Exhibit 14.1

i2 Telecom International, Inc.

Code of Ethics and Conduct

1.0 Introduction

i2 Telecom has adopted this Code of
Ethics and Conduct to communicate to all i2 Telecom people the ethical and legal standards that we expect you to observe when dealing with i2 Telecom, your i2 Telecom colleagues, our clients and our suppliers.

We expect all i2 Telecom people to act ethically and obey the law. You should use i2 Telecoms Core Values and the principles described in this Code
as guidelines in deciding how to proceed when you encounter ehtical or legal issues involving i2 Telecom. We have adopted this Code to give you guidance for resolving these ethical and legal issues. In particular, this Code addresses the following
general topics:



| |  |  | Observing all laws and regulations
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| |  |  | Avoiding conflicts of interest
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| |  |  | Maintaining accurate and complete company records
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| |  |  | Protecting confidential information
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Because rapid
changes in our industry and in the law constantly present new issues, we cannot create guidelines that address all circumstances or constitute the definitive answer on any question. When you are in doubt about the correct or best course of action,
you should always consider consulting your manager for guidance.

We firmly believe that a strong commitment to ethical and legal conduct
is essential for us to successfully achieve our Purpose and Vision. We, therefore, require all i2 Telecom people to comply with this Code. To help ensure this compliance, we have established a procedure for reporting suspected violations of the
Code. Any violations of the Code may result in disciplinary action, including termination of employment. These matters are described in more detail at the end of this Code.

Throughout this Code, we use the terms i2 Telecom people, you and your to refer to all i2 Telecom employees,
directors and independent contractors, and the terms i2 Telecom, the company, we and our to refer to i2 Telecom International, Inc. and its subsidiaries, both domestic and international. We use the
term Code to refer to this document, as it may be amended from time to time.



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2.0 Observing all Laws and Regulations

2.1 Generally

We expect you to comply
with all applicable local, state and federal laws and regulations, both domestic and international, and refrain from illegal, dishonest or unethical conduct. Although laws and regulations may sometimes be ambiguous and difficult to interpret, we
expect you to make a good-faith effort to follow both the letter and the spirit of the law.

In addition, we expect you to comply with all
i2 Telecom policies and procedures which apply to you. These include, but are not limited to, our policies on equal opportunity, harassment, drug-free workplace, computer usage and information technology, data protection, expense reimbursement and
travel, as well as our internal financial controls and procedures. We may modify or update these policies and procedures in the future, and adopt new company policies and procedures from time to time. You are also expected to observe the terms of
any Non-Disclosure, Non-Solicitation and Non-Compete Agreement, Employment Agreement or other similar agreement that applies to you. If you previously signed one of these agreements with i2 Telecom, then it remains in full force and effect.

2.2 Bribes and Kickbacks

Bribery is illegal and subject to criminal penalties in the United States and many other countries. Bribery is forbidden under the U.S. Foreign Corrupt Practices Act, which is described in more detail in Section 2.3 of this Code, and
other laws and regulations. You may not give any bribes, kickbacks or other similar considerations to any person or organization to attract business. All decisions regarding the purchasing of materials, supplies and services must be made on the
basis of competitive price, quality and performance, and in a way that preserves i2 Telecoms integrity.

Fees, commissions or other
amounts paid to outside consultants, agents or other third parties must be fully disclosed to our Chief Financial Officer or Controller, and must be legal, proper and reasonable in relation to customary commercial practice. Payments to these persons
should never be used to accomplish indirectly what i2 Telecom could not properly or legally do directly.

You should also be familiar with,
and observe, the provisions of Section 3.3 of this Code relating to Gifts, Gratuities and Entertainment, because the giving or receiving of such items could constitute an illegal bribe or kickback under certain circumstances.

2.3 International Operations

You are
expected to comply with our policies applicable to international business transactions and with the legal requirements and ethical standards of each country in which you conduct i2 Telecom business, as well as with all U.S. laws applicable in other
countries.



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The U.S. Foreign Corrupt Practices Act (FCPA) applies to business transactions both inside the United
States and in other countries. Its requirements relate to accurate and complete financial books and records, transactions with foreign government officials and restrictions on the use of funds for unlawful or improper purposes. Because violation of
the FCPA can bring severe penalties, including criminal fines for the company and individuals and jail terms, it is essential that you become familiar with the FCPAs requirements if you are living or working in a foreign country. Other
statutes that may affect our international operations include, but are not limited to, the Anti-Bribery and Fair Competition Act and the Export Administration Act. If you have any questions regarding these legal requirements, please contact our
Chief Operating Officer.

