EXHIBIT 14 Ethics and Conduct E-1   340 Code of ConductEffective
Date: 4/1/2009Purpose of the Code of Conduct
This
 Code of Conduct is to act as a guide to assist Breda Telephone Corp., and
 those employed by, or affiliated with Breda Telephone Corp. to live up to our
 ethical standards  and their own. It summarizes many of the rules and laws
 that Breda Telephone Corp. operates under. This Code goes beyond legal
 minimums and sets further goals for us.
This Code is neither a contract nor a comprehensive manual that
 covers every situation we may encounter. It is a guide that highlights key
 issues and identifies policies and resources to help us reach good decisions.Responsibility and Accountability
Each of us has the personal responsibility to make sure our actions
 align with this Code of Conduct and the laws that apply to our organization
 and us. If you have questions or concerns about illegal or unethical acts,
 check with management or the Board. Keep in mind that failure to abide by
 this Code and the law will lead to disciplinary measures, which may mean
 dismissal.
Each Breda Telephone Corp. employee is expected to read the entire
 Code of Conduct. No code can guarantee ethical behavior. Only we can.
All new employees must sign an acknowledgment form confirming that
 they have read the Code of Conduct and understand its provisions. All
 employees will be required to make similar acknowledgments on a periodic
 basis. Failure to read the Code of Conduct or to sign an acknowledgment form,
 however, does not excuse an employee from the terms of this Code of Conduct.Management
Breda Telephone Corp.s management team is expected to lead
according
 to our standards of ethical conduct, in both words and actions. Managers are
 responsible for promoting communications. Management must model respect and
 consideration for each of our co-workers. Management must be diligent in
 looking for indications that unethical or illegal conduct has occurred. If a
 manager knows that an employee is contemplating a prohibited action and does
 nothing, the manager will be responsible along with the employee. If you ever
 have concerns about unethical or illegal activities you are expected to take
 appropriate and consistent actions, and inform your manager or a board
 member.E-2

340 Code of Conduct (continued)Effective
Date: 4/1/2009Our Responsibility To Each Other
Respect: We will treat each other with
 respect at all times, just as we wish to be treated ourselves. We will value
 the difference of diverse individuals and cultures. Employment decisions will
 be based on business reasons, such as qualifications, talents and
 achievements, and will comply with local and national employment laws.
Harassment: Abusive, harassing or offensive conduct is
unacceptable, whether
 verbal, physical or visual. Examples include derogatory comments based on
 racial, ethnic, religious, or sexual characteristics or disability. We are
 encouraged to speak out when a co-workers conduct makes us uncomfortable, and
 to report harassment when it occurs.
Safety and Health: We are all responsible
 for maintaining a safe workplace by following safety and health rules and
 practices. We are responsible for immediately reporting accidents, injuries,
 and unsafe equipment practices or conditions to a supervisor or other
 designated person. Breda Telephone Corp. is committed to keeping its
 workplaces free of hazards. In order to protect the safety of all employees,
 each of us must report to work free from influence of any substance that
 could prevent us from conducting work activities safely and effectively.
 Threats or acts of violence or physical intimidation are strictly prohibited.Our Responsibility to Customers and
 Consumers
Product Quality and Safety: To maintain
 Breda Telephone Corp.s valuable reputation, compliance with our quality
 processes and safety requirements is essential. We damage our good name when
 we deliver products and/or services that fail to live up to our standard.
Sales and Marketing: We will build long-term relationships
 with our customers by demonstrating honesty and integrity. All of our
 marketing and advertising will be accurate and truthful. Deliberately
 misleading messages, omissions of important facts, or false claims about our competitors
 offerings are never acceptable. We will only obtain business legally and
 ethically. Bribes or kickbacks are not acceptable. Guidance concerning
 customer gifts, travel and entertainment is in the Conflicts of Interests
 section of this Code and other Company policies.
Customer Information: We must protect customer information
 that is sensitive, private or confidential just as carefully as our own. Only
 those who have a need to know should have access to confidential information.
 We will abide by all state and federal laws regarding confidentiality of
 information.E-3

340 Code of Conduct (continued)Effective
Date: 4/1/2009
Government Customers: We must be aware of all legal and
 contractual obligations in dealing with governments. National and local
 governments have specific and varied procurement laws and regulations that
 have been established to protect the public interest. These laws generally
 prohibit or put strict limits on gifts, entertainment and travel offered to
 government officials. They also often apply to the hiring of current or
 recently retired officials and their families, and to any conduct that may be
 viewed as improperly influencing objective decision-making. Many other laws
 strictly govern accounting and billing practices applied to the fulfillment
 of government contracts and subcontracts. These laws are applicable to Breda
 Telephone Corp. When Breda Telephone Corp. uses suppliers or subcontracts to
 fulfill its commitments; we may also be responsible for communicating these
 unique governmental requirements to them. Those who deal with government
 officials and contracts are responsible for knowing and complying with
 applicable laws and regulations.Our Responsibility to Business Partners
Doing Business With Others: We will not do
 business with others who are likely to harm Breda Telephone Corp.s
 reputation. For example, we will avoid doing business with others who
 intentionally and/or continually violate the law. These laws include, for
 example, local, environmental, employment, safety, and anti-corruption
 statutes. All arrangements with third parties must comply with Breda
