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EXHIBIT 99.3 AXCESS INTERNATIONAL, INC.
WHISTLEBLOWER POLICY Purpose This policy establishes standards and procedures to ensure that complaints and concerns
(each an Allegation) regarding the Axcess International Inc. (Company) operations, conduct
and reporting are handled in a manner that complies with managements and the Audit Committees
objectives. In addition, this policy:  
    establishes guidance for the receipt, retention, and treatment of verbal or
written reports received by the Company regarding accounting, internal controls,
auditing matters, disclosure, fraud and unethical business practices, whether
submitted by Company employees or third parties (Allegation), and
    establishes guidance for providing Company employees a means to make Reports in a
confidential and anonymous manner, and
    makes clear the Companys intention to discipline, up to and including
termination of employment, any person determined to have engaged in retaliatory
behavior, pursuant to Section 301 of the Sarbanes-Oxley Act of 2002 and Rule 10A-3 under the Securities
Exchange Act of 1934. Receipt This policy and information regarding problem resolution resources shall be provided to the
Companys employees and made generally available through the Company website and / or intranet. The
Company has designated the Chairman of the Audit Committee of the Board of Directors to be the
recipients of all the Allegations. Any Allegation received by a Company officer, director, or
employee from a Company or non-Company source should be immediately forwarded to Chairman of the
Audit Committee. Procedures The Audit Committee shall receive, retain, investigate, document and act on all Allegations
concerning accounting, internal accounting controls and auditing matters and other unethical or
illegal business conduct. In addition the Audit Committee shall receive and oversee the
handling and disposition of all Allegations regarding improper conduct towards employees and

violations of Company policies, laws or regulations regarding harassment, discrimination,
affirmative action and health and safety issues. The Audit Committee shall determine whether the Audit Committee, the Companys Outside Counsel
or management should investigate an Allegation, taking into account the following
considerations, in addition to any other factors that the Audit Committee deems appropriate
under the circumstances:  i.
    Who is the alleged wrongdoer?ii.
    How serious is the alleged wrongdoing?iii.
    How credible is the allegation of wrongdoing? If the Audit Committee determines that management should investigate the Allegation, the Audit
Committee will notify the Chief Executive Officer in writing of that conclusion. Management,
under the guidance of the CEO, shall promptly thereafter investigate the Allegation and shall
report the results of its investigation, in writing, to the Audit Committee. Management shall be
free in its discretion to engage outside auditors, counsel or other experts to assist in the
investigation and in the analysis of results. If the Audit Committee determines that Outside Counsel should investigate the Allegation, the
Audit Committee will notify the Outside Counsel in writing of that conclusion. The Outside
Counsel shall promptly thereafter investigate the Allegation and shall report the results of the
investigation, in writing, to the Audit Committee. The Outside Counsel shall be free in his or
her discretion to engage outside auditors, counsel or other experts to assist in the
investigation and in the analysis of results. If the Audit Committee determines that it should investigate the Allegation, the Audit Committee
shall promptly determine what professional assistance, if any, it needs in order to conduct the
investigation. The Audit Committee shall be free in its discretion to engage outside auditors,
counsel or other experts to assist in the investigation and in the analysis of results. The




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Audit Committee shall investigate and document the Allegation with the assistance of the
Companys Chief Financial Officer, if any, who shall report to and be solely under the direction
of the Audit Committee. Prompt and corrective action will be taken when and as warranted in the judgment of the Audit
Committee. Delegation of Authority With In the Audit Committee At the discretion of the Audit Committee, responsibilities of the Audit Committee created
by these procedures may be delegated to any member of the Audit Committee or to a subcommittee
of the Audit Committee and / or Board. Interpretation The Audit Committee, in consultation with outside counsel shall have the authority to make
interpretations regarding the operation of this Policy. Retaliation Retaliation against any employee that files a Report or voices a concern under this policy is
strictly prohibited. Employees determined to have engaged in retaliatory behavior or who fail to
maintain an employees anonymity if requested may be subject to discipline, which could include
termination of employment. Any employee who feels that he or she has been subjected to any behavior
that violates this policy should immediately report such behavior to his or her supervisor, Chief
Executive Officer, Chief Financial Officer or the Chairman of the Audit Committee. Please note
however, that employees who knowingly file misleading or false reports, or without a reasonable
belief as to truth or accuracy, will not be protected by this policy and may be subject to
discipline, including termination of employment. Audit Committee Review of Reports A summary of reports received under this policy will be communicated to the Board on a
quarterly basis (or a more frequent basis should conditions warrant more timely action). Reporting Allegations Anyone may forward Allegations on a confidential or anonymous basis to the Audit Committee by
writing to the Audit Committee c/o Axcess International Inc., 3208 Commander Drive, Carrollton,
Texas 75006 or by calling the following hotline: 972-407-6080 ext. 237. The Audit Committee, in its
discretion, may appoint a representative to monitor receipt of Allegations. Dated and approved by the Board of Directors on this 22nd day of February 2005.