(the "Company")

Our Code of Ethical Conduct serves to guide the actions of our employees, officers and directors in ways that are consistent with our core values: honesty, integrity, diversity,quality, respect, responsibility, and accountability.

We shall consistently treat our customers, employees, shareholders, suppliers, and the community with honesty, dignity, fairness, and respect. We will conduct our business with the highest ethical standards. Each one of us is charged with the responsibility to uphold and extend our standards for ethical behavior.


The Company is committed to providing quality products that meet or exceed the expectations of our customers. Deficiencies that threaten the physical well being of any person or put the financial security of our company at risk should be reported immediately to management.


The health and safety of the Company's employees is of utmost importance. Our work processes and policies are designed to minimize risk. We all must routinely review and improve workplace conditions to ensure a safe and healthful workplace and must promptly report accidents, injuries, and unsafe equipment, practices or conditions to supervisors and management. All employees must report to work free from the influence of any substance that could prevent them from conducting work activities safely and effectively.


We value and respect the diversity of our employees, officers, directors, suppliers, customers, and communities. We work to eliminate discrimination and harassment in all of its forms. Our company is committed to providing equal opportunity in all of our employment and purchasing practices. Harassment or discriminatory conduct by employees will not be tolerated.


We respect the needs and concerns of the communities in which we live and work. Sound waste management, recycling and energy conservation are legal, ethical, and business requirements. In meeting that commitment, we have implemented appropriate environmental management systems and closely monitor such systems to ensure that these standards are met.


The Company is committed to providing privacy protection of employee data maintained by the company. Employee data will be used for the sole purpose of supporting company operations and providing employee benefits. Our "Employee Privacy Policy" contains more detailed information in this regard.

We have put safeguards in place to ensure that personal data is protected from unauthorized access and disclosure, including limiting access to such data only to those employees with a legitimate business purpose. All employees are responsible for ensuring compliance with this employee privacy policy.


Protecting information about the Company's products, activities, performance, or plans is critical to our competitive position and reputation. Good judgment is needed to determine what information can or cannot be disclosed to others. Should there be any question as to whether certain information is confidential, employees should consult their supervisor.

The use of confidential company information for the personal gain of an employee, officer, director, or anyone else is contrary to the Company's policies and, in many cases, unlawful. Confidential information includes all nonpublic information that might be of use to competitors, or harmful to the company or its customers, if disclosed.

Buying or selling the Company stock on the basis of material nonpublic information is also prohibited. It is unlawful to communicate this information to other persons who may trade in our stock. Our "Corporate Disclosure Policy" outlines a more detailed policy in this regard.


The best interests of the Company are expected to be foremost in the minds of our employees, officers, and directors as they perform their duties. When we become employees of the company, and receive pay and benefits, we make this commitment.

It is wrong to seek any other economic gain by virtue of being a Company employee, officer, or director. Giving or receiving anything of enough value to influence sound business judgment is prohibited. This also applies to family, friends and business associates.

Employees may not work for or receive payments for services from any competitor, customer, distributor, sub-contractor or supplier of the Company without approval of management. The skills acquired by employees and used for the benefit of the Company must not be used in such a way that could hurt the business of the Company. Employees serving on boards of directors or similar bodies for an outside company or government agency require approval of management in advance.

No employee may allow his or her investments to influence, or appear to influence, their independent judgment on behalf of the Company. If there is a doubt about how an investment might be perceived, it should be disclosed to management. No employee is permitted to acquire rights to property or materials while in possessing knowledge that the Company may be interested in pursuing such an opportunity where such information is not yet public.

The Company trusts its employees, officers, and directors with information about company activities and with company funds and property. Use of any of these in a way that conflicts with company interests is strictly prohibited.


Employees are personally accountable for any form of company funds such as gas cards, tickets, cash, and cheques. Those who authorize the use of funds must ensure that the Company has received proper value in return.


The Company trusts its employees with information about company activities and with company property. Use of these in a way that conflicts with company interests, or in any manner that may reasonably be considered offensive or disruptive to another employee, is strictly prohibited. Company information and property may only be used for business purposes and other purposes approved by management and in any case may never be used for illegal purposes.


