Code of Business Conduct and Ethics

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AQUATREAT Code of Business Conduct and Ethics

The Company’s directors, officers and employees are required to comply with the Company’s Code of
Business Conduct and Ethics. The purpose of the Company’s Code of Business Conduct and Ethics is to deterwrongdoing and to promote, among other things, honest and ethical conduct and to ensure to the greatest possible extent that the Company’s business is conducted in a consistently legal and ethical manner. The Code of Business Conduct and Ethics is intended to cover the requirement of a Code of Ethics for senior financial
officers as provided by the AQUATREAT rules with respect to Regulations and Procedures of Ministry of
Human Resources and Social Development. Employees may submit concerns or complaints regarding ethicalissues on a confidential basis by means of a telephone call to an assigned voicemail box or via email. All
concerns and complaints are investigated by the audit committee.
The Company will also disclose any amendment to, or waiver from, a provision of the Code of
Business Conduct and Ethics that applies to a director or officer in accordance with applicable NASDAQ and
SEC requirements.

Code of Business Conduct and Ethics

Our Responsibilities—Personal Integrity, Corporate Values and Ethical Principles
AQUATREAT’ (the “Company”) continued growth, profitability and prosperity is linked to our
employees’ ability to make decisions that are consistent with AQUATREAT’s core values and ethical
principles. We are a Company committed to:

Passion for Excellence—Strive to achieve the best in everything we do.
Integrity—Hold ourselves to the highest ethical standards. To interact in an open, honest positive
manner and be guided by what is right.
Teamwork—Work together with trust, openness, honesty and respect.
Inspired People—Build a culture where people are motivated, engaged, valued and growing. Our
people make the difference and are the essence of AQUATREAT.

Our core values support and guide our leadership in establishing the strategic direction of the Company.
Sound judgment shall be exercised in the service of our reputation as a business leader, employer of choice,
and good corporate citizen. Our employees and representatives are expected to conduct their business in
accordance with these values and with our Standards of Business Ethics and Conduct (“The Standards”).
AQUATREAT’s reputation is based on the personal integrity of each of its employees and those with whom
we do business. We strive to be compliant with laws, regulations and policies; we endeavor to conduct
ourselves in a manner beyond reproach. Actions speak louder than words.
This booklet is not a set of rules. It is a resource to be used in making decisions that will affect us all. It
provides guidance in assessing situations. As always, if you are faced with a situation in which the proper
path is unclear—think and ask before you act. Only with all of us working together can we continue to
achieve our vision.

Our Responsibilities to Our Stakeholders

To Ourselves
Integrity is at the heart of who we are as individuals. Integrity is at the heart of AQUATREAT as well.
—To Each Other
We owe each other honesty, respect, and fair treatment. We value the unique contributions of each
To Our Business Partners, Clients, and End-User Customers

Our business partners, clients, and end-user customers trust the quality and value of our service
offerings. We depend on strong relationships with our business partners and clients to provide us with
continued opportunities to grow our business.
To Our Shareholders
Our shareholders trust us to responsibly use all our assets to make our business grow.
—To Our Community
When we give back to the community, we instill pride in our employees and gain the respect of the
citizens in our community.
The Ethics Committee and Compliance
The AQUATREAT Ethics Committee is dedicated to giving employees the support and advice they need to
act according to The Standards and AQUATREATs’ ethical principles. Appointed by AQUATREAT’s
Executive Team, we act as a resource, providing the information, tools, and strategies to assist employees in
making ethical business decisions.
The Ethics Committee has a charter to:
• Help employees use the Company’s ethical principles in their decision-making processes
• Provide guidance for employees who have questions about business ethics and compliance issues
• Support employees who may be facing ethical challenges in the workplace
• Interpret policies
• Provide easily accessible information on The Standards, policies, and procedures
• Foster an atmosphere of trust and open communication where employees feel comfortable coming
forward and talking about issues
As such, we expect employees to act proactively, raising concerns about ethical issues, and reporting any
conduct believed to be a violation of The Standards, a Company policy or procedure, or a government law or
regulation. Members of AQUATREAT’s management team are expected to maintain an “open-door” policy
regarding employee questions, and to support any employee who comes forward to discuss an issue or report
a potential violation.
Reporting Concerns/Getting Advice
The best starting point for resolving concerns, reporting potential violations, or getting advice on
ethics-related issues is usually your manager—assisted by organizations including Human Resources and
Finance. You may also contact the toll-free AQUATREAT Ethics Line, anonymously (caller ID is blocked),
at REDACTED (or you may email the Committee at REDACTED to request guidance or make a good-faith
report about misconduct or a violation of The Standards, a Company policy or procedure, or a government
law or regulation. All complaints should include sufficient information to determine the specific issue, the
period of time during which the violation or misconduct occurred, and how to contact you for additional
information (if you so choose). All reports are taken seriously. Each allegation is investigated and, if
substantiated, resolved through appropriate corrective action and/or discipline. If you choose to identify
yourself, you will be provided with feedback when the Ethics Committee has completed its review.
Every reported complaint will be investigated appropriately, promptly, and with as much confidentiality as
Retaliation is Prohibited
AQUATREAT prohibits retaliation or retribution against any employee for cooperating in an
investigation or for making a complaint. Retaliation or retribution for cooperating in or filing a complaint is
illegal and is grounds for immediate termination. If you feel you have been retaliated against, you should
contact Human Resources or the Ethics Committee.

