Local and International Anti-Trust Policy

Purpose

Northeast Data employees will comply with all applicable antitrust and competition laws in the performance of their responsibilities for and on behalf of the company. All operations and all functions supporting those operations, no employee shall engage in any conduct in violation of the antitrust or competition laws. It is the responsibility of each employee to recognize potential antitrust or competition law concerns as they arise and to consult with the Legal Department before taking any action.

Northeast Data is committed to free and open competition.

Policy Statement

Northeast Data will never make agreements, exchange information with competitors of any of the following topics:

• Pricing
• Terms and conditions of sales or purchase
• Costs
• Profit Margins
• Employment Practices
• Sales and Marketing plans
• Services Offered
• Customers Served
• Bidding plans
• Markets
• Boycotting or otherwise refusing to do business with a third party
• Destroying another competitor

Northeast Data will always obtain competitive data or information such as information about competitors pricing or their actions in the marketplace.

Approval from our legal department is needed before any employee may participate in any trade association (local or via international)

Enforcement

Failure to comply with this policy will result in disciplinary action, up to and including termination of employment.

Note: Northeast Data reserves the right to modify this policy at any time.