Ineo Tech will conduct its business honestly and ethically whenever we operate in the world. We will constantly improve the quality of our product and services and will create a reputation for honestly, fairness, respect, responsibility, integrity, trust and sound business judgement. No illegal or unethical conduct on the part of officers, directors, employee or affiliates is in the company’s best interest. Ineo Tech will not compromise its principles for short-term advantages. The ethical performance of our company 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.

a. Directors and employees of the company must never permit their personnel interested to conflict, or appear to conflict, with the interests of the company, its client or affiliates.

b. Directors and employees must be particularly careful to avoid representing Ineo Tech in any transaction with others with whom there is any outside business affiliation or relationship.

c. Directors and employees shall avoid using their company contacts to advance their private business or personal interests at the expense of the company, its clients or affiliates.

d. No bribes, kickbacks or others similar remuneration or consideration shall be given to any person or organization in order to attract or influence business activity. Directors and employees shall avoid gift, gratuities, fees, bonuses or excessive entertainment, in order to attract or influence business activity.

e. Directors and employees of Ineo Tech will often come into contact with, or have possession of, propriety, confidential or business – sensitive information and must take appropriate steps to assure that such information is strictly safeguarded. This information- whenever it is on behalf of our company or any of our client or affiliates- could include strategic business plan, operating results, marketing strategies, customer list, personnel records, upcoming acquisitions and divestitures, new investments, and manufacturing costs, processes and methods. Propriety, confidential and sensitive business information about this company, others companies, individuals and entities should be treated with sensitivity and discretion and only be disseminated on a need-to know basis.

f. Misuse of material inside information in connection with trading in the company’s securities can expose an individual to civil liability and penalties under applicable Securities Law. Under this law, directors and employees in possession of material information not available to the public are insider trading. The act prohibit insiders from trading in, or recommending the sales or purchase of, the company securities, while such inside information is regarded as material, or if it is important enough to influence 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 following guidelines should be followed in dealing with inside information:

i. Until the material information has been publicly released by the company, an employees must not disclose it to anyone except those within the company whose positions require use of the information.

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

iii. Employees shall not buy or sell securities of another corporation, the value of which is likely to be affected by an action by the company of which the employee is aware and which has not been publicly disclosed.

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

h. Directors and employees will refrain from gathering competitor intelligence by illegitimate means and refrain from acting on knowledge which has been gathered in such a manner. The Directors and employees of Ineo Tech will seek to avoid exaggerating or disparaging companies of the services and competence of their competitors.

i. Directors and employees will remain personally balances so that their personnel life will not interfere with their ability to deliver quality product or services to the company and its clients. Directors and employees agree to disclose unethical, dishonest, fraudulent and illegal behavior, or the violation of company policies and procedures, directly to management.

Violation of this code of ethics can results in discipline, including possible termination. The degree of discipline relates in part to whether there was a voluntary disclosure of any ethical violation and whether remember that good ethics is good business.