BUSINESS CONDUCT

CODE OF BUSINESS CONDUCT

It is a fundamental policy of the Company that all employees and Representatives observe and comply with the laws and regulations applicable to Polargo's business in each country where we operate and that each employee, franchisee and representative acts with high standards of business integrity.

YOUR COMMITMENT

As an employ or representative of Polargo, you must act with honesty and integrity in all matters. We also expect our suppliers, franchisees and all business partners to adhere to the principles set out in this Code.

WHAT IS IN THIS CODE – AND WHY IT MATTERS

The most valuable asset of Polargo is its brand. Among the important things the brand represents is our Company’s reputation for honesty and integrity. That reputation endures because of our values and our commitment to conduct responsible business in the right way.

This Code of Business Conduct is designed to give a broad and clear understanding of the conduct expected of all involved individuals everywhere we do business. This Code emphasizes our social responsibility as corporate citizens. The underlying principle is that this Code represents the overarching and primary code for Polargo from which all other corporate codes stem. The core message is the same: as employees and Representatives of Polargo, the way that we behave towards each other and towards those outside the Company, directly impacts our reputation with consumers, public officials, suppliers, franchisees and other stakeholders.

That reputation is critical to our commercial success and long term sustainability. We ask consumers to believe in our brand and in the Company that stands behind the brand. On a personal as well as a professional level, we all want to be proud of Polargo. This Code sets out Polargo's commitment to conducting business in accordance with our values and with all relevant laws and regulations.