Our Underlying Values and Principles

OUR VALUES:

We believe that the capacity to accomplish our mission requires that we have a clearly defined set of principles that are based on sound and proven values. Achieving our mission requires that all of our team members subscribe to the values and principles that we consider essential. Our underlying values include, but are not limited to, the following: Honesty, Integrity, Ethics, Respect for Others, Loyalty, Passion for Serving Others, Accountability, Responsibility, Dedication, Commitment, Teamwork, Focus and Proactive Behavior. While this is a lengthy, and seeming long and idealistic listing, we believe that these and similar values provide a good foundation for the principles which guide our company.

OUR PRINCIPLES:

Principles are fundamental observations concerning the relationships between action and the subsequent effects of that action on the attainment of organizational objectives. Our Principles of Business Conduct are based on the values we embrace and represent who we are and what we stand for. We strive to earn and maintain the trust and respect of all with whom we conduct business.

Each of us has an individual responsibility for ethical behavior. The success of Jackson Property Company depends on our individual moral character, commitment to the organization, and self-control. We cannot achieve organizational success without individual success and vice versa. While all of our team members are expected to read, understand and commit to these principles, ensuring that they govern our actions is a matter of individual spirit and intent. These principles include but are not limited to the following:

1. Our responsibility to our employees: We respect the dignity of each Jackson Property Company employee. Each of us wants and deserves a workplace where we are respected, satisfied, and appreciated. Abusive, harassing or offensive conduct, whether verbal, physical or visual, is unacceptable. We are encouraged to speak out when a co-workers conduct makes us uncomfortable, and to report harassment to our managers and to Employee Resources when it occurs.

We are all responsible for conducting our work activities to the best of our ability. Each of us will be familiar with the Jackson Property Company Employee Handbook and other Company policy manuals and will strive to comply with them in practice and in spirit

2. Our responsibility to our clients and our residents: Jackson Property Company exists solely because of our clients, investors and our residents and serving them is the basis of our business.

a. We will build long-term relationships with our clients and our residents by demonstrating honesty and integrity. All of our marketing and advertising will accurately represent our products and services.

b. We must protect information about our clients, investors and our residents just as carefully as we would our own and as the law requires. Residents should be given access to personally signed documents in accordance with company policy. Clients and investors will have full access to all information concerning their property.

c. We will treat the investment of our client with all diligence and care as if it were our own.

d. We have a responsibility to protect all assets entrusted to us from loss, damage, misuse or theft. Client assets, such as funds or computers, may only be used for business purposes.

e. We will safeguard all proprietary information by keeping it secure, and limiting access to those who have a need to know in order to do their jobs. Proprietary information includes any information that is not generally known to the public and is helpful to Jackson Property Company, or would be helpful to competitors. The obligation to preserve proprietary information continues even after employment ends.

3. Accuracy of Company Records: We require honest and accurate reporting of information in order to make responsible business decisions. All financial books, records and accounts must accurately reflect transactions and events, and conform both to required accounting principles and to Jackson Property Company's internal controls. No false, misleading or incomplete entries may be made.

4. Business Communications: All business records and communications should be clear, truthful and accurate. We will avoid comments containing exaggeration, colorful language and the like in communications of all kinds, including e-mail and informal notes or memos. Business records and communications often become public through litigation, government investigations and the media. Records should be maintained according to Jackson Property Company=s record retention practices.

5. Our responsibility to our vendors: Building quality relationships with other companies gives Jackson Property Company a competitive advantage as follows:

a. Doing Business with Others: We will strive to ally with companies that share our commitment to ethics and values. We will not do business with others if they violate the law, or if a business relationship with them would likely harm our reputation.

b. Spending Practices: Decisions to spend or commit Company assets or assets of our clients must be based solely on the best interests of our client and our company. Vendors earn our business based on product or service suitability, price, delivery and quality. Our purchase agreements and contracts will clearly identify the services or products to be provided, their costs and any other relevant terms. Costs must be commensurate with the services or products provided.

6. The Decision Making Process: We will make business decisions based on the best interest of our clients and Jackson Property Company. Playing favorites or having conflicts of interest in practice, or in appearance, is contrary to fair treatment and good business judgment. We will avoid any relationship, influence, or activity that might impair, or even appear to impair, our ability to make objective and fair decisions when performing our jobs. When we are required to disclose any relationship to our client or investor we will always provide full disclosure.

7. We will endeavor to be a learning organization that respects and encourages hard work, innovation and creativity. Our employees will be encouraged, recognized and rewarded for their efforts, best practices and the achievement of their goals for their property.