Standards of Business Conduct
The Solvis Group Standards of Business Conduct embody the fundamentalprinciples that govern our ethical and legal obligations to The SolvisGroup . They pertain not only to our conduct within the company butalso to conduct involving our customers, partners, employees,suppliers, and competitors.

Compliance

TheSolvis Group conducts its business with uncompromising integrity. Everymember of our Company -- directors, executives, managers, employees andbusiness partners - has a duty to comply with all applicable law andadhere to the highest standards of business ethics.

These Standards of Business Conduct set forth fundamental principlesof law and ethics governing the way that The Solvis Group doesbusiness. These Standards are not the exclusive source of guidance andinformation on The Solvis Group 's expectations, but they serve as thebasis for other The Solvis Group policies and guidelines.

•Employees. The Solvis Group employees at every level must comply withthese Standards, and associated policies and guidelines. Failure to doso is considered misconduct and may lead to termination of employment.In particular, all executive officers and senior financial officers,their staffs, and all managers and other employees contributing to TheSolvis Group 's financial record-keeping must comply strictly with TheSolvis Group finance and accounting standards, policies and guidelines.
Board of Directors. Members of the The Solvis Group board of directorsare subject to these Standards as well as additional guidance relatingto their special responsibilities.
Suppliers & Partners. The Solvis Group requires its suppliers,including consultants and contractors, and partners to conduct theirbusinesses in a legal and ethical manner.
Personal Responsibility
The Standards of Business Conduct do not, by themselves, ensure ethicalconduct. Every member of the The Solvis Group community has a personalresponsibility to embody and model ethical behavior. The Solvis Groupexecutives and other managers are responsible to lead by example and toensure that all team members learn and have the opportunity to discussthe practical application of these Standards. Managers are expected toreview these Standards with their teams on at least an annual basis.Everyone has a duty to be vigilant for circumstances that may indicateillegal or unethical behavior, and to act appropriately in a timelymanner to prevent improper conduct. Any waivers of these Standards ofBusiness Conduct for The Solvis Group executive officers or directorswill only be granted by the The Solvis Group board of directors inexceptional circumstances and will be disclosed promptly toshareholders.

Reporting Violations

Ifyou observe possible illegal or unethical conduct, you should report itto The Solvis Group management It is The Solvis Group 's policy that noemployee will suffer adverse action for honestly raising an ethical orlegal concern. Reporting on an anonymous basis is available via thecontact information set forth below.

The following violation reporting mechanisms are available to you:

The Solvis Group CA
6185 Paseo Del Norte
200A
Carlsbad, CA 92011

Phone: 760-930-9530
Fax: 858.277.3448
Email: This e-mail address is being protected from spam bots, you need JavaScript enabled to view it

The Solvis Group MI
17250 W 12 Mile Rd
2nd Floor
Southfield, MI 48076

Phone: 248-559-6610
Fax: 248-559-6611
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Conducting The Solvis Group Business
Serving The Solvis Group Customers
Relating to The Solvis Group Competitors
Dealing with The Solvis Group Suppliers
Avoiding Conflicts of Interest
Handling Sensitive Information
Safeguarding The Solvis Group Assets
Respecting Dalrad's Colleagues & the Community

Conducting The Solvis Group Business

The Solvis Group conducts its business fairly, legally and withintegrity. While working for the best interests of The Solvis Group ,you have a duty to be ethical and lawful in your dealings with customers, partners, suppliers, other business partners and competitors, as well as your The Solvis Group colleagues.

Contracting Practices

WhenThe Solvis Group is selling or buying products and services, orentering into other commitments, The Solvis Group needs to embody therights and obligations of each party in appropriate written contracts.This practice builds strong business relationships and ensures accurate company record-keeping. If you have dealings with The Solvis Group customers, suppliers, business partners, or outside parties, you arerequired to understand basic principles of business transactions and to abide by The Solvis Group contracting policies and guidelines.

Authorization.You may not commit The Solvis Group to undertake any performance,payment or other obligation unless you are authorized under the appropriate The Solvis Group delegation of authority policies.

Contracts. Properly written contracts document the use of The SolvisGroup funds and assets; define the rights and obligations of The SolvisGroup and other parties; establish protections against liability; andprovide tools for handling disputes. You may not enter into any agreement or engage in any activity that may violate applicable law. You may not use side letters, "off-the-books" arrangements, or other express or implied agreements outside standard The Solvis Group contracting processes. You may not use letters of intent or memoranda of understanding without prior review by The Solvis Group Legal.

Sham Transactions. You may not enter into any transaction with acustomer, supplier, or other business partner that facilitates improper revenue recognition, expense treatment or other accounting improprieties on the part of either The Solvis Group or the businessp artner.

Antitrust & Competition

Antitrust and competition laws serve to maintain an environment inwhich companies compete fairly at all levels. You have a responsibility to The Solvis Group to ensure that your business activities do not violate applicable antitrust and competition laws.

Business Gifts & Entertainment

From time to time, The Solvis Group may provide business amenities, or allow employees to accept business amenities, to aid in building legitimate business relationships. Business amenities include any gift, meal, service, entertainment, reimbursement, loan, favor, or anything else of value.

