WASÉYABEK FEDERAL SERVICES CODE OF CONDUCT

The Waséyabek Federal Services (WFS) Code of Conduct outlines expected behaviors
for all WFS employees. WFS will conduct its business fairly, impartially, in an ethical and
proper manner, and in full compliance with all applicable laws and regulations. Integrity
must underlie all company relationships, including those with customers, suppliers,
communities and among employees. Employees will not engage in conduct or activity
that may raise questions as to the company’s honesty, impartiality, reputation or
otherwise cause embarrassment to the company. Nothing in this policy, however,
prohibits an employee from discussing information about wages or other terms and
conditions of employment.

Employees will ensure that:

• They do not engage in any activity that might create a conflict of interest for the
company or for themselves individually.

• They do not take advantage of their WFS position to seek personal gain through the
inappropriate use of WFS non-public information or abuse of their position. This
includes not engaging in insider trading.

• They will follow all restrictions on use and disclosure of information. This includes
following all requirements for protecting WFS information and ensuring that non-
WFS proprietary information is used and disclosed only as authorized by the owner
of the information or as otherwise permitted by law.

• They observe that fair dealing is the foundation for all of our transactions and
interactions.

• They will protect all company, customer and supplier assets and use them only for
appropriate company-approved activities.

• Without exception, they will comply with all applicable laws, rules and regulations.

• They will promptly report any illegal or unethical conduct to management or other
appropriate authorities (i.e., Ethics, Law, Security, or EEOC).

Every employee has the responsibility to ask questions, seek guidance and report
suspected violations of this Code of Conduct. Retaliation against employees who come
forward to raise concerns will not be tolerated.

1
UNETHICAL BEHAVIOR
It is not possible in a general policy statement to define all the various circumstances
and relationships that would be considered "unethical.” The list below demonstrates
some of the types of activity that would be considered unethical:

• Simultaneous employment by a competitor, customer, vendor or supplier of WFS;

• Holding a substantial interest in, or participating in the management of, a firm to
which WFS sells to or purchases from;

• Borrowing money or other items of significant value from customers or firms,

other than recognized loan institutions, from which WFS buys services,
materials, equipment, or supplies;

• Accepting gifts or entertainment from a customer or from an outside organization

or agency that is in any way involved with WFS;

• Speculating or dealing in materials, equipment, supplies, services, or property

purchased by WFS;
• Participating in civic or professional organization activities in a manner
whereby WFS’s confidential information is divulged;

• Misusing privileged information or revealing confidential data to outsiders; or

• Using one's position in WFS or knowledge of its affairs for outside personal gain.
Employees are expected to conduct themselves ethically at all times. Employees
must refrain from taking part in, or exerting influence in, any transaction in which
their own interests may conflict with the best interests of WFS. Engaging in
unethical behavior, as determined in the sole discretion of WFS, may result in
disciplinary action, up to and including termination.