Our customers and co-workers expect honest and ethical conduct from each Invertix employee every day. The intent of the ethics policy is to set forth clearly our standards of ethical conduct, in an effort to reaffirm our shared commitment to our core values, as defined in this manual. Generally, in the performance of their duties, employees of the Company are expected to make every effort to meet ethical standards and to avoid any actions that may create even the appearance of violating the law and ethical standards.

Employees shall adhere to all equal opportunity laws/regulations. Employees 1) shall not engage in outside employment that conflicts with Invertix policies or interests, or employment that is competitive to Invertix; 2) shall not accept anything of monetary value from any entity (company or individual) in excess of $25 per calendar year; 3) shall not disclose confidential or proprietary Company information; 4) shall not knowingly make unauthorized commitments on behalf of the Company; and 5) shall not engage in behavior that could be interpreted as constituting a conflict of interest.

The company prides itself on the high standards of excellence embodied by our operating principles. We expect our employees to personify these ideals in their dealing with persons both inside and outside the company. The following standards of conduct is intended to provide guidelines for the professional, ethical, legal, and socially responsible behavior we expect of our employees.

1. 1. Standards of Conduct

All employees are expected to perform their duties effectively and efficiently; to follow Invertix rules and their supervisor's directives; to display loyalty and integrity; and to avoid conduct that is illegal, improper, or otherwise brings discredit or interferes with efficient operation. Any employee who acts in a manner inconsistent with these basic principles is subject to discipline, up to and including termination. Responsibility for imposing proper discipline rests in the first instance with an employee's supervisor, but senior management will ordinarily review situations involving serious discipline or termination as well.

In situations where Invertix believes that the problems with an employee's performance may be corrected in a reasonable time, Invertix may choose to place the employee on probation, giving him/her notice of deficiencies in performance and an opportunity to correct them.

Invertix may terminate an employee immediately for serious misconduct, including but not limited to dishonesty, insubordination, illegal conduct, serious deviations from rules and procedures (including those involving safety), nonperformance of duties, or any other conduct that significantly interferes with the efficient operation of Invertix.

2. 2. Fair Treatment

As a company, we expect that all employees will treat one another with respect and dignity. Equal opportunity and fair treatment extend to all employees. Invertix specifically prohibits discrimination on the basis of age, color, disability, ethnicity, marital or family status, national origin, race, religion, gender, sexual orientation, veteran status, or any other characteristic protected by law. These principles apply to all employment decisions, including recruiting, hiring, training, promotions, pay, benefits, transfers, and workforce reductions. In addition to full compliance with all Equal Employment Opportunity laws and all other applicable civil rights, human rights, and environmental and labor laws, which are available upon request, Invertix is committed to providing an environment that values diversity and fosters respect and continuing learning.

3. 3. Employee Conduct

It is each employee's responsibility to be aware of and adhere to Company policies, procedures and common sense standards of conduct. Among the causes for corrective action, which may include immediate termination, are the following:

• Any act of dishonesty, including theft or misappropriation of money, supplies, information, services, equipment or time
• Any act which call into question the employee.s integrity, such as falsification of company records and documents, competing in business with the Company or any other conflict of interest, divulging trade secrets or confidential information, or conviction of a felony
• Any act which may create a dangerous situation, such as carrying a weapon on Company premises, physically assaulting or verbally threatening another individual, or disregard of property or safety standards
• Violation of the Company's Substance Abuse Policy
• Refusal to perform a job assignment or request by management, insubordination or discourteous conduct toward customers, associates or managers
• Failure to adhere to attendance or timekeeping regulations including excessive absenteeism or tardiness
• Any act of harassment or intimidation of a co-worker, including sexual, racial, ethnic, religious, national origin or disability harassment
• Violation of the Company's Policies and Procedures

This list is not comprehensive and other actions of a similar nature could also lead to corrective action, up to and including termination. Should you have a question concerning any of the above or if you are ever in doubt about whether certain conduct is permitted, please consult with your manager or a Human Resources representative.

The Company's expectation for conduct is as follows:

• Conduct yourself professionally and in a business-like manner always maintaining a high ethical and moral standard which does not discredit them, Invertix, or Invertix clients. This requirement applies to work performance carried out at Invertix offices as well as at the client site(s).
• Be aware of, and abide by, the laws of the United States and other jurisdictions in which we do business.
• Adhere to the spirit of the law and observe recognized standards of fairness and personal integrity.
• Deal with clients and vendors in a professional, courteous manner, remembering that they are very important to the accomplishment of our mission.
• Perform assigned tasks in an efficient, reliable, and timely manner being economical in utilizing both Company and customer resources.
• Conduct yourself in a considerate, friendly, and constructive manner towards fellow employees, avoiding outbursts of anger, use of foul or in appropriate language, hurtful gossip, rudeness, discourteous behavior, or physical assaults.
• Work professionally as a member of a team, even when under pressure.
• Keep internal Invertix information and client information confidential.
• Arrive at work promptly and avoid excessive absences or abuse of the Invertix leave policies
• Maintain a level of cleanliness and neatness in their assigned work areas that is consistent with Invertix standards and to clean up after themselves in all common areas.
• Refrain from possessing, using, or being under the influence of alcohol or illegal drugs in the workplace which is in accordance with Invertix Drug-Free Workplace Policy.
• Adhere to all policies and procedures adopted by Invertix.

An employee that violates any of these policies may be subject to discipline, up to and including termination.

1. 3.1. Company Responsibilities

Invertix is responsible for making sure that all employees are aware of and understand the standards of conduct. Invertix is responsible for creating a work environment wherein these standards may be successfully applied. Invertix will provide education and training on ethical issues and will make available continuing counsel on Company rules and regulations to any employee who seeks it.

2. 3.2. Supervisor Responsibility

Each supervisor is responsible for assuring that every employee under his or her supervision read the Policy and Procedure Manual and understands its importance.

3. 3.3. Employee Responsibility

Each employee is responsible for conducting his or her work in a manner consistent with Invertix Vision and our Ethics Policies. Any employee who suspects or has knowledge of infractions of these Standards of Conduct should immediately bring the matter to the attention of the employee supervisor, or the Manager of Human Resources located at Corporate Headquarters in McLean, VA.