The Company documents a wide range of its activities. The integrity of these records is relied upon to make important business decisions and take actions. Therefore, it is essential that all records are accurate and complete. This responsibility prohibits false or misleading entries regarding both the amount or purpose of transactions. Some examples include vouchers, bills, financial data, expense reports, and performance records. Violations can be reported pursuant to our "Whistleblower Policy".


All internal business communications, formal or informal, should be clear, truthful and accurate. The use of exaggeration, colourful language, guesswork, legal conclusions, and derogatory remarks or characterizations of people and businesses should be avoided.

Neither the Company nor its representatives will do business with others who are likely to harm the Company's reputation. Subcontractors must act consistently with this Code, and joint ventures or alliances will only be formed with businesses that share the Company's commitment to ethical standards. All arrangements with agents, consultants or subcontractors, or regarding joint ventures or alliances must comply with this Code and applicable laws.


It is prohibited to use any illegal or unethical methods to gather competitive information. If information is obtained by mistake that may constitute a trade secret or confidential information of another business, or if there are questions about the legality of information gathering, either management or, where appropriate, the Company's legal counsel should be consulted immediately.


Employees are free to support community, charity and political organizations and causes of their choice, as long as it is clear that their views and actions are not those of the Company. Outside activities must not interfere with job performance. No one may pressure another employee to express a view that is contrary to a personal belief, or to contribute to or support political, religious or charitable causes.

No one may, except with the approval of management, make any political contribution on behalf of the Company or use the Company's name, funds, property, equipment or services for the support of political parties, initiatives, committees or candidates.


Electronic commerce, electronic mail, and other Internet-related systems are intended to be used for company business only. Additionally, all information on company computer systems, including electronic mail, is the property of the Company. Therefore, to ensure that computing resources are used in accordance with expectations, management may inspect and disclose the contents of electronic messages if such inspection and disclosure is made for legitimate business purposes or is necessary to protect the rights and property of the Company. Our "Use of Electronic Mail and Internet" Policy provides a more detailed policy in this regard.


Any employee, officer or director involved in court or other similar proceedings arising out of his or her employment with, or service to, the Company shall abide by the rules of that forum, cooperate with the orders of that forum, and not in any way commit perjury or obstruction of justice. All the Company employees must, at a minimum, comply with all applicable laws that relate to the conduct of our business in the relevant jurisdiction.


Each employee, officer, and director of the Company is expected to carry out his or her work in accordance with the business standards of conduct of the Company. Managers are expected to implement policies, programs, and procedures and ensure adequate communications as well as ensure internal controls are in place for their business unit to ensure compliance with the spirit and intent of applicable laws and policies. Managers and supervisors are responsible for distributing copies of the "Code of Ethical Conduct" to employees, as well as making them aware of the importance and specific requirements of this policy.

Employees are urged to direct any questions or concerns about the Company's activities to their supervisors or the human resources department, (or to the Compliance Officer if the matter pertains to the "Whistleblower Policy"). Any employee who suspects that a violation of the Code of Ethical Conduct has occurred is obligated to report it, and such employee shall be protected from retaliation.


Upon notification of a violation of this Code, a thorough investigation will be conducted, by management, or the Audit Committee, as appropriate. Corrective and disciplinary actions will be taken, if appropriate, up to and including the laying of criminal charges and termination of employment.



The Code of Ethics and Conduct ("Code") of Infolink Technologies Ltd. (the "Corporation") requires employees, officers and directors of the Corporation to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. In addition, the Corporation strives to maintain financial records and prepare financial statements and reports which comply with all applicable accounting principles and laws. As employees and representatives of the Corporation, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations. Unlawful activity of any kind is prohibited.


The goal of this Whistleblower Policy (the "Policy") is to discourage illegal activity and business conduct that damages the Corporation's good name, business interests, and its relationship with shareholders and the community at large. This Policy provides an avenue for employees to raise concerns regarding breaches of the Code and questionable accounting or auditing matters and provides reassurance that they will be protected from reprisals or victimization for whistleblowing in good faith.


