Employee Code Of Business Conduct

Kapco Global basic policy is and has always been to conduct our business in a lawful and ethical manner. This Code of Business Conduct sets forth our commitment to integrity as the cornerstone for behavior of Kapco Global employees and all others who act on our behalf. Our ethical standards are based on respect for the dignity of each individual, a commitment to honesty and fairness and our desire to be a good corporate citizen.

Corporate Policies – Kapco Global maintains written corporate policies covering a wide variety of legal and ethical behavior. All employees are expected to comply with these policies.

Responsibility for Ethical Behavior

All Kapco Global employees are responsible for ethical behavior. Questions regarding legal or ethical situations should be directed to the employee’s manager, the General Counsel, the President, or any member of the Board of Directors. Employees will not suffer any adverse effects to their jobs or careers as a result of raising such issues.

Legal Compliance

Kapco Global intends to conduct its business in a way that not only conforms to the letter of the law, but also promotes the spirit of fairness and honesty behind the laws.

Dealing with Others

Kapco Global will deal fairly with our customers, suppliers, business partners and fellow employees.

Employment Practices

Kapco Global has a policy prohibiting sexual, racial, or other unlawful harassment of any kind. Kapco Global is committed to equal employment opportunity.

Anti-Trust Laws

Kapco Global will compete fairly and legitimately, and will comply with all anti-trust laws.

International Business

Kapco Global will comply with all laws which apply in the countries where we do business. In countries where common business practices are less restrictive than those outlined in our Code of Business Conduct, we will follow the more restrictive policies in the Code of Business Conduct.