When you are confronted with an ethical dilemma, it is your responsibility to TAKE ACTION. The
decision-making model outlined below can help you assess whether or not a particular action is “the right
thing to do.” Keep in mind that not taking action is itself an action that can have serious consequences to the
Company and its employees.
Remember that work stress and too-rapid decision-making can often impact ethics. If you feel that you
are under pressure to make a decision that you aren’t yet comfortable with, take a few minutes and run
through the ACTION model.
ACTION Decision-Making Model
Act Responsibly
• Have you taken responsibility for your share of the problem? It’s ok to acknowledge mistakes.
• Do you have all the information you need?
• Has the information been clarified?
Consider Our Core Values
• Does it demonstrate respect for our People?
• Does it demonstrate Excellence?
• Does the action reflect Integrity?
• Does it promote Teamwork?
Trust Your Judgment
• Is the action fair?
• Does it feel comfortable?
• Is it the “right” thing to do?
• Could it be shared publicly?
• Can you look yourself in the mirror and say that you acted with integrity?
Identify Impact on Stakeholders
• Does the action have a negative or positive impact on our stakeholders?
Obey the Rules
• Does the action comply with:
• The law?
• Company policy?
• Regulatory agency requirements?
• Customer requirements?
• Outsource partner or client requirements?
Notify Appropriate Persons
• Have communications been open and honest?
• Have potential problems been disclosed?
The Standards
Set an Example—Comply with the Rule of Law and Our Core Values
AQUATREAT operates within the bounds of the laws, rules, and regulations that are relevant to our
business. The rule of law is fundamental to civil society, to the democratic process, and to the conduct of
business in a dynamic global marketplace. However, today’s market demands that companies meet higher
standards—simply obeying the law is not enough. To achieve higher standards of behavior, we need to make
business decisions that are aligned with our core values of respect for our people, passion for excellence,
integrity and teamwork.

The first and foremost obligation of responsible corporate citizenship is to obey the laws of the
countries and communities in which AQUATREAT does business. Any case of noncompliance with
applicable law may
subject the violating employee to disciplinary action. The fact that in some countries certain standards of
conduct are legally prohibited, but these prohibitions are not enforced in practice, or their violation is not
subject to public criticism or censure, will not excuse an illegal action by a AQUATREAT employee.
AQUATREAT is a good corporate citizen not just because we comply with the law, but because our
employees are also expected to act according to our core values. We are committed to going beyond mere
compliance—beyond simply “doing things right.” We aspire to “do the right thing” by being faithful to and
executing the principles and guidelines cited in The Standards and to act in ways that exceed the minimum
standards set by law. Each of us is personally responsible for meeting this obligation.
Each AQUATREAT employee is responsible for displaying integrity. Business integrity is hard to define, but
everybody knows it when they see it. Among other things, it means honesty, and obeying the law. It means
treating those with whom we work with fairness and respect. And it means being accountable and taking
responsibility for actions and consequences.
It is also the responsibility of each AQUATREAT employee to comply with The Standards, and to take
action or report to management when aware of criminal acts or acts in violation of the Standards. Employees
who fail to comply with The Standards, including not reporting known unethical activities, will be subject to
disciplinary action.
Individuals who report an ethical or legal concern in good faith will never be subject to retaliation for
reporting. Any employee responsible for retaliation against an individual who in good faith reports a known
or suspected violation will be subject to disciplinary action, including termination. Additionally, employees
who knowingly submit false reports of ethical or legal concerns or violations will also be subject to
disciplinary action.
Managers are expected to exemplify the highest standards of ethical business conduct and encourage
discussion of the ethical and legal implications of business decisions. Managers have a responsibility to
create and sustain a work environment in which employees, consultants and contract workers know that
ethical and legal behavior is expected of them.
This responsibility includes ensuring that the Standards are communicated to all those working for the
manager. Managers are also responsible for ensuring that employees who need to know additional
information in order to do their jobs, for example regarding environmental health and safety, antitrust or
international business practices, receive appropriate policies and training.
Managers must be diligent in looking for indications that are unethical, or where illegal conduct has occurred,
and take appropriate and consistent action to address any situations that seem to be in conflict with the law or
The Standards. Managers also need to be careful not to hire or delegate authority to any individual whom
they have reason to believe may engage in unlawful conduct or unethical activities.
Failure to comply with this core policy shall result in disciplinary action, up to and including dismissal.
Respect Others—Value Personal Dignity and Differences

