Code of Conduct
This Affinity Code of Professional Conduct ("Code of Professional Conduct") applies to all employees of Affinity and its reporting subsidiaries. The employees of Affinity and its reporting subsidiaries are expected to abide by this Code of Professional Conduct and are expected to comply with all applicable laws, rules and regulations and abide by all policies and procedures adopted by Affinity from time to time that govern the conduct of its employees. This Code of Professional Conduct is intended to supplement any other policies and procedures adopted by Affinity Group from time to time that govern the conduct of its employees, including those contained in the Affinity Employee Handbook.
All employees of Affinity and its reporting subsidiaries shall:
| (a) | Engage in and promote honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships; |
| (b) | Avoid conflicts of interest and disclose to the CFO or General Counsel of Affinity Group any material transaction or relationship that reasonably could be expected to give rise to such a conflict; |
| (c) | Take all reasonable measures to protect the confidentiality of non-public information about Affinity or its subsidiaries and their customers obtained or created in connection with your activities and prevent the unauthorized disclosure of such information unless required by applicable law or regulation or legal or regulatory process; |
| (d) | Produce full, fair, accurate, timely and understandable disclosure in reports and documents that Affinity Group or its subsidiaries files with, or submits to, the Securities and Exchange Commission and other regulators and in other public communications made by Affinity Group or its subsidiaries; |
| (e) | Comply with all applicable governmental laws, rules and regulations, as well as the rules and regulations of applicable regulatory agencies; and |
| (f) | Promptly report any possible violation of this Code of Professional Conduct to the CFO, General Counsel and the Audit Committee Chairman of Affinity at coe@affinitygroup.com. |
You understand that you will be held accountable for your adherence to this Code of Professional Conduct. Your failure to observe the terms of this Code of Professional Conduct may result in disciplinary action, up to and including termination of employment. Violations of this Code of Professional Conduct may also constitute violations of law and may result in civil and criminal penalties for you, your supervisors and/or Affinity.
If you have any questions regarding the best course of action in a particular situation, you should promptly contact the CFO, General Counsel and the Audit Committee Chairman of Affinity at coe@affinitygroup.com. You may choose to remain anonymous in reporting any possible violation of this Code of Professional Conduct.

