Abatix Corp. and Subsidiary (Abatix) Policy & Procedures

Page 1 of 8

|Title: | Code of Business Conduct   and Ethics for   Directors, Officers and Employees | Effective Date: May 6, 2004   Revised Date:
|------ | ----------------------------------------------------------------------------- | -------------------------------------------

|Prepared by:
  Frank Cinatl | Reviewed by:   Senior Management | Approved by:   Board of Directors
|--------------------------- | -------------------------------- | ---------------------------------
|                            |                                  |                                  

POLICY SUMMARY

The policy of Abatix is to comply with all applicable laws and to adhere to the highest ethical standards in the conduct of our business.

PURPOSE

Our goal is for Abatix to be known, trusted and respected as one of the best enterprises in the world.  To do that requires strong financial and ethical performance. This Code of Business Conduct and Ethics policy (The Code) provides general principles to follow to ensure that each of its directors, officers and employees act responsibly and maintain the highest standards of personal and professional integrity in all aspects of their daily activity.

This Code is designed to promote:

| | Compliance with applicable governmental law, rules and   regulations;                                                                                                                                   
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| | Honest and ethical conduct, including the ethical handling   of actual or apparent conflicts of interest between personal and professional   relationships;                                             
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| | Full, fair, accurate, timely and understandable disclosure   in periodic reports and other filings with the Securities and Exchange   Commission and in other public communications made by the Company;
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| | Avoidance of conflicts of interest, including disclosure   of any material transaction or relationship that reasonably could be expected   to give rise to such conflict;                               
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| | The prompt internal reporting of violations of this Code;   and                                                                                                                                         
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| | Accountability for adherence to this Code.                                                                                                                                                              

RESPONSIBILITY

It is each director, officer and/or employees responsibility to acquire and maintain a working knowledge of the business laws and ethics policies as applicable to their responsibilities with the Company, both by studying this Policy and other materials given to the employee by the Company, and by reading publications and other generally available sources of information about these matters.  If a director, officer or employee has a question as to the proper application of this Policy or about what is required by law in any given situation, they should consult with the companys legal counsel.

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Abatix Corp. and Subsidiary (Abatix) Policy & Procedures

Page 2 of 8

|Title: | Code of Business Conduct   and Ethics for   Directors, Officers and Employees | Effective Date: May 6, 2004   Revised Date:
|------ | ----------------------------------------------------------------------------- | -------------------------------------------

|Prepared by:   Frank Cinatl | Reviewed by:   Senior Management | Approved by:   Board of Directors
|--------------------------- | -------------------------------- | ---------------------------------
|                            |                                  |                                  

PROCEDURE

|1.0 | Professional Conduct                                                                                                                                                                                                                                                                                                                                                                                                                                                   
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|    |                                                                                                                                                                                                                                                                                                                                                                                                                                                                        
|    | Our stockholders, customers and other parties with whom we   do business have strong views about our Company, and, as its suppliers, we   need to promote values and behavior that enhance the Companys reputation   within the community.  It is   imperative that we conduct our professional and business activities with   complete integrity, fair dealing and in a manner that inspires the confidence   and trust of our stockholders, customers and suppliers.
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|2.0 | 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, officers and employees must   respect and obey the laws of the cities, states and countries in which we   operate.                                                                                                                                                                                                             
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|3.0 | Conflicts of Interest                                                                                                                                                                                                                                                                                                                                                                                                                                                  
|    |                                                                                                                                                                                                                                                                                                                                                                                                                                                                        
|    | All directors, officers and employees shall conduct their   personal business and private affairs so as to avoid any actual or potential   conflicts of interest between themselves and the Company and shall take   immediate and appropriate action to resolve any conflict of interest which   actually arises.  A conflict of   interest arises when ones judgment is or may be influenced by considerations   of improper personal gain or benefit.            
|    |                                                                                                                                                                                                                                                                                                                                                                                                                                                                        
|    | Examples of potential conflicts of interest include, but   are not limited to, the following:                                                                                                                                                                                                                                                                                                                                                                          
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|    | Conflicts of interest are prohibited as a matter of   Company Policy, except as specifically and expressly approved by the Board of   Directors.  Conflicts of interest may   not always be easily discernable, so if you have any questions, you should   consult with management, the Companys legal counsel and/or refer to the Team   Member Reference Manual.                                                                                                    