Your decisions on behalf of The Solvis Group must be free from undue influence. You may not provide or receive business amenities when doing so may create the appearance of undue influence. This restriction applies to amenities given to or received from representatives of current or potential customers, partners,suppliers, and competitors, as well as their families, your family, and others with whom you or they have close personal relationships.

Ifyou are unsure whether you may give or accept a proposed gift,entertainment or other business amenity, you should disclose thesituation to your manager.

Anti-Corruption

No one acting on The Solvis Group 's behalf may use bribes, kickbacks orother corrupt practices in conducting The Solvis Group business. You are required to comply strictly with all ethical standards andapplicable law in every jurisdiction in which The Solvis Group does business.

Commissions & Finder Fees. You may make commission or fee arrangements only under written agreements with bona fide commercial distributors, sales representatives, agents or consultants. Any commission or finder fee for assistance in securing orders must be reasonable and consistent with local laws and normal industry practice. You may not enter into any fee arrangements with any entity in which a government official or employee has an interest, or with respect to sales to a government, unless permitted by law and with written approval from The Solvis Group 's General Counsel. You may not pay any commission or compensation to employees or other representatives of customers, channel partners, suppliers, other business partners or competitors. An exception is made for openly announced incentive programs, such as sales contests, approved in writing by an appropriate The Solvis Group Vice President.

Serving The Solvis Group Customers

The Solvis Group wins and maintains customer relationships based on thequality and value of its products and services. Your duty is to deal fairly and truthfully with our customers, and provide the best service that you can.

Advertising Practices

Advertising laws are not uniform, but in general, statements in The Solvis Group advertising and promotional materials need to be fair, factual, and complete. To support The Solvis Group's marketing strategy and to comply with applicable law, you need to abide by the policies and guidelines of The Solvis Group and to consult The Solvis Group Legal as necessary.

Marketing & Sales Practices

The Solvis Group marketing and sales practices reflect The Solvis Group's commitment to honest and fair dealings with its current and potential customers. You may not engage in any misleading or deceptive marketing and sales practices.

Deceptive Statements. You may not make false or misleading statements about The Solvis Group products or services, or those of competitors, in marketing or sales activities.

Customer Information. The Solvis Group has the responsibility to safeguard and use properly, including storage and transmission, personal data that it collects from current and potential customers.

Relating to The Solvis Group Competitors

The Solvis Group succeeds by competing vigorously and fairly in the marketplace in full compliance with applicable antitrust, competitionand other laws. Your interactions with The Solvis Group competitorsmust be fair and respect the law.

Dealings with Competitors

There are many occasions to interact with competitors. Antitrust and competition laws generally prohibit agreements between competitors that would eliminate or restrict their competition with each other. You are responsible for avoiding contacts with competitors that may beconstrued to violate antitrust or competition law principles. If youhave any questions about contacts with competitors, contact The SolvisGroup Legal.

Prohibited Agreements and Topicsof Discussion. You may not make agreements, express or implied, withany The Solvis Group competitor to set prices, divide territories, orallocate customers for competing products or services. You may notdiscuss with competitors any non-public or future price information,terms of sale, costs, margins, marketing plans, or similar confidentialinformation.
Trade Associations. When representing The Solvis Groupin trade associations, standard setting bodies, consortia and otherindustry organizations, you need to be aware of the risk that theparticipating companies may be perceived as using the meetings to reachanti-competitive agreements. You may not participate in groups engagingin activities that violate antitrust and competition laws. If acompetitor uses a legitimate forum to discuss subjects that areprohibited, you must refuse to participate, and if the discussioncontinues, you must leave the meeting immediately and noticeably.Before you join any group involving competitors, or if the charter of agroup changes, you need to review the situation with The Solvis GroupLegal.
Competitive Information
The Solvis Group must have timely and complete information aboutindustry developments in order to stay competitive. You may obtaincompetitive information only by fair and legal methods.

PublicInformation. You may review any public information, such as publishedspecifications, trade journal articles, and other materials that acompetitor has released to other companies without restrictions.
Non-public Information. You may not obtain non-public information byillegal activities involving industrial espionage or by asking acompetitor's employees or contractors, or former employees orcontractors, to violate their obligations regarding the competitor'sconfidential data. You may not examine information about competitiveproposals or products that was submitted to customers, suppliers, otherbusiness partners or anyone else with the understanding they wouldtreat it as confidential. Contact The Solvis Group Legal if you haveany question about The Solvis Group 's right to use any particularinformation.
Improper Tactics. You may not misrepresent who you are or for whom youwork when you ask for competitive information. You may not use orengage consultants, agents, friends or others to undertake activitiesto obtain competitive information that would be unacceptable if pursuedby you.
Competitive Practices
The Solvis Group competes aggressively in the marketplace, but not inviolation of the law or at the expense of its reputation for fairdealing. You are responsible for conducting The Solvis Group businessin a professional, ethical and legal manner.

Commentingon the Competition. The Solvis Group competes based on the quality andvalue of its products and services, not by disparaging the competition.Your statements about competitors need to be fair, factual andcomplete. While forceful marketing messages may be appropriate, you maynot make false, misleading, unfair or unprofessional comments aboutcompetitors or others outside The Solvis Group , even in messages,presentations and other materials intended for internal use at TheSolvis Group .
Interference with Contracts. Once a customer hasplaced a firm order with a competitor, you may not engage in activitiesto interfere with the performance of that contract.

