Ethical Business Practices

• Commercial Bribery
  We prohibit employees from receiving, directly or indirectly, anything of value in return for using or agreeing to use his or her position for the benefit of that other person. Similarly, commercial bribes, kickbacks, gratuities and other payoffs and benefits paid to any customer are prohibited. However, this does not include expenditures of reasonable amount for meals and entertainment of customers if they are otherwise lawful, and should be included on expense reports and approved under standard Company procedures.

• Accounting Controls, Procedures and Records
  We accurately keep books and records of all transactions and the dispositions of our assets as required by law, as well as maintain a system of internal accounting controls to ensure the reliability and adequacy of our books and records. We ensure only transactions with proper management approval are accounted for in our books and records.

• Use and Disclosure of Inside Information
  We strictly prohibit disclosure of material inside information to persons within the company whose positions deny access to such information. Inside information is any data that has not been publicly disclosed.

• Confidential or Proprietary Information
  We take extra care to keep our customers' trust and confidence in us. Thus, we prohibit employees from disclosing confidential or proprietary information outside the Company that could be harmful to our clients, or to the Company itself. Such information may only be shared with other employees on a need-to-know basis.

• Conflicts of Interest
  We designed our policy to eliminate conflicts between the interests of employees and the Company. Since it is difficult to define what constitutes a conflict of interest, employees should be sensitive to situations which could raise questions of potential or apparent conflicts between personal interests and the Company's interests. Personal use of Company property or obtaining Company services for personal benefit may constitute a conflict of interest.
• Fraud and Similar Irregularities
  We strictly prohibit any fraudulent activity that might injure our customers and suppliers, as well as the Company. We follow certain procedures concerning the recognition, reporting and investigation of any such activity.