Code of Conduct

Lucent Aquatech employees will always act lawfully, ethically, and in the best interests of the Company. This Code of Business Conduct and Ethics (the “Code of Conduct”) sets out basic guiding principles. Employees are encouraged to report any suspected noncompliance to the immediate Supervisor, Directors or Partner Manager.

Compliance with Laws, Rules and Regulations

Employees must follow applicable laws, rules and regulations at all times. Employees with questions about the applicability or interpretation of any law, rule or regulation, should contact the immediate Supervisor, Directors or Partner Manager.

Conflicts of Interest

Employees are expected to use their judgment to act, at all times and in all ways, in the best interests of Lucent Aquatech. A “conflict of interest” exists when an employee’s personal interest interferes with the best interests of Lucent Aquatech. A conflict of interest may also arise from an employee’s business or personal relationship with a customer, supplier, competitor, business partner, or other employee, if that relationship impairs the employee’s objective business judgment.

Discrimination and Harassment

All employees of Lucent Aquatech are responsible for maintaining and promoting an environment that is free of discrimination and harassment and for promptly reporting any incidents that they believe to be acts of discrimination or harassment. The Company recognizes its responsibility to deal quickly, fairly, and effectively with harassment and discrimination should it arise. A person who knows of or is in possession of information of harassment and/or discrimination and has the authority to penalize or prevent the conduct, or the continuation or repetition of the conduct and fails to use that authority will be considered responsible for failing to exercise his/her authority.

Health and Safety

Lucent Aquatech provides a clean, safe and healthy work environment. Each employee has responsibility for maintaining a safe and healthy workplace by following safety and health rules and practices and reporting accidents, injuries and unsafe conditions, procedures, or behaviors.

Violence and threatening behavior are not permitted. Employees must report to work in a condition to perform their duties, free from the influence of illegal drugs or alcohol.

Waivers

Waivers of this Code of Conduct may be made only in a manner permitted by law.