ATN expects and depends on each of its directors, officers, employees, agents and consultants at all times to act ethically, honestly, lawfully and with integrity. We have included a link to our Code of Ethics below, that should serve as a basic guide to help you make good choices in the course of your employment with us and to promote the ethical handling of conflicts of interest, full and fair disclosure, and compliance with laws, rules and regulations. We expect you to follow this Code and use good judgment in
applying its principles to your conduct. Ethical decision making is not always easy, and this Code does not explain the appropriate ethical behavior for every situation. As a guide to assist you in making the right choice, ask yourself the following questions:
Does it feel right?
Will it reflect negatively on me or on the Company?
Would I be embarrassed if others knew about it?
How would this look in the newspapers?
Can I sleep at night?

We encourage all employees, directors, consultants or agents to make a report utilizing this hotline or directly to ATN's General Counsel or Internal Audit department if a situation occurs that is not in keeping with our Code of Ethics.

Our continuing success depends in part on each of us acting ethically and with integrity every day in everything that we do. Simply put, we cannot be successful if any part of our success is achieved through dishonesty, fraud or other unethical or illegal behavior. Ethical conduct is not an impediment to business success; it is an essential element of such success.

Our Code of Ethics is the roadmap for how we should serve our mission and conduct our business. The Code spells out our commitment to pursue our daily activities ethically and transparently, with everyone from our customers, regulators, business partners and counterparties, to our vendors, co-workers and others. While our business has expanded significantly since our founding in 1987, the underlying values guiding our conduct have not changed. Act with integrity. Do the right thing. Don’t cut corners. Treat others as you would like to be treated. If you face a situation not explicitly covered by the letter of this Code, take the high road and obey its spirit.

Each of us is required to confirm our understanding of this Code and its principles, so I urge you to read it carefully, become familiar with its principles and discuss it with your supervisor and co-workers. Of course, the Code cannot address every possible situation, and issues will continue to evolve as our company continues to grow and develop. Ask questions if you are uncertain about how to handle a situation, and report any compliance or ethics issues or concerns.

We are in business for the long term. Unethical behavior not only is wrong, it prevents us from achieving our long term goals. Please join me in upholding our commitment to ethics and integrity by following the standards outlined in this Code every day.





Michael T. Prior
President and Chief Executive Officer