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This Code of Conduct ("Code") is intended to ensure that ApproachIT business is conducted in compliance with all applicable laws and regulations and in a manner that is consistent with ApproachIT professional and ethical standards. All ApproachIT employees, consultants, subcontractors, and/or any authorized ApproachIT representative required to fully abide by and comply with this Code. Finally, this Code emphasizes that unlawful and unethical practices will not be tolerated, that disclosures of facts related to business transaction must be factual and accurate

I. Ethical Standards

ApproachIT value statement provides that "We act with integrity, honesty, and respect". Our reputation depends on our ability to maintain the achievement of those ideals and to conduct business ethically. Ethical business conduct is essential to our continued success. Accordingly, all parties and individuals will:

1. Conduct its business in compliance with all applicable international, federal, state and local laws, regulations, tariffs and rules, including, without limitation, the International Chamber of Commerce rules and practices.

2. Deal in good faith, with a commitment to honest dealing, and not engage in fraudulent behavior.

3. Not engage in transactions without a legitimate business purpose and which are intended to mislead or to circumvent facts.

4. Not collude with other ApproachIT business employees, consultants, and/or affiliates in any business transaction that is considered in conflict of interest of ApproachIT.

5. Ensure that every deal is completed with utmost integrity.

6. Properly record, classify, and summarize transactional events for further review.

7. Comply with rules required by our clients when transacting in their facilities.

8. No one is authorized to transact on behalf of ApproachIT without previous written, signed, and sealed permission.

II. Information Disclosure and Documentation

ApproachIT will:

1. Provide accurate and factual information to clients, regulators, employees, consultants, and business affiliates in compliance with all applicable rules and requirements necessary to understand all facts related to conducting business transaction.

2. Maintain and adhere to internal procedures designed to ensure that all business transaction are properly documented in a timely fashion and that no events or artifacts are concealed or misrepresented.

3. Maintain documentation on all transactions for an appropriate period of time as required under applicable laws and regulations.




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