It has been and always will be the policy of MONAMI to conduct its business with the highest degree of integrity and honesty.Our credibility and reputation as a company are dependent on our actions as individuals. Therefore, in every business decision, employee interaction and contact with our customers, contractors, suppliers and others, it is our duty to abide by the values, policies and laws which guide our business. We are confident that consistently ethical conduct is a major factor in our success as a highly respected industry leader.

Managers are expected to understand and inform all regular and temporary employees and contractors under their supervision of this policy, ensuring that their group both abides by the letter and spirit of the law and observes the highest standards of business integrity. Managers should teach by example the exercise of sound and mature judgment in all business relationships. Because our actions during and outside work hours reflect on the reputation of the Company, employees are expected to refrain from any action or association that might embarrass or discredit MONAMI

This policy statement addresses several key areas of business conduct; however, no policy or rule can anticipate or address all situations that may arise and we will invariably encounter "gray areas" in the application of this policy. It is expected that every MONAMI employee will adhere to this standard of conduct, using his or her best judgment and seeking advice from managers, Human Resources representatives, the Legal representative or Management Support (hereinafter ‘MS’) executive to assist in decisions where the course of action is unclear. Violations will subject employees to disciplinary action up to and including termination.

MONAMI shall protect the rights of its shareholders and respect their reasonable demands and suggestions. We shall establish a mutual trust between its shareholders and investors and maximize shareholder values through disclosure of information concerning company's management and operational results.

MONAMI shall treat equally and fairly each and every shareholder including minority shareholders.We shall ensure that its management decisions are made with constant regard to the interests of all its shareholders in such a way that the interests or rights of minority shareholders are not infringed in an unfair manner.

MONAMI shall prepare and keep the accounting record according to generally accepted accounting principles to provide its interested parties with fully transparent information on its financial condition and operational results. and provide its management information in an accurate and timely manner so that users of this information such as investors are able to use it in making sensible investment decisions.

Executives and employees shall not trade the stock or other securities of a company using material non-public information about the company acquired in the course of the performance of their duties. Executives and employees shall not disclose any material non-public information about a company that could influence its stock price to any third party except through a legitimate procedure.

MONAMI is committed to achieving full customer satisfaction by conducting business from the customer's perspective and by providing the best products and services that meet customer needs and enhance their reliability. MONAMI shall provide customers with accurate information concerning its products and services and refrain from excessive advertising or PR.

MONAMI shall protect customer privacy while ensuring their interest and security, and shall not commit any act unfair to its customers. We shall respect and comply with any laws regarding consumer protection.

In competing with competitors, MONAMI shall pursue a policy of fair competition while respecting the order of the market mechanism, according to the principle of free competition. MONAMI shall adhere to the orderliness of fair trade and related laws and regulations.

MONAMI shall seek to promote mutual growth with its business partners by enhancing mutual trust and cooperative relationships through fair transactions with them. In the normal course of business, MONAMI shall not influence nor force any person to commit any illegal act through the use of its advantageous position.

Every employee at MONAMI is an important contributor to MONAMI's success. We work as a team to produce quality products and solutions that meet or exceed quality commitments and the highly reasonable expectations of our customers. In so doing, the Company is committed to recruiting, promoting and compensating employees based on their qualifications & competencies to perform job responsibilities and contribution to the Company’s success, and to prevent any form of harassment.

An Equal Opportunity Employer, the Company treats all employees fairly, without regard to age, race, national origin, religion, sex, condition of pregnancy, marital status, disability, veteran status and sexual orientation. MONAMI firmly believes that a high-quality, diverse workforce is the key to maintaining our competitive advantage.

MONAMI shall strive to create and maintain a proper working environment in order to ensure the protection of the health and safety of its executives and employees.and shall support the fostering of talents and help its employees to achieve self-realization by respecting individual self-control and creativity and providing them with equal opportunities. MONAMI shall respect the personalities and basic rights of its directors and employees while nurturing a culture in which they make suggestions and proposals freely.