2.4 Political Activity

We do not make contributions or payments that could be considered a contribution to political parties or candidates, or to intermediary organizations such as political action committees. However, you are free to
exercise your right to make personal political contributions within legal limits, unless these contributions are otherwise prohibited by other i2 Telecom policies. You should not make these contributions in a way that might appear to be an
endorsement or contribution by i2 Telecom. You should be certain that you understand, and are complying with, all such laws and regulations before making any political contributions. We will not reimburse you for political contributions in any way.

2.5 Antitrust

Antitrust laws generally prohibit agreements or actions that restrain trade or reduce competition. The free enterprise system rests on the notion that free and open competition is the best way to ensure an adequate supply of products and
services at reasonable prices. We expect you to adhere to both the spirit and the letter of the antitrust laws of the United States and with all applicable antitrust laws governing competition in any country in which i2 Telecom does business.
Violation of antitrust laws can result in severe civil and criminal penalties, including imprisonment for individuals, and i2 Telecom can be subjected to substantial fines and damage awards.

2.5.1 Agreements with Competitors

The following agreements, arrangements or understandings between i2 Telecom and its competitors (whether oral or in writing) must be avoided:



| |  |  | Agreements that affect the price or other terms or conditions of sale.
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| |  |  | Agreements regarding the clients to whom i2 Telecom will, or will not, sell its services.
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| |  |  | Agreements to refuse to sell to particular clients or to refuse to buy from particular suppliers.
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| |  |  | Agreements that limit the types of services which i2 Telecom will provide.
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Contacts with our competitors are sensitive and risky, because courts can infer an agreement or collusion from these contacts when they are followed by common action or behavior. We recognize that we may need to work
with our competitors on projects at the request of our clients. In all contacts with our competitors, you are expected to avoid discussing prices, costs, competition, division of markets, marketing plans or studies, and any other proprietary or
confidential information.

You should consult with our Chief Operating Officer or Chief Financial Officer when planning to contact a
competitor. If any competitor initiates a discussion with you involving the subjects above, you should immediately excuse yourself from the conversation and report the matter to our Chief Operating Officer.

2.5.2 Agreements with Clients and Customers

Our clients and customers must be free to decide when, and under what conditions, they will purchase i2 Telecoms services. While we may request or recommend certain terms and conditions for doing business, we cannot take coercive
action to require clients to comply with these requests or recommendations.

The following kinds of agreements might be unlawful, depending
on the facts and circumstances involved. You should not enter into these agreements without the approval of our Chief Operating Officer:



| |  |  | Exclusive-dealing agreements requiring clients to purchase all of their requirements for a certain service from i2 Telecom or prohibiting clients from purchasing services from a
competitor.
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| |  |  | Agreements requiring clients to buy one i2 Telecom service offering as a condition of obtaining another i2 Telecom offering.
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| |  |  | Reciprocity arrangements involving i2 Telecom using its purchasing power to require a supplier to purchase our services.
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2.6 Securities Laws and Insider Trading

The U.S. federal securities laws are built on the premise that a purchaser and a seller of securities should have equal access to important information regarding the company whose securities they are trading. Consequently, federal
securities laws forbid an investor from purchasing or selling securities based upon inside information not available to the other party.



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The consequences of insider trading violations can be severe. i2 Telecom people who trade on inside
information, or who communicate (or tip) this information to others so that they may trade, may face a civil penalty of up to three times the profit gained (or loss avoided), a substantial criminal fine and a jail term of up to ten
years. Additionally, if we or our senior officers do not take appropriate steps to prevent i2 Telecom people from insider trading, we may also face severe legal consequences, including, among other things, substantial criminal penalties.

2.6.1 Policy Statement

i2 Telecom
people who have material, nonpublic (i.e., inside) information about the company should not buy or sell i2 Telecom securities (including derivative securities such as put and call options) until a reasonable time after the inside
information has been publicly disclosed. You also should not disclose inside information to others outside i2 Telecom until a reasonable time after the information has been publicly disclosed. In addition, it is never appropriate for you to advise
others to buy or sell i2 Telecom securities.