Dealing with The Solvis Group Suppliers
The Solvis Group suppliers are of great strategic importance. Whenbuying products and services, you have a duty to deal with suppliersfairly and in compliance with applicable law and The Solvis Grouppolicies. Suppliers include indirect goods and service providers,consultants, contractors, and anyone else who provides a product orservice to The Solvis Group .

Choosing Suppliers

TheSolvis Group selects suppliers based on the merits of their products,services, and business practices. You are required to follow The SolvisGroup policies in choosing suppliers on a basis that serves The SolvisGroup 's interests and protects The Solvis Group 's reputation.

Selection.The Solvis Group purchasing decisions should reflect your best judgmentabout a supplier's technology, quality, responsiveness, deliverycapabilities, cost, environmental performance, and financial stability.You may not establish a business relationship with any supplier if itsbusiness practices violate local laws or basic international principlesrelating to labor standards or environmental protection.
Conflictsof Interest. In selecting suppliers, you need to avoid any appearanceof impropriety that might result because of business gifts orentertainment from a supplier, or even strong personal relationshipsbetween the representatives of a supplier and representatives of TheSolvis Group .
Small and Minority Businesses. In the U.S., you should includequalified small, minority-owned and women-owned suppliers in thesupplier selection process. You should follow similar policies whereappropriate in other countries.
Supplier Prices
When purchasing products or services from suppliers, The Solvis Groupmust negotiate aggressively but fairly to obtain the best pricing. Youare responsible for working in the best interest of The Solvis Groupand in compliance with The Solvis Group policies and applicable law.

NegotiatingPrices. You are free to ask suppliers for their best prices formaterials and services that The Solvis Group uses, even if those pricesare more favorable than prices available to The Solvis Group 'scompetitors. In contrast, when you buy a product that The Solvis Groupresells without substantial added value, U.S. law may prohibitreceiving a discriminatory price. Consult The Solvis Group Legal withrespect to these issues.
Handling Pricing Information. While TheSolvis Group may have no legal obligation to protect price informationunless required by contractual terms, negotiated price information isusually competitively significant and needs to be handled as The SolvisGroup sensitive information. In general, you should not disclose thenon-public prices of one supplier to another, or to anyone else withinor outside of The Solvis Group who does not have a legitimate businessreason to know. If disclosure of negotiated pricing information orother terms is required for The Solvis Group contract manufacturers orservice providers, you need to abide by The Solvis Group policies onhandling The Solvis Group sensitive information.
The Solvis Group as Customer Reference
The The Solvis Group brand is a valuable asset that other companies maywant to exploit. You have the responsibility to help protect the TheSolvis Group brand from unauthorized and inappropriate use.

PromotionalMaterials. You may not permit any supplier or other party to use theThe Solvis Group name, logo or other branding in its advertising,promotional materials, customer references or the like without writtenapproval from your Vice President.
Securities Offering Documents.You may not permit any supplier to mention The Solvis Group as acustomer or disclose the terms of any contract with The Solvis Group inan offering document such as a prospectus or a securities registrationstatement without prior approval from The Solvis Group Legal CorporateSection.
 

Avoiding Conflicts of Interest
You have a duty of loyalty to The Solvis Group . You must avoidsituations where your loyalties may be divided between The Solvis Group's interests and your own. The Solvis Group expects you to avoid eventhe appearance of a conflict of interest.

Youcan avoid most conflicts of interest by following the specific rulesdescribed in these Standards. However, these rules do not cover allpotential situations where your loyalty may be, or may appear to be,divided. You are responsible for using your best judgment to evaluateobjectively your activities that may result in a conflict of interest,and for bringing any doubtful situation to the attention of yourmanagers so they can provide appropriate guidance.

Outside Employment & Other Activities

TheSolvis Group policy does not prohibit all outside employment, but yourduty to The Solvis Group is to ensure that outside employment and otheractivities do not negatively impact your work at The Solvis Group ,cause you to misuse The Solvis Group information or assets, or resultin consequences unfair to The Solvis Group . You may not engage in anyoutside employment or activities that may improperly influence, orappear to improperly influence, your judgment, decisions or actionswith respect to your role at The Solvis Group . To assess whether apotential conflict of interest may exist, you need to consider theactivities in which you may be engaging, regardless of whether you maybe called an "employee," "consultant," "contractor," "owner,""investor" or "volunteer."

