Code of Ethical Conduct

Rauch International Group’s policy is to maintain the highest ethical standards and comply with all applicable laws and regulations of the United States, federal, state and local where Rauch transacts business.

Some Rauch policies are based on the requirements of applicable law and others are just good ethics and business sense. While Rauch International has and will have foreign locations as either wholly owned subsidiaries, country specific resident entities, partnerships or teaming agreements, Rauch International Group’s headquarters are organized under United States law. This means that Rauch International Group is primarily governed by United States law, and that United States law applies to some of Rauch’s business outside the United States.

Rauch does business in many countries around the world and, as a good business citizen; we must observe the applicable laws of the countries in which Rauch does business. Sometimes there is a conflict between the United States law and the law of one of the other countries in which Rauch operates. In these situations Rauch will resolve the conflict with the advice and counsel of appropriate legal services.

We believe that adherence to this policy will ensure our continued success and in order to maintain our commitment to integrity, we have established this Code of Ethical Conduct.

It is the personal responsibility of each Individual, Affiliate, Subsidiary and Strategic Partner working for or with Rauch International Group to observe the standards of conduct and other requirements of the Code of Ethical Conduct whether or not these standards and requirements are also imposed by law.

Individuals, Subsidiaries, Affiliates and Strategic Partners working for or with Rauch International Group must practice fair dealing, honesty and integrity in every aspect of dealing with other company employees, the public, the business community, shareholders, customers, suppliers, competitors and government authorities. When acting on behalf of the Rauch International Group, Individuals, Subsidiaries, Affiliates and Strategic Partners shall not take unfair advantage through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or other unfair-dealing practices.

Rauch policy prohibits unlawful discrimination against employees, shareholders, directors, customers or suppliers on account of race, color, age, sex, religion or national origin. All persons shall be treated with dignity and respect and they shall not be unreasonably interfered with in the conduct of their duties and responsibilities.

Any individual, affiliate and strategic partner working for or with Rauch International Group who does not comply with these standards and requirements is acting outside the scope of his or her employment and or contract, responsibilities or agency.

Individuals, affiliates and strategic partners working for or with Rauch International Group are expected to read both the Code and the Program and fully comply with them. Integrity is everyone’s personal responsibility.

Any Individuals, Subsidiaries, Affiliates and Strategic Partners working for or with Rauch International who becomes aware of any unethical or illegal act of Rauch or any Individuals, Subsidiaries, Affiliates and Strategic Partners working for or with Rauch International Group must report that violation immediately to the CEO or Project Manager, or Director of Business Conduct

All Individuals, Subsidiaries, Affiliates and Strategic Partners working for or with Rauch International Group must comply with this Code of Conduct. No Individuals, Subsidiaries, Affiliates and Strategic Partners working for or with Rauch International Group should be misguided by any sense of loyalty to Rauch or a desire for profitability that might cause him or her to disobey any applicable law or Rauch policy. Violation of this Code is subject to discipline, which may include discharge and or contract cancellation.

If any individual, affiliate and strategic partner working for or with Rauch International Group have any questions about the policies, he or she should contact the Director of Business Conduct.