This Code of Business Conduct (the "Code " ) reaffirms MOX's long-standing policy that

its directors, officers and employees conform to the highest legal, ethical and moral standards in conducting the businesses of MOX Property Corporation and its subsidiaries and affiliates (collectively, "MOX" or the "Company"). This Code is intended to provide general guidelines that will:

> Ensure compliance with laws and regulations that govern MOX's business activities;

> Foster a standard of conduct that reflects positively on MOX and its employees;

> Protect MOX from financial loss; and

> Preserve a corporate climate in which the integrity and dignity of each individual is not compromised.

Responsibility for adherence to this Code rests with each individual.

Compliance with Laws, Rules and Regulations

MOX is subject to various federal, state, local and foreign laws and regulations. MOX is committed to complying with these laws and regulations. No director, officer or employee of the Company is authorized to undertake any activities in the name of MOX, whether administrative, financial or operating, that would violate any federal, state, local or foreign laws or regulations. Any unlawful acts are always outside the scope of employment. Observing the law is required.

Careful attention must be given to federal and state securities laws and MOX's Statement of Policies and Procedures Governing Material, Non-Public Information and the Prevention of Insider Trading. In addition, careful attention must be given to the Foreign Corrupt Practices Act, the Age Discrimination in Employment Act, the Americans with Disabilities Act and the civil rights laws. Also, MOX is a drug-free workplace. Lastly, all employees are expected to read and comply with the terms and conditions set forth in MOX's Employee Handbook.

MOX neither condones nor tolerates any conduct that violates the law or discredits the Company's good reputation. It is the duty of each director, officer and employee to avoid any circumstance that would violate this Code or the laws and regulations that govern MOX's businesses.

Safety

At MOX, we understand that accidents are prevented through careful planning, training and cooperative efforts in all areas of our operations. Therefore, safety is the responsibility of every MOX employee and the single focus of our corporate safety team. All work is performed in the safest manner possible consistent with good construction practices.

Construction is a unique industry in terms of safety challenges and advancements. While construction methods and techniques have improved, consistently increasing industry efficiency and productivity, the accident incidence rate for construction continues to be of concern. Direct and indirect job costs for doing business are known to fluctuate in direct proportion to the incidence of accidents. Effective preventive measures must be identified and successfully applied.

Discrimination and Harassment

MOX affirms its commitment to afford all individuals who have the necessary qualifications an equal opportunity to compete for employment and advancement within MOX. MOX is committed to the philosophy and principle of equal employment opportunity for all present and prospective employees. MOX's objective is to provide a work environment free of discrimination and harassment based on gender, race, color, national origin, age, religion, marital status, disability, sexual orientation or veteran status.

To ensure equal employment opportunity, MOX has established a policy prohibiting discrimination concerning any individual or group because of any of the factors listed in the prior sentence.

Every director, officer and employee is expected to be sensitive to and aware of any behaviors or situations that could be interpreted as harassment, including sexual harassment, and is responsible for taking steps to correct any such behavior or stop any such actions. The offensive and/or hostile working conditions created by harassment will not be tolerated. Any complaints alleging harassment, including sexual harassment, are to be handled in a timely manner, in accordance with the policies set forth in MOX's Employee Handbook.

Each officer and employee is expected to read and comply with MOX's policy prohibiting discrimination and harassment. An employee's supervisor, the Human Resources Department or the Legal Department should be contacted to report an instance of discrimination or harassment.

Confidentiality

Confidential information is the kind of information known only to persons having a confidential relationship with MOX and includes all non-public information that might be of use to MOX's competitors, or harmful to MOX, its customers or its Strategic Alliance Partners, if disclosed, such as trade secrets, know-how, ideas, inventions, processes, techniques, programs (whether in source code or object code form), formulae, data, plans, strategies, forecasts, marketing materials, financial information, accounting systems, contact management systems, customer information, personnel records and other similar materials.

Confidential information is deemed to be the exclusive property of MOX. In the course of their work, directors, officers and employees may become aware of confidential information. Such information must be held in the strictest confidence both during and subsequent to the term of directorship or employment of the director or officer and employee, respectively. In addition, confidential information is to be used solely for corporate purposes.