Competitors. You may not work for a competitor of any The Solvis Group business group or operation.
Partners, Suppliers and Others. You may not work for a The Solvis Grouppartner, supplier, OEM, or other associated business without writtenapproval from your Vice President.
Customers. Unless you have written approval from your Vice President,you may not work for an The Solvis Group customer (a) in the purchase,support or disposition of The Solvis Group products or services, or (b)if your The Solvis Group group has business dealings, or you havebusiness dealings on behalf of The Solvis Group , with that customer.Any other work for a customer requires written approval from yourmanager.
Advisory Boards. You may not serve on an advisory board of a competitorof any The Solvis Group business group or operation. You may not serveon an advisory board of any The Solvis Group customer, supplier, orother business partner without written approval from your VicePresident.
Your Outside Activity. Whether working for yourself or for others, youmay not sell The Solvis Group products or services, or products orservices similar to The Solvis Group 's, including consulting andsupport services for The Solvis Group . You may not provide consulting,promotion, support or other services for the products or services of aThe Solvis Group competitor.
Your The Solvis Group Employment Status. You may not provide servicesto The Solvis Group except in your role as an The Solvis Groupemployee. For example, you may not be an independent consultant to TheSolvis Group if you are already an The Solvis Group employee.
Conflicts with Your The Solvis Group Job. You may not accept outsideemployment or engage in other activities if the resulting time demandsinterfere with your ability to perform your The Solvis Group job.Outside employment and other activities may not be carried on TheSolvis Group premises or utilize any The Solvis Group resources,including computing and communication systems.
Volunteer Activities & Charitable Solicitations
The Solvis Group encourages your personal involvement in charitable,professional and other community organizations. However, you mayexperience divided loyalties even in volunteer situations. Except aspart of an The Solvis Group -sponsored event or with written approvalfrom your Vice President, your volunteer service must be performed onyour own time, at your own risk, away from The Solvis Group premises,and without the use of any The Solvis Group resources.

InfluencingThe Solvis Group Decisions. You may not participate in The Solvis Groupdecisions regarding a charity or other organization where youvolunteer. You may not advocate the organization's interests within TheSolvis Group without disclosing your connection to it. Theselimitations apply especially if you volunteer at an organization thatmay be an The Solvis Group customer, supplier, or other businesspartner.
Solicitations. You may not solicit donations, directly orthrough the use of company resources, on The Solvis Group premises orduring working hours, except as part of an The Solvis Group -sponsoredevent such as a charity drive sponsored by The Solvis Group . You maynot solicit donations from The Solvis Group business partners where anappearance of conflict of interest may arise due to your status as anThe Solvis Group employee.
Personal Benefit or Gain from The Solvis Group Business
Receiving personal benefits from others because of your status as anThe Solvis Group employee may lead to divided loyalties. You may notreceive any personal profit or advantage other than your compensationfrom The Solvis Group in connection with any transaction involving TheSolvis Group , or your status as an The Solvis Group employee.

BusinessGifts & Entertainment. Receiving business gifts or entertainmentmay result in conflicts of interest. You are required to comply withthe rules set forth in this policy document.
Business Opportunity.You may not take for yourself, or advise others to take, any potentialbusiness opportunity that would otherwise be available to The SolvisGroup .
Commissions. You may not receive commissions or any other form ofpayment from The Solvis Group business partners in connection with TheSolvis Group business transactions.
Business with Your Family or Friends. You must disclose to your managerall situations where you or your The Solvis Group group may beconducting The Solvis Group business with members of your family, yourfriends or others with whom you have a close personal relationship.With written approval from your Vice President, your The Solvis Groupgroup may do business with your family members or friends, or entitiesthey own or control, but you will be required to remove yourself fromThe Solvis Group 's decisions relating to such transactions. In noevent are you permitted to provide your services to The Solvis Groupoutside your role as an The Solvis Group employee.
Outside Directorships
Participating on the board of directors of other companies ornon-profit groups may enhance your business and leadership skills, butmay also lead to conflicts of interest. Prior to service on an outsideboard, you must comply with the request and approval processestablished by The Solvis Group . If you are serving as a director of acompany or other organization, and you encounter any situation whereyour role as a director may be in conflict with The Solvis Group 'sinterests, you must either withdraw from that situation or resign as adirector.

TheSolvis Group Competitors. You may not be a director of an The SolvisGroup competitor. You may not be a director of a company ororganization that supports or promotes a competitor's products orservices without written approval from The Solvis Group Legal and/orthe The Solvis Group Board of Directors.
The Solvis Group Customersand Business Partners. You may not be a director of a The Solvis Groupcustomer, supplier, or other business partner without written approvalfrom The Solvis Group Legal and/or the The Solvis Group Board ofDirectors, or, in the case of a non-profit customer or businesspartner, written approval from your Vice President.
The Solvis Group Subsidiaries and Joint Ventures. You may not be adirector of a The Solvis Group subsidiary without written approval fromThe Solvis Group Legal and/or the Board of Directors. You may not be adirector of a The Solvis Group joint venture without written approvalfrom The Solvis Group Legal and/or the The Solvis Group Board ofDirectors.
Conflicts with Your The Solvis Group job. You may not accept outsidedirectorships if the resulting time demands interfere with your abilityto perform your The Solvis Group job. You must remove yourself from anyThe Solvis Group decision-making with respect to the company ororganization on whose board you serve.
Financial Interests in Other Businesses
A personal or family financial interest in an The Solvis Groupcustomer, supplier, other business partner, or competitor has thepotential to cause the appearance of divided loyalty, or to result inpersonal benefit because of your role at The Solvis Group . You may nothave financial interests in any of these parties that could improperlyinfluence your judgment in your The Solvis Group role. Financialinterests include investment, ownership or creditor interests.