No i2 Telecom person shall sell short i2 Telecom stock or engage in other
transactions where the person will earn a profit based on a decline in i2 Telecoms stock price.

These rules also apply to the use of
material, nonpublic information about other companies (including, for example, our clients, customers, competitors and potential business partners).

In addition to you, these rules apply to your spouse, children, parents and siblings, as well as any other family members living with you in your household.

2.6.2 Further Explanation

What is
inside information? Inside information is material information about i2 Telecom which has not been publicly disclosed. This information can relate to i2 Telecoms financial condition, earnings or business, or to any
important development involving i2 Telecom.

What information is material? Information is material if it is
information that a reasonable investor might consider important in deciding whether to buy, sell or hold securities. Examples of information which may be material include: financial results or forecasts; a significant proposed acquisition or sale of
a business; a stock split; significant litigation; and changes in customary earnings trends.

What information is nonpublic?
Information is nonpublic until the time it has been effectively disclosed to the public. Effective disclosure occurs when information is included in a press release issued by i2 Telecom, is revealed during a i2 Telecom conference call to
which the general public has been invited to participate or is included in our public filings with the U.S. Securities and Exchange Commission.



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What is a reasonable waiting period before purchases and sales can be made? The investing public must
have sufficient time to analyze the information that has been disclosed before i2 Telecom insiders can trade. For matters disclosed in a i2 Telecom press release or conference call, a good rule of thumb is that purchases and sales can be made
beginning 48 hours after the disclosure.

What transactions are prohibited? A i2 Telecom person who has inside information about i2 Telecom
is prohibited from: (a) trading in i2 Telecom securities (including derivative securities such as put and call options); (b) having others trade in i2 Telecom securities for your benefit; and (c) disclosing the inside information to
(or tipping) anyone else who might then trade. These prohibitions continue for as long as the information remains material and nonpublic.

What transactions are allowed? A i2 Telecom person who has inside information about i2 Telecom may, nonetheless: (a) exercise i2 Telecom stock options for cash (but may not sell the option shares he or she
receives upon the exercise); and (b) buy shares under an Employee Stock Purchase Plan (but may not sell those shares). These cash option exercises and ESPP purchases are allowed because the other party to the transactions is i2 Telecom itself,
and because the option exercise and ESPP purchase prices do not vary with the market, but, rather, are fixed in advance under the terms of their governing plans.

2.6.3 Blackout Policy for i2 Telecom People

In addition to our General Insider Trading Policy, which
is summarized above, we have adopted the following Blackout Periods Trading Policy to help ensure compliance with insider trading laws. This policy applies to all i2 Telecom people.



| |  |  | No i2 Telecom person may purchase or sell i2 Telecom securities (including derivative securities such as put and call options) during the following periods:
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| |  |  | The period beginning two weeks before the end of a fiscal quarter and ending 48 hours after that quarters public earnings release.
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| |  |  | The period beginning with i2 Telecoms public release of any material (previously nonpublic) information and ending 48 hours after the release.
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| |  |  | Any other period established from time to time by our Chief Financial Officer or other i2 Telecom executive officer by notice to all i2 Telecom people due to particular inside
information concerning the company (as discussed in the General Insider Trading Policy) to which you may then have access.
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| |  |  | This Blackout Periods Trading Policy shall not apply to the following:
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| |  |  | Exercises of i2 Telecom stock options for cash (but not the sale of the shares received upon exercise).
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| |  |  | Purchases of shares under an Employee Stock Purchase Plan (but not the sale of those shares).
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| |  |  | Each member of the Board of Directors and each i2 Telecom Officer at or above the Vice President level should notify our Chief Financial Officer before purchasing or selling any i2
Telecom securities (including derivative securities such as put and call options), even if none of the blackout periods described above are in effect, and obtain clearance from our Chief Financial Officer that the proposed purchase and
sale complies with all securities laws and regulations, including the insider trading rules.
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| |  |  | In addition to you, these rules apply to your spouse, children, parents and siblings, as well as any other family members living with you in your household.
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2.7 Government Contracting

We, from time-to-time, do business with federal, state or local government agencies in the United States and in the other countries in which we carry on business. All i2 Telecom people engaged in business with these
entities must know and abide by specific rules and regulations which govern relations with public agencies. If you have questions regarding the rules and regulations that apply in a particular country, you should contact our Chief Operating Officer.

