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| It is the policy of United PanAm Financial Corp. ("the Company"), the parent company of United Auto Credit Corporation to conduct its business in accordance with the highest ethical standards in order to merit and maintain the complete confidence and trust of its customers and the public in general. This Code of Personal and Business Conduct and Ethics ("Code") addresses both business and social relationships that may present legal and ethical concerns and also sets forth a code of conduct to guide the members of the board of directors, officers and employees. We expect every employee, officer and director of the Company to read and understand the Code and its application to the performance of his or her business responsibilities. Directors, officers and employees must conduct their personal affairs and maintain their business transactions in a manner which does not result in adverse comments or criticisms from the public or in any way damage our reputation as a responsible financial services organization. Unless otherwise set forth herein, the term "employee" refers to all officers and employees of the Company and its subsidiaries.
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