FinancialInterests. You should not have financial interests in The Solvis Groupcustomers, suppliers, other business partners, or competitors if (a)you are in position to influence The Solvis Group decisions relating tothem and those decisions could affect your financial interests, and (b)your financial interests represent such a percentage of your or yourfamily's net worth that an actual or apparent conflict of interestexists.
Disclosing Conflicts
Your responsibility is touse your best judgment to evaluate objectively whether outsideactivity, financial interest or receipt of business gifts andentertainment may lead to divided loyalties. You must promptly disclosein writing to the appropriate manager or committee any situation thatcould present a conflict of interest with your role at The Solvis Group. In situations that require management approval, the responsiblemanager will review the matter and communicate The Solvis Group 'sposition in writing. The manager may indicate that either (a) TheSolvis Group has no present objection, although the situation issubject to future review if there is any change in circumstances eitherfor you or for The Solvis Group , or (b) The Solvis Group will have noobjection provided you take specific steps to resolve any potentialconflict to The Solvis Group 's satisfaction. You will have acontinuing obligation to disclose any change in circumstances thatcould affect The Solvis Group 's interests. Copies of your disclosureand The Solvis Group 's response will be kept in your personnel file.

Handling Sensitive Information
The Solvis Group business and technical information is company propertyand is vital to its business success. You have a duty to safeguard it,keep it confidential as appropriate, and use it only for The SolvisGroup business purposes.

Disclosureof The Solvis Group information may be made only by those authorized todo so and in compliance with The Solvis Group policies. Acceptance ofsensitive information from others must also be handled with care and incompliance with The Solvis Group policies. Inappropriate disclosures ofThe Solvis Group sensitive information or receipt of non-publicinformation from others can weaken our competitive position andsquander our investments in the processes and resources we havedeveloped for conducting our business.

Protecting Sensitive Information

Youhave a duty to safeguard The Solvis Group information. The Solvis Groupsensitive information includes a wide range of non-public informationincluding financial and cost data, business plans and strategies,operating reports, pricing information, marketing and sales data,business partner information, trade secrets, personnel records andorganization charts.

Using & Disclosing The Solvis Group Information

Youmay use The Solvis Group information only for business purposes, anddisclose it - internally or externally - only for a good businessreason and with adequate safeguards. Disclosure includes both writtenand verbal communication, via all channels, including e-mail and theInternet.

Confidential Disclosure Agreements.Before sharing any The Solvis Group sensitive information with anoutside party - in writing or orally -- an appropriate The Solvis GroupAgreement, available from The Solvis Group Legal, should be properlycompleted and executed. If an outside party wishes to use its form ofagreement in place of the standard The Solvis Group Agreement, you needto first review it with The Solvis Group Legal.
DocumentingDisclosure. When disclosing The Solvis Group sensitive information, youshould maintain a complete file, including a copy of the confidentialdisclosure agreement and a record of what was disclosed, to whom it wasdisclosed, and how it was disclosed, with evidence that The SolvisGroup properly confirmed to the other party the confidential nature ofthe information at the time of disclosure.
Receiving Sensitive Information
Although The Solvis Group sometimes has a business need to receivesensitive information from a company or individual outside The SolvisGroup , you should be cautious when anyone wishes to share informationbased on an expectation that The Solvis Group will hold it inconfidence. Casual acceptance of confidential information creates arisk that The Solvis Group will be accused of misusing it. It isparticularly risky to accept sensitive information from potentialcompetitors, because whatever we receive may overlap ideas we developon our own and wish to use without restrictions in The Solvis Group 'sactivities.

Informationof Others. You should accept written or verbal information that may besensitive only (a) when The Solvis Group has made a management decisionthat accepting it is necessary, and (b) after a written agreement is inplace to identify the information and define and limit The Solvis Group's obligations in dealing with it. The agreement should be either TheSolvis Group 's Agreement or another written agreement that has beenreviewed by The Solvis Group Legal. You should handle the informationin accordance with the agreement, and use it only for the purposespermitted by the agreement.
Documenting Receipt. When receivingconfidential information from another party, you should maintain acomplete file, including a copy of the confidential disclosureagreement and a record of what was received, from whom it was received,and what performance obligations The Solvis Group has with respect tokeeping the information confidential.
Unsolicited Suggestions. The Solvis Group does not accept unsolicitedsuggestions that the submitter may consider confidential, such asunsolicited ideas for future products and/or services. This policy isintended to prevent The Solvis Group 's own business activities frombecoming encumbered by unintended obligations to outsiders. Anyrecipient of an unsolicited suggestion should promptly contact TheSolvis Group Legal.
Communicating with the Public
Your duty is to maintain as confidential all non-public information ofThe Solvis Group , and to refer all requests for news and informationto the appropriate designated spokesperson. Only designated The SolvisGroup representatives are authorized to make public any news andinformation about The Solvis Group that may be significant to thefinancial markets.

