GeoLogics's fundamental ethical principles are:

Every GeoLogics employee is responsible for the propriety and consequences of his or her actions.

Every GeoLogics employee must conduct all aspects of company business in an ethical and legal manner obeying the appropriate laws of the United States (including localities and states) and nations where GeoLogics does business or seeks to do business.

Employee conduct on behalf of the company with customers, suppliers, the public and one another must reflect the highest standards of honesty, integrity and fairness. Strict adherence by each GeoLogics employee to this Code and to the Standards of Conduct is essential to the success of GeoLogics. Compliance with and effective enforcement of the Code or Standards is a key responsibility of GeoLogics management and will be addressed as an element of each employee's regular evaluation.

Failure to comply with the Code or Standards of Conduct will result in appropriate disciplinary action, which may include termination of employment, reimbursement to GeoLogics for any resulting losses or damages and referral for civil or criminal prosecution. Principles of fairness will apply and employees will be provided an opportunity to explain his or her actions.

Standards of Conduct
It would be impossible for GeoLogics to have written standards of conduct for each and every situation employees may encounter. GeoLogics must rely on the judgment and vigilance of each employee to perform his or her duties with integrity and in compliance with the law.

Conflict of Interest
Each GeoLogics employee must be careful to avoid situations that might involve a conflict of interest or appear questionable to others. In general, there are two major areas of concern:

Participating in activities that conflict or appear to conflict with GeoLogics responsibilities, and

Giving or receiving anything that might influence the recipient or cause another person to believe that the recipient may be influenced - this includes offering or accepting bribes, kickbacks, illegal payments, or gratuities.

GeoLogics employees must avoid any actions that may appear to involve a conflict of interest with GeoLogics activities. These include any business, financial, or other relationships with suppliers, customers, or competitors by GeoLogics employees, their close family or their close associates outside of GeoLogics. Questionable activities include serving on the board of directors of a competing or supplier company, significant ownership in a competing or supplier company, consulting with or working for a competing or supplier company and participating in any outside business during GeoLogics business hours.

Employees must observe GeoLogics ethical standards and U.S. laws and regulations, when providing or accepting meals, entertainment, or gifts in business situations. Circumstances may differ depending on the client type:

U.S. Government Business
Rules of conduct with U.S. government officials are strict and well defined by law, government regulations, and GeoLogics policy. GeoLogics employees will not provide meals, entertainment, or gifts of value to U.S. government agents; nor may any GeoLogics employee or representative discuss employment opportunities with government agents without the prior approval of GeoLogics's Counsel.

Commercial Business
It is permissible for GeoLogics or its employees to pay for meals, refreshments, and other ordinary or necessary expenses relating to company business with commercial entities. Employees should use good judgment, observe all civil and criminal laws, and follow guidelines that apply to recipients.

Other Business
Many state, county, and local governments have specific rules regarding the conduct of their consultants. It is the responsibility of GeoLogics employeess to seek out these rules of conduct, understand their application in the specific business setting and to comply legally and in spirit. The same requirements extends to foreign governments as well. GeoLogics employees with direct procurement-related responsibilities, regardless of the business sector in which they work, may not accept any meals, transportation, refreshments, entertainment, gifts or anything else of value from suppliers or their personnel or representatives. Other GeoLogics employees may accept modest meals, transportation, refreshments, entertainment or gifts but must not accept anything that might be considered excessive or intended to influence the employee.

GeoLogics's policy does not permit payment or reimbursement for transportation expenses of non-GeoLogics workers.