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Abatix Corp. and Subsidiary (Abatix) Policy & Procedures

Page 3 of 8

|Title: | Code of Business Conduct   and Ethics for   Directors, Officers and Employees | Effective Date: May 6, 2004   Revised Date:
|------ | ----------------------------------------------------------------------------- | -------------------------------------------

|Prepared by:   Frank Cinatl | Reviewed by:   Senior Management | Approved by:   Board of Directors
|--------------------------- | -------------------------------- | ---------------------------------
|                            |                                  |                                  

|4.0 | Insider Trading                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       
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|    | It is both unethical and illegal to buy, sell, trade or   otherwise participate in transactions involving securities of the Company   while in possession of material information concerning the Company that has   not been released to the general public.    Securities laws may be violated if any director, officer, employee, or   any of his or her relatives or friends, trade in securities of the Company   while in possession of such inside information.  All non-public information about the Company should be   considered confidential inside information.  Anyone with access to such confidential inside information is   prohibited from using or sharing such information for stock trading purposes,   including trading of the Abatix stock fund in the Companys 401K plan, or for   any purpose other than to conduct Company business.
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|5.0 | Corporate Opportunities                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               
|    |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       
|    | Directors, officers and employees are prohibited from   taking for themselves any opportunity that is discovered through the use of   corporate property, information or position without the consent of the Board   of Directors.  No director, officer or   employee may use corporate property, information, or position for improper   personal gain.  Directors, officers   and employees owe a duty to the Company to advance its legitimate business   interests when the opportunity to do so arises.                                                                                                                                                                                                                                                                                                                                                         
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|6.0 | Competition and Fair Dealing                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          
|    |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       
|    | We seek to outperform our competition fairly and honestly.   We seek competitive advantages through superior performance and never through   unethical or illegal business practices.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 
|    |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       
|    | Stealing 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, officer and employee should endeavor to respect the rights of   and deal fairly with the Companys customers, suppliers, competitors and   employees. No unfair advantage should be taken of anyone through   manipulation, concealment, abuse of privileged information, misrepresentation   of material facts, or any other unfair dealing practice.                                                                                                                                                                                                                                                                          

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Abatix Corp. and Subsidiary (Abatix) Policy & Procedures

Page 4 of 8

|Title: | Code of Business Conduct   and Ethics for   Directors, Officers and Employees | Effective Date: May 6, 2004   Revised Date:
|------ | ----------------------------------------------------------------------------- | -------------------------------------------

|Prepared by:   Frank Cinatl | Reviewed by:   Senior Management | Approved by:   Board of Directors
|--------------------------- | -------------------------------- | ---------------------------------
|                            |                                  |                                  

|7.0 | Gifts and Entertainment                                                                                                                                                                                                                                                                                                                                                                                                                                                                
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|    | The purpose of business entertainment and gifts in a   commercial setting is to create good will and to further working   relationships. Any gift that is excessive and has the potential to unduly   influence judgment should not be given or accepted. Gifts from suppliers or   customers should not be solicited. Moreover, gifts of cash or cash   equivalents are prohibited.    Non-monetary, unsolicited gifts may not be accepted or given unless:                           
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|    | Employees must report to their supervisor any frequent   gifts or offers of gifts received from one source and any offer of a gift,   even if not accepted, that appears unusual or excessive.                                                                                                                                                                                                                                                                                         
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|8.0 | Payments to Government Personnel                                                                                                                                                                                                                                                                                                                                                                                                                                                       
|    |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        
|    | The U.S. Foreign Corrupt Practices Act prohibits the   giving of anything of value, directly or indirectly, to officials of foreign   governments or foreign political candidates in order to obtain or retain   business. Illegal payments to government officials of any country are   strictly prohibited.                                                                                                                                                                          
|    |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        
|    | In addition, the U.S. government has a number of laws and   regulations regarding business gratuities which may be accepted by U.S.   government personnel. The promise, offer or delivery to an official or   employee of the U.S. government of a gift, favor or other gratuity is a   violation of these rules and may not only violate Company policy, but may   also be a criminal offense. State and local governments, as well as foreign   governments, may have similar rules.
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|9.0 | Discrimination and Harassment                                                                                                                                                                                                                                                                                                                                                                                                                                                          
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|    | The diversity of the Companys employees 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. In addition, retaliation against individuals for raising claims   of discrimination or harassment is prohibited.                                                                                                                                 