We respect the personal dignity of each individual, honor diversity, and are intolerant of violence,
discrimination, harassment, or retribution in our workplace. We strive to be an employer of choice committed
to creating, managing, leveraging, and valuing diversity. We work hard to create a positive work environment
where each individual is appreciated, proud, satisfied, and adds value to the Company. We practice equal
opportunity without regard to race, religion, color, national origin, gender, sexual orientation, age, disability,
or veteran or marital status. Our employment and personnel decisions are based on individual merit and
Company requirements. Retaliation is not tolerated.
Our goal is to deal fairly and equitably with our coworkers, suppliers, outsource partners, and customers. All
AQUATREAT employees are expected to treat others with dignity and respect. AQUATREAT managers at

all levels have a special obligation to encourage and cultivate a safe and secure workplace in which
employees and other stakeholders can raise issues or concerns without fear of retaliation.
Human Rights and the Law
AQUATREAT complies with employment laws in every country in which it operates, and supports
fundamental human rights for all people.
We will not employ children or forced labor. We will not allow physical punishment or abuse. We will
respect the right of employees to exercise their lawful right of free association. AQUATREAT
enthusiastically supports laws prohibiting unjustified discrimination based on a person’s race, color, gender,
national origin, age, religion, disability, veteran status, sexual preference, marital status or other protected
Fair Treatment and Opportunity
AQUATREAT is firmly committed to the fair treatment and compensation of employees. All applicants and
employees are judged by their qualifications, demonstrated skills and achievements. We believe in
recognizing and rewarding excellent performance, and offering opportunities for advancement through
training and promotions.

We believe that differences should be valued. Every employee deserves the opportunity to work and grow in an environment that is free of discrimination and harassment, and that supports work/life flexibility. At
AQUATREAT, diversity will be accepted throughout the organization. In exchange, we will benefit from the
creativity, varied perspective, innovation, and energy that result from a diverse workforce.
AQUATREAT’ employees have the right to work in an environment that is free from intimidation,
harassment and abuse. At AQUATREAT, we are committed to providing a work environment free of
unlawful harassment of any kind. Verbal or physical conduct by any employee that harasses another or
disrupts another’s work performance or creates an intimidating, offensive, abusive, or hostile work
environment will not be tolerated. Our anti-harassment policy applies to all persons involved in the operation
of the Company and prohibits unlawful harassment by any employee.
In addition, unwelcome sexual advances, requests for sexual favors, and other unwelcome verbal or physical
conduct of a sexual nature are specifically prohibited. Employees are encouraged to help each other by
speaking out when a co-worker’s conduct makes them or others uncomfortable, and are responsible for
promptly reporting harassment when it occurs.
AQUATREAT has internal complaint procedures to immediately address and undertake an effective,
thorough, and objective investigation. If an employee believes that he/she has been unlawfully harassed, they
should submit a written complaint to their manager, the CEO, COO, or Human Resources as soon as possible
after the incident. If it is determined that unlawful harassment has occurred, effective remedial action will be
taken. Any employee determined by AQUATREAT to be responsible for unlawful harassment will be subject
to appropriate disciplinary action, up to and including termination.
Promote a Healthy and Safe Workplace—Make a Better World

When we protect the health and safety of our coworkers, our community, and the environment, we
demonstrate respect and contribute to a positive work environment. Without respect for health, safety, and
the environment, we put our coworkers, our employees, our clients, our customers and the public at risk.
AQUATREAT is committed to protecting the health and safety of our employees, the public, our customers,
suppliers, and visitors. Our policy is to maintain a drug-free, secure workplace where all employees are
attentive to hazard prevention and the avoidance of accidents and injuries. Posted safety regulations,
statistics, and warnings are guides to help us stay out of harm’s way—observed accidents, injuries, or hazards
should be immediately reported to Company management.
To support this commitment, each employee is responsible for observing the safety and health rules and
practices that apply to his or her job. Employees are also responsible for taking precautions necessary to

protect themselves and their co-workers, including immediately reporting accidents, injuries, and unsafe
practices or conditions. Appropriate and timely action will be taken to correct known unsafe conditions.
Build Trust—Keep Accurate, Complete Company Books and Records