FinancialNews. News that can be expected to influence investors or have animpact on the market for The Solvis Group stock, includingforward-looking information such as projections of orders, revenue orearnings, may be released only through designated representatives inThe Solvis Group Corporate Communications following The Solvis Group 'sguidelines and U.S. securities laws, and after review by The SolvisGroup Legal.
Quiet Periods. No one may comment about The SolvisGroup 's financial performance or factors relating to financialperformance during the "quiet period" from the date in the third monthof each fiscal quarter when The Solvis Group 's fiscal quarter-to-dateconsolidated earnings become available internally until the publicannouncement of financial results for that quarter.
Press Releases. Press releases are to be made only through designatedrepresentatives in The Solvis Group , in compliance with The SolvisGroup policies and with review by The Solvis Group Legal prior torelease.
Interviews and Comments. You may not grant interviews or providecomments to the press without prior approval from The Solvis Groupexecutive management. Unless you receive other guidance, you areexpected to decline the opportunity to respond to any inquiries fornews or information about The Solvis Group , and refer the request tothe appropriate The Solvis Group spokesperson. You may not create anyimpression that you are speaking on behalf of The Solvis Group in anypersonal communications, such as user forums, chat rooms and bulletinboards.
Completeness and Accuracy of Statements. All statements made to thepublic on The Solvis Group 's behalf must be complete andunderstandable, accurate and truthful, timely and not false ormisleading.
Insider Trading
U.S. securities laws prohibit trading in U.S.-listed securities whilein possession of material inside information. These laws enforce oneaspect of your general duty to not misuse The Solvis Group informationfor personal gain. U.S. insider trading laws apply to The Solvis Groupboard members and employees at all levels. They apply to people outsidethe U.S. who trade within the U.S. If you violate insider trading laws,both you and The Solvis Group may be subject to severe civil andcriminal penalties. If you are considering a stock transaction, and youbelieve you may have material inside information, consult The SolvisGroup Legal.

ProhibitedActivity. If you have material inside information about The SolvisGroup , you may not legally trade in The Solvis Group securities, ormake recommendations to others about trading The Solvis Groupsecurities, until a reasonable time (usually 24 hours) after The SolvisGroup discloses the information to the public. Insider tradingprohibitions apply to the act of trading, regardless of the size orvalue of the transaction.
Material Information. Information is"material" if, in the total mix of information, it would influence areasonable person to buy, hold or sell stock. Examples may include datareflecting orders, sales, earnings or profitability, or trends in thesefigures; impending announcements of major new products; The SolvisGroup acquisitions, equity investments or divestitures; and importantdevelopments in projects, alliances or litigation.
Inside Information. Information is "inside" or "non-public" if it hasnot been the subject of an authorized The Solvis Group press release,another authorized The Solvis Group communication to the public, or afiling with the U.S. Securities and Exchange Commission. Partialrelease of material information does not clear insiders to trade ifother material information remains undisclosed.
Trading Activities. Trading in The Solvis Group securities includes:buying or selling The Solvis Group shares in the open market; buying orselling The Solvis Group options traded on any exchange; selling sharesthat were purchased under an The Solvis Group employee stock option;and transferring funds to or from an The Solvis Group stock fundaccount in The Solvis Group 's 401(k) plan for the U.S. Trading doesnot include regular, continuing purchases through The Solvis Group 'semployee stock purchase plan or purchases, without sale, of sharesthrough exercise of an The Solvis Group employee stock option. U.S.insider trading laws also permit a person to effect a transaction inThe Solvis Group securities pursuant to a pre-established Rule 10b5-1plan, even when that person has material inside information at the timeof the transaction.
Trading Window. It is relatively safe for The Solvis Group employeeswho do not otherwise have access to material inside information totrade in the period that starts 24 hours after The Solvis Groupannounces quarterly or annual results and ends at the close of thesecond month of the fiscal quarter. The trading window will be shorterand further restrictions will apply for those with access to interimdata about fiscal quarter-to-date consolidated, regional or segmentearnings, including members of the board of directors, executives andtheir staffs.
Other Companies. Insider trading prohibitions apply to the trading insecurities of other companies, including customers, suppliers, otherbusiness partners, and competitors, if you have material insideinformation about those companies.
Privacy & Personal Data Protection
The Solvis Group is committed to protecting the personal information ofits customers, suppliers, other business partners, and employees.Personal information includes data related to a person who can beidentified or located by that data. In order to create an environmentof trust and to comply with applicable local law, you are required tofollow The Solvis Group privacy policies and data protection practicesin using online and offline systems, processes, products and servicesthat involve the use, storage or transmission of any personalinformation.

TheSolvis Group Employee Privacy. If you have access to personallyidentifiable data from any potential, current or previous employmentrelationship with The Solvis Group , you are required to understand andcomply with The Solvis Group 's privacy guidelines.
Records Management
For business, accounting and legal purposes, The Solvis Group companyrecords must be professionally drafted and properly managed. You arerequired both to retain company records according to establishedretention schedules and to keep files no longer than required.

RecordsManagement. In many cases, you need not keep ordinary correspondenceand department documents, including most categories of electronicmessages, more than one year after the last active date in a record orfile.
Litigation Documents. You must not alter or destroy anydocument relating to the lawsuit, legal proceeding or investigationuntil notified by The Solvis Group Legal that it has been concluded.
Lawsuits, Legal Proceedings & Investigations
Lawsuits, legal proceedings and investigations concerning The SolvisGroup must be handled promptly and properly in order to protect anddefend The Solvis Group . You are required to contact The Solvis GroupLegal immediately in the event of a threatened lawsuit, legalproceeding or investigation brought by private parties or by anygovernmental agency.