3.0 Avoiding Conflicts of Interest

3.1 Generally

All i2 Telecom people have a duty of loyalty to act in the best interests of the company. We expect you to
avoid situations and relationships that involve actual or potential conflicts of interest. Generally, a conflict of interest arises whenever your personal interests diverge from your responsibilities to i2 Telecom or from i2 Telecoms best
interests. Put another way, a conflict of interest is created whenever an activity, association or relationship of yours might impair your independent exercise of judgment in i2 Telecoms best interest.

Examples of situations that could be perceived as conflicts of interest and should be avoided include:



| |  |  | Conducting i2 Telecom business with a company owned, partially owned, or controlled by you or a member of your family.
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| |  |  | Ownership of more than one percent of the stock of a company that competes or does business with i2 Telecom (other than indirect ownership as a result of owning a widely-held mutual
fund).
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| |  |  | Working as an employee or a consultant for a competitor, regulatory government entity, client or supplier of i2 Telecom.
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| |  |  | Doing any work for a third party that may adversely affect your performance or judgment on the job or diminish your ability to devote the necessary time and attention to your
duties.
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| |  |  | Appropriating or diverting to yourself or others any business opportunity or idea in which i2 Telecom might have an interest.
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These situations (and others like them), where your loyalties to i2 Telecom could be compromised, must be avoided. If you believe that you are involved
in a potential conflict of interest, we expect you to discuss it with your manager or our Chief Operating Officer. If a conflict is determined to exist, you must disengage from the conflict situation or terminate your employment with i2 Telecom.

3.2 Use of Our Assets

You are responsible for the proper use of i2 Telecoms physical resources and property, as well as its proprietary information.

Our offices, equipment, supplies and other resources may not be used for activities which are not related to your employment with i2 Telecom, except for any activities that have been approved in writing in advance by us, or for personal
usage that is minor in amount and reasonable. If you are found to be engaging in, or attempting, theft of any i2 Telecom property, including documents, equipment, intellectual property, personal property of other employees, cash or any other items
of value, you may be subject to immediate termination of your employment and possible criminal proceedings. We expect you to report any theft or attempted theft to your manager or our Chief Operating Officer.

Proprietary words, slogans, symbols, logos or other devices used to identify i2 Telecom and its proprietary services and technologies are important
business tools and valuable assets which require care in their use and treatment. You may not negotiate or enter into any agreement respecting i2 Telecoms trademarks, service marks or logos without first consulting our Chief Operating Officer.
We also respect the intellectual property rights of others, and any proposed name of a new service or offering intended to be sold or provided to clients should be submitted to a member of the Marketing team for clearance prior to its adoption and
use. Similarly, using the trademark or service mark of, or referencing for marketing purposes, another company (even one with whom i2 Telecom has a business relationship), requires clearance or approval by our Marketing team, to
determine whether the use of that other companys mark is proper. You should avoid the unauthorized use of copyrighted or patented materials of others and should ask a member of our Marketing team if you have any questions regarding the
permissibility of



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photocopying, excerpting, electronically copying or otherwise using copyrighted or patented materials. In addition, simply because material is available for
copying (such as content or images downloaded from the Internet) does not mean that it is automatically legal or permissible to copy or distribute. All copies of work that is authorized to be made available for ultimate distribution to the public
(including all machine readable works such as computer software) should bear the prescribed form of copyright notice.

3.3 Gifts,
Gratuities and Entertainment

3.3.1 Giving

You may not offer money, gifts or other items or services of value to clients or customers or potential clients or customers for the purpose of securing a contract or obtaining favorable treatment. Business-connected
favors or gifts may not be extended to clients or suppliers (current or prospective), unless they:



| |  |  | Are consistent with customary business practices.
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| |  |  | Do not have substantial monetary value and would not be viewed as improper by others.
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| |  |  | Do not violate applicable laws or regulations.
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Business
entertainment in the form of meals and beverages may be offered only if these activities and related expenses are modest and infrequent. Other forms of entertainment (such as tickets to local sporting, civic or cultural events) are allowed only if
reasonable, customary and not excessive.

