ENDUSTRIAL SUPPORT LTD

CODE OF ETHICS AND BUSINESS CONDUCT

Introduction

The Company’s Business Ethics Policy, which is embodied in the following standards, is a guide to ethical decision-making. We are committed to uncompromising integrity in our undertakings, which we relate to each other and to people outside the Company.

While the standards in this Policy are mainly based on laws, they also reflect the values, which define our Company.

We must constantly strive to avoid any circumstances, which may create a conflict between our personal interests and those of the Company.

The standards in this Policy may be implemented, interpreted, or amended from time to time through written procedures or other compliance guidelines. This Policy and related procedures and compliance guidelines are available on our website www.endustrialsupport.com

Each of us is personally responsible for making sure that our business decisions and actions comply at all times with the spirit as well as the letter of this Policy. If we have questions about the application of a standard we should seek guidance from the Company’s legal governance. It is each employee’s responsibility to report the behavior of others to the legal governance if we have reason to believe that the behavior violates this Policy.

All supervisory and management employees, including all officers and directors of the Company, have a special responsibility to lead according to the standards in this Policy, in both words and action. Our supervisory and management employees are also expected to adhere to and promote our “open door” policy. This means that they are available to anyone with ethical or other concerns, questions or complaints. All concerns, questions and complaints will be taken seriously and handled promptly, confidentially and professionally. No retaliation will be taken against any employee for raising any concern, question or complaint in good faith.

The following standards of conduct will be enforced at all organizational levels. Anyone who violates them will be subject to prompt disciplinary action, which may include dismissal for cause.

Compliance with Laws, Rules and Regulations

Wherever we do business, employees and directors of the Company are required to comply with all applicable laws, rules and regulations. The standards in this Policy must, of course, be interpreted in the context of applicable law and practice in the countries where we operate, as well as good common sense. Any suspected or actual violation of any applicable law, rule or regulation or our contractual obligations or undertakings should be reported immediately to the Company Directors.

Conflicts of Interest

Every employee has a duty to avoid business, financial or other direct or indirect interests or relationships which conflict with the interests of Endustrial Support, or which divides his or her loyalty to Endustrial Support. Conflicts can arise from situations that benefit you directly, or from situations that have a negative impact on Endustrial Support. Any activity which even appears to present such a conflict must be avoided or terminated unless, after disclosure to the appropriate level of management, it is determined that the activity is not unethical or improper, does not compromise integrity and is not detrimental to the reputation and standing of Endustrial Support.

Examples of conflicts include the following situations:

1. Using your position in Endustrial Support to hire family members or friends, including consultants.
2. Making significant use of Endustrial Support time or resources for private personal.
3. Making significant use of Endustrial Support time, phones or computers to benefit your private business interests such as doing private research to invent patents not related to Endustrial Support’s interests, running an outside business, or day trading in shares.
4. Using your position in Endustrial Support to influence purchasing decisions for businesses you own, or which are owned by family members or friends, so that Endustrial Support pays more.
5. Using Endustrial Support resources to achieve promotions in professional or other organizations which are not work-related.
6. A personal or family interest in an enterprise that has material business dealings (e.g., competitors, suppliers, and customers) with Endustrial Support.

These situations are provided as illustrations, so this list is not comprehensive.

Human Rights

Endustrial Support acknowledges the human rights of its employees throughout the globe and endeavors to provide a safe and healthy working environment for all of its employees. Endustrial Support supports the elimination of all forms of forced, bonded or compulsory labor, the freedom of association and the right to choose a collective bargaining representative if desired. Endustrial Support further supports and upholds the elimination of discriminatory practices with respect to employment and occupation, and promotes and embraces diversity in all aspects of its business operations.

Endustrial Support is an equal opportunity employer and does not discriminate either directly or indirectly against employees or prospective employees on the basis of race, color, religion, sex, sexual preference/orientation, citizenship, marital status, veteran status, national origin, age or disability, or against any other protection established by applicable law or regulation.

Workers Rights

We are committed to ensuring that all employees are trained and aware of their entitlement to leave their position with Endustrial Support as set under the terms of their contract.

Child Labour Avoidance: Endustrial Support will not employ Persons under the age of 16years in any manner.

Wages & Benefits: Worker pay shall comply with all applicable wage laws, including those relating to minimum wages for the applicable country.

Information and Confidentiality

Information is a valuable corporate asset. All employees and directors have an obligation to safeguard confidential information about the Company and confidential information that our suppliers and customers have entrusted to us. Generally speaking, confidential information is information that has not been disclosed to the general public or that gives our business an advantage over our competitors or could expose us to harm or liability if released prematurely or inappropriately.

Employees and directors must remain conscious at all times of their obligation to protect confidential information against unauthorized disclosure. In no event should confidential information be disclosed to third parties in violation of the Company’s Policy and Procedure on Confidential Information. This is an obligation not limited to the duration of employment or service; the obligation continues after an employee or director leaves the Company.

Bribery and Corruption

Commercial bribery of any nature is a violation of Company policy and is unlawful. Employees are strictly prohibited from offering any form of bribe, kickback, or other like payment to any person.

The Company’s books and records must accurately and fairly present the results of operations and the financial condition of the Company. False or misleading entries are strictly prohibited, and the Company will not condone any undisclosed liabilities or unrecorded bank accounts or other unrecorded assets established for any purpose.

No employee may authorize payment of Company funds knowing that any part of the payment will be used for any purpose other than the purpose described in the documents supporting the payment.

Fair Dealing

The Company is committed to having its employees deal fairly and honestly with the Company’s customers, suppliers, competitors and other employees.

Proper Use of Company Assets

Safeguarding the Company’s assets and the assets of others entrusted to the Company is the responsibility of all employees and directors. Company resources, including time, material, equipment and information, are provided for company business use. Nonetheless, occasional personal use is permissible as long as it does not affect job performance or cause a disruption to the workplace. Employees and those who represent Endustrial Support are trusted to behave responsibly and use good judgment to conserve company resources. Managers are responsible for the resources assigned to their departments and are empowered to resolve issues concerning their proper use. Generally, we will not use company equipment such as computers, copiers and fax machines in the conduct of an outside business or in support of any religious, political or other outside daily activity. Solicitation of Company employees by non-employees is prohibited at all times. Solicitation by an employee of another employee is prohibited, while either the person doing the soliciting or the person being solicited is on working time and or Company property. Distribution of materials by employees in work areas or on working time is prohibited.

In order to protect the interests of Endustrial Support and our fellow employees, we reserve the right to monitor or review all data and information contained on an employee’s company-issued computer or electronic device, the use of the Internet or Endustrial Support’s intranet. We will not tolerate the use of company resources to create, access, store, print, solicit or send any materials that are harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate.

Government Officials/Employees – Gifts, Payments, Etc.

Countries have laws or rules, which impose restrictions on the value of any gift, which we may wish to make to government officials and employees. It is the policy of the Company to comply with all of those laws and rules.

Annual Compliance Certificates; Investigations; Disciplinary Action

Each management employee will be required to review this Policy and discuss it with his or her direct reports at least once annually and to affirm compliance with this Policy annually in writing. Allegations of potential wrongdoing will be investigated promptly and will be reported to the Audit Committee of the Board of Directors. All employees are required to cooperate fully with any internal or external investigation. Employees must also maintain the confidentiality of any investigation and related documentation unless specifically authorized.

Reporting and Queries

Employees or directors who have questions about this Policy should contact our General Counsel for guidance without fear of retaliation. If you have reason to believe that an actual or potential violation of this Policy is occurring or has occurred, you should contact our General Counsel immediately, again without fear of retaliation.