Ethical Business Conduct, Conflicts of Interest, and Outside Activity

It is the responsibility of each Mobius employee and member of each partner company, teammate and subcontractor to perform in an ethical manner and avoid conflicts of interest. This requires that each individual, no matter the corporate affiliation, recognize and avoid any situation that might, directly or indirectly, adversely affect the employee's judgment in acting for, or on behalf of Mobius or involve a conflict between personal interests and the interests of Mobius and its ethical and legal conduct of business.

Employees of all associations must maintain a constant awareness of the importance of ethical business conduct and must disqualify themselves from taking part in or exerting influence over any transaction where their own personal interests may conflict with the best interests of the work they are performing for Mobius or in partnership with Mobius or where their actions would violate the laws of the United States. Additionally, company or customer property, information, or business opportunities, may not be used for personal gain.

Employees must avoid any relationship or activity that might impair, or even appear to impair, their ability to make objective and fair decisions when performing their jobs. At times, an employee may be faced with situations in which business actions taken on behalf of Mobius or its subcontract employer may conflict with the employee’s own personal interests.

Conflicts of interest could arise in the following circumstances:

• Being employed by, or acting as a consultant to, a competitor or potential competitor, supplier or contractor, regardless of the nature of the employment, while employed with Mobius or a subcontractor to Mobius

• Serving as a board member for an outside commercial company or organization.

• Owning or having a substantial interest in a competitor, supplier, or contractor

• Accepting gifts, discounts, favors, or services from a customer/potential customer, competitor, or subcontractor, unless equally available to all company employees

Mobius does not intend to interfere with the rights of employees to conduct their personal business affairs and engage in outside activities that do not conflict with their obligations to Mobius or their direct employer who subcontracts to Mobius. However, activities and conduct away from the job must not compete with, conflict with, or compromise the company interests or adversely affect job performance and the ability to fulfill all job responsibilities. Employees are prohibited from performing any services for customers on nonworking time that are normally performed by Mobius. This prohibition also extends to the unauthorized use of any company tools or equipment and the unauthorized use of application of any confidential information. In addition, employees are not to solicit or conduct any outside business during paid working time.

Employees are cautioned to carefully consider the demands that additional work activity will create before accepting outside employment. Outside employment will not be considered an excuse for poor job performance, absenteeism, tardiness, leaving early, refusal to travel or refusal to work overtime or different hours. If Mobius determines that an employee’s outside work interferes with performance, the employee may be asked to terminate the outside employment.

Standards of Conduct

While it is not possible to list all behaviors that may be deemed offensive and worthy of disciplinary action, the rules outlined to all employees will be held; this is not an all-inclusive list. It is Mobius' philosophy that each employee should be encouraged to express his/her own individuality, and to have as much control of their working environment as is consistent with the smooth functioning of the company.

However, it is necessary for employees to observe some basic rules to:

• Allow other employees to work to full efficiency;

• Protect the health and safety of all employees;

• Maintain the professional image Mobius has built with its stakeholders

Every Mobius employee is expected to:

• Observe the rules for working hours and absences set forth;

• Accurately complete all company records, including time-cards and expense reports;

• Observe all Security Policies and Procedures including those requiring employees working in facilities where classified work is performed to consent to random searches of personal effects upon entering or leaving the facility;

• Perform his/her work properly and efficiently, and meet established standards of quality;

• Respect the smoking rules, which are instituted by each office individually;

• Treat customers, partners and other employees with dignity and respect; and

• Exercise good judgment that is consistent with this policy

Repeated disregard of the above rules can lead to discipline up to and including termination.

There are some offenses that will not be tolerated and are grounds for immediate dismissal.

These are:

• Theft, or willful damage or destruction of the company's or another employee's property

• Knowingly submitting falsified documents or records;

• Acts of physical violence;

• Violation of Mobius’ policy on drug and substance abuse;

• Being under the influence of alcohol during working hours;

• Carrying or having firearms or other dangerous weapons on company premises without express management approval;

• Knowingly and willfully violating Mobius’ policy on Ethical Business Conduct, Conflict of Interest and Outside Activity; and

• Willful breaches of security.