Code of Ethics

ASCEND International Limited employees and all its associates strictly abide by this "Code of Ethics" and associated Compliance Principles as published in manuals, procedures, and contracts of employment.

The Code of Ethics under which ASCEND International Limited operates includes the following:

1. Integrity

1.1 ASCEND International Limited's work shall be carried out in a professional, independent and impartial manner.

1.2 ASCEND International Limited's work shall be carried out honestly, with no influence tolerated in respect to any deviation from either approved methods or procedures.

1.3 Data, Information and other material facts shall be recorded as is basis and will not be improperly changed.

2, Conflicts of interest

2.1 Conflicts of interest shall be avoided with any related entity in which there is a financial or commercial interest and to which services are provided.

2.2 Employees shall avoid conflicts of interest with the activities of the company.

2.3 All employees shall be free from any conflict of interest. Conflicts of interest can include, but are not limited to, ownership or involvement in outside interests that could influence or adversely affect the employee's performance or the Company's reputation.

3. Confidentiality

3.1 ASCEND International Limited shall treat all information received in the course of the provision of its services as business confidential to the extent that such information is not already published, generally available to third parties or otherwise in the public domain.

4. Anti-Bribery

4.1. No reward, gift, or favor in return for, or dependent on, the outcome of any work will be accepted and any offer will be reported.

4.2 ASCEND International Limited prohibits (a) the offer, giving, or acceptance of a bribe in any form, including kickbacks, on any portion of a contract payment, or (b) the use of other routes or channels for provision of improper benefits to, or receipt of improper benefits from, customers, agents, contractors, suppliers or employees of any such party or government officials.

4.3 While the Company is Customer Focused in providing its service, it will not tolerate any breach of Ethics, Law, or Company Policy in order to satisfy Customer requirements, whether stated or implied. Any attempt to subvert this policy is to be reported to management either through normal channels or the confidential facility.

5. Fair Marketing

5.1. All employees shall (a) conduct marketing (including comparisons with, or references to, competitors, competitors' services or third parties) in a manner that is truthful, not deceptive or misleading or likely to mislead, and is consistent with applicable laws; and (b) present itself in a fair manner; and (c) ensure presentational information, including descriptions of ASCEND International Limited's network and affiliations, resources employed and services provided, is accurate and unambiguous.

5.2 No misrepresentation of financial data will be made. All financial reports will reflect accurately the current position and performance of the Company in accordance with Company Policy and legal requirements.

Any infraction of the abovementioned policies will subject the employee to disciplinary action, up to and including dismissal.