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Code of Business

Conduct and

Ethics Policy

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+Build Trust & Credibility

Integrated from project formation to final reporting, our state-of-the-art Warehouse ManagementSystem allows GFX to exceed turn-time expectations and minimize dispensable transportationcosts -costs that coulddelay campaigns or dcor from creating consumer impressions in-store.#

We utilize sophisticated bar-code technology to assure package details are verified beforeshipment, allowing us to continually improve upon the quality of the information at the source.This ensures an information flow that facilitates optimal project rollout. Whats more, allinformation is fed back into GFX Symphonyto guarantee the learning is paid forwardon every project.

+Respect for the IndividualWe all deserve to work in an environment where we are treated with dignity and respect.GFX is committed to creating such an environment because it brings out the fullpotential in each of us, which, in turn, contributes directly to our business success.

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+Create a Culture of Open & Honest Communication

At GFX everyone should feel comfortable to speak his or her mind regarding ethics concerns. Managershave a responsibility to create an open and supportive environment where employees feel comfortableraising such questions. We all benefit tremendously when employees exercise their power to preventmistakes or wrong-doing by asking the right questions at the right times. #

GFX will investigate all reported instances of unethical behavior. In every instance where improperbehavior is found to have occurred, the company will take appropriate action. We will not tolerateretaliation against employees who raise genuine ethics concerns in good faith. #

Employees are encouraged to address such issues with their manager or Human Resources, asmost problems can be resolved swiftly. If for any reason that is not possible or if an employee isnot comfortable raising the issue with his or her manager or HR, GFXs CEO does operate withan open-door policy.

Management has the added responsibility for demonstrating, through their actions, theimportance of this Code. In any business, ethical behavior does not simply happen; it isthe product of clear and direct communication of behavioral expectations, modeled fromthe top and demonstrated by example. Again, ultimately, our actions are what matters. #

To make our Code work, managers must be responsible for promptly addressing ethicalquestions or concerns raised by employees and for taking the appropriate steps to dealwith such issues. Managers should not consider employees ethics concerns as threatsor challenges to their authority, but rather as another encouraged form of businesscommunication. At GFX we want the ethics dialogue to become a natural part ofdaily work.

+Set Tone at the Top

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+Uphold the Law

Management has the added responsibility for demonstrating, through their actions, the importanceof this Code. In any business, ethical behavior does not simply happen; it is the product of clearand direct communication of behavioral expectations, modeled from the top and demonstratedby example. Again, ultimately, our actions are what matters. #

To make our Code work, managers must be responsible for promptly addressing ethicalquestions or concerns raised by employees and for taking the appropriate steps to dealwith such issues. Managers should not consider employees ethics concerns as threatsor challenges to their authority, but rather as another encouraged form of businesscommunication. At GFX we want the ethics dialogue to become a natural part ofdaily work.

We are dedicated to ethical, fair and vigorous competition. We will sell GFX products andservices based on their merit, superior quality, functionality and competitive pricing. Wewill make independent pricing and marketing decisions and will not improperly cooperateor coordinate our activities with our competitors. We will not o$er or solicit improperpayments or gratuities in connection with the purchase of goods or services for GFXor the sales of its products or services, nor will we engage or assist in unlawful boy-cotts of particular customers.

Competition

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+Uphold the Law

It is important that we respect the property rights of others. We will not acquire or seek toacquire improper means of a competitors trade secrets or other proprietary or confidentialinformation. We will not engage in unauthorized use, copying, distribution or alteration ofsoftware or other intellectual property.

Proprietary Information

We will not selectively disclose (whether in one-on-one or small discussions, meetings,presentations, proposals or otherwise) any material nonpublic information with respectto GFX, its business operations, plans, financial condition, results of operations or anydevelopment plan. We should be particularly vigilant when making presentations orproposals to customers to ensure that our presentations do not contain materialnon-public information.

Selective Disclosure

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+Avoid Conflicts of Interest

We must avoid any relationship or activity that might impair, or even appear to impair, our ability to makeobjective and fair decisions when performing our jobs. At times, we may be faced with situations wherethe business actions we take on behalf of GFX may conflict with our own personal or family interests

because of the course of action that is best for us personally may not also be the best course of actionfor GFX. We owe a duty to GFX to advance its legitimate interests when the opportunity to do so arises.We must never use GFX property or information for personal gain or personally take for ourselves anyopportunity that is discovered through our position with GFX.

Conflicts of Interest

Here are some other ways in which conflicts of interest could arise:

+ Being employed (you or a close family member) by, or acting as a consultant to,

a competitor or potential competitor, supplier or contractor, regardless of the

nature of the employment, while you are employed with GFX.

+ Hiring or supervising family members or closely related persons.

+ Serving as a board member for an outside commercial company or organization.

+ Owning or having a substantial interest in a competitor, supplier or contractor.

+ Having a personal interest, financial interest or potential gain in any GFX transaction.

+ Placing company business with a firm owned or controlled by a GFX employee or

his or her family.

Determining whether a conflict of interest exists is not always easy to do. Employees witha conflict of interest question should seek advice from management. Before engaging inany activity, transaction or relationship that might give rise to a conflict of interest,employees must seek review from their managers or the HR department.

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+Avoid Conflicts of Interest

GFX is committed to competing solely on a merit of our products and services. We should avoidany actions that create a perception that favorable treatment of outside entities by GFX was sought,received or given in exchange for personal business courtesies. Business courtesies include gifts,

gratuities, meals, refreshments, entertainment or other benefits from persons or companies withwhom GFX does or may do business. We will neither give nor accept business courtesies thatconstitute, or could reasonably be perceived as constituting, unfair business inducements thatwould violate law, regulation or polices of GFX or customers, or would cause embarrassmentor reflect negatively on GFXs reputation.

