CODE OF CONDUCT

This Code of Business Conduct is monitored by infoWave Ethics Program Office and is annually affirmed by our employees. This Code of Business Conduct applies to all employees of infoWave and Silicon Interfaces its subsidiaries (collectively referred to as “iW“). This Code of Business Conduct has been designed to deter wrongdoing and to promote:

• Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships
• Full, fair, accurate, timely, and understandable disclosure in reports and documents that iW files with, or submits to, government agencies and in other public communications
• Protecting iW′s confidential and proprietary information and that of our customers′ and vendors′
• Compliance with applicable governmental laws, rules and regulations
• The prompt internal reporting of violations of this code
• Accountability for adherence to this code

In some circumstances, infoWave may request for some personal information from you, like your name, e-mail address, company name, or telephone number. You are at liberty to respond or not to respond to these inquiries and any and all information provided is strictly voluntary. infoWave uses this information to get valuable feedback from your experience on our Web site. In addition, infoWave may also use your personal information for its other business purposes or in order to help serve you better be it by informing you of new services, products, alliances etc that could help you in your business.

OVERVIEW OF BUSINESS ETHICS

We believe that long-term, trusting business relationships are built by being honest, open and fair. We promise to uphold the highest professional standards in all global business operations. We also expect that those with whom we do business (including suppliers, customers or re-sellers) will adhere to the standards set by iW's Code of Business Conduct.

Outstanding employees are key to iW's success. Everyone is part of the company team, and each of us deserves to be treated with dignity and respect. In addition, every employee is responsible for his/her own conduct. No one has the authority to make another employee violate SI's Code of Business Conduct, and any attempt to direct or otherwise influence someone else to commit a violation is unacceptable.

Managers, in particular, set an example for other employees and are often responsible for directing the actions of others. SI requires all employees, including managers, to know and understand the Code of Business Conduct, as it applies personally to the employee or manager and to those under his/her supervision.

The fundamental principle that underlies the way we do business at SI is good judgment. An understanding of our legal and ethical parameters enhances that judgment. SI has a responsibility to pay constant attention to all legal boundaries and to comply with all applicable laws and regulations in all of its operations worldwide. We have the same obligation to the communities in which we do business and to the customers with whom we do business. For everyone at SI, this means following the spirit of the law and doing the right, ethical thing even when the law is not specific.

This code outlines the broad principles of legal and ethical business conduct embraced by SI. It is not a complete list of legal or ethical questions an employee might face in the course of business, and therefore, this code must be applied using common sense and good judgment. Additionally, under certain circumstances local country law may establish requirements that differ from this code. Employees worldwide are expected to comply with all local country laws and SI business conduct policies in the area in which they are conducting SI business.

Although we realize that no two situations are alike, we aim for consistency and balance when encountering any ethical issues. It is essential that we all keep an eye out for possible infringements of SI's business ethics - whether these infringements occur in dealings with the government or the private sector, and whether they occur because of oversight or intention. Employees who have questions regarding business conduct or possible violations should contact their local HR representative or the SI Ethics Program Office.

CONFLICTS OF INTEREST

Employees are expected to make or participate in business decisions and actions in the course of their employment with SI based on the best interests of the company as a whole, and not based on personal relationships or benefits. Conflicts of interest can compromise employees' business ethics. Employees are expected to apply sound judgment to avoid conflicts of interest that could negatively affect SI or its business. At SI, a conflict of interest is any activity that is inconsistent with or opposed to SI′s interests, or gives the appearance of impropriety.

Employees should avoid any relationship that would cause a conflict of interest with their duties and responsibilities at SI. Employees are expected to disclose to us any situations that may involve conflicts of interests affecting them personally or affecting other employees or those with whom we do business

Honoraria : Speaking at events, when it is determined to be in iW′s best interests, is considered part of an employee's normal job responsibilities. Because employees will be compensated by iW for most or all of their time spent preparing for, attending, and delivering presentations approved by management, employees should not request or negotiate a fee or receive any form of compensation (excepting the novelties, favors or entertainment described below) from the organization that requested the speech, unless the employee first receives express authorization from the iW vice president for their organization; alternatively, a fee can be accepted provided it is donated to the iW Foundation or other non-profit charitable organization.

Inventions, Books, and Publications : SI or iW employees must receive written permission from the iW Management for their organization before developing, outside of iW, any products, software, or intellectual property that is or may be related to iW′s current or potential business

Favors, Gifts and Entertainment : iW has many customers, suppliers and other business partners, all of whom are vital to our company′s success. All of these relationships must be based entirely on sound business decisions and fair dealing. Business gifts and entertainment can build goodwill, and are a part of normal relationships with our business partners, but they can also create a perception of conflict of interest that can undermine the integrity of our relationships. This is why all iW or SI employees are expected to know this policy and to know the equivalent policies of our partners and customers. Any courtesy should always comply with the policies of the recipient′s organization, and those we are doing business with should understand our policy as well. iW has a separate policy for giving gifts internally to employees

“Favors, gifts and/or entertainment“ means anything of value, including meals, lodging, discounts, loans, cash, favorable terms on any product or service, services, equipment, prizes, products, transportation, use of vehicles or vacation facilities, stocks or other securities (including accepting the opportunity to buy “directed shares“ - also called “friends and family shares“ - from a company where the iW employee is now or is likely to become in any way involved in iW′s relationship with that company), home improvements, tickets and gift certificates. The potential list is endless – these are just examples. Note: In some cases, more restrictive standards on favors, gifts and entertainment may apply than are described here – for instance, special rules apply to those dealing with government agencies, and the legal rules may differ in various countries, or partners and customers may have policies of their own with which we are expected to comply in our business relationships. Employees must not accept or give favors, gifts or entertainment that violates those standards. Always keep in mind that you should never offer or accept favors, gifts or entertainment that would embarrass iW or its customers, vendors or suppliers.

