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standards for inter and intra office activity. This Code is in addition to other policies andpractices of the Company.     Each person is accountable for their compliance with this Code. Violations of this Code mayresult in disciplinary action against the violator.Questions, Contacts, and Reporting     If you have questions, concerns, suggestions or complaints, you should share them with someonewho can address them properly. In most cases, an employee’s supervisor is in the best position toaddress an area of concern. However, if you are not comfortable speaking with your supervisor oryou are not satisfied with your supervisor’s response, you are encouraged to speak with anyone inCompany management whom you are comfortable in approaching.     Any violations of this Code must be reported to the Company’s Board of Directors, inaccordance with the procedures outlined in the Company’s compliance reporting policy (WhistleblowerPolicy).Compliance with Laws and Regulations     Intrinsic in this Code is the understanding that you will comply with all laws, rules,regulations, and other requirements as set forth by local, State and Federal governments, and, ifapplicable, international law.     In no case will a you offer, promise or give money, gifts, loans, rewards, favors or anythingof value to any governmental official, employee, agent or other person which is prohibited by law.Financial Reporting     It is the Company’s policy to provide full, fair, accurate, timely and understandabledisclosure in its financial and regulatory reporting and in its disclosures to the public.Employees are to ensure that all transactions are executed in accordance with management authorityand that all transactions are recorded in sufficient detail to permit preparation of appropriatefinancial statements and disclosure. All terms and conditions of significant transactions are tobe in writing, and no oral agreements or amendments will be made. No false or misleading entrieswill be made on the Company’s books or records for any reason. No payment or reimbursement ofexpenses shall be made without adequate supporting documentation or invoices.     Any director or officer of the Company, or any person acting under their direction, isprohibited from taking any action to intentionally mislead or manipulate any independent public orcertified accountant engaged in the performance of an audit of the financial statements of theCompany for the purpose of rendering those financial statements materially misleading.Conflicts of Interest     You are prohibited from using your position with the Company, or any of its customers, forprivate gain, to advance personal interests or to obtain favors or benefits for
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yourselves, members of your family or any other individuals, corporations or businessentities. You will not, without written consent from your supervisor, engage in any activity thatcompetes with the interests of the Company, or that could harm the business or reputation of theCompany.     You shall conduct your personal affairs such that your duties and responsibilities to theCompany are not jeopardized and/or legal questions do not arise with respect to your association orwork with the Company.Confidentiality     You will respect the confidentiality of information, from both internal and external sources,and will disclose such information to third parties only when authorized or legally obligated to doso. In no case will confidential information be used for your personal gain of any directrelations of yours.Insider Trading     You are required to comply with the Company’s Insider Trading and Disclosure Policy. If youhave access to material, non-public information concerning the Company, you are not permitted touse or share that information for stock trading purposes. Insider trading, which is the use ofmaterial, nonpublic information for personal financial benefit, or to allow others to make aninvestment decision on the basis of this information, is unethical and illegal, and may subject youto criminal and civil liability.ACKNOWLEDGMENT AND CERTIFICATION     The undersigned hereby acknowledges and certifies that the undersigned:     (a) has read and understands the Silicon Mountain Holdings, Inc.’s Code of Business Conductand Ethics (the “Code of Ethics”);     (b) understands that the Chief Financial Officer is available to answer any questions theundersigned has regarding the Code of Ethics; and     (c) will continue to comply with the Code of Ethics for as long as the undersigned is subjectthereto.     Signature: