all assets, resources and information entrusted to them;
• For supervisors, engage in and promote honest and ethical conduct among employees under their supervision and throughout the Corporation.

This Code supplements and reflects the corporate values stated in the Corporation’s Employee Handbook.  Employees and Directors are expected to abide by the Employee Handbook, this Code and all other applicable policies and guidelines of the Corporation referred to in the Corporation’s Employee Handbook.

Financial Reporting and Disclosure
Employees and Directors will seek to promote fair, accurate, timely and understandable disclosure by the Corporation in the reports and documents it files with or submits to regulatory bodies, shareholders and the general public.  Employees and Directors shall seek to promote ethical behavior by other Officers and Employees of the Corporation involved in financial reporting.

Consequences of Violations
Any violation of this Code may result in disciplinary action up to and including suspension, termination of employment or resignation from the Board of Directors.

Reporting of Violations
Any Employee or Director who becomes aware of actual or potential infractions of this Code or who has concerns regarding questionable accounting or auditing matters involving the Corporation or any Employee or Director should communicate that concern directly to the toll-free Ethics Hotline at (800) 932-5378, any time of day or night.  An operator is available to take your report and direct it to the appropriate person for investigation and response.  This service is confidential and anonymous.

Requests for Waivers and Changes in the Code of Ethics
Waivers of this Code may only be granted by the Audit Committee of the Board of Directors of the Corporation or similarly constituted committees or individuals at the several subsidiaries and affiliates of the Corporation (the “Committee”).  The Committee will not grant waivers except under extraordinary circumstances.  In addition, any waivers of or changes to any of the items set forth immediately following the third paragraph of the Purpose section of this Code shall be documented in appropriate minutes and publicly disclosed as necessary on a timely basis.

Initial Certification
Each Employee shall certify in writing his or her acknowledgment of their obligations as specified in the Code of Ethics upon their initial hiring by the Company.

Annual Certification
Annually, all Board of Directors, Executive Vice President and above, and the President will acknowledge that they have received, read and understand The Corporation’s All Employee and Director’s Code of Ethics, that they understand that they will be held accountable for their adherence to the provisions of that policy and that they agree to comply with the policy and have complied with the policy during the year prior to this certification. 

Disclosure of the Code of Ethics
The Corporation will make a copy of its Code available to its funders and the public in the following way:

Internal Use
This Code is intended solely for internal use by the Corporation and does not confer any rights on any third party, nor does it constitute an admission by or on behalf of the Corporation as to any fact, circumstance