This excerpt taken from the HPOL DEF 14A filed Sep 22, 2006.
Code of Ethics
The Board will approve the Code of Ethics including any amendments from time to time. Revisions to the Code of Ethics will first be reviewed by the Audit Committee which will make recommendations to the Board. Each proposal to waive the Companys Code of Ethics for any director or Executive Officer must be approved in advance by the Audit Committee and the Board and promptly disclosed as required by NASDAQ Exchange Rules and applicable law.