This Code of Business Conduct and Ethics (the "Code") of Electronic Payment & Transfer Corp ("EP&T" or the "Company") has been adopted by the Board of Directors to explicitly define the expected standards of business conduct and principles of ethical behavior that support a core value of the Company -- personal and corporate integrity. All employees, officers, and directors of the Company (collectively, "we", "us", "our") are expected to be familiar with the Code and are required to comply with its provisions.

The integrity and reputation of EP&T depend on our collective and individual honesty, fairness, and integrity. Each of us is responsible for applying common sense and high personal ethical standards in making business decisions where there is no stated guideline in this Code or any other EP&T policy. This Code addresses conduct that is particularly important to proper dealings with third parties in the marketplace, our Company, and our stockholders, and is intended to supplement and be read in conjunction with all other policies of EP&T.

If a law conflicts with a policy in this Code, you must comply with the law; however, if a local custom or policy conflicts with this Code, you must comply with the Code. If you have any questions about these conflicts, you should ask your supervisor how to handle this sitution.

The Code describes guidelines and available compliance resources. In addition, each of us is encouraged to ask questions about conduct that may violate this Code, to voice concerns, or to clarify any terms of this Code. Each of us should be alert for potential violations of this Code by others and should report suspected violations without fear of retaliation. Anyone who violates this Code may be subject to disciplinary action, up to and including termination of employment and, in appropriate cases, civil action or referral for criminal prosecution.