CODE OF ETHICS

•   We serve our clients with integrity, competence and objectivity •   We keep client information and records of client engagements confidential and a Non-Disclosure policy is in place in every case •   We only use client proprietary Information with the client's permission while we conduct services on their behalf •   We will not abuse our client's trust by taking advantage of confidential information for the benefits of our firm, other clients or ourselves •   We will not engage in any direct or indirect conflict of interests activities between our clients. We will only become involved with more than one client, who may be in competition with the knowledge of and in some cases with the client's prior permission

•   We will only accept the engagements for which we are qualified by our experience and competence. •   From time-to-time, we will invite our Business Alliances or outside experts to jointly work with us on some special cases that it requires different expertise. We would not engage in such activities without our client's prior approval •   We will only assign and match our consultants with clients based on the confidence of the consultant's knowledge, experience and expertise in the area that client requires

•   We will respect the intellectual property rights of our clients, other consulting firms and sole practitioners and will not use proprietary information or methodologies without permission •   We will not advertise our services in a deceptive manner and will not misrepresent the consulting profession, consulting firms or sole practitioners Any misbehavior or breach of this Code of Ethics will be reported to the Institute of Management Consultants in New York