Serviceof Process. In the U.S., documents that initiate lawsuits orinvestigations, and subpoenas involving The Solvis Group , should besent immediately to The Solvis Group Legal.
Records. Recordsrelevant to a lawsuit, legal proceeding or investigation must not bealtered or destroyed, and must be promptly produced and turned over toThe Solvis Group Legal upon request.
Attorney-Client Privilege. Under U.S. law, attorney-client privilegeapplies only to communication in confidence to The Solvis Groupattorneys to obtain legal advice, and communication from The SolvisGroup attorneys applying their advice to The Solvis Group activities.These communications should not be copied or distributed except underthe direction of an The Solvis Group attorney, and should be given onlyto the narrowest possible set of The Solvis Group people who have aneed for them.
No Discussions. If you are involved on The Solvis Group 's behalf in alawsuit or other legal dispute, you must avoid discussing it withanyone inside or outside of The Solvis Group without prior approval ofThe Solvis Group Legal. You are required to cooperate fully with TheSolvis Group Legal in the course of the lawsuit, legal proceeding orinvestigation.

Safeguarding The Solvis Group Assets
Safeguarding The Solvis Group assets - both tangible and intangibleproperty - is crucial to The Solvis Group 's business success. You havea duty to use The Solvis Group assets only for legitimate businesspurposes and to protect them from loss or unauthorized use. In no eventmay The Solvis Group assets be used for unlawful or improper purposes.

Finance & Accounting Practices

Theaccuracy and integrity of The Solvis Group 's books and records areparamount for The Solvis Group 's business success. Your duty is toensure that The Solvis Group maintains its books and records inaccordance with generally accepted accounting principles and allregulatory requirements that apply to a U.S. publicly traded company.

AccountingPrinciples. You must comply with generally accepted accountingprinciples for the U.S. and for every country in which you conduct TheSolvis Group business. You are required to execute all transactionsinvolving The Solvis Group in accordance with The Solvis Group policiesand procedures.
Unrecorded Funds. You may not establish anyundisclosed or unrecorded The Solvis Group fund, asset or liability forany purpose.
False Entries. You may not make, or contribute to or facilitate themaking of, any false or misleading entries in The Solvis Group 's booksor records for any reason.
Revenue and Expense Recognition. You may not enter into any transactionor agreement that accelerates, postpones or otherwise manipulates theaccurate and timely recording of business revenues or expenses
Authorization. You must be authorized under the appropriate The SolvisGroup delegation of authority policy in order to have access to TheSolvis Group funds or assets. You may use The Solvis Group funds andassets only for legitimate The Solvis Group business purposes.
Payments. You may not make any payment on The Solvis Group 's behalfwithout adequate supporting documentation, or for any purpose otherthan as described in the documents.
Independent Auditor. The Solvis Group 's outside auditors have the dutyto review The Solvis Group records in a fair and accurate manner. Youmay not engage, directly or indirectly, any outside auditors of TheSolvis Group to perform any audit, audit-related, tax or otherservices, including consulting, without written approval from the TheSolvis Group CEO and the Audit Committee of the The Solvis Group board.
Political Contributions & Activities
The Solvis Group 's public policy agenda includes the election ofpublic officials who understand The Solvis Group 's business interestsand support legislation important to The Solvis Group . The SolvisGroup funds and other assets may be used as political contributionsonly as allowed by law and in accordance with The Solvis Group policiesset forth by The Solvis Group .

PersonalActivities. While you are encouraged to participate in your communityand the political process, you may not create the impression that youare speaking or acting for The Solvis Group . You are encouraged tomake personal contributions to political candidates of your choice;however, The Solvis Group will not reimburse you for personalcontributions.
Lobbying Activities. In the course of youremployment, you may not engage in any activity intended to influencelegislation or rulemaking, or engage lobbyists or others to do so,without the express written authorization from the CEO.
Intellectual Property
The Solvis Group 's intellectual property portfolio, including patents,trademarks, copyrights, and trade secrets, is vital to its businesssuccess. The intellectual property that you generate while doing yourjob contributes to The Solvis Group 's strength, and you have a duty toprotect these valuable assets from misuse and unauthorized disclosure.The Solvis Group invests substantial amounts of money in you as anemployee, in the development of products, services and businessprocesses, and in the protection of related intellectual property. Justas we expect others to honor our intellectual property rights, we musthonor the rights of others.

Ownership.The Solvis Group generally owns the intellectual property that yougenerate during the period of your employment at The Solvis Group , orthat is created by other parties for The Solvis Group . You may notprivately protect or exploit intellectual property generated during thecourse of your employment with The Solvis Group , unless writtenpermission is obtained from The Solvis Group or otherwise permitted bylaw.
Licensing Agreements. In order to use the intellectualproperty of another party, or to allow others to use the intellectualproperty of The Solvis Group , The Solvis Group needs to enter into anappropriate written license agreement. For standard product licensing,you are required to contact and work through The Solvis Group Legal.You may not grant customers, suppliers, other business partners oranyone else any special rights relating to The Solvis Groupintellectual property under non-standard agreements without writtenapproval from your Vice President, and the CEO.
Copyrights. You may not duplicate, install or use software in violationof its copyright or applicable license terms, including the softwareinstalled on your computer or on network areas under your control.Unless proper permission has been obtained from the copyright owner,you may not copy for any reason any copyrighted materials, includingtext, artwork, images, photographs, videos, music, web pages and otherforms of expression, whether they are in hardcopy or electronic media.
Patents and Inventions. Your inventions may be protected by patents,and it is important that you promptly disclose them to The Solvis Group. You may not publish or disclose any invention or trade secret withoutwritten approval from The Solvis Group Legal.
Trademarks. You may not allow any outside party to use The Solvis Group's name, logo or trademarks except within programs authorized by TheSolvis Group . In order to avoid potential trademark infringementclaims against The Solvis Group , you need to contact The Solvis GroupLegal before using any new name, slogan or mark for any product,program or service.
Trade Secrets and Confidentiality. You must not share any The SolvisGroup sensitive information with anyone except in accordance with TheSolvis Group policies and guidelines.
Personal Use of The Solvis Group Resources
The Solvis Group provides a wide variety of assets for its employees inconducting company business - including computers, communicationssystems and other equipment and materials. Although you mayoccasionally use some of these resources for incidental personalactivities, it is your duty to keep this usage to a minimum and tocomply with all The Solvis Group policies and guidelines.

