Accountant Anywhere (AA) team members including Directors, officers and employees are committed to the following code of conduct.

GENERAL

AA is committed to upholding the highest standards of conduct. AA’s code of conduct is reflective of this policy. The code of conduct, improved from time to time, applies to all Directors, officers and employees. The standards are not exhaustive. The underlying principles of high standards apply to all issues even if they are not covered specifically in the standards. Directors, Officers and Employees are expected to bring all violations to the attention of any non-executive member of the Board of Directors.

CORPORATE CITIZENSHIP

AA shall be a good corporate citizen and shall comply with the letter and spirit of all laws governing its operations, conduct its affairs in accordance with best moral, professional, legal and ethical standards. AA shall deal with customers, suppliers, government, employees, competitors and community in a fair manner with honesty, integrity and ethics. AA shall not strive to take unfair advantage through any unfair practice.

FAIR BEHAVIOR IN MARKET PLACE

AA is committed to add value to clients business in the market place. However, AA shall be lawful and fair while being competitive. AA shall not indulge in violating laws applicable to competitive behaviour (anti-trust laws, for example). AA shall not indulge in securing competitive advantage through illegal or unlawful means. Collection of intelligence about competition shall be through lawful means alone. AA respects the intellectual property rights of its customers, suppliers and competitors at all times. AA holds strict compliance related to intellectual property rights and shall strive to comply with laws that apply to its principal market, the United States of America in addition to the laws that apply to its place of operation.

FINANCIAL INTEGRITY AND REPORTING

AA shall maintain its accounts and report financial results in a true and fair manner consistent with US GAAP in addition to applicable financial standards. AA shall maintain sufficient business and reporting controls consistent with its size to protect company and shareholders’ interest. AA will not falsify records or reports.

EQUAL OPPORTUNITY EMPLOYER

AA is an equal opportunity employer. AA shall not discriminate on the basis of gender, nationality, race, colour, religion, marital status or age. AA believes diversity of people in the company adds value to the business. Hiring, promotion and compensation decisions shall be entirely based on fitment, appropriateness to work demands and market conditions alone.

HEALTH AND SAFETY

AA shall strive to provide and maintain a safe and healthy work environment. Compliance with all health and safety related law and regulations are a minimum commitment. AA expects its directors; officers and employees to be aware of the health and safety policies and practices and help all customers, contractors, and visitors comply with these policies and practices while in AA premises or while working on behalf of AA.

AA Directors, officers, employees and contractors designated to work in customer or supplier environments shall comply with the health and safety policies and practices in force in such environments. All accidents, however minor, are reportable to HR.

ENVIRONMENT

AA shall comply with all laws and regulations relating to protection of Environment. AA shall co-operate to the maximum extent with the Community in protecting the environment. AA shall comply with all record keeping and reporting obligations. AA cherishes the need to keep our environment sustained for the future.