ETHICAL CODE

Expert IT Service Grup SRL

(hereinafter: "Expert IT")

1. Purposes of the ethical code

Expert IT is committed to fair, moral and appropriate business behavior; its employees are
obliged to act in accordance with ethical and moral standards and principles, amongst themselves
as well as with all 3rd parties, including Expert IT's suppliers and other debtors. In accordance
with this, an Ethical code has been drawn up, composed of a general code of conduct to assure
that the employees and management of Expert IT will adhere to these criteria. It is understood
that the ethical code can’t, and doesn’t attempt to encompass all obligatory conduct; having said
this, the values and principles included will be able to guide the decision making process even in
situations which are not explicitly dealt with.

2. Adherence to the law, company practice and enforcement policy of Expert IT

Expert IT emphasizes that the Ethical Code isn’t meant to replace any law, statute or professional
guidelines applying to Expert IT and/or its employees. Adherence to the Ethical Code is an
integral part of the Ethical Code. The same applies to Company policy whose existence is an
integral part of the Ethical Code.

3. Conflict of interest
Expert IT employees are required to act and reach decisions having only the interests of The
Company in mind. In accordance with this, every employee should refrain from acting in a way
that
could be seen as a conflict of interest between his position in Expert IT and his /his relatives
personal affairs and/or other position. An employee must immediately disclose to his manager all
information pertaining to the possible conflict of interest. An employee who must reach a
decision
regarding a matter that he/his relatives will benefit from must pass this decision to his manager.
An employee should also refrain from making personal business connections with sources which
are
connected to Expert IT and his position in Expert IT. It should be clarified that the prohibition
of a conflict of interest applies not only to concrete situations, but also to situations where there
might
be a concern of conflict of interest, meaning situations which will not allow the employee to
reach
decisions having only Expert IT's best interest in mind.

4. Conducting business with integrity, fairness, credibility and respect for all people
Expert IT employees are obliged:
- To respect all people without prejudice; to respect all clients, partners, suppliers, competitors
and amongst themselves.
- To avoid fraud and deception, to conduct relationships based on mutual trust between
themselves and others.
- To sustain Expert IT's contractual and business obligations, and fulfill all undertakings made
during the course of business.
- To refrain from breaching competitors property rights, and the use of illegal conduct in order to
harm competition.

5. Personal liability, initiative and involvement, and cooperation in order to achieve Expert IT's
business goals.
Expert IT strives to attain, in full partnership with its employees Expert IT's goals and success. In
accordance with this, Expert IT strives that all its employees will truly identify itself with Expert
IT, and promote this feeling amongst all its employees. All employees must act with integrity
and fairness towards Expert IT and take personal responsibility and initiative to advance Expert
IT. Each and every employee should adhere to truthful and transparent reporting within Expert
IT and outside it.

6. Business opportunity exploitation and competition with Expert IT

All employees shall refrain from acting in a way which can be conceived as business opportunity

exploitation and/or any act which can be seen as company competition. Information brought to
the
attention of an employee during the course of business shall only be used for the purposes that
the
information was passed to him, and not in order to receive personal/3rd party benefits. An
employee
must always have Expert IT's best interests in mind when dealing with 3rd parties and no
intentions to exploit information, contacts or any other business opportunity for his personal
gain.
An employee must also refrain from using Expert IT's reputation or assets (including trade
secrets) for his personal gain.

7. Gifts and Benefits

In order to avoid situations where external considerations guide an employee, employees must
not
accept money, equivalent to money, services or any other benefits from organizations who do
business with Expert IT/could potentially do business with Expert IT; this excludes situations
which are expressly allowed under Expert IT regulations.

8. Maintaining confidentiality
All Employees are obliged to maintain confidentiality regarding all information brought to their
attention
throughout the course of their employment, regardless of the source, including information
regarding
suppliers, co workers etc. Employees are only allowed to make use of information for the
purposes to
which it was brought to their attention and to the extent necessary. The abovementioned doesn’t
apply
to situations where the disclosure is permitted by the relevant authorities, mandatory by law, or
the
information is universally known. This guideline must be upheld even after termination of
employment.

9. Protection of Expert IT assets

The use of Expert IT assets, both tangible (such as phones and office supplies) and intangible
(such as intellectual property) should be used with efficiency and for suitable business purposes
only.
It should be remembered that the use of assets in an inefficient manner or for personal purposes
will have consequences on Expert IT's profit.

10. Consulting relevant company body

In case of doubt regarding how to act or which decision to reach, an employee should consult the
relevant Company body, be it his superior or other professional body.

11. Delegation of authority

Delegation of authority shall be done in a clear and proper manner, in accordance with Company
policy. It is the delegator's responsibility to use good judgment with regards to the person
delegated to
and the scope of delegation. Delegation of authority doesn’t eliminate the delegator's
responsibility, and he should supervise the person delegated to on a regular basis.

12. Use of authority

An employee shall not create any liabilities in name of Expert IT unless expressly authorized by
Expert IT.

13. Conduct at the workplace

Proper conduct and representation of Expert IT should be upheld at all times. All employees
should take care of their appearance according to their position in Expert IT. A nice, calm and
respectful atmosphere should be maintained at all times. Company employees will act in a polite
and
respectful manner towards their co-workers and all others. Verbal/physical violence and any
other form
of threat or harassment is strictly prohibited. All employees will execute their work in a
professional, efficient and reliable manner, in collaboration with their co-workers and other
Company units.

14. Involvement in community

Expert IT places a high emphasis on community involvement and donates to various causes on
a regular basis. Expert IT encourages employees to volunteer and give back to the community,
which is in line with Expert IT's commitment to social responsibility.

15. Transparency and reliability regarding company publications

Expert IT pays high regard to transparency and reliability regarding its publications and reports
(including financial statements) to the public and the authorities.

16. Corporate governance

Corporate governance principles refer to the management's work in relation to the board, the
audit
committee, the shareholders and the relevant stakeholders, by agreeing to an audit mechanism,
supervision, transparency and reporting.
* Expert IT has internal and external auditing, who supervise and verify that Expert IT is
meeting all its legal requirements and regulations.
* Expert IT holds Board meetings and committee meetings as required, and pays attention to all
the approvals from the relevant bodies.

17. Implementation of the ethical code

All Company employees are obliged to uphold the ethical code. In addition, an employee who
has
reservations regarding another co-workers behavior, be it breach of law, guidelines by certified
bodies
and/or the ethical code, is obliged to immediately report this to Expert IT manager or to the body
in
charge of the ethical code. Breach of the ethical code may have serious repercussions, including
dismissal or in serious cases even criminal charges. Expert IT operates on a regular basis to
implement this ethical code amongst both its current and new employees, by setting examples
through Company management and drawing conclusions from previous events.