THE
SECURUS CODE OF ETHICS




2009




CODE
OF ETHICS






Ethical
behavior is an important part of how we do business at Securus. The Company’s
reputation and integrity are its most valuable assets and are determined by the
collective and individual actions of its directors, officers, associates, agents
and representatives. Ethical behavior applies to each and every one of us and to
every part of our business – whether internal or external relationships,
competitive practices, legal compliance or financial integrity.


This Code
prescribes the minimum standards of conduct and business ethics expected of the
Company’s directors, officers, associates, agents and representatives and is
designed to assist us in avoiding situations which might reflect unfavorably
upon the Company as well as upon ourselves. The Securus Code of Ethics applies
to Securus Technologies and its subsidiaries, and to their directors, officers,
associates, agents and representatives. An individual who undertakes to act in a
manner that violates this Code should recognize that such actions place their
service to Securus in jeopardy.




Our
Values




Although
we have high expectations of our Associates, set aggressive goals and hold
ourselves accountable, we treat each other with fairness, respect and dignity.
We take personal responsibility for individual and organizational success, while
recognizing the value that each of us contributes.




Compliance
with Laws and Regulations




The
Company is committed to conducting its business affairs with honesty and in full
compliance with all applicable laws, rules and regulations. We respect the law,
and we have a responsibility to understand the laws and how they apply to our
jobs.


The
Company supports each person in this responsibility and provides the necessary
resources for compliance. When the application of laws or regulations is
uncertain, you should seek guidance from your supervisor. At the appropriate
point the Company’s General Counsel may be consulted.




Confidential
Information




We use
confidential information only for the business purpose for which it was
developed or given. We respect the confidentiality of information about the
Company, its customers, Associates, vendors and partners. Confidential
information will not be used for personal benefit. We also maintain the
confidentiality of information entrusted to us by others. We comply with the
laws and regulations which prohibit insider trading of securities. We protect
the intellectual property rights, including copyrights, patents, licenses and
trademarks, and other proprietary information of the Company.




Conflicts
of Interest




We avoid
conflicts, and the appearance of conflicts, between personal interests and
official responsibilities on behalf of the Company. We use corporate resources –
time, personnel, equipment and supplies – for Company business or Company
approved activities.


We do not
take personal advantage of business opportunities that are discovered through
the use of Company property, information or position. The Company’s directors,
officers and Associates do not engage in business activities in competition with
the Company.


Any
director or executive officer of the Company who is aware of any existing or
potential conflict of interest should immediately disclose such conflict of
interest to the Audit Committee of the Board of Directors of the Company (the
“Audit Committee”). Any other officer or Associate of the Company who is aware
of any existing or potential conflict of interest should immediately disclose
such conflict of interest to his or her supervisor, who shall in turn report
such conflict of interest to The Human Resources Department.


After
such disclosure is made, the conflict of interest will be reviewed by the Audit
Committee (for directors and executive officers of the Company) or the Chief
Executive Officer (the “CEO”) of the Company (for other officers and Associates
of the Company) and a decision will be made as to whether the conflict of
interest requires a waiver of this Code, termination of the activity or other
corrective action. Each director, officer and Associate of the Company is
encouraged to request pre-clearance from the Audit Committee (in the case of
directors or executive officers of the Company) or the CEO (in the case of other
officers and Associates of the Company) for any relationship, transaction or
arrangement that could constitute a potential conflict of interest.




Gift
and Gratuities




Do not
accept, offer or authorize gifts, entertainment, or other favors that are not a
reasonable part of a business relationship. We exercise hospitality with
discretion, so as not to jeopardize the integrity of those with whom we do
business.


Because
rules regarding gifts and gratuities to public officials can vary from state to
state and even from agency to agency, do not offer a gift of any type, to any
public official unless management has determined that such a gift is appropriate
and legal.




Competitive
Practices




We
compete vigorously, but fairly, on the basis of price, superior services,
dependability and products. We do not enter into understandings or agreements
between competitors regarding prices, terms of sales, division of markets or
customers, or any other activity that restricts competition.


We
conduct competitive marketing activities, including gathering of competitive
intelligence, fairly and honestly.




Financial
Integrity




We are
prudent in our expenditures on behalf of the Company and we record all business
transactions in accordance with accepted accounting principles. We maintain
appropriate internal controls designed to prevent or detect fraud and ensure
that every accounting or financial record, and supporting data, describe the
transaction accurately without omission, concealment or falsification. Our
financial integrity commitment also extends to business transactions between
subsidiary Companies to ensure all activity is properly reflected. We maintain
and retain all business records accurately and in compliance with applicable
laws and Company policy.


The
following applies to officers, Associates, agents and representatives of the
Company who prepare, maintain or have custody of the Company’s books, records
and accounts:





1.
            Failure
      to record bona fide transactions, assets or liabilities is
      prohibited.




2.
            The
      use of Company funds or assets for any unlawful or improper purpose is
      prohibited.




3.
            Undisclosed
      or unrecorded funds or assets of the Company must not be established for
      any purposes.




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4.
            False
      or artificial entries must not be made in the books or records of the
      Company for any reason, and there is to be no engaging in any arrangement
      that results in such prohibited acts. No payment on behalf of the Company
      will be approved or made with the intention or understanding that any part
      of such payment is to be used for a purpose other than that described in
      the documents supporting the
payment.




5.
            Officers,
      Associates, agents and representatives must not improperly use or permit
      others to improperly use Company property or
  materials.




6.
            Any
      director, officer, Associate, agent or representative who discovers a
      falsified record (or who is requested to falsify a record) is required to
      promptly report that fact to the Audit
  Committee.





In
addition, no director, officer, Associate, agent or representative of the
Company may knowingly alter, destroy, mutilate, conceal, cover up, falsify or
make a false entry in any record, book, account, document or tangible object
with the intent either to impair the integrity or availability of such record,
book, account, document or object in an official proceeding or to obstruct,
impede, direct or influence the investigation or proper administration of any
matter within the jurisdiction of any department or agency of the United States
or any bankruptcy case, or in relation or contemplation of any such matter or
case.


We
believe in making full, fair, accurate, timely and understandable disclosure in
the reports we file under securities laws and in other public
communications.




External
Relationships




We will
not conduct business with anyone who does not operate with integrity or who
compromises the Company’s values and ethical standards.




Duty
to Act




Each of
us has a clear, legal mandate to act ethically on the Company’s behalf and is
obligated to promptly report to management any activities that may be in
violation of this Code of Ethics or any applicable laws or regulations. The
Company has in place appropriate processes to provide for the timely and
effective review of such reports and will not tolerate any retaliation against
those fulfilling this obligation.


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