Because of tax and other legal reporting rules, it is essential that our expense report records accurately reflect favors, gifts and entertainment provided to customers. You are required to report properly in your expense reports, all expenditures for favors, gifts or entertainment conducted as part of your iW or SI employment, and you must accurately state the purpose of the expenditures or the identities of the individuals receiving the favors, gifts or entertainment.

Favors, Gifts and Entertainment to Public Sector/Government Officials Raise Special Risks - It is very important that when working with any public sector official – regardless of location, department or agency, and including government-controlled organizations such as public universities or telecom service providers – that you know the specific rules related to the giving of favors, gifts and entertainment to that official. It is each iW employee′s responsibility to know the specific rules related to the giving of favors, gifts or entertainment to public sector employees. For example, although iW may pay for travel expenses for private-sector customer visits to iW facilities or meetings, it is typically inappropriate to pay for such expenses for government officials

Other considerations : In rare circumstances, local customs in some countries may call for the exchange of gifts having more than nominal value as part of the business relationship. In these situations, gifts may be accepted only on behalf of iW (not an individual) with the approval of the employee′s Management and Human Resources Department.

Industry Associations : Membership on boards of industry associations generally does not present financial conflicts of interest. However, employees should be sensitive to possible conflicts with iW′s business interests, if, for instance, the association takes a position adverse to iW′s interests or those of key customers

Supervisory Relationships with Family Members: Supervisory relationships with family members present special workplace problems, including a conflict of interest, or at least the appearance of conflict, in various personnel decisions that the supervisor makes. Accordingly, iW or SI employees must avoid a direct reporting relationship with any member of their family or others with whom they have a significant relationship. If such a relationship exists or occurs, the employee must report it in writing to the HR Representative.

PROPRIETARY INFORMATION

Proprietary information is defined as information that was developed, created, discovered by or on behalf of iW, or that became known by or was conveyed to the company, that has commercial value in iW′s business or that iW does not want publicly disclosed. It includes but is not limited to software programs and subroutines, source and object code, trade secrets, copyrights, ideas, techniques, know-how, inventions (whether patentable or not), and any other information of any type relating to designs, product specifications, configurations, toolings, schematics, master works, algorithms, flowcharts, circuits, works of authorship, formulae, mechanisms, research, manufacture, assembly, installation, marketing, pricing, customers, salaries and terms of compensation of company employees, and costs or other financial data concerning any of the foregoing or the company and its operations generally.

iW′s business and business relationships center on the confidential and proprietary information of SI and of those with whom we do business– customers, vendors, and others. Each employee has the duty to respect and protect the confidentiality of all such information. The disclosure or use of confidential and proprietary information - whether iW′s or a third party's – should be covered by a written agreement. In addition to the obligations imposed by that agreement, all employees should comply with the following requirements:

• Confidential information should be received and disclosed only under the auspices of a written agreement
• Confidential information should be disclosed only to those iW employees who need to access it to perform their jobs for iW
• Confidential information of a third party should not be used or copied by any iW employee except as permitted by a written agreement between iW and the third party owner
• Unsolicited third-party confidential information should be refused or, if inadvertently received by an employee, returned unopened to the third party or transferred to the iW Legal Department for appropriate disposition
• Employees must refrain from using any confidential information belonging to any former employers (with the exception of any such information acquired by iW), and such information must never be brought to iW or provided to other employees

Export, Re-Export and Transfer Policy :

Design, Development, and Production Technology

iW design, development, and production technology (“Controlled Technology“) is subject to national security, foreign policy, and anti-terrorism laws and regulations.

Employees shall secure Controlled Technology in a manner that prevents unauthorized access by persons/nationals (internal or external) of territories or countries that have not ratified global weapon non-proliferation treaties.

Employees shall not electronically, verbally or physically transfer Controlled Technology to persons of the countries identified above without written authorization of iW′s Export & Technology Control group. Non-disclosure Agreements do not constitute written authorization to transfer design, development, or production technology.

Use technology (basic operational data) and technology that has been made publicly available, with the exception of cryptography, may be exported to all nationals and territories except those embargoed or sanctioned by the United States.

Privacy : iW has established guidelines for the collection, use and disclosure of personal data. All iW operations, activities and functions that collect, use, receive, or distribute personal data must adhere to these guidelines. Moreover, all electronic and physical resources, whether owned or leased by SI, and the messages, files, data, software or other information stored or transmitted on them are, and remain at all times, the property of SI, and SI reserves the right to inspect these items