Our reputation depends on the confidence others have in us, which is partially based on the accuracy of our
written records and verbal statements. By demonstrating honesty in our accounting and labor-charging
practices, we generate trust with our stakeholders and enhance our reputation. When we fail to record
financial information and time accurately, we severely damage our reputation; risk losing business, and
decrease customer and shareholder confidence.
AQUATREAT will only use Company funds or assets for purposes that can be disclosed and recorded
promptly and accurately in our books and records. We will not make false entries for any reason, nor will we
alter documents or sign documents when we lack the proper authority to do so. We will not make or approve
payments on behalf of the Company if they will not be used, or might be used, for something other than the
stated purpose. AQUATREAT’ financial books, records, and statements shall properly document all assets
and liabilities, shall accurately reflect all transactions of the Company, and shall be retained in accordance
with AQUATREAT’ record retention policies and all relevant laws and regulations. No employee, agent,
representative, client or outsource partner, or customer shall falsify a record. The Company follows Generally
Accepted Accounting Principles and complies with Financial Accounting Standards Board regulations to
provide a uniform basis for measuring, managing, and reporting Company operations.
Accuracy of Business Records
Honest and accurate recording and reporting of information is extremely important. Investors count on
AQUATREAT to provide accurate information about its businesses and to make responsible business
decisions based on reliable records. Employees throughout AQUATREAT are responsible for properly
recording many kinds of information.
It is wrong, for example, to make false claims on an expense report or time sheet, to falsify performance
metrics, to record false sales or record them early, to understate or overstate known liabilities and assets, or to
defer recording items that should be expensed. No entry may be made that intentionally hides or disguises the
true nature of any transaction.
All financial books, records and accounts must accurately reflect transactions and events, and conform both
to Generally Accepted Accounting Principles and to AQUATREAT’ system of internal controls. Undisclosed
or unrecorded funds, assets or liabilities are not allowed. Employees uncertain about the validity of an entry
or process are expected to consult with the Corporate Controller or Vice President, Finance.
Creating and Retaining Business Records

Almost all business records—including email and computer records—may become subject to public
disclosure in the course of litigation or governmental investigations. Records are also often obtained by
outside parties or the media. Employees should therefore attempt to be as clear, concise, truthful and accurate
as possible when recording any information. Avoid exaggeration, colorful language, guesswork, legal
conclusions, and derogatory characterizations of people and their motives.
Documents should only be destroyed in accordance with the applicable document retention policy, and never
in response to or in anticipation of an investigation or audit. Contact the Ethics Committee if there is any
doubt about the appropriateness of document destruction.

Keep Your Commitments—Negotiate, Perform, and Market in Good Faith


Our success in the marketplace is based on the quality of our services, the perception that our services
provide value to our clients, and the competence and honesty of our sales presentations. AQUATREAT
prospers only to the degree that we serve our clients well—and treat them, our coworkers, our customers, our
vendors and our competitors fairly and honestly. When we fail to negotiate, perform, or market in good faith,
we seriously damage our reputation and lose the loyalty of our clients.

Fair competition is the hallmark of our relationships—our business dealings will be frank and respectful, and
we strive to generate mutually advantageous relationships and satisfactory outcomes.
AQUATREAT believes in doing business with those suppliers, contractors, partners, agents, sales
representatives, distributors and consultants who embrace and demonstrate high standards of ethical business
behavior. AQUATREAT will not knowingly use suppliers who operate in violation of applicable law or
regulation, including local, environmental, employment or safety laws.
Marketing, Negotiations, and Contract Execution
We are committed to the truthful and accurate communication of information about our services. Promotional
materials will be honest and factual, not misleading or deceptive. AQUATREAT employees are expected to
execute Company agreements in an ethical and conscientious manner—and always in accordance with our
contractual obligations. We will always obtain proper approvals before deviating from a contract or other
Purchasing Practices
All purchasing decisions must be made based on the best value received by AQUATREAT. Employees
should take care that personal or family relationships not influence or appear to influence objective business
decisions. Obtaining competitive bids, verifying quality and service claims on a regular basis and confirming
the financial and legal condition of the supplier are all important steps in good purchasing decisions.
Agreements should be written, and clearly set forth the services or products to be provided, the basis for
earning payment, and the applicable rate or fee. The amount must not be excessive in light of industry
practice and must be commensurate with the services provided. AQUATREAT will respect the confidential
information of our suppliers.
Cost and Pricing Data
As a Company that may provide services to the United States Government, we must be especially vigilant in
ensuring that we negotiate our contracts fairly and truthfully. In some cases, as with the Truth in Negotiations
Act in the United States, we are required to disclose all cost or pricing data that supports our proposals (even
if we choose not to use that data in our proposals). To this end, we will make no false claims or seek to
misrepresent relevant information. Examples of cost and pricing data include supplier quotes; nonrecurring
costs; information on changes in production methods and in production or purchasing volume; data
supporting projections of business prospects and objectives and related operations costs; unit cost trends;
make-or-buy decisions; estimated resources to attain business goals; information on management decisions
that could significantly bear on costs; and actual costs on past similar jobs, including work in process.
Contract Performance
Every day, thousands of individual tasks are completed successfully that meet or exceed our clients’
expectations and fulfill the Company’s contractual obligations. Quality at AQUATREAT means doing the
job right, on time, and always to the satisfaction of the client. Quality does not come from an “after-the-fact”
repair or rework job—it is a behavior that results in doing our job right the first time, with concern for the
highest ethical standards and personal integrity.

