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CODE OF ETHICS

Code of Conduct 2006

The North American Coal Corporation strictly enforces the NACCO Industries, Inc. and Subsidiaries Code of Corporate Conduct to emphasize to employees, customers and suppliers that we will do business only in compliance with the highest legal and ethical standards.

Concerns relating to possible violations of the company's Code of Corporate Conduct or any unethical, dishonest, or illegal conduct by any employee should be reported in writing to:

THOMAS A. KOZA
Vice President - Law and Administration, and Secretary
The North American Coal Corporation
14785 Preston Road, Suite 1100
Dallas, Texas 75254-7891

or by calling the:

CORPORATE COMPLIANCE HELPLINE
1.877.367.4448

The Helpline is a toll-free number that is always available. All concerns will be handled strict confidence and may be reported anonymously.