INFORMATICS GROUP PERSONNEL AND PROCEDURES MANUAL EMPLOYEE CODE OF ETHICS AND POLICY FOR REPORTING IMPROPER ACTION AND PROTECTING EMPLOYEES AGAINST RETALIATION (WHISTLE BLOWER)

CONTENTS

1.1 Purpose
1.2 Policy Statement
1.3 Definitions
1.4 Prohibited Conduct
1.5 Prohibited Conduct after Leaving Company
1.6 Procedures for Reporting
1.7 Complaints, Investigations, Hearings and Enforcement
1.8 Protection Against Retaliatory Actions
1.9 Responsibilities

EMPLOYEE CODE OF ETHICS AND POLICY FOR REPORTING IMPROPER CONDUCT AND PROTECTING EMPLOYEES AGAINST RETALIATION

1.1 Purpose

A. The Directors of Informatics believe that to achieve a high standard of corporate governance for the operations of the group, employees must maintain a high level of integrity and professionalism in their conduct and ensure compliance with all laws and regulations in their dealings with all stakeholders. Accordingly, it is the purpose of this policy to establish ethical standards of conduct for all employees of the group; to set forth those acts that are incompatible with such standards; to require disclosure by such employees of private financial or other interests in matters affecting the company; and to provide effective means for enforcement thereof.

B. This policy shall be liberally construed in favour of protecting the group's interest in full disclosure of conflicts of interest and promoting ethical standards of conduct for all its employees.


C. This policy shall be interpreted and applied to allow inadvertent minor violations to be corrected and cured without disciplinary action and in conformance with the spirit and purpose of this policy.

1.2 Policy Statement

It is the policy of the Informatics group to encourage reporting by its employees of improper conduct by officers or employees and to protect employees who have reported such improper conduct in accordance with the group's policies and procedures.

1.3 Definitions

As used in this policy, the following terms shall have the meanings indicated:
A. "Employee" means every position of employment in the Informatics group.

B. "Group" means any Company which is a subsidiary of the Informatics group of
companies

C. "Immediate family" means:

1. A spouse;
2. Any dependent parent, parent-in-law, child or son-in-law or daughter-in-law;or
3. Any parent, parent-in-law, child, son-in-law, daughter-in-law, sibling, uncle, aunt, cousin, niece, nephew residing in the household of the employee.

D. "Person" means individual, association, corporation, or other legal entity.

E. "Improper conduct" means any action by an employee:

1. That is undertaken in the performance of the employee's official duties, whether or not the action is within the scope of the employee's employment; and
2. That (i) is in violation of any law or rule, (ii) is an abuse of authority, or (iii) is a gross misuse of company funds.
"Improper conduct" does not include personnel actions, including employee grievances, complaints, appointments, promotions, transfers, assignments, reassignments, reinstatements, restorations, reemployment, performance evaluations, reductions in pay, dismissals, suspensions, demotions, alleged violations of labor agreements or reprimands.

F. "Retaliatory action" means any adverse change in the terms and conditions of an     employee's employment.

1.4 Prohibited Conduct

No employee shall:

A. Disqualification From Acting On Company Business.

1. Engage in any transaction or activity, which is, or would to a reasonable person appear to be in conflict with or incompatible with the proper discharge of official duties, or which impairs, or would to a reasonable person appear to impair, the employee's independence of judgment or action in the performance of official duties and fail to disqualify him or herself from official action in those instances where conflict occurs;

2. Have a financial or other private interest, direct or indirect, personally or through a member of his or her immediate family, in any matter upon which the employee is required to act in the discharge of his or her official duties, and fail to disqualify himself or herself from acting or participating;

3. Fail to disqualify himself or herself from acting on any transaction which
involves the company and any person who is, or at any time within the preceding twelve (12) month period has been a private client of his or hers, or of his or her firm or partnership;

4. Have a financial or other private interest, direct or indirect, personally or through a member of his or her immediate family, in any contract or transaction to which a company in the group may be a party, and fails to disclose such interest to the appropriate authority prior to the formation of the contract or the time the company enters into the transaction.

