Ethics & Professionalism

Introduction of Ethicspoint

The reputation of corporate America has suffered greatly over the past several years, due in large measure to some significant business failures
including Enron, WorldCom and the like. Evidence from those business
failures show that people within the affected companies may have had
knowledge of illegal or unethical acts, but did not know how or to whom they
should report that knowledge, or perhaps they feared retaliation. In some
cases, had proper authorities been advised, disaster may have been averted.

At The Horton Group we want to make sure you have the tools at your disposal
should you find it necessary to report wrongdoing, including fraud, theft or
other financial irregularities that could adversely affect our Company. To
expedite this process, Horton has entered into a business relationship with
EthicsPoint.

EthicsPoint is a comprehensive and anonymous Internet and telephone based
reporting tool that assists the Board of Directors, management and employees
as we work together to ensure The Horton Group and its employees do not fall
victim to accounting and auditing fraud, discrimination or harassment,
falsification of contracts, improper use of gifts and entertainment, or
violation of policy. EthicsPoint is easy to use and confidential. I
encourage you to check out their website at www.ethicspoint.com. Attached is
a Q&A to answer questions about EthicsPoint and how it may be used, should
the need arise. Going forward, it is also our intent to create an outlet for
our clients to report activity using Ethicspoint through a link on our
internet site.

At The Horton Group, we take particular pride in the honesty and integrity
of our employees. With your help, The Horton Group and its employees will
continue to be recognized not only for superior levels of service, but also
for aspiring to the highest standards of honesty and integrity.