Act Responsibly—Disclose and Resolve Potential Conflicts of Interest


Integrity in a business relationship means that all participants are working together for the common good, and
are not making decisions based on self-interest. When we act with integrity, we earn trust and build long-term
client and customer relationships. When we act, or appear to be acting, in our own self-interest, we lose trust
and damage our reputation.

Conflicts of Interest

Shareholders of AQUATREAT expect that business decisions are made in the best interest of the Company.
Actions must be based on sound business judgment, and not motivated by personal interest or gain. Any
situation that creates or appears to create a conflict of interest between personal interests and the interests of
AQUATREAT must be avoided. Potential conflict of interest situations must be reported to an employee’s
manager and to the Ethics Committee.

AQUATREAT expects that our business will be conducted free from any actual or potential conflict that
might arise when one’s loyalty is split between personal interests and those of the Company. Judgment can
be affected in any transaction or relationship where an individual might find that AQUATREAT’ interest
competes with his or her own. AQUATREAT wants loyalty to come easily, and we will work together to
resolve disclosed conflicts
in a mutually satisfactory manner. Our clients, customers and suppliers can expect to be dealt with fairly and
impartially, free from any conflicting interests.
AQUATREAT employees have a duty to avoid financial, business, or other relationships that might interfere
with this commitment. Each of us will scrupulously avoid even the appearance of a conflict between personal
interests and those of the Company in matters of importance to AQUATREAT business, and we expect those
with whom we interact to support us in this endeavor.

Family Members and Close Personal Relationships

A conflict of interest may arise when doing business with or competing with organizations that employ or are
partially owned by family members or close personal friends. Family members include spouse, children,
parents and siblings.

Personal Investments
Employees may not own, either directly or indirectly, a substantial interest in any business entity that does or
seeks to do business with, or is in competition with AQUATREAT, without written approval of the COO. As
a guide, “substantial interest” includes the ownership by an employee or family member of more than 5% of
a Company’s outstanding securities or that represents more than 5% of the total assets of the employee or
family member. Employees are also prohibited from taking for themselves business or investment
opportunities that are discovered through the use of our property, information or position. This includes
directly or indirectly buying, leasing or otherwise acquiring rights to any property or materials if they believe
that AQUATREAT may also be interested in pursuing such opportunity.
You must disclose any matter that casts doubt on your ability to act objectively and in AQUATREAT best
interest. Employees, representatives, and agents of the Company who may have an actual or potential conflict
should report all pertinent details in writing to their manager and the Ethics Committee.

Any of the following situations could present a conflict of interest and should be disclosed:
• Employment by a competitor; regardless of the nature of the employment, while employed by
AQUATREAT. Dual employment may also create time management issues—AQUATREAT is the
primary employer in all such circumstances.
• Placement of business with a firm in which an employee or close family member has a substantial
ownership or management interest.
• Ownership of, or substantial interest in, a Company, which is a competitor or a supplier to
• Acting independently as a consultant to a AQUATREAT customer or supplier.
• Using Company assets, intellectual property, or proprietary interests for personal gain.
• Acceptance of anything of value—such as gifts of more than a nominal value, discounts, or
compensation—from an individual or entity that does or seeks to do business with AQUATREAT.
• Hiring relatives to work directly for you at AQUATREAT, especially when you have control or
influence over their work assignments, compensation, or promotional opportunities.

