ATD LINES RAILWAY BUSINESS CAR SERVICES-Business Conduct and Ethics For Directors

BUSINESS CONDUCT AND ETHICS FOR DIRECTORS

I. INTRODUCTION

American Train Destination Lines, known as ATD LINES has adopted the following Code of Business Conduct and Ethics for Directors.

ATD LINES Code of Ethic intent and purpose is to strengthen the Board of Directors and each Director as to ethical risk factors, towhich provide method of disciplines to Directors on recognition and provide a resolution process of mutual understanding in ethical issues. Toward providing procedures and methods to report unethical conduct, and accountability.

ATD LINES Code of Ethic has been interpreted and endorsed, pursuant to the New York Stock Exchange "corporate governance listing standards". ATD LINES understands that such codes or policy can not be applicable all conflict situations, as the code of ethics intention are to serve as a discipline procedure for directors.

ATD LINES Directors are encouraged to investigate particular circumstances of the provisions found in code of ethic and bring attention to the Chairman of Directors and Corporate Governance Committee, for further consultation with legal counsel to resolve any issue.

ATD LINES Board of Directors and governance committee may waiver the code of ethics.

ATD LINES Directors and Officers are expected to be in full compliance.

II. CONFLICTS OF INTEREST

ATD LINES Directors must avoid any conflicts of interest.

ATD LINES disclosure of conflict must be reported to Chairman of Directors and Corporate Governance Committee for appropriate legal resource consultation.

ATD LINES conflict of interest occurs when private interest interferes with corporate objectives or situation of actions or interest provide difficulty to be objective or effective in discision procedures.

ATD LINES conflict of interest can result in improper attention given to personal interest and power of position.

III. CORPORATE OPPORTUNITIES

ATD LINES Directors are prohibited from:

a). Engaging in personal opportunities to gains through discovery, use of corporate property, information and position,

b). Competition with ATD LINES,

c). Notwithstanding these provisions:

ATD LINES Directors may pursue opportunities related corporate business and only if ATD LINES discloses disinterest determinations not to purse such opportunity.

IV. CONFIDENTIALITY

ATD LINES Directors are required to maintain confidentiality of information entrusted, except when disclosure is authorized or legally mandated.

ATD LINES confidential information as related to operations and objectives includes non-public information, that could be utilized by competitors or harmful to market strategies if disclosed.

V. FAIR DEALING

ATD LINES Directors must strengthen and improve policies designed to promote positive ethical determination of fairness and equitable understanding in furtherance of business objectives.

ATD LINES Directors are forbidden to engage in unfair advantage to manipulation, conceal, abuse of privileged information, misrepresentation of material facts, or any unfair practice.

VI. PROTECTION AND USE OF COMPANY ASSETS

ATD LINES Directors must take reasonable and equitable protect of assets and policies practices that provide methodology for achievement and efficiency.

ATD LINES Directors are only authorized to utilize assets for legitimate business purposes and corporate objectives of operations.

VII. COMPLIANCE WITH LAWS, RULES, AND REGULATIONS

Directors shall strengthen and improve compliance standards with policies designed to promote protect of employees and officers with laws, rules, regulations and insider trading.

ATD LINES Transactions in securities and exchange are governed by "Insider Trading Policy".

VIII. ENCOURAGING THE REPORTING OF ILLEGAL OR UNETHICAL BEHAVIOR

ATD LINES Directors policies that:

a). Promote ethical tolerance;

b). Encourage communication to supervisors, managers, or other appropriate personnel for solutions and course of action;

c). Encourage public safety standards to report violations of laws, rules, regulations, unethical code misconduct of policies to appropriate personnel;

d). ATD LINES will not allow retaliation for reports made in good faith.

IX. VIOLATIONS

ATD LINES Directors be advised to communicate any suspected violations to Chairman of Directors and Corporate Governance Committee.

ATD LINES Directors and Corporate Governance Committee shall designate a reasonable and equitable individual to investigate violations, and consider evaluation for appropriate action.

1). ATD LINES SECURITY
2). Unethical Reporting: (800) 241-5689