PHENOM ELITE will conduct its business honestly and ethically whereve we operate in the world. We will constantly improve the quality of our services, products, and operations and will create a reputation for honesty, fairness, respecte, responsibility, integrity, trust, and a sound business judgment. No illegal or unethical conduct on the part of officers, directors, employees, or affiliates is in the company’s best interest. PHENOM ELITE will not compromise its principles for short-term advantages. The ethical performance of this comapny is the sum of the ethics of the men and women who work here. Thus, we are all expected to adhere to high standards of personal integrity.

Officers, directors, and employees of the company must never permit their personal interest to conflict, or appear to conflict, with the interest of the company, its clients, or affiliates. Officers, directors, and employees must be particularly careful to avoid representing PHENOM ELITE in any transaction with others with whom there is any outside business affiliation or relationship. Officers, directors, and employees shall avoid using their company contracts to advance their private business or personal interests at the expense of the company, it’s clients, or affiliates.

No bribes, kickback or other similar remuneration or considersation shall be given to any person or organization in order to attract or influcence business activity. Officers, directors, and employees shall avoid gifts, gratuities, fees, bonsuese or excessive entertainment, in order to attract or influcence business activity.

Officers, directors, and employees of PHENOM ELITE will often come into contact with, or have possession of, proprietary, confidential or business-sensitive information and must take appropriate steps to assue that such information is strictly safeguarded. This information - whether it is on behalf of our company or any of our clients or affiliates- could include strategic business plans, operating results, marketing strategies, customer lists, personnel records, upcoming acquisitions and divestitures, new investments and manufacturing costs, processes and methods. Proprietary, confidential and sensitive business information about this company, other companies, individuals, and entities should be treated with sensitivity and discretion and only be disseminated on a need-to-know basis.

Misuse of material inside information in connection with trading the company’s securities can expose an individual to civil liability and penalties. Under this ACT, directors, officers, and employees in possession of material information not available to the public are “insiders.” Spouses, friends, suppliers, brokers, and other outside the company who may have aquired the information directly or indrectly from a direcrot, officer, or employees are also “insiders.” The ACT prohibits insiders from trading in, or recommending the sale or purchase of, the company’s secruities, while such inside information is regarded as “material”, or if its is important enough to influcence you or any other person in the purchase or sale of securities of any company with which we do business, which could be affected by the inside information.

The follow guidelines should be followed in dealing with inside information: -Until the material information has been publicly released by the company, an employee must not be disclose it to anyone except those within the company whose positions require the use of the information.

-Employees must not buy or sell the company’s securities when they have knowledge of material information concerning the company until it as been disclosed to the public and the public has had sufficient time to absorb the information.

-Employees shall not buy or sell securities of another corporation, the value of which is likely to be affected by an aciton by the compnay of which the employee is aware and which has not bee pubilcly discolsed.

Officers, directors, and employees will seek to report all information accurately and honestly, and as otherwise required by applicable reporting requirements.

Officers, directors, and employees will refrain from gathering competitor intelligence by illegitimate means and refrain from acting on the knowledge that has been gathered in such a manner.

The officers, directors, and employees of PHENOM ELITE will seek to avoid exaggerating or disparaging comparisons of the services and competence of their competitors.

Officers, directors, and employees will obey all Equal Employment Opportunity laws and act with respect and responsibly towards others in all of their dealigns.

Officers, directors, and employees will remain personal balanced so that their personal life will not interfere with their ability to deliver quality products or services to the company and its clients.

Officers, directors, and employees agree to disclose unethical, dishonest, fraudulent, and illegal behavior, or the violation of company policies and procedures, directly to management.