Act with Integrity – Stay Clear of Improper Business Courtesies

To maintain trust in our business relationships, we must always act with integrity. We must steer clear of
giving or receiving gifts that are intended to influence, or appear to influence, business decisions. When we
accept or give such gifts, it can undermine customer relationships, hurt our reputation, and put the Company
in legal jeopardy.
In many industries and countries, gifts and entertainment are used to strengthen business relationships.
AQUATREAT recognizes that gifts, gratuities, and other business courtesies may occasionally be
appropriate in building and maintaining business relationships with clients, customers, suppliers, and other
stakeholders. Gifts and entertainment should further the business interests of AQUATREAT and not be
lavish or in excess of the generally accepted business practices of one’s industry. However, our employees,
representatives, and agents must avoid even the perception of favorable treatment or the appearance of
impropriety when offering or accepting any item of value in conducting the Company’s business. Throughout
the world, one principle is common and clear: No gift, favor, or entertainment should be accepted or provided
if it will obligate or appear to obligate the recipient.
Requesting or soliciting personal gifts, favors, entertainment, or services is unacceptable. Accepting gifts of
cash or cash equivalents is also always unacceptable. Additionally, employees may not exploit their position
to solicit vendors, including financial institutions, to provide individual preferential treatment in pricing,
terms, or loans.
When considering whether to accept or offer a gift, gratuity, or other business courtesy, AQUATREAT
employees are expected to use moderation and prudent judgment. Although specific policies and procedures
must be your guide, begin by assuring yourself that any offer you would make or courtesy that you would
accept would leave you feeling comfortable if known by your manager, coworker, family member, or the
public. If you are a buyer, influence buying, or are involved in procurement transactions in any way (e.g.
determine specifications, evaluate bids, etc.), you must refrain from offering or accepting business courtesies
that could be perceived as affecting your objectivity or influencing your decisions. If the “right thing to do” is
not obvious, seek guidance from your manager, or the Ethics Committee.
Gifts, Gratuities, and Other Business Courtesies
Generally, our employees should limit themselves to accepting gifts or entertainment of nominal or
insignificant value ($20 or less), in accordance with current IRS guidelines. When offering a business
courtesy, it must be consistent with acceptable marketplace practices, not lavish or extravagant, and not
violate the recipient organization’s own rules of standards of conduct.
Government Gift Policies
Government employees are subject to varied and complex rules, often prohibiting them from accepting
anything of value unless specifically provided for in relevant statutes or regulations. These rules flow down
to prime contractors and higher-tier subcontractors who are conducting the Government’s business, so it is
important to remember that even commercial customers could be subject to government regulations in such
Laws and regulations, such as the Anti-Kickback Act and the Foreign Corrupt Practices Act (FCPA) in the
United States, have been created to ensure that business decisions are free from unfair influence. Bribes and
other corrupt offers not only violate AQUATREAT policy; they are illegal—subjecting both AQUATREAT
and the individual to civil and criminal penalties. When dealing with government customers or officials,
whether they are domestic or international, we must be especially mindful as these laws and regulations have
been put in place to protect the public’s interests. Any offer of money or gifts intended to influence a
business decision should be reported to your manager or the Ethics Committee.
Recipients of prohibited gifts or favors should let management know and return the gift with a letter
explaining AQUATREAT’ policy. If a gift is perishable or impractical to return, management should first
attempt to donate it to charity or, alternatively, distribute it to employees, with a letter of explanation to the
donor from the originally intended recipient.
Focus on Global Responsibility—Our Reputation Extends Across Borders

AQUATREAT could be expanding globally in the future. Success in any global business transaction depends
on our compliance with country-specific constraints and conditions, and sensitivity to local customs. Laws,
regulations, and conventions governing business relationships vary from country to country. AQUATREAT
obligation to comply with KSA law and regulation does not end, however, when we, or our services, exit the
United States, nor does our commitment to treat our stakeholders with concern and respect.
We have great responsibilities in any country where we may do business. Being a responsible corporate
citizen means being sensitive to the people who live in varied global communities. It requires that we know
and comply with the laws, regulations, and customs of each host country and community in which we
conduct business. Finally, being a good corporate citizen means that we conduct the Company’s business not
as a “foreigner” but rather as part of the fabric of that host nation and/or community in which we live and
work. AQUATREAT recognizes that we will be welcome only as long as we make a positive contribution in
each of these host nations.

Be Responsible to Our Shareholders—Don’t Trade on “Inside” Information


AQUATREAT’ success in the marketplace requires the trust and confidence of the investment community.
Achieving this trust requires that we act with integrity when trading public securities, following federal and
state securities laws. When we succumb to temptation and trade on “inside” information, stock prices are
affected, often with a negative impact on shareholders.
Federal and state securities laws prevent investors who possess material information (information not readily
available to all current and potential investors) from using that information to buy or sell publicly traded
securities. Securities include common stocks, bonds, puts and calls, options, futures, straddles, and other
financial instruments. Material information is that which reasonably can be expected to affect the market
value of securities or to influence investor decisions with respect to securities transactions. Such information
includes, but is not limited to, financial and key business data; merger, acquisition, or divestiture discussions;
award or cancellation of a major contract; changes in key management; forecasts of unanticipated financial
results; significant litigation; and gain or loss of a substantial customer or supplier.
AQUATREAT employees will comply fully with federal and state securities laws and be alert to the laws of
other countries when making personal investments. In particular, we comply with those laws and regulations
relating to the disclosure of material corporate information and “insider” trading. These laws provide for
substantial civil and criminal penalties for individuals found to have violated them and may bear on the
ability of the Company to publicly trade its shares and other financial instruments.
Insider trading generally involves buying or selling securities while in possession of information not
available to the public in order to obtain a personal trading benefit. Likewise, most stock-tipping violations
involve the disclosure of inside information, often to a relative, colleague, or friend, to obtain an indirect
personal benefit by enabling the recipient to buy or sell securities on the basis of such information. An
“insider” includes not only directors and officers of the Company, but anyone who possesses material
information that has not been disclosed to the general public.
AQUATREAT’ employees in possession of, or with access to, material, nonpublic information gained
through their work at AQUATREAT may not use such information to trade in AQUATREAT securities—or
the securities of another Company (suppliers, vendors, clients, customers, etc.) to which the information
pertains, in accordance with AQUATREAT’s Insider Trading Policy. You may not engage in any other
action to take advantage of, or pass on to others, material information prior to its release to the public at large
and for a reasonable period of time thereafter. Except for properly authorized Company disclosures, you are
responsible for maintaining the confidentiality of material Company information. You must refer all outside
inquiries about AQUATREAT, whether from the media, a government agency, or otherwise, to the
appropriate AQUATREAT Vice President in charge of external communications.
If you have any questions about compliance with securities laws and regulations, you should contact the
Ethics Committee, but here are some simple rules to remember:

