ETHICS FOR EVERYONE AT SWARM SYSTEMS LTD

1. Our Commitment

Swarm Systems Ltd (the Company) is committed to honesty, fairness, providing a safe and healthy environment, and respecting the dignity of everyone. We are committed to observe sound environmental business practices.

2. Provide a Positive Work Environment

We will provide a work environment where people feel respected, satisfied, and appreciated. We respect cultural diversity and will not tolerate harassment or discrimination of any kind -- especially involving race, color, religion, gender, age, national origin, disability, and veteran or marital status.

Providing an environment that supports honesty, integrity, respect, trust, responsibility, and citizenship permits us the opportunity to achieve excellence in our work. Everyone involved with the Company must contribute to the creation and maintenance of such an environment, that will bring out the best in all of us.

3. Keep Accurate and Complete Records

We must maintain accurate and complete Company records. Transactions between the Company and outside individuals and organizations must be promptly and accurately entered in our books in accordance with generally accepted accounting practices and principles.

4. Obey the Law

We will conduct our business in accordance with all applicable laws and regulations.

5. Avoid Conflicts of Interest

We have an obligation to give their complete loyalty to the best interests of the Company. We should avoid any action that may involve, or may appear to involve, a conflict of interest with the Company. Nobody should have any material financial or other business relationships with suppliers, customers or competitors that might impair the independence of any judgment they may need to make on behalf of the Company. We are under a continuing obligation to disclose any situation that presents the possibility of a conflict or disparity of interest between us and the Company.

6. Compete Ethically and Fairly for Business Opportunities

We must comply with the laws and regulations that pertain to the acquisition and sale of goods and services. We will compete fairly and ethically for all business opportunities. In circumstances where there is reason to believe that the release or receipt of non-public information is unauthorized, do not attempt to obtain and do not accept such information from any source.

7. Avoid Illegal and Questionable Gifts or Favors

The sale and marketing of our products and services should always be free from even the perception that favorable treatment was sought, received, or given in exchange for the furnishing or receipt of business courtesies. We will neither give nor accept business courtesies that constitute, or could be reasonably perceived as constituting, unfair business inducements or that would violate law, regulation or policies of the Company, or could cause embarrassment to or reflect negatively on the Company's reputation. Paying bribes or kickbacks, engaging in industrial espionage, obtaining the proprietary data of a third party without authority, or gaining inside information or influence are just a few examples of what could give us an unfair competitive advantage and could result in violations of law.

8. Maintain the Integrity of our Network

Business integrity is a key standard for the selection and retention of those who represent the Company. Partners (agents, representatives, consultants, contractors and subcontractors) must certify their willingness to comply with the Company's policies and procedures and must never be retained to circumvent our values and principles.

9. Protect Proprietary Information

Proprietary Company information may not be disclosed to anyone without proper authorization. Keep proprietary documents protected and secure. In the course of normal business activities, suppliers, customers and competitors may sometimes divulge to you information that is proprietary to their business. Respect these confidences.

10. Obtain and Use Company Assets Wisely

Personal use of Company property must always be in accordance with corporate policy. Proper use of Company property, information resources, material, facilities and equipment is your responsibility. Use and maintain these assets with the utmost care and respect, guarding against waste and abuse, and never borrow or remove Company property without management's permission.

11. Create Shared Value

Create shared value not just profit per se. Create economic value in a way that shares value with our network and also creates value for society. Achieve growth by building a strong eco-system of independent, value-creating people and organisations.

12. Ask

No Code of Ethics can cover every situation that might arise in a company. This Code is designed to let you know our basic guiding principles and provide explanation on how to handle various situations. If you have questions on any situation, whether or not described in this Code, please ask. The first place to turn is your immediate supervisor or manager. If you are uncomfortable discussing a situation with your immediate supervisor or manager, you may go to anyone in management whom you feel comfortable with, including the General Counsel or CEO of the Company. We cannot stress our final point enough: "When in doubt, ask."