3.3.2 Receiving

To avoid even the implication of impropriety, you should decline any gift, favor, entertainment or anything else of value from current or prospective
clients, suppliers or contractors or their representatives except for:



| |  |  | Gifts that do not have substantial monetary value given at holidays or other special occasions.
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| |  |  | Reasonable entertainment at lunch, dinner or business meetings where the return of the expenditure on a reciprocal basis is likely to occur and would be properly chargeable as a
business expense.
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Other routine entertainment that is business-related such as sports outings or cultural events is
acceptable under this policy only if reasonable, customary and not excessive.



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Ultimately, you must exercise good business judgment in deciding which situations are unacceptable. If
there is ever any doubt as to the acceptability of any entertainment activity, consult with your manager or our Chief Operating Officer.

4.0
Maintaining Accurate and Complete Company Records

4.1 Accounting and Financial Records

We are required under U.S. federal securities laws and generally accepted accounting principles to keep books, records and accounts that accurately
reflect all transactions and to provide an adequate system of internal accounting and controls. We expect you to ensure that those portions of our books, records and accounts for which you have responsibility are valid, complete, accurate and
supported by appropriate documentation in verifiable form.

You should not:



| |  |  | Improperly accelerate or defer expenses or revenues to achieve financial results or goals.
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| |  |  | Maintain any undisclosed or unrecorded funds or off the book assets.
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| |  |  | Establish or maintain improper, misleading, incomplete or fraudulent accounting documentation or financial reporting.
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| |  |  | Record revenue for any project that has not fully complied with i2 Telecoms revenue recognition guidelines.
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| |  |  | Make any payment for purposes other than those described in the documents supporting the payment.
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| |  |  | Submit or approve any expense report where you know or suspect that any portion of the underlying expenses were not incurred or are not accurate.
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| |  |  | Sign any documents believed to be inaccurate or untruthful.
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All i2 Telecom people who exercise supervisory duties over i2 Telecom assets or records are expected to establish and implement appropriate internal controls over all areas of their responsibility. This will help ensure the safeguarding of
i2 Telecoms assets and the accuracy of our financial records and reports. We have adopted various types of internal controls and procedures as required to meet internal needs and applicable laws and regulations. We expect you to follow these
controls and procedures to the extent they apply to you, to assure the complete and accurate recording of all transactions.

Any accounting
entries or adjustments that materially depart from generally accepted accounting principles must be approved by our Audit Committee and reported to our independent auditors. You must not interfere with or seek to improperly influence (directly or
indirectly) the review or auditing of our financial records by our Audit Committee or independent auditors.



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If you become aware of any questionable transaction or accounting practice concerning i2 Telecom or our
assets, we expect you to report the matter immediately to a member of our Audit Committee. In addition, we expect you to report all material off-balance-sheet transactions, arrangements and obligations, contingent or otherwise, and other i2 Telecom
relationships with unconsolidated entities or other persons that may have material current or future effects on our financial condition or results of operations to a member of our Audit Committee.

Section 6.2 of this Code describes the procedure for making these reports. You may also make an anonymous report under Section 6.2 if you are
not comfortable revealing your identity when making a report.

4.2 Disclosures to Investors

We are required under U.S. federal securities laws to provide the public with periodic disclosure regarding our business and financial condition (such as
quarterly and annual reports and materials for our annual shareholders meeting). We provide additional disclosures to the public through our quarterly earnings calls and press releases. All i2 Telecom people who participate in the preparation
or dissemination of these disclosures, or who provide information that they know may be used in the preparation of these disclosures, have a legal and ethical duty to ensure that the content of the disclosures is accurate, complete and timely.

We have created disclosure controls and procedures which are designed to ensure that all public disclosures are accurate, complete and
timely. If you become aware that our public disclosures are not accurate, complete and timely, or become aware of a transaction or development you believe may require disclosure, you should report the matter immediately to our Chief Financial
Officer.

4.3 Retention of Documents

Certain types of documents and records must be retained for specific periods of time, because of legal and regulatory requirements, or contractual obligations to our clients, customers and suppliers. These periods of
time, and the types of documents and records covered, may vary among the different countries in which we carry on business. We expect you to comply with the document retention requirements that apply in the countries in which you are working. If you
are working with these types of documents and records, or are uncertain whether the documents or records you are working with are subject to these retention requirements, please consult with your manager.

Whenever you become aware that documents or records of any type may be required in connection with a lawsuit or government investigation, you must
preserve all possibly relevant documents. This means that you must immediately stop disposing of or altering those documents pertaining to the subjects of the litigation or investigation, even if that activity is ordinary or routine. If you are
uncertain whether documents or records under your control should be preserved because they might relate to a lawsuit or investigation, you should contact our Chief Operating Officer.