It is the responsibility of all employees, officers and directors of the Corporation to report any violations or suspected violations of the Code and any concerns regarding accounting, financial statement disclosure, internal accounting or disclosure controls or auditing matters (a "Complaint") in accordance with this Policy.


No employee, officer or director of the Corporation who in good faith makes a Complaint shall suffer harassment, retaliation or adverse employment consequences. An employee that retaliates against someone who has made a Complaint in good faith is subject to discipline up to and including termination of employment.


This Policy is intended to encourage and enable employees and others to raise serious concerns within the Corporation rather than seeking resolution outside the Corporation. The Corporation has an open door policy and encourages employees to share their questions, concerns, suggestions or complaints with someone who can address them properly. In most cases, an employee's supervisor is in the best position to address an area of concern. However, it you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor's response, you are encouraged to speak with anyone in management whom you are comfortable approaching.

For suspected fraud or securities law violations, or when you are not satisfied or uncomfortable with following the Corporation's open door policy, individuals should contact the Corporation's Compliance Officer directly.

Supervisors and managers are required to report all Complaints to the Corporation's Compliance Officer who has specific and exclusive responsibility to investigate all Complaints. A sample Complaint Form is attached hereto as Exhibit A, which is recommended for use by the person receiving the Complaint.


The Corporation's Compliance Officer is responsible for investigating all reported Complaints. The Compliance Officer is Wanda Lee, the Chief Financial Officer of the Corporation and interim President and Chief Executive Officer of the Corporation. The telephone number for the Compliance Officer is (416) 504-8805 and her email is wlee@infolinkca.com. If you are not comfortable speaking with the Compliance Officer or the Compliance Officer is unavailable and the matter is urgent, you may contact the Chairman of Infolink's Board of Directors, Mr. Stewart Wright at (416) 214-4379 or by email at wrightstewart@aol.com.


The Compliance Officer has direct access to the Audit Committee at any time and is required to report to the Audit Committee at least annually on compliance activity.

The Audit Committee shall address all reported Complaints. The Compliance Officer shall immediately notify the Audit Committee of any Complaint and work with the Audit Committee until the matter is resolved.


Anyone filing a Complaint must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of the Code or constitutes a questionable accounting or auditing matter. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offence.


The Corporation will treat all Complaints as confidential and privileged to the fullest extent permitted by law. The Corporation will exercise particular care to keep confidential the identity of any person making a Complaint under this procedure until a formal investigation is launched. Thereafter, the identity of the person making the Complaint may be kept confidential, if requested, unless such confidentiality is incompatible with a fair investigation, unless there is an overriding reason for identifying or otherwise disclosing the identity of the person or unless such disclosure is required by law. In this instance, the person making the Complaint will be so informed in advance of his or her being identified with the Complaint. Where disciplinary proceedings are invoked against any individual following a Complaint, the Corporation will normally require the name of the person making the Complaint to be disclosed to the person subject to such proceedings.

The Corporation encourages individuals to put their name to any Complaint they make, but any person may also make anonymous Complaints. In responding to an anonymous Compliant, the Corporation will pay due regard to fairness to any individual named in the Complaint, the seriousness of the issue raised, the credibility of the information or allegations in the Complaint and the prospects of an effective investigation and discovery of evidence.

Investigations will be conducted as quickly as possible, taking into account the nature and complexity of the Complaint and the issues raised therein.

Complaints may be submitted on a confidential basis by the complainant or may be submitted anonymously. Complaints will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

This Policy encourages employees to put their names to allegations because appropriate follow-up questions and investigation may not be possible unless the source of the information is identified. Reported violations or suspected violations expressed anonymously will be investigated, but consideration will be given to the following factors: 1) the seriousness of the issue; 2) the creditability of the concern; and 3) the likelihood of confirming the allegation from a reliable source.


The Compliance Officer will notify the sender and acknowledge receipt of a Complaint, if it has not been filed anonymously, within five business days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.


This Policy is in effect as of June 27, 2005.

The Corporation reserves the right to modify or amend this Policy at any time as it may deem necessary.

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