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Abatix Corp. and Subsidiary (Abatix) Policy & Procedures

Page 5 of 8

|Title: | Code of Business Conduct   and Ethics for   Directors, Officers and Employees | Effective Date: May 6, 2004   Revised Date:
|------ | ----------------------------------------------------------------------------- | -------------------------------------------

|Prepared by:   Frank Cinatl | Reviewed by:   Senior Management | Approved by:   Board of Directors
|--------------------------- | -------------------------------- | ---------------------------------
|                            |                                  |                                  

|10.0 | Health and Safety                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        
|---- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
|     |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          
|     | The Company strives to provide a safe and healthy work   environment. Each of us share the responsibility for maintaining a safe and   healthy workplace by following safety and health rules and practices and   reporting accidents, injuries, unsafe equipment and any other unsafe   practices or conditions.  Further,   misusing controlled substances or selling, manufacturing, distributing,   possessing, using or being under the influence of illegal drugs on the job is   absolutely prohibited.                                                                                                                                                                                                                                                                                                                                                           
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|11.0 | Fair and Accurate Record-Keeping                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         
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|     | The Company is committed to producing full, fair,   accurate, timely and understandable disclosure in reports and documents that   it files with, or submits to, the Securities and Exchange Commission and   other regulators.  Accordingly, the   Company requires honest and accurate recording and reporting of information.   All of the Companys books, records, accounts and financial statements must   be maintained in reasonable detail, must appropriately reflect the Companys   transactions and must conform both to applicable legal requirements and to   the Companys system of internal controls.    By way of example, unrecorded or off the books funds or assets   should not be maintained, only the true and actual number of hours worked   should be reported, and business expense accounts must be documented and   recorded accurately.
|     |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          
|     | Business records and communications sometimes become   public. Accordingly, we should avoid exaggeration, derogatory remarks,   guesswork, or inappropriate characterizations of people and companies that   may be misunderstood. This applies equally to e-mail, internal memos, and   formal reports. Records should always be retained or destroyed according to   the Companys record retention policies.    Inappropriate access or modifications to, or unauthorized destruction   of, accounting or other business records is prohibited.  These prohibitions apply to all business   records and data, regardless of whether such data and records are in written   form or electronically stored.                                                                                                                                                             
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|12.0 | Confidentiality                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          
|     |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          
|     | Directors, officers and employees of the Company are   expected to keep all nonpublic information regarding the Company, its   business, employees, customers or suppliers confidential even if their   employment with the Company ends. Confidential information may include such   things as advertising and marketing plans, business plans, research and   development, financial information, employment matters, supplier and customer   information, software and documentation, and other information which is not   generally known to the public.                                                                                                                                                                                                                                                                                                             

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Abatix Corp. and Subsidiary (Abatix) Policy & Procedures

Page 6 of 8

|Title: | Code of Business Conduct   and Ethics for   Directors, Officers and Employees | Effective Date: May 6, 2004   Revised Date:
|------ | ----------------------------------------------------------------------------- | -------------------------------------------

|Prepared by:   Frank Cinatl | Reviewed by:   Senior Management | Approved by:   Board of Directors
|--------------------------- | -------------------------------- | ---------------------------------
|                            |                                  |                                  