Gifts, Gratuities & Business Courtesies

Most business courtesies o$ered to us in the course of our employment are o$ered becauseof our positions at GFX. We should not feel any entitlement to accept and keep a business

courtesy. Although we may not use our position at GFX to obtain business courtesies, andwe must never ask for them, we may accept unsolicited business courtesies that promotesuccessful working relationships and good will with the firms that GFX maintains or mayestablish a business relationship with.#

Employees who award contracts or who can influence the allocation of business,who create specifications that result in the placement of business or who participatein negotiation of contracts must be particularly careful to avoid actions that create theappearance of favoritism or that may adversely a$ect the companys reputation forimpartiality and fair dealing. The prudent course is to refuse a courtesy from asupplier when GFX is involved in choosing or reconfirming a supplier or undercircumstances that would create an impression that o$ering courtesies is theway to obtain GFX business.

Accepting Business Courtesies

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+Avoid Conflicts of Interest

Employees may accept unsolicited gifts, other than money, that conform to thereasonable ethical practices of the marketplace, including:

Gifts

+ Flowers, fruit baskets and other modest presents that commemorate a special occasion.

+ Gifts of nominal value, such as calendars, pens, mugs, caps and t-shirts (or other

novelty, advertising or promotional items).

Generally, employees may not accept compensation, honoraria or money of any amountfrom entities with whom GFX does or may do business. Tangible gifts (including ticketsto a sporting or entertainment event) that have a market value greater than $100 maynot be accepted unless approval is obtained from management. #

Employees with questions about accepting business courtesies should talk to theirmanagers or Human Resources.

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+O!ering Business Courtesies

Any employee who o$ers a business courtesy must assure that it cannot reasonably be interpretedas an attempt to gain an unfair business advantage or otherwise reflect negatively upon GFX. Anemployee may never use personal funds or resources to do something that cannot be done withGFX resources. Accounting for business courtesies must be done in accordance with approvedcompany procedures. #

Other than to our government customers, for whom special rules apply, we may provide non-monetary gifts (i.e., company logo apparel or similar promotional items) to our customers.Further, management may approve other courtesies, including meals, refreshments orentertainment of reasonable value, provided that:

+ The practice does not violate any law or regulation or the standards of conduct of therecipients organization.

+ The business courtesy is consistent with industry practice, is infrequent in nature and

is not lavish.

+ The business courtesy is properly reflected on the books and records of GFX.

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+Set Metrics and Report Results Accurately

We create, retain and dispose of our company records as part of our normal course of businessin compliance with all GFX policies and guidelines, as well as all regulatory and legal requirements.#

All corporate records must be true, accurate and complete, and company data must be promptly andaccurately entered in our books in accordance with GFXs and other applicable accounting principles.

Corporate Recordkeeping

At times, we are all faced with decisions we would rather not have to make and issues wewould prefer to avoid. Sometimes, we hope that if we avoid confronting a problem, it willsimply go away. #

At GFX, we must have the courage to tackle the tough decisions and make di%cult choices,secure in the knowledge that GFX is committed to doing the right thing. At times this willmean doing more than simply what the law requires. Merely because we can pursue acourse of action does not mean we should do so.#

Although GFXs guiding principles cannot address every issue or provide answersto every dilemma, they can define the spirit in which we intend to do business andshould guide us in our daily conduct.

Promote Substance Over Form

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+Set Metrics and Report Results Accurately

Each of us is responsible for knowing and adhering to the values and standards set forth in thisCode and for raising questions if we are uncertain about company policy. If you are concernedwhether the standards are being met or are aware of violations of the Code, you must contactHuman Resources.#

GFX takes seriously the standards set forth in the Code, and violations are cause fordisciplinary action up to and including termination of employment.

Accountability

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+Be Loyal

Integral to GFXs business success is our protection of confidential company information,as well as nonpublic information entrusted to us by employees, customers and other businesspartners. Confidential and proprietary information includes such things as pricing and financialdata, customer names/addresses or nonpublic information about other companies, includingcurrent or potential supplier and vendors. We will not disclose confidential and nonpublicinformation without a valid business purpose and proper authorization.

Confidential and Proprietary Information

Company resources, including time, material, equipment and information, are providedfor company business use. Nonetheless, occasional personal use is permissible as longas it does not a$ect job performance or cause a disruption to the workplace.#

Employees and those who represent GFX are trusted to behave responsibly and use

good judgment to conserve company resources. Managers are responsible for theresources assigned to their departments and are empowered to resolve issuesconcerning their proper use.

Use of Company Resources

GFX is a high-profile company in our community, and from time to time, employees maybe approached by reporters and other members of the media. In order to ensure that wespeak with one voice and provide accurate information about the company, we shoulddirect all media inquiries to the Marketing Director. No one may issue a press releasewithout first consulting with the Marketing Director.

Media Inquiries

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+Do the Right ThingSeveral key questions can help identify situations that may be unethical, inappropriate or illegal.

Ask yourself:

+ Does what I am doing comply with GFX guiding principles, Code of Conduct and company policies?

+ Have I been asked to misrepresent information or deviate from normal procedure?

+ Would I feel comfortable describing my decision at a staff meeting?

+ How would it look if it made the headlines?

+ Am I being loyal and responsible to my company and myself?

+ Is this the right thing to do?