Executives and employees shall not use abusive language or commit any act that harms the relationship between colleagues. This includes physical, verbal, visual language and acts which might be interpreted as sexual harrassment by any person in the organization.

It is MONAMI's policy to comply with both the letter and the spirit of all applicable civil and criminal laws and regulations governing its operations and to conduct its business so that the Company will be recognized as a good and law-abiding corporate citizen. Every employee with significant responsibilities should have a working knowledge of permissible activities involved in his or her work and where there is any question will seek guidance from a manager.

There are numerous laws which govern our conduct in almost all aspects of our business. The following is a list of areas to which specific laws apply and every employee is required to consult the appropriate Company personnel to ensure compliance with these laws. These areas include: intellectual property (patent/copyright/trademark), taxation, labor standards, securities trading, environmental matters, government contracting, corrupt practices, import/export matters, political activity, mergers and acquisitions, and many other areas.

Again, any questions concerning the application of this policy or a particular law to a specific situation should be discussed with an employee's immediate manager or the Legal representative. Any such questions may be referred to higher levels of management when necessary. Whenever there exists a potential violation of law or possible ethical compromise of a legal requirement, every employee has an obligation to avoid or to promptly correct the situation as necessary.

In certain countries it is customary and necessary to make expediting payments to assure routine administrative actions by government employees to which the Company is lawfully entitled. It is also customary in certain countries to make payments or give gifts to individuals in order to maintain the goodwill of the recipient toward the Company. Such expediting and goodwill payments and gifts are permitted under this policy provided that: (i) no single payment or gift exceeds U.S. $50.00; (ii) no individual receives payments or gifts totaling more than U.S. $500.00 in any twelve-month period; (iii) approval for the payment or gift is given by two levels of supervision above the person making the payment or gift, including the country/division manager and (iv) no such payment or gift is incorrectly or falsely entered on the Company's books and records.

MONAMI shall endeavor to contribute to the national economy and social development through improving productivity, job creation, faithful tax payment, and making contributions to society MONAMI shall protect the nature and maintain a clean environment.

Each executive and employee shall share corporate philosophy, values and goals while faithfully fulfilling their duties according to business conduct guidelines. Executives and employees shall take initiatives in creating a positive organizational culture based on communication and mutual trust between supervisors and subordinates, and between colleagues.Executives and employees shall perform their duties with integrity and in a legitimate manner while complying with any laws and regulations pertaining to the performance of their duties and company's regulations

MONAMI expects the undivided loyalty of its employees. This means that employees should be free from any interest, influence or relationship which might conflict, or appear to conflict, with the best interests of the Company or the effectiveness of their job performance.

Employees must, therefore, avoid any investment, gratuity or association which interferes, or might reasonably be thought to interfere, with their best judgment in the performance of their job duties and other actions affecting the Company. It is important to closely examine any gift, loan or other special preference offered by a person or organization that does or wants to do business with the Company. Any employee who has specific questions regarding the propriety of a particular action, including acceptance of gratuities from suppliers or contractors, should speak with his immediate manager.

The following are examples of unacceptable business practices which represent or give rise to a conflict of interest or other ethical breach: Use of a MONAMI position, or resources or confidential information gained as a result of such position, for personal gain; Acceptance of any item or service of significant value from someone doing business with MONAMI where such item is offered or appears to be offered in exchange for any type of favorable treatment or advantage;

Unauthorized outside employment or consulting which in any way affects or impacts the Company's interests; Offering any type of payments or business courtesy of significant value (e.g., entertainment, meals, transportation or lodging) to a government official, supplier or customer for the purpose of unduly influencing any government or organizational decision or obtaining favorable treatment or advantage. Conflict of interest issues can and should be resolved by informing his immediate manager and/or Legal representative of the potential conflict and obtaining a written authorization to proceed whenever required.