Don’t trade on information unavailable to the public.
Don’t pass information along to others that give them an advantage in the financial marketplace.
Protect Sensitive Information—Assets Worthy of Care

One of AQUATREAT’ most valuable assets is information. We are contracted with our clients to maintain
the security of their customers’ information. Like all other assets, information that is not generally disclosed
and is helpful to the Company, client Company, (or would be to competitors) must be protected. Some
examples of the areas that offer AQUATREAT a competitive advantage include: client and customer
databases, trade secrets, detailed sales and profit figures, new product or marketing plans, service offering
ideas or information and information about potential acquisitions, divestitures and investments.
Safeguard confidential information by keeping it secure, limiting access to those who have a need to know in
order to do their job, disposing of proprietary documents in secure containers and avoiding discussion of
confidential information in public areas, for example on planes, elevators and mobile phones. The obligation
to preserve AQUATREAT’ confidential information is ongoing, even after employment ends.
AQUATREAT employees will protect the Company’s intellectual property, and act responsibly with the
sensitive information of clients, competitors, customers, and other stakeholders. Each employee and those
that are granted access to such sensitive information (including Company private, competition sensitive, and
proprietary information) are obligated to protect and maintain its confidentiality and are prohibited from
disclosing it unless authorized by designated Company officials. This sensitive information also includes bid
prices, competitor pricing, or technical data, or proposal evaluations. Sensitive information from other
companies (or proprietary information)—whether marked with a restrictive legend or unmarked—may only
be used for the purpose(s) authorized by the owner Company.
AQUATREAT employees will not use improper means to seek proprietary information about a competitor—
especially theft, illegal entry, electronic eavesdropping, or surveillance. We will not misrepresent ourselves,
our positions, or our circumstances to persuade another to release information (by posing as a customer, for
example), nor will we commission a third party to do so. Similarly, we will be careful not to transfer outside
the Company confidential electronic mail messages or any message intended for internal use only. We will
respect our coworkers’ personal privacy and protect private personnel information from those inside or
outside AQUATREAT who have no need to know. We trade on trust and our reputation for integrity.
Devious tactics that undermine the confidence others have in us do not follow our ethical principles.
Care for Company Assets—Respect Our Resources


Effective use of Company resources is critical to our bottom line. When we use Company resources wisely,
we demonstrate our efficiency. When we waste Company resources, we increase Company costs and reduce
All employees are entrusted with numerous Company assets, and have a special responsibility to protect
them. This includes not only cash and other financial assets, but also assets like office equipment, inventory,
computer networks and supplies.
AQUATREAT commits to our shareholders and clients that our employees and partners will demonstrate
good judgment and discretion when utilizing Company or client-owned resources. Such resources include
computers, telephones, Internet access, electronic mail (email) tools, voice mail, reproduction equipment,
printers, facsimile systems, office supplies and facilities. Likewise, we will exercise prudence in our
expenditures, pursuing best value and return on our investments.
Company computers, printers or networks may only be used in accordance with Company policy, and may
never be used to access, receive or transmit material that others would find offensive. Unauthorized copying
of software, tapes, books and other legally protected work is a misuse of assets and may expose the Company
to legal liability.

Any act by a AQUATREAT employee that involves theft, fraud, embezzlement, or misappropriation of any
property is prohibited and will be grounds for immediate termination.
Employees shall use Company or customer-owned assets first and foremost for business purposes and to
advance the Company’s strategic objectives. However, occasional limited personal use may occur when it
does not compromise AQUATREAT’ interests. Each of us is responsible for safeguarding these assets—
never borrowing or removing them from Company premises without proper authorization and always being
mindful not to deplete their value, add significant cost for the Company, or use them in a manner that
adversely affects the Company’s reputation.
When using the Company’s assets for personal reasons, follow these guidelines:
• Do not use AQUATREAT assets in support of a personal business, consulting effort, or similar
private venture, or to support the business of another Company or firm, outside fund raising activity,
political activity, or lobbying.
• Limit time spent to a reasonable duration and frequency—always incidental to your workday and
never charged to the Company or client. Use may not interfere with, or adversely affect, your job
performance or that of any other person or organizational requirement.
• Do not use AQUATREAT assets to support any illegal or other purpose that could cause
embarrassment to AQUATREAT or otherwise adversely affect its interests.
• Do not use AQUATREAT assets to be disruptive or offensive (e.g., involving sexually explicit
materials, or materials that are discriminatory, hateful, or threatening) to others.
• Do not sell, loan, give away, or dispose of AQUATREAT property without proper authorization.
• When unsure of what constitutes appropriate use of AQUATREAT’ assets, consult with your
manager or the Ethics committee.
Demonstrate Citizenship—Engage in Community and Political Activities

