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Security Services

                                                    WORKPLACE INTEGRITY

POLITICAL CONTRIBUTIONS AND ACTIVITIES

Company funds and resources may not be used to contribute to or otherwise used to support any political campaign, political party, political candidate, or any of their affiliated organizations..

Employees may voluntarily participate in the political process, but such activities must take place on the employee’s own time and at the employee’s own expense. Each employee is responsible for complying fully with all laws and regulations, including local laws, relating to political contributions and interactions with government officials. Employees may not engage in political activities that potentially conflict with their work duties and responsibilities to the Company, including by acting as an advisor to or spokesperson for candidates for public office. Employees shall not apply any pressure, direct or indirect, to other employees that infringes on an individual’s right to decide whether, to whom, and in what amount a personal political contribution is to be made.

SOLICITATION

COBRA™ employees may not engage in solicitation, advertising, or distribution of leaflets, products, or brochures for personal interest or employee profit at work, on Company premises, or through use of Company resources, such as e-mail, fax machines, computers or telephones.

Employees may ask fellow employees to support non-profit or charitable causes, as long as requests are

- Respectful toward other employees;

- Voluntary;

- Not for personal gain;

- Do not interfere with job performance; and

- Are non-discriminatory and non-threatening.

Solicitation for personal interests or gain can make others uncomfortable and can be counter pro­ductive to building trusted work relationships. Additionally, using Company resources for personal financial gain can limit the availability of those resources for business purposes and reflect negatively on COBRA™ in the marketplace.

THEFT

Misappropriation, larceny, embezzlement, mischarging of time, and other forms of theft are strictly prohibited and are a violation of law. Any theft, regardless of relative value or damage to the Company, supplier, or customer, will result in severe consequences for the employee who engages in such behavior.

UNPROFESSIONAL BEHAVIOR

Company employees are expected to conduct themselves professionally and in a manner consistent with our values at all times. Unprofessional behavior or conduct that negatively affects the Company’s business interests or reputation is prohibited.

RESPONDING TO INVESTIGATIONS OR LEGAL ACTIONS

Damage to COBRA’s™ reputation may result when the Company is involved in an investigation or litigation. Employees are required to cooperate with internal investigations. Employees must never alter any documents or electronic records, lie to or mislead an investigator, or obstruct the collection of information relating to an investigation or any legal action brought against or on behalf of the Company.

Employees must notify the HR HEAD or his representative immediately if they learn that any government agency or any third party is conducting an investigation or asking for information pertaining to a suspected violation of law. The HR HEAD or his representative  will review information before it is released to the inves­tigative agencies.

INTEGRITY IN THE HANDLING OF RESOURCES AND DATA

COBRA’s™ resources include time, material, facilities, equipment, information, and services. These resources should only be used for authorized business purposes, unless a specific exception has been approved by management. Under no circumstances should COBRA’s resources be used for any illicit or illegal purposes or for any purpose that runs contrary to any provision of this Code.

PROPERTY

Company-owned equipment, including telephones, fax machines, and computers, are to be used primarily for business purposes. Although limited personal use of COBRA’s™ communications systems and equipment is permitted, users should not assume that any such communications are private. Employees may not use COBRA’s™ communication channels or access to the internet at work to post, store, transmit, download, or distribute any threatening materials or to knowingly, recklessly, or maliciously transmit false materials, obscene materials, or anything constituting or encouraging the violation of any laws. The unauthorized removal of Company property may be considered theft.

ACCURATE RECORDS AND SUBMISSIONS

COBRA™ has a strict policy of complying with all record retention requirements imposed by laws and regulations. Employees must not improperly destroy, alter, make false entries on, or willfully fail to make correct entries on any Company documents or records. Company employees are also expected to ensure that any information provided internally or to outside parties is accurate and truthful. When COBRA™ is asked to provide information to a government or other regulatory authority, inaccuracies or falsehoods could result in severe legal and financial consequences for the Company; therefore, extra care must be given to any statements, certifications, representations, and submissions made to a government, regulatory authority, or an employee or representative of a government or regulatory authority.

COMPANY BOOKS, RECORDS, AND REPORTS

All Company books and records must be maintained in accordance with generally accepted accounting practices and applicable laws and regulations. No false, misleading, inaccurate, or artificial entries may be made in the books and records of the Company. The Company maintains an effective internal control system to provide reasonable assurance that transactions are executed in accordance with proper management authorization and are properly reflected within the Company’s financial records in accordance with statutory accounting principles.

ACCURATE TIME-KEEPING AND OTHER RECORDS

In reporting his or her time, each employee certifies how his or her time was spent on work-related activities. The accuracy of time records directly affects the accuracy of the data upon which COBRA’s™ billing systems depend. Improperly shifting costs from one contract or project to another, improperly charging labor or materials, and falsifying time-keeping or other records are strictly prohibited.

PROTECT COMPANY PROPRIETARY INFORMATION

Information, knowledge, or know-how that gives a competitive advantage is considered intellectual property and is a valuable asset. COBRA’s™ intellectual property must be used for authorized Company business purposes only. Employees must protect COBRA’s™ proprietary or private information, which may include, but is not limited to, technical designs or strategy, software, employee records, or information learned in a partnership or teaming arrangement. Employees should be especially cautious when providing such information to an outside entity and take proper steps to ensure that the receiving party will protect COBRA’s™ proprietary information.

COBRA’s™ intellectual property, including data and information systems, customer lists, and other trade secrets, must remain with the Company when an employee leaves the Company. Use of COBRA’s™ intellectual property by a former employee may be a violation of law.

PROTECT PERSONAL INFORMATION

The Company is the custodian of personal data belonging to employees and others with whom we conduct business. To continue building and sustaining a culture of trust, we must protect personal data and use it only for authorized purposes. Personal data may only be collected if there is a specified, legitimate business purpose, and such data shall not be used in ways that are incompatible with the stated purpose. Data gathered must be relevant and not excessive in light of the purposes for which it is collected and used.

Employees who are granted access to Company-controlled personal data for legitimate business purposes must safeguard such data. Employees may not disclose such information without proper authorization and must never use personal information for any purpose for which it was not intended, including for personal gain.

Misuse of personal data could result in significant financial or social harm, including the following:

- Discrimination based on age, race, color, religion, origin, gender, sexual orientation, physical or mental disability, veteran status, or other protected classes;

- Identify theft; and/or

- Access to money, goods, services, or any other thing of value.

Violation of the laws and regulations governing data privacy can result in fines and penalties to the Company and/or criminal prosecution of the individual who compromises the information.

PROTECT CLASSIFIED AND NATIONAL SECURITY INFORMATION

Due to the nature of our business, Company employees are routinely trusted with classified and other important security information. All employees who are granted access to classified and other important security information must take all necessary measures to protect such information. Unauthorized access, dissemination, acceptance, or handling of classified information is strictly prohibited. Classified and other important security information may not be disclosed to another person without the express approval from the HR HEAD. Failure to properly protect classified information could result in, fines and penalties, and/or suspension or debarment of COBRA™ from receiving future contracts awarded.