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5.0 Protecting Confidential Information

5.1 i2 Telecom Confidential Information

You will often have access to information that is private to i2 Telecom, has not been made public and constitutes trade secrets or proprietary information. Protection of this information is critical to our ability to grow and compete.

Under the laws of most countries where we do business, trade secrets are legally protected property as long as they remain secret (meaning
not generally or publicly known).

Your obligations with respect to our confidential trade secrets and proprietary information are:



| |  |  | Not to disclose the information outside of i2 Telecom.
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| |  |  | Not to use the information for any purpose except to benefit i2 Telecoms business.
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| |  |  | Not to disclose the information within i2 Telecom, except to other i2 Telecom people who need to know, or use, the information and are aware that it constitutes a trade secret or
proprietary information.
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These obligations continue even after you leave i2 Telecom, until the information becomes publicly
available or until we no longer consider it a trade secret or proprietary information. We remind you that you may have previously signed, as a condition of your employment or continued employement, a Non-Disclosure, Non-Solicitation and Non-Compete
Agreement, Employment Agreement or other similar agreement that contains governs your obligations with respect to our information. Any documents, papers or records that contain trade secrets or proprietary information are our property, and must
remain at the company.

Our confidential trade secrets and proprietary information may include, among other things, information regarding
our operations, business plans, customers, strategies, trade secrets, records, finances, assets, technology, data or other information that reveals the processes, methodologies, technology or know how by which our existing or future
products, services, applications or methods of operation are developed, conducted or operated.

5.2 Confidential Information of Others

In the normal course of business, you will acquire information about many other organizations, including clients, customers, suppliers
and competitors. This is a normal business activity and is not unethical in itself. We properly gather this kind of information for such purposes as evaluating clients business needs, determining system requirements, extending credit and
evaluating suppliers. We also collect information on competitors from a variety of legitimate sources to evaluate the relative merits of our own services and marketing methods.



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There are, however, limits to the ways that this information should be acquired and used. You should not
use information obtained from our clients, customers or suppliers in any way that harms them or violates our contractual obligations to them. When working with sensitive information about clients, customers or suppliers, you should use that
information only for the purposes for which it was disclosed to you and make it available only to other i2 Telecom people with a legitimate need to know.

You should not use illegitimate means to acquire a competitors trade secrets or other confidential information. Illegal practices such as trespassing, burglary, wiretapping, bribery and stealing are obviously
wrong. We will not tolerate any form of questionable intelligence-gathering.

In addition, we strive to protect the privacy of personal
information of others. We will only collect, use, process, and disclose an individuals personal information in accordance with applicable law, our internal policies and our contractual obligations to our clients or customers.

5.3 Inadvertent Disclosure

You
should be careful to avoid the inadvertent disclosure of proprietary information. To avoid inadvertent disclosure, you should never discuss with any unauthorized person proprietary information that i2 Telecom considers confidential or which we have
not made public. You also should not discuss this information even with authorized i2 Telecom people if you are in locations where unauthorized people may overhear you, such as trade shows, airplanes or elevators, or when using non-secure electronic
bulletin boards or databases. You should also not discuss this information with family members or with friends, because they may innocently or unintentionally pass the information on to someone else.

5.4 Contacts with Reporters, Analysts and Other Media

Because of the importance of the legal requirements regarding disclosure of certain information to our investors, we must make certain that any information regarding our business, financial condition or operating
results that is released to the public is accurate and consistent. As a result, you should not discuss internal i2 Telecom matters with anyone outside of i2 Telecom, except as clearly required in the performance of your job duties.

This prohibition applies particularly to inquiries about i2 Telecom made by the news media, securities analysts and investors. All responses to these
inquiries must be made only by authorized persons: only our Chief Executive Officer, Chief Financial Officer and Chief Operating Officer (and individuals specifically designated by them) are authorized to discuss information about i2 Telecom with
the news media, securities analysts and investors. If you receive inquiries from these sources, you should immediately refer them to one of these authorized spokespersons.