When we give back to the community and participate appropriately in the political process, we improve our
standing in the community and gain respect. When we aren’t involved, we alienate our neighbors and miss a
valuable opportunity to strengthen our marketplace relationships.
Our employees recognize the benefits afforded personally, to their communities, and to AQUATREAT when
they are involved in civic affairs and the political process. AQUATREAT strongly encourages each of its
employees to become actively involved in the life of the community by sponsoring and participating in
initiatives for the betterment of the quality of life. No one in the Company, however, may pressure another
employee to contribute to or participate in charitable organizations. Voluntary personal contributions to
candidates, parties of employee choice and civic organizations are encouraged and are consistent with
AQUATREAT’ commitment to citizenship and community involvement. Employees must recognize,
however, that their involvement and participation must be on an individual basis, on their own time and at
their own expense.
AQUATREAT respects the right of each of its employees to participate in the political process and to engage
in political activities of his or her choosing. While involved in their personal civic and political affairs,
however, employees must at all times make clear that their views and actions are their own, and not those of
AQUATREAT. Employees may not use AQUATREAT resources to support their personal choice of
political parties, causes, or candidates.
Lobbying activity on behalf of the interests of AQUATREAT is permissible, but highly regulated by law.
Employees who communicate with government employees and officials on issues that affect AQUATREAT
must contact the COO to ensure that such activities fully comply with the law and that AQUATREAT’
lobbying efforts are coordinated.

Outside the Kingdom., AQUATREAT will honor local laws and applicable Saudi Arabia. laws, including the
Foreign Corrupt Practices Act. Generally speaking, the FCPA prohibits AQUATREAT from directly or
indirectly offering, promising to pay or authorizing the payment of money or anything of value to foreign
government officials, parties, or candidates for the purpose of influencing the acts or decisions of foreign
officials. Not all payments to government
officials are illegal, but FCPA rules are complex. The COO must be consulted in advance of any payment to
a foreign official.
Promote Fair Trade and Free Enterprise—Boycotts and Price Fixing Erode Public Trust


Maintaining a level playing field in the course of doing business fosters fair play, promotes healthy
competition and contributes to keeping the global marketplace dynamic and robust. When a Company has an
unfair advantage in the marketplace, competition is stifled and customers are negatively affected.
AQUATREAT promotes fair trade and free enterprise. Many of the countries in which AQUATREAT could
operate in have enacted antitrust laws that prohibit unlawful “restraint of trade” and our Company rigorously
observes these states and regulations. Although these laws will vary from country to country, the antitrust
laws of the Saudi Arabia are representative of typical statutes. Generally, such laws prohibit restrictive trade
agreements and/or practices that may reduce competition without providing beneficial effects to consumers.
Such agreements and/or practices violate both public policy and AQUATREAT policy.
Prohibited “restraint of trade” practices that violate antitrust laws generally include:
• Agreements and understandings among competitors to fix or control prices
• Boycotts of specified suppliers or customers
• Efforts to misrepresent, disparage, or harass competitors
• Coordinating with competitors to allocate customers and/or territories
• Limitations on the production or sale of products or product lines for anticompetitive purposes
• Contracts or other arrangements that involve exclusive dealing
• Tie-in sales or other restrictive agreements with suppliers and customers
• Price discrimination
• Other restrictive terms of sale as between customers
Saudi Arabia. law prohibits KSA. firms and persons (and their controlled foreign subsidiaries) from
complying with foreign countries’ boycotts against countries friendly to the Kingdom of Saudi Arabia, and
from providing information concerning business relationships with boycotted countries.
AQUATREAT shall not participate in any foreign economic boycott not sanctioned by the KSA.
Government, and will not provide information concerning business relationships with boycotted countries.
AQUATREAT must report any direct or indirect request to participate in an unsanctioned boycott or forward
prohibited boycott-related information to the Kingdom’s government.
AQUATREAT employees shall not engage in any discussion with representatives of other companies,
agencies, or governments regarding possible “restraint of trade” or anti-boycott activities. You must report to
the Ethics Committee and the COO any such discussion initiated by any client or potential client. Violations
of Saudi Arabia antitrust and anti-boycott laws or regulations can subject both the Company and the
employee to severe criminal and civil penalties and fines.