In our competitive environment, protection of the Company's assets is crucial. MONAMI's assets include not only physical things but also proprietary information, which includes intellectual property, internal databases, customer lists, confidential technical data, organization charts, employee directories, compensation information and other business secrets. Every employee is responsible for protecting MONAMI’s assets in general.

Executives and employees are personally responsible for protecting company's property, intellectual property rights and business secrets entrusted to them, and for supporting the protection of the company's assets in general. In addition, they shall not use them for personal purposes. Executives and employees shall not engage in any unfair transaction based on their professional position or use confidential information acquired from company for their own pecuniary or other benefit. Executives and employees shall not disclose any material information to any third party that may prejudice company's interests.

Accordingly, MONAMI's proprietary information must not be disclosed, verbally, in writing, or electronically (e.g. via the internet), unless authorized by a nondisclosure agreement. We must all guard against inadvertent loss of company property. It is critically important to be careful in speaking with all outsiders to avoid disclosure of any of the Company's technical, financial, product development and Company business secrets. We must also ensure that confidential discussions are not overheard by others or disclosed by careless transmission of electronic mail. Any documents containing proprietary information should be so marked and, when disposed of, they should be shredded. As employees of a leading technology company, we store a great deal of information on computer drives and diskettes. If any such information (such as a computer, a diskette or hard copy) is lost or stolen, it is imperative that employees report this loss immediately to their immediate manager and to Corporate HR.

Every employee records, maintains or submits some kind of information within the Company. Examples include, but are not limited to: reporting the right lines, overtime or time worked; product testing results; customer call and service reports; product order or shipment reports; financial records and expense reports. False, misleading or dishonest reporting, both inside and outside the Company, is not only strictly prohibited, it could lead to civil or even criminal liability. For example, falsification of expense reports or time records may be considered theft. Submission of false information to the government can, in some instances, lead to fines or imprisonment. Accordingly, information must be recorded or reported accurately and honestly.

Executives and employees shall not engage in any political activity during office hours and shall not use the organization itself, or the manpower and property of the company, for political activity. The right of each executive and employee to participate in political life, and his or her political opinions, shall be respected, but it is the responsibility of each executive and employee to avoid situations where the company may be mis-represented.

All MONAMI facilities are drug-free workplaces. All employees and contractors must understand that it is prohibited to possess, use or distribute illegal drugs or any controlled substance without an authorized prescription on Company premises or while performing work for the Company.

At MONAMI, ethics is everyone's business. All managers are responsible for communicating this policy to the employees under their supervision and the policy will be electronically available at all times. Any revisions or updates to this policy will be published periodically and appropriately distributed for inclusion in the on-line Human Resources reference materials (e.g. Intranet) and other appropriate locations. All MONAMI employees are required on a periodic basis to acknowledge in writing their understanding and receipt of, as well as compliance with, this policy as pertains to the business conducted in their teams/departments.

Any employee having information, knowledge or suspicion of any actual or contemplated action which is, or appears to be, in violation of this Code of Conduct is required to report the matter promptly to his or her manager, the Legal representative, the MS director established by the Company. All employees are required to recognize the critical importance of legal compliance and the Company's commitment to ethical conduct. Failure to report a known violation of law or policy may result in disciplinary action up to and including termination.

If the report is made to the employee's immediate manager, the manager shall promptly report the matter to the Legal representative or the MS Executive. In some cases, employees may report issues to the MONAMI CEO. Employees who report an actual or apparent violation of this policy will not be subject to retaliation or reprisal from any person as a result of having disclosed the violation and any such attempt at retaliation or reprisal will result in disciplinary action up to and including termination.

The expectations set forth in this Code of Conduct are both fundamental and important. The Company is committed to providing employees all resources necessary to understand and comply with its terms and the terms of the underlying laws and policies. All Code of Conduct terms should be construed in tandem with the Company's policies, procedures and other stated guidelines, and in conjunction with any applicable laws, rules or regulations. Any employee who is uncertain as to the meaning or interpretation or application of this policy to a specific situation should seek guidance from his or her immediate team manager or the MS Executive or the Legal representative..