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This prohibition also applies to communications made by i2 Telecom people about i2 Telecom internal
matters in any electronic medium, including, but not limited to, communications via e-mail and communications through or on Internet chat sites. i2 Telecom people may not post comments concerning i2 Telecom to Internet chat sites and may not repond
to comments concerning i2 Telecom that are posted on Internet chat sites. This applies regardless of whether such posting or response is done under a real name, a fictious or screen name, or the name of family member or other affiliate.

6.0 Administration of this Code

6.1 Ongoing
Review of Compliance

We require all i2 Telecom people to comply with this Code. Upon your receipt of this Code, and also from time to
time as we deem to be necessary, we will require you to sign an acknowledgement confirming that you have read and understood the Code and agree to comply with its provisions. We reserve the right to monitor your continuing compliance with the
provisions of this Code and to investigate any suspected violations. If substantiated, these violations could result in disciplinary action, as described more fully in the following sections.

6.2 Reporting of Suspected Violations

We expect you to bring to the attention of our Chief Operating Officer or Chief Financial Officer (or any people that they designate) information about suspected violations of this Code by any other i2 Telecom person. If you have
information about suspected improper accounting or auditing matters, you should bring such information to the attention of our Chief Financial Officer or a member of our Audit Committee.

If you are not comfortable revealing your identity when making a report, you can also make an anonymous report to our Chief Financial Officer or our
Audit Committee.

You should feel safe in reporting this information, without regard to the identity or position of the suspected offender.
We will treat the information in a confidential manner (consistent with appropriate evaluation and investigation) and will not take any acts of retribution or retaliation against you for making a report.

Because failure to report criminal activity can itself be understood to condone the crime, we emphasize the importance of reporting. For both criminal
activity and other violations of this Code, failure to report knowledge of wrongdoing may result in disciplinary action against those who fail to report.

6.3 Non-Retaliation

Retaliation in any form against a i2 Telecom person who reports a violation of
this Code (even if the report is mistaken but was submitted in the good faith belief it was correct) or who assists in the investigation of a reported violation is itself a serious violation of this Code. Acts of retaliation should be reported
immediately and may result in severe disciplinary action.



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6.4 Investigation of Suspected Violations

Suspected violations will be investigated under the supervision of our Chief Operating Officer, as the Chief Operating Officer deems appropriate. You are
expected to cooperate in the investigation of reported violations. When practical and appropriate under the circumstances, and in order to protect the privacy of the persons involved, those people investigating the suspected violation will attempt
to keep confidential the identity of someone who reports a suspected violation or who participates in the investigation. There may be situations, however, when this information must be disclosed as part of our investigation.

6.5 Disciplinary Action

If our Board
of Directors (or those acting under its supervision) determine, in its good faith discretion, that you have violated any provision of this Code you may be subject to disciplinary action, including termination of your employment, without prior
warning.

6.6 Special Provisions Applicable to Certain Executive Officers

Given the important position of trust and authority that they occupy, our Chief Executive Officer, Chief Operating Officer and Chief Financial Officer
(collectively, the Financial Executives) should act extremely cautiously in interpreting and applying this Code. Financial Executives should consult with our outside legal counsel with respect to any proposed actions or arrangements that
are not clearly consistent with the Code. In the event that a Financial Executive wishes to engage in a proposed action or arrangement that is not consistent with the Code, the Financial Executive must obtain a waiver of the relevant Code provisions
in advance from our Audit Committee.

The Sarbanes-Oxley Act of 2002 imposes certain reporting requirements on i2 Telecom with respect to
our Financial Executives compliance with the Code. In accordance with these requirements, we will publicly report on a Current Report on Form 8-K any waivers of any provision of the Code granted by our Board of Directors to any Financial
Executive. Violations of the Code by our Financial Executives may also be immediately reported on Form 8-K.

6.7 Revisions and Updates
to this Code

This Code may be revised, changed or amended at any time by our Board of Directors. Following any material revisions or
updates, an updated version of this Code will be distributed to you, and will supercede the prior version of this Code effective upon distribution. We may ask you to sign an acknowledgement confirming that you have read and understood the revised
version of the Code, and that you agree to comply with its provisions.

6.8 Important Disclaimers

This Code reflects general principles to guide you in making ethical decisions and cannot, and is not intended to, address every specific situation in
which we may find it appropriate to take disciplinary action. This Code is not intended to create any contract (express or implied) with you, including without limitation any employment contract, or to constitute any promise that your employment
will be not terminated except for cause.



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