B. Improper Use of Official Position.

1. Use his or her official position for a purpose that is, or would to a reasonable person appear to be primarily for the private benefit of the employee, rather than primarily for the benefit of the company; or to achieve a private gain or an exemption from duty or responsibility for the employee or any other person;

2. Use or permit the use of any person, funds, or property under his or her official control, direction, or custody, or of any company funds or property, for a purpose which is, or to a reasonable person would appear to be, for other than for a company purpose;

3. Regardless of prior disclosure thereof, have a financial interest, direct or indirect, personally or through a member of his or her immediate family, in a business entity doing or seeking to do business with the company, and influence or attempt to influence the selection of, or the conduct of business with, such business entity by the company.

C. Accept Gifts or Loans.

1. Solicit or receive any retainer, gift, loan, entertainment, favor, or other thing of monetary value from any person or entity where the retainer, gift, loan, entertainment, favor, or other things of monetary value has been solicited, or received or given or, to a reasonable person, would appear to have been solicited, received or given with intent to give or obtain special consideration or influence as to any action by such employee in his
or her official capacity.

D. Disclose Privileged and/or Confidential Information.

1. Disclose or use any privileged, confidential or proprietary information gained by reason of his or her official position for the immediate or anticipated personal gain or benefit of the employee or any other person or entity; provided, that nothing shall prohibit the disclosure or use of information which is a matter of public knowledge, or which is available to the public on request.

E. Hold Financial or Beneficial Interest

1. Regardless of prior disclosure thereof hold or acquire a beneficial interest, direct or indirect, personally or through a member of his or her immediate family, in any contract which, in whole or in part, is, or which may be, though, or under the supervision of such employee; or accept, directly or indirectly, any compensation, gratuity, or reward in connection with such contract from any other person or entity beneficially interested therein.

1.5 Prohibited Conduct After Leaving Company

A. No former employee shall, during the period of one (1) year after leaving employment:

1. Disclose or use any privileged or proprietary information gained by reason of his/ her employment for his/ her gain or anticipated gain, or for the gain or anticipated gain of any person, unless the information is a matter of public knowledge or is available to the public on request;

1.6. Procedures for Reporting Improper Conduct

Informatics employees who become aware of improper conduct should raise the issue first with their supervisor. If requested by the supervisor, the employee shall submit a written report to the supervisor, or to some person designated by the supervisor, stating in detail the basis for the employee's belief that an improper conduct has occurred. Where the employee reasonably believes the improper conduct involved his or her supervisor, the employee may raise the issue directly with the HR Director or such other person as may be designated by the HR Director to receive reports of improper conduct. In the event that an employee wishes to submit a compliant against the HR Director, the compliant shall be filled with the Internal Audit Director who shall assume the role of the HR Director to carry out the investigation.

The supervisor, the HR Director or Internal Audit Director or the HR Director or Internal Audit Director's designee(s), as the case may be, shall take prompt action to assist the company in properly investigating the report of improper conduct. Informatics officers and employees involved in the investigation shall keep the identity of reporting employees confidential to the extent possible under law, unless the employee authorizes the disclosure of his or her identity in writing. After an investigation has been completed, the employee reporting the improper conduct shall be advised of a summary of the results of the investigation, except that personnel actions taken as a result of the investigation may be kept confidential.

Informatics employees may report information about improper conduct directly to the
appropriate government agency with responsibility for investigating the improper conduct if the employee reasonably believes that an adequate investigation was not undertaken by Informatics to determine whether an improper conduct occurred or that insufficient action has been taken to address the improper conduct or that for other reasons the improper conduct is likely to recur.

1.7 Complaints, Investigations, Review and Enforcement

A. Any person may file a complaint alleged a violation of this policy as set forth in Section 1.6 Procedures For Reporting Improper Conduct.