|13.0 | Protection and Proper Use of Company Assets                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  
|---- | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
|     |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              
|     | All directors, officers and employees should endeavor to   protect the Companys assets and ensure their efficient use. Theft,   carelessness and waste have a direct impact on the Companys   profitability.  Any suspected incident   of fraud or theft should be immediately reported for proper handling. Company   equipment should not be used for non-Company business, though incidental   personal use may be permitted.                                                                                                                                                                                           
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|14.0 | Observance of Authority Limits                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               
|     |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              
|     | The Company has established an authorization matrix that   sets forth specific authority limits for the most common transactions   conducted by officers, managers and employees of the Company.  All employees are required to observe   these limits. Any action that an individual may take beyond the limits of   their authority will be deemed to be a violation of this Code and will become   the responsibility of the individual, not Abatix.  If anyone has questions concerning whether or not he or she is   authorized to take a particular action, he or she should raise the question   to senior management.
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|15.0 | Waivers of the Code of Business Conduct and Ethics                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           
|     |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              
|     | Any waiver of this Code may be made only by the Board of   Directors, which will ascertain whether a waiver is appropriate and ensure   that the waiver is accompanied by appropriate controls designed to protect   the Company.  Any waiver concerning a   director or executive officer of the Company shall be promptly disclosed to   the stockholders by the Company on a Form 8-K, along with the reasons for the   waiver.                                                                                                                                                                                           
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|16.0 | Reporting Illegal or Unethical Behavior                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      
|     |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              
|     | If you become aware of an ethical issue and/or possible   violation of this Code it is your responsibility to promptly report it. It is   the policy of the Company not to permit retaliation for an employees good   faith report of questionable behavior and/or misconduct by another.  Employees are expected to cooperate in   internal investigations of alleged misconduct. The following steps should act   as a guide when reporting violations of this Code:                                                                                                                                                      
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Abatix Corp. and Subsidiary (Abatix) Policy & Procedures

Page 7 of 8

|Title: | Code of Business Conduct   and Ethics for   Directors, Officers and Employees | Effective Date: May 6, 2004   Revised Date:
|------ | ----------------------------------------------------------------------------- | -------------------------------------------

|Prepared by:   Frank Cinatl | Reviewed by:   Senior Management | Approved by:   Board of Directors
|--------------------------- | -------------------------------- | ---------------------------------
|                            |                                  |                                  

|17.0 | Compliance Procedures                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  
|---- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
|     |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        
|     | We must all work together to ensure compliance with this   Code. In some situations, however, it may be difficult to determine whether   certain conduct is improper and unethical. Since every situation that may   arise cannot be anticipated, the following steps should act as a guide when   faced with difficult questions or problems:                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         
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|18.0 | Accountability for Adherence to this Code                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              
|     |                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        
|     | All directors, officers and employees are responsible for   reporting any fact or circumstance which they know has resulted or will   result in a violation of this Code.    After the Board of Directors is notified of an alleged activity, they   will convene a meeting, conduct an investigation and deliberate on the   facts.  The Board of Directors   will hire professional advisors to help with the process if it is deemed   necessary.  The Board of Directors has   the ultimate and final responsibility for determining whether a potential or   actual violation exists and will take whatever disciplinary or other action   it deems appropriate to protect the Company, including, without limitation,   the termination of the individual(s) responsible for the violation.  For further information concerning   reporting guidelines please see Section 16 and 17 of this Code.

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Abatix Corp. and Subsidiary (Abatix) Policy & Procedures

Page 8 of 8

|Title: | Code of Business Conduct   and Ethics for   Directors, Officers and Employees | Effective Date: May 6, 2004   Revised Date:
|------ | ----------------------------------------------------------------------------- | -------------------------------------------

|Prepared by:   Frank Cinatl | Reviewed by:   Senior Management | Approved by:   Board of Directors
|--------------------------- | -------------------------------- | ---------------------------------
|                            |                                  |                                  

|19.0 | Acknowledgment                                                                                                                                                                                                                                                                                                              
|---- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
|     |                                                                                                                                                                                                                                                                                                                             
|     | I acknowledge that I have received and read this Code of   Business Conduct and Ethics and understand my obligation as an employee to   comply with the principles, policies and laws outlined in the Code.  This Code should be read in conjunction   with the Team Member Reference Manual and all other Company policies.

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|Signature |  | Date

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