Code of
Ethics
This Code
of Ethics applies to the employees and directors of Information Systems
Associates, Inc. (“Information Systems”).
Information
Systems expects all of its employees and directors to act in accordance with the
highest standards of personal and professional integrity in all aspects of their
activities, to comply with all applicable laws, rules and regulations, to deter
wrongdoing and abide by the Information Systems policies and procedures adopted
by Information Systems that govern the conduct of its employees and directors,
as follows:
(a)
Engage in and promote honest and ethical conduct, including the ethical handling
of actual or apparent conflicts of interest between personal and professional
relationships;
(b) Avoid
conflicts of interest and to disclose to the Director of Information Systems
Compliance any material transaction or relationship that reasonably could be
expected to give rise to such a conflict;
(c) Take
all reasonable measures to protect the confidentiality of non-public information
about Information Systems or its subsidiaries and their customers obtained or
created in connection with employee's activities and to prevent the unauthorized
disclosure of such information unless required by applicable law or regulation
or legal or regulatory process;
(d)
Produce full, fair, accurate, timely, and understandable disclosure in reports
and documents that Information Systems or its subsidiaries files with, or
submits to, the Securities and Exchange Commission and other regulators and in
other public communications made by Information Systems or its
subsidiaries;
(e)
Comply with applicable governmental laws, rules and regulations, as well as the
rules and regulations of self-regulatory organizations of which Information
Systems or its subsidiaries is a member; and
(f)
Promptly report any possible violation of this Code of Ethics to the Director of
Information Systems Compliance or any of the parties or channels listed in the
Information Systems policies.
Employees
and directors are prohibited from directly or indirectly taking any action to
fraudulently influence, coerce, manipulate or mislead Information Systems or its
subsidiaries' independent public auditors for the purpose of rendering the
financial statements of Information Systems or its subsidiaries
misleading.
Employees
and directors understand that they will be held accountable for their adherence
to this Code of Ethics.
Their
failure to observe the terms of this Code of Ethics may result in disciplinary
action, up to and including termination of employment. Violations of this Code
of Ethics may also constitute violations of law and may result in civil and
criminal penalties for directors, employees, their supervisors and/or
Information Systems.
If
employees and directors have any questions regarding the best course of action
in a particular situation, they should promptly contact the Director of
Information Systems Compliance, Gerald Kieft. Employees and directors may choose
to remain anonymous in reporting any possible violation of this Code of
Ethics.