B. The complaint shall be in writing and shall, except as described in section C below, be signed by the complainant. The written complaint should state the nature of the alleged violation(s), the date(s), time and place of each occurrence, and name of the person(s) charged with the violation(s). The complaint shall be filed with the HR Director or Internal Audit Director who shall provide a copy to the person charged with a violation. The complainant shall provide the HR Director or Internal Audit Director with all available documentation or other evidence to demonstrate a reason for believing that a violation has occurred.

C. This policy is intended to protect employees who choose to come forward in good faith
with complaints about improper conduct of Informatics employees. Anonymous complaints have the potential to subject the person who is the subject of the complaint to an investigation that may, at the least, cause stress and embarrassment, and may, at most, result in discipline or termination of employment. The Company is reluctant to begin an investigation based on an anonymous complaint due to the fact that evidence will be difficult to obtain and verify, and it will be impossible to assess the complainant's credibility. Complainants and whistleblowers have protection from retaliation under Company policy, and a thorough investigation of such complaints is the Company's goal. It is not possible to conduct a thorough investigation when a complainant remains anonymous. Therefore, the Company reserves the right to decline to investigate any complaint that is provided anonymously.

D. Within thirty (30) days after receipt of a complaint, the HR Director or Internal Audit Director or his designate shall conduct a preliminary investigation. If the HR Director or Internal Audit Director is implicated in the complaint, the CEO will determine who will conduct the Company's investigation. Criminal allegations will be referred to the proper law enforcement agency.

E. If the HR Director or Internal Audit Director determines, after preliminary investigation, that there are no reasonable grounds to believe that a violation has occurred, the HR Director or Internal Audit Director shall advise the CEO to dismiss the complaint. If the CEO does so dismiss the complaint, he or she shall do so in writing, setting forth the facts upon which the dismissal is based, and shall provide a copy of the written dismissal to the complainant, to the person charged with the violation and to the HR Director or Internal Audit Director.

F. The HR Director or Internal Audit Director shall refer a complaint to the CEO for action after his or her preliminary investigation, unless the CEO has dismissed the complaint; the HR Director or Internal Audit Director requests from the CEO more time to conduct an investigation; the HR Director or Internal Audit Director has determined that the violation was inadvertent and minor and was or is being satisfactorily corrected and cured; or with respect to a knowing or material violation, the HR Director or Internal Audit Director recommends to the CEO a settlement.

G. If the CEO determines that an employee has violated the provisions of this policy, the CEO may subject the employee to disciplinary action. In addition to any other penalty herein or otherwise provided by law, a violation shall be cause for suspension, discharge, or removal from employment, or such other disciplinary action as may be deemed necessary and proper, and consistent with personnel ordinances and rules; provided, that this section shall not derogate from employee rights under his terms of employment.

1.8 Protection Against Retaliatory Actions

Informatics officials and employees are prohibited from taking retaliatory action against an employee because he or she has in good faith reported an improper conduct in accordance with these policies and procedures.
Employees who believe that they have been retaliated against for reporting an improper conduct should advise in writing their supervisor, the HR Director or Internal Audit Director or the HR Director or Internal Audit Director's designee(s). Informatics officials and supervisors shall take appropriate action to investigate and address complaints of retaliation. If the employee's supervisor, the HR Director or Internal Audit Director, or the HR Director or Internal Audit Director's designee(s), as the case may be, does not satisfactorily resolve an employee's complaint that he or she has been retaliated against in violation of this policy, the employee may obtain protection under this policy by escalating his concern to the CEO.

1.9 Responsibilities

The HR Director is responsible for implementing Informatics' policies and procedures
(1) for reporting improper conduct and
(2) for protecting employees against retaliatory actions.

This includes ensuring that this policy and these procedures
(1)are permanently posted where all employees will have reasonable access to them,
(2)are made available to any employee upon request and
(3)are provided to all  newly- hired employees. Officers,managers and supervisors are    responsible for ensuring  the procedures are fully implemented within their areas of    responsibility.

Violations of this policy and these procedures may result in appropriate disciplinary action, up to and including dismissal.

You can blow the whistle by reporting your allegations in writing to whistleblower@informaticseducation.com