Employees should report any observed or suspected violation of this Code to a supervisor or by contacting the President & CTO by emailing him at jbrasher@ovantellc.com. If an employee is uncertain whether any particular situation is a violation of this Code, he/she should report the situation. The Company will not tolerate retaliation or reprisal against employees who, in good faith, make such a report. Any employee who participates in such retaliation or reprisal will be subject to disciplinary action, up to and including termination.

The Company will determine, in its sole discretion, whether any practice, conduct or activity constitutes a violation of this Code. A conflict of interest may have to be resolved before the offender can continue his/her/its business relationship with the Company. Employees are expected to cooperate in internal investigations of misconduct.

Any failure to comply with the standards established by this Code may lead to disciplinary action, up to and including termination.