Introduction

This Code of Business Conduct and Ethics (this “Code”) shall apply to all directors and officers of SHARKREACH, Inc. (the “Company”, “we”, “us” or “our”) and is designed to provide guidance regarding the Company’s standards of integrity and business conduct. Every director and officer of the Company is expected to adhere to the principles and procedures set forth herein. The purpose of this Code is to promote:

  • Honest and ethical conduct, including fair dealing and the ethical handling of actual or apparent interest between personal and professional relationships;
  • Conducting business with professional competence and integrity;
  • Full, fair, accurate, timely and understandable disclosure;
  • Compliance with applicable laws, rules and regulations;
  • Prompt reporting of violations of this Code; and Accountability for adherence to this Code and to deter wrongdoing.

If a law conflicts with a policy in this Code, you must comply with the law. If you have any questions about these conflicts, you should ask your supervisor how to handle the situation.
Those who violate the standards in this Code will be subject to disciplinary action, up to and including termination of employment.

 

l. Compliance with Laws, Rules and Regulations

Obeying the law, both in letter and in spirit, is the foundation on which this Company’s ethical standards are built. All directors and officers must respect and obey the laws, rules and regulations of the cities, states and countries in which we operate. It is the personal responsibility of each individual to adhere to the standards and restrictions imposed by those laws, rules and regulations. Any director or officer who is unfamiliar or uncertain about the legal rules involving the Company’s business conducted by him or her should consult with higher levels of management or the Company’s Chief Financial Officer before taking any actions that may jeopardize the Company or that individual.

 

2. Professional Competence and Integrity

The Company is committed to deliver professional services in accordance with its policies and relevant technical and professional standards, to meet its contractual obligations, and to uphold its name and reputation.

 

3. Conflicts of Interest

A “conflict of interest” exists when a person’s private interest interferes in any way with the interests of the Company. A conflict situation can arise when a director or officer takes actions or has interests that may make it difficult to perform his or her Company work objectively and effectively. Conflicts of interest may also arise when a director or officer, or members of his or her family, receives improper personal benefits as a result of his or her position in the Company. Loans to, or guarantees of obligations of, directors and officers and their family members may create conflicts of interest.

It is almost always a conflict of interest for an officer or director to work simultaneously for a competitor, customer or supplier. You are not allowed to work for a competitor as a consultant or board member. The best policy is to avoid any direct or indirect business connection with our customers, suppliers or competitors, except on our behalf. Conflicts of interest are prohibited as a matter of Company policy, except under guidelines approved by the board of directors of the Company (the “Board”). Conflicts of interest may not always be clear-cut, so if you have a question, you should consult with higher levels of management. Any officer or director who becomes aware of a conflict or potential conflict should bring it to the attention of appropriate personnel.

 

4. Related-Party Transactions

A related-party transaction is a business deal or arrangement between two parties who are joined by a special relationship prior to the deal. For example, a business transaction between a major stockholder and the Company, such as a contract for the stockholder’s company to perform renovations to the Company’s offices, would be deemed a related-party transaction. Public companies are required to disclose certain transactions with related parties such as executives, associates and their family members in their Annual Report on Form 10-K. While the great majority of related-party transactions are perfectly normal, the special relationship inherent between the involved parties creates potential conflicts of interest which can result in actions which benefit the people involved as opposed to the stockholders.

Related-party transactions are prohibited as a matter of Company policy, except under guidelines approved by the Board. All related-party transactions must be approved in advance by the Audit Committee or, in the absence thereof, the Board.

 

5. Insider Trading

Directors and officers who have access to confidential information are not permitted to use or share that information for stock trading purposes or for any other purpose, except the conduct of our business. All non-public information about the Company should be considered confidential information. To use non-public information for personal financial benefit or to “tip” others who might make an investment decision on the basis of this information is not only unethical, but also illegal. If you have any questions, please consult the Chief Financial Officer by calling 1-877-525-SHARKREACH.

 

6. Corporate Opportunities

Directors and officers are prohibited from taking for themselves personally (or directing to a third party) opportunities that are discovered through the use of corporate property, information or position without the consent of the Board. No director or officer may use corporate property, information, or position for improper personal gain, and no director, officer or employee may compete with the Company directly or indirectly. Directors and officers owe a duty to the Company to advance its legitimate interests when the opportunity to do so arises.

 

7. Competition and Fair Dealing

We seek to outperform our competition fairly and honestly. Obtaining illegally proprietary information, possessing trade secret information that was obtained without the owner’s consent or inducing such disclosures by past or present employees of other companies is prohibited. Each director or officer should endeavor to respect the rights of and deal fairly with the Company’s customers, suppliers, competitors and employees. No director or officer should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other intentional unfair-dealing practice.

The purpose of business entertainment and gifts in a commercial setting is to create good will and sound working relationships, not to gain unfair advantage with customers. No gift or entertainment should ever be offered, given, provided or accepted by any director or officer, family member of the individual or agent unless it: (1) is not a cash gift, (2) is consistent with customary business practices, (3) is not excessive in value, (4) cannot be construed as a bribe or payoff and (5) does not violate any laws or regulations. Please discuss with appropriate personnel any gifts or proposed gifts that you are not certain are appropriate.

 

8. Discrimination and Harassment

The diversity of the Company’s directors and officers is a tremendous asset. We are firmly committed to providing equal opportunity in all aspects of employment and will not tolerate any illegal discrimination or harassment of any kind. Examples include derogatory comments based on racial or ethnic characteristics and unwelcome sexual advances.

 

9. Health and Safety

The Company strives to provide each employee with a safe and healthy work environment. Each director and officer has responsibility for maintaining a safe and healthy workplace for all employees by.