Bestway Rental, Inc. is founded on our commitment to the highest ethical principles and standards. We value honesty and integrity above all else. Upholding these commitments is essential to our continued success. Accordingly, we will conduct our business honestly and ethically wherever we operate in the world. We will constantly improve the quality of our services, products and operations and will create a reputation for honesty, fairness, respect, responsibility, integrity, trust and sound business judgment.

It is the responsibility of every one of us to comply with all applicable laws, rules and regulations. No illegal or unethical conduct on the part of our officers, directors, employees or affiliates is in the company's best interest. We will not compromise our principles for short-term advantage. The ethical performance of this company is the sum of the ethics of the men and women who work here. Thus, we are all expected to adhere to high standards of personal integrity.

Conflicts of Interest

In general, you should avoid situations where your personal interests conflict, or appear to conflict, with those of the company, our clients or our affiliates. Officers, directors and employees must be particularly careful to avoid representing Bestway Rental, Inc. in any transaction with others with whom there is any outside business affiliation or relationship. Officers, directors and employees shall avoid using their company contacts to advance their private business or personal interests at the expense of the company, our clients or our affiliates.

It is not possible to describe every conflict of interest, but some situations that could, in certain circumstances, cause a conflict of interest include:

• Doing business with family members
• Having a significant financial interest in another company with whom we do business
• Taking a second job that interferes with your ability to fulfill your obligations to the company
• Managing your own business
• Serving as a director of another company with whom our company does business
• Diverting a business opportunity from our company to another company

Prior to engaging in any of the foregoing activities, you should receive the prior approval of your immediate supervisor or our Corporate Secretary.

Loans to Company Insiders

As a public company, we are subject to the Sarbanes-Oxley Act of 2002 (the "Act"), which, among other things, prohibits us from extending credit in the form of personal loans to our directors, executive officers with the title of vice president or above, and any other officer or employee that has a policy-making function with us. Both direct loans by the company to any such person and guarantees by the company of the obligations of any such person are covered by the Act. Consequently, all officers, directors and employees should be particularly cautious with respect to any transaction that might be construed as a prohibited extension of credit. If you are uncertain as to whether a potential transaction would fall within the foregoing provisions of the Act, you should contact your immediate supervisor promptly to discuss the matter.

Gifts

No bribes, kickbacks or other similar remuneration or consideration shall be given to any person or organization in order to attract or influence business activity. Officers, directors and employees shall avoid gifts, gratuities, fees, bonuses or excessive entertainment, in order to attract or influence business activity.

You may accept novelty or promotional items or modest gifts related to commonly recognized occasions, such as a promotion, holiday, wedding or retirement, if:

• this happens only occasionally
• the gift was not solicited
• disclosure of the gift would not embarrass our company or the people involved

If the value of the gift exceeds $100, however, you must provide written notification to, and receive a confirmation of the receipt of such written notification from, our Chief Financial Officer. Our Chief Financial Officer will then determine if there are any issues or problems related to your retention of such gift.

In addition, you may accept an occasional invitation to a sporting activity, entertainment or meal if:

• this happens only occasionally
• the activity is of reasonable value and not lavish

Debt Collection

Many states have fair debt collection laws that require debt collectors to treat debtors fairly and prohibit certain methods of debt collection. Most of these laws prohibit activities such as:

• Contacting a debtor at an inconvenient time or place, unless the debtor consents to such contact;
• Contacting a debtor at work if you are aware that the debtor's employer disapproves of such contact;
• Contacting a debtor as opposed to the debtor's attorney after being instructed by the debtor to deal strictly with the debtor's attorney;
• Discussing a debtor's debt with third parties other than the debtor and the debtor's attorney;
• Harassing, oppressing or abusing a debtor or any other third party in connection with collecting the debt owed;
• Using false statements or unfair practices to collect the debt owed; and
• Threatening to bring criminal charges or have the debtor arrested.

To the extent that the debt collection laws in your state apply to our business, either now or at some point in the future, we are committed to maintaining absolute compliance with it. If you are uncertain as to whether a potential action would violate applicable state debt collection laws, you should contact your immediate supervisor promptly to discuss the matter.

Confidential Information

Officers, directors and employees will often come into contact with, or have possession of, proprietary, confidential or business-sensitive information and must take appropriate steps to assure that such information is strictly safeguarded. This information - whether it is on behalf of our company or any of our clients or affiliates - could include strategic business plans, operating results, marketing strategies, customer lists, personnel records, upcoming acquisitions and divestitures, new investments, processes and methods. Proprietary, confidential and sensitive business information about this company, other companies, individuals and entities should be treated with sensitivity and discretion and only be disseminated on a need-to-know basis within the company.

Officers, directors and employees will refrain from gathering competitor intelligence by illegitimate means and refrain from acting on knowledge which has been gathered in such a manner. The officers, directors and employees of Bestway Rental, Inc. will seek to avoid exaggerating or disparaging comparisons of the services and competence of their competitors.

Material Inside Information

Because we are a public company, we are subject to a number of laws concerning the purchase and sale of our stock and other publicly traded securities. Regardless of your position with us, if you are aware of what is known as "material inside information" regarding our company, business, affairs or prospects, you may not disclose that information to anyone outside our company, and you are not allowed to buy or sell our stock or other publicly-traded securities until the material inside information is known not only by individuals within our company, but also by the general public. The improper use of material inside information is known as insider trading. Insider trading is a criminal offense and is strictly prohibited.
"Material inside information" is any information concerning us that is not available to the general public and which an investor would likely consider to be important in making a decision whether to buy, sell or hold our stock or other securities. A good rule of thumb to determine whether information about us is material inside information is whether or not the release of that information to the public would have an effect on the price of our stock. Examples of material inside information include information concerning earnings estimates, changes in previously released earnings estimates, a pending stock split, dividend changes, significant merger, acquisition or disposition proposals, major litigation, the loss or acquisition of a major contract and major changes in our management. Material inside information is no longer deemed "inside" information once it is publicly disclosed and the market has had sufficient time to absorb the information. Examples of effective public disclosure are the filing of such inside information with the Securities and Exchange Commission, or the printing of such information in publications of general circulation, in each case giving the investing public a fair amount of time to absorb and understand our disclosures.

