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Code of ethics

Act with integrity and ethically

One of the pillars of the QMC Way, or QMC Telecom’s non-negotiables in the way we operate and work, is that all of our actions with all of our constituents are guided by uncompromising ethical standards. To assist and guide us in this manner, our Board of Directors has adopted and our team has implemented a Code of Ethics and Business Conduct Policy (the “Code”) that is applicable to all directors, officers, employees and agents of QMC Telecom and its subsidiaries. As specified in the Code, all of our team members must conduct themselves with the highest degree of honesty, integrity and ethics and within the confines of the law when acting on behalf of QMC Telecom.

As part of the Code, our Board of Directors has adopted an Anti-Corruption Policy that is also applicable to all directors, officers, employees and agents of QMC Telecom and its subsidiaries. It is our policy to comply with all applicable requirements of the US Foreign Corrupt Practices Act (FCPA) and the applicable anti-bribery and anti-corruption laws of the countries in which we operate. QMC Telecom is committed at all levels of the company to a principle of zero tolerance in all anti-corruption and anti-bribery matters. We have established an Ethics Committee that is responsible for overseeing the implementation of the Code and the Anti-Corruption Policy and for resolving all matters that may arise under the Code and the Anti-Corruption Policy.