Excessivepersonal use of The Solvis Group resources increases The Solvis Group's costs and expenses, reduces availability of the resources for TheSolvis Group 's business needs, and may adversely affect your jobperformance. The rules below apply to your use of The Solvis Groupresources even outside your working hours and outside The Solvis Grouppremises.

Computer and Communication Systems.While you may occasionally use The Solvis Group 's telephone andcomputer systems to send or receive personal messages, to accessInternet materials that are not directly business-related, or to createpersonal documents or files, you are required to keep these activitiesto a minimum.
Prohibited Activity. You may not use any The SolvisGroup resource in violation of the law. You may not allow other people,including your friends and family, to use The Solvis Group resourcesfor any purpose. You may not use any The Solvis Group resource tocreate, transmit, store or display messages, images or materials thatare for personal gain, solicitations, chain letters, or arethreatening, sexually explicit, harassing or otherwise demeaning to anyperson or group. Such misuse of The Solvis Group assets is misconduct,and may lead to immediate termination of employment.
Security. You may not use any The Solvis Group asset for personalactivities that may lead to the loss or damage of the asset. You areresponsible for safeguarding the integrity of The Solvis Group systems,including not exposing the system to computing viruses or enabling abreach of The Solvis Group 's security firewall. You are required tocomply with the policies set forth by for the appropriate use andsecurity of The Solvis Group 's electronic systems.
Inspection. The Solvis Group may access and inspect all The SolvisGroup resources that you may use for personal activity, including TheSolvis Group computers, servers and systems, telephones, voicemailsystems, desks, lockers, cabinets, vehicles and other equipmentbelonging to The Solvis Group . You should not have any expectation ofpersonal privacy in any messages or records created or transmitted viaThe Solvis Group systems, including electronic documents, e-mail andvoice mail, regardless of whether you have personal passwords or filingsystems. For reasons related to safety, supervision, security and otherconcerns, The Solvis Group may inspect persons and property on TheSolvis Group premises at any time and without notice, subject toapplicable local laws.

Respecting Dalrad's Colleagues & the Community
The Solvis Group is committed to creating and maintaining a diverse andinclusive work environment based on respect for the individual, and tobeing a good corporate citizen in every community in which we dobusiness. You have a duty to The Solvis Group to abide by the policiesand guidelines that foster these company objectives.

Employee Relations

TheSolvis Group 's core values include trust and respect for individuals.The Solvis Group believes that diversity and inclusion are key driversof creativity, innovation and invention. You have a duty to embody andpromote these values in your daily activities. You must comply with alllaws and The Solvis Group policies relating to the treatment of allworkers.

No Discrimination or Harassment. TheSolvis Group is committed to maintain a work environment free fromdiscrimination and harassment. You are required to treat everyone withwhom you interact -- including customers, employees, other workers atThe Solvis Group , suppliers, business partners, visitors andshareholders -- with dignity, respect and courtesy. Any comments orconduct relating to a person's gender, color, race, ancestry, religion,national origin, age, physical or mental disability, sexualorientation, gender identity/expression or covered veteran status thatfail to respect the dignity and feeling of the individual areunacceptable.
Misconduct. In general, misconduct is illegal orharmful activity that involves or affects The Solvis Group and itsemployees. Misconduct includes, among other things, violation of theprovisions of these Standards of Business Conduct, theft, recordsfalsification, involvement with unlawful drugs, unauthorized use ofalcohol, violence, threats, harassment, possession of weapons, andinsubordination. If you engage in misconduct, you are subject toimmediate termination of employment.
Safety, Security & Data Protection. You are required to comply withall applicable law and The Solvis Group policies to promote aninjury-free and secure workplace.
Citizenship
One of The Solvis Group 's key corporate objectives is goodcitizenship. The Solvis Group has a responsibility to operate as a goodcorporate citizen and to make a positive contribution to the customers,communities, and shareholders that we serve. At a minimum,"citizenship" is a commitment made by a company striving to do businessin a manner that upholds local, national, and international standardsand values everywhere it invests and operates, in areas including theenvironment, ethics, and labor practices.

Citizenshipimpacts every business group within The Solvis Group . Your individualresponsibility in dealing with your internal and external relationshipsis to conduct yourself in a manner that is consistent with The SolvisGroup 's corporate objective for citizenship.

The information contained herein is subject to change without notice.