Corporate Code of Conduct

The success of Prism Systems is dependent on the trust and confidence we earn from our employees and customers. We gain credibility by adhering to our commitments, displaying honesty and integrity and reaching company goals solely through honorable conduct. At Prism Systems everyone should feel comfortable to speak their mind, particularly with respect to ethics concerns. Managers have a responsibility to create an open and supportive environment where employees feel comfortable raising such questions. Everyone benefits when employees exercise their power to prevent mistakes or wrongdoing by asking the right questions at the right times.

Prism Systems will investigate all reported instances of questionable or unethical behavior. In every case where improper behavior is found to have occurred, the company will take appropriate action. We will not tolerate retaliation against employees who raise genuine ethics concerns in good faith. Employees are encouraged to address such issues with their immediate supervisor as most problems can be resolved swiftly. If for any reason that is not possible or, if an employee is not comfortable raising the issue with their immediate supervisor, the employee can raise their concerns with any member of the management team.

Management has the added responsibility for demonstrating, through their actions, the importance of this Code. In any business, ethical behavior is the product of clear and direct communication of behavioral expectations, modeled from the top and demonstrated by example. Managers must promptly address ethical questions or concerns raised by employees and take the appropriate steps to deal with such issues. Managers should not consider employees’ ethics concerns as threats or challenges to their authority, but rather as another encouraged form of business communication.

Uphold the Law

Our commitment to integrity begins with complying with the laws, rules and regulations where we do business. Further, each of us must have an understanding of the company policies, laws, rules and regulations that apply to our specific roles. If we are unsure whether a contemplated action is permitted by law or policy, we should seek advice from our immediate supervisor. We are all responsible for preventing violations of law and for raising concerns if we see possible violations.

Prohibition of Corruption and Bribery

Prism Systems will tolerate no form of, and not engage, directly or indirectly, in any form of corruption or bribery and not grant, offer or promise anything of value to a government official or to a counterparty in the private sector in order to influence official action or obtain an improper advantage.

Fair Competition and Anti-Trust Laws

We are dedicated to ethical, fair and vigorous competition. We will sell Prism Systems products and services based on their merit, superior quality, functionality and competitive pricing. We will make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our competitors. We will not offer or solicit improper payments or gratuities in connection with the purchase of goods or services for Prism Systems or the sales of its products or services, nor will we engage or assist in unlawful boycotts of particular customers.

Intellectual Property Rights

Integral to our business success is the protection of confidential company information, as well as nonpublic information entrusted to us by employees, customers and other business partners. Confidential and proprietary information includes such items as pricing and financial data, customer names/addresses or nonpublic information about other companies, including current or potential suppliers and vendors. We will not disclose confidential and nonpublic information without a valid business purpose and proper authorization.

It is important that we respect the property rights of others. We will not acquire or seek to acquire by improper means a competitor’s trade secrets or other proprietary or confidential information. We will not engage in the unauthorized use, copying, distribution or alteration of software or other intellectual property.

Conflicts of Interest

We must avoid any relationship or activity that might impair, or even appear to impair, our ability to make objective and fair decisions when performing our jobs. We must at all times avoid any conflicts of interest that may adversely influence business relationships. Occasionally, we may be faced with situations where the business actions we take on behalf of Prism Systems may conflict with our own personal or family interests. We owe a duty to Prism Systems to advance its legitimate interests when the opportunity to do so arises. We must never use Prism Systems property or information for personal gain or personally take for ourselves any opportunity that is discovered through our position with the company. Employees with a conflict of interest question should seek advice from their immediate supervisor or any member of the management team before engaging in any activity, transaction or relationship that might give rise to a conflict of interest.

We are committed to competing solely on the merit of our products and services. We should avoid any actions that create a perception that favorable treatment of outside entities was sought, received or given in exchange for personal business courtesies. Business courtesies include gifts, gratuities, meals, refreshments, entertainment or other benefits from persons or companies with whom we conduct or may conduct business. We will neither give nor accept business courtesies that constitute, or could reasonably be perceived as constituting, unfair business inducements that would violate law, regulation or policies of Prism Systems or customers, or would cause embarrassment or reflect negatively on our reputation.

Respect for the Individual

We all deserve to work in an environment where we are treated with dignity and respect. Prism Systems is committed to creating such an environment as it brings out the full potential in each of us which, in turn, contributes directly to our business success. To this end Prism Systems will:

• Promote equal opportunities for and treatment of its employees irrespective of skin color, race, nationality, social background, disabilities, sexual orientation, political or religious conviction, sex or age;
• Respect the personal dignity, privacy and rights of each individual;
• Refuse to employ or make anyone work against their will;
• Refuse to tolerate any unacceptable treatment of employees, such as mental cruelty, sexual harassment or discrimination;
• Prohibit behavior including gestures, language and physical contact, that is sexual, coercive, threatening, abusive or exploitative;
• Provide fair remuneration and to guarantee the applicable national statutory minimum wage;
• Comply with the maximum number of working hours laid down in the applicable laws;
• Recognize, as far as legally possible, the right of free association of employees and to neither favor nor discriminate against members of employee organizations or trade unions.

Prism Systems is an equal employment/affirmative action employer and is committed to providing a workplace that is free of discrimination of all types and from abusive, offensive or harassing behavior. Any employee who feels harassed or discriminated against should report the incident to their immediate supervisor or to any member of the management team.

Prohibition of Child Labor

We will not employ workers under the age of fifteen (15) or, in those countries subject to the developing country exception of the International Labour Organisation (ILO) Convention 138, workers under the age of fourteen (14).

Health and Safety

Prism Systems is dedicated to maintaining a healthy work environment. The company safety manual has been developed to provide information and instructions to ensure your safety in the workplace. As a fundamental component of our safety commitment, Prism Systems will:

• take responsibility for the health and safety of all its employees;
• control hazards and take the best reasonably possible precautionary measures against accidents and occupational diseases;
• provide training and ensure that employees are educated in health and safety issues.

Employees are encouraged to raise any safety concerns or questions about the workplace with their immediate supervisor or any member of the management team.

Environmental Protection

We will act in accordance with the applicable statutory and international standards regarding environmental protection. We will additionally work to minimize environmental pollution and make continuous improvements in environmental protection.

Supply Chain

We will use all reasonable efforts to promote among our suppliers’ compliance with this Code of Conduct and we will comply with the principles of non-discrimination with regard to supplier selection and treatment.

Conflict Minerals

We will take all reasonable efforts to avoid in its products the use of raw materials which directly or indirectly finance armed groups who violate human rights.