In addition to being prohibited from buying or selling our stock or other publicly-traded securities when you are in possession of material inside information, you are also prohibited from disclosing such information to anyone else (including friends and family members) in order to enable them to trade on the information. In addition, if you acquire material inside information about another company due to your relationship with us, you may not buy or sell that other company's stock or other securities until such information is publicly disclosed and sufficiently disseminated into the marketplace.

Equal Employment Opportunities

We are committed to providing equal employment opportunities for all our employees and will not tolerate any speech or conduct that is intended to, or has the effect of, discriminating against or harassing any qualified applicant or employee because of his or her race, color, religion, sex (including pregnancy, childbirth or related medical conditions), national origin, age, physical or mental disability, veteran status or any characteristic protected by law. We will not tolerate discrimination or harassment by anyone - managers, supervisors, co-workers, vendors or our customers. This policy extends to every phase of the employment process, including: recruiting, hiring, training, promotion, compensation, benefits, transfers, discipline and termination, layoffs, recalls, and company-sponsored educational, social and recreational programs, as applicable.

Health and Safety

We believe that management and each and every employee have a shared responsibility in the promotion of health and safety in the workplace. You should follow all safety laws and regulations, as well as company safety policies and procedures. You should immediately provide written notification to, and receive a confirmation of the receipt of such written notification from, our Chief Financial Officer regarding any accident, injury or unsafe equipment, practices or conditions.
You also have an obligation to carry out company activities in ways that preserve and promote a clean, safe, and healthy environment. You must strictly comply with the letter and spirit of applicable environmental laws and the public policies they represent.

The consequences of failing to adhere to environmental laws and policies can be serious. Our company, as well as individuals, may be liable not only for the costs of cleaning up pollution, but also for significant civil and criminal penalties.

Record Retention

Our records should be retained or discarded in accordance with our record retention policies and all applicable laws and regulations. From time to time we are involved in legal proceedings that may require us to make some of our records available to third parties. It is a crime to alter, destroy, modify or conceal documentation or other objects that are relevant to a government investigation or otherwise obstruct, influence or impede an official proceeding. The law applies equally to all of our records, including formal reports as well as informal data such as e-mail, expense reports and internal memos. If the existence of a subpoena or a pending government investigation is known or reported to you, you must retain all records that may pertain to the investigation or be responsive to the subpoena.

The Network

Officers, directors and employees agree to disclose unethical, dishonest, fraudulent and illegal behavior, or the violation of company policies and procedures, directly to management or an alternative method is an anonymous phone call to The Network.

The Network is a toll-free information-gathering service that offers coworkers a convenient and confidential way to bring concerns, questions, or suggestions regarding unethical or illegal activities to management's attention. Coworkers may call the service at 1-800-241-5689 at any time, 24 hours a day, 365 days a year to describe in detail their concerns or suggestions.

Administration of the Code of Ethics

Distribution

All of our directors, officers and employees will receive a copy of this code when they join our company. Updates of the code will be distributed to all directors, officers and employees.

Role of Supervisors and Officers

Supervisors and officers have important roles under this code and are expected to demonstrate their personal commitment to this code by fostering a workplace environment that promotes compliance with the code and by ensuring that employees under their supervision participate in our company's compliance training programs.

Reporting Violations

All employees are obliged to report violations of this code or the law and to cooperate in any investigations into such violations. We prefer that you give your identity when reporting violations, to allow the company to contact you in the event further information is needed to pursue an investigation, and your identity will be maintained in confidence to the extent practicable under the circumstances and consistent with enforcing this code. However, you may anonymously report violations. To report a violation, you should provide written notification of the violation to, and receive a confirmation of the receipt of such written notification from, our Chief Financial Officer.

Investigations

We will initiate a prompt investigation following any credible indication that a breach of law or this code may have occurred. We will also initiate appropriate corrective action as we deem necessary, which may include notifying appropriate authorities.

Disciplinary Action

If you violate any provision of this code, you may be subject to disciplinary action, up to and including discharge. Please be aware that we may seek civil remedies from you and if your violation results in monetary loss to us, you may be required to reimburse us for that loss. If you are involved in a violation, the fact that you reported the violation, together with the degree of cooperation displayed by you and whether the violation is intentional or unintentional, will be given consideration in our investigation and any resulting disciplinary action.

No Retaliation

We will not retaliate against anyone who, in good faith, notifies us of a possible violation of law or this code, nor will we tolerate any harassment or intimidation of any employee who reports a suspected violation. In addition, there are federal "whistleblower" laws that are designed to protect employees from discrimination or harassment for providing information to us or governmental authorities, under certain circumstances, with respect to certain laws such as those governing workplace safety, the environment, securities fraud and federal law relating to fraud against shareholders.

Approvals

Approvals required under this code should be documented.

Waivers

Any request for a waiver of this code must be submitted in writing to our Chief Financial Officer, who shall have authority to decide whether to grant a waiver. However, a waiver of any provision of this code for a director or an executive officer must be approved by our Board of Directors or its designated committee and will be promptly disclosed to the extent required by law or regulation.