CLEAR LAM PACKAGING, INC. and SUBSIDIARIES CODE OF ETHICS APPLICABLE TO THE PRINCIPAL EXECUTIVE, FINANCIAL And ACCOUNTING OFFICERS

Applicable to:

The Chief Executive Officer, Corporate or Subsidiary President, Chief Financial Officer, Corporate or Subsidiary Vice President of Finance, Corporate or Subsidiary Controller and the Assistant Controller (Collectively the "Principal Executive, Financial and Accounting Officers").

Clear Lam requires its Principal Executive, Financial and Accounting Officers to: (i) act in accordance with the highest standards of personal and professional integrity in all aspects of their activities; (ii) comply with applicable laws, rules and regulations; (iii) deter wrongdoing; and (iv) abide by the policies and procedures adopted by Clear Lam that govern the conduct of its employees. This Code of Ethics sets forth principles that these officers must adhere to and advocate.

As a Principal Executive, Financial or Accounting Officer of Clear Lam, you will fulfill this responsibility by doing the following:

HONEST AND ETHICAL CONDUCT

Act at all times with honesty, integrity and independence. Encourage the ethical handling of actual or apparent conflicts of interest between personal and professional relationships. Obtain quarterly approval from the Board of Directors prior to transacting with a related party. Consider the impact of all investments, interests and associations on your independent exercise of judgment in Clear Lam’s best interests. Act honestly and ethically in dealing with each other, your fellow employees, customers, and suppliers. Protect and respect the confidentiality of information acquired in the course of your employment except when authorized or otherwise legally obligated to disclose. Support and enforce this Code of Ethics.

ACCURATE AND TIMELY FINANCIAL RECORDING

Establish and monitor controls and procedures designed to produce full, fair, accurate, timely and understandable disclosure in reports and documents that are submitted to the Shareholders, Banks and Financial Institutions and other public communications made by Clear Lam. Establish and monitor controls and procedures designed to ensure that no records contain any false or intentionally misleading information, no transactions are intentionally misclassified; all transactions are supported by accurate and required documentation and record retention and disposal comply with applicable legal and regulatory requirements.

COMPLIANCE WITH APPLICABLE GOVERNMENTAL LAWS, RULESAND REGULATIONS

Comply with all applicable rules and regulations of federal, state, or local government, and other regulatory agencies.

REPORTING OF CODE VIOLATIONS

Promptly report any violation or suspicion of violation of this Code of Ethics directly to the Board of Directors or through the Company’s anonymous incident reporting system.

ACCOUNTABILITY

Full compliance of this Code of Ethics is required. By signing this document, you acknowledge that you understand and agree to adhere to this Code of Ethics. You also understand that changes in and waivers of this Code may be made only by the Board of Directors and will be promptly disclosed as required under applicable law and regulations. Furthermore, you understand that any violation may be grounds for disciplinary action up to and including termination.

SIGNATURES

Signatures for the "Code of Ethics" for the Chief Executive Officer, Division or Subsidiary Presidents, Chief Financial Officer, Clear Lam or Subsidiary Vice President of Finance, Clear Lam or Subsidiary Controller and Assistant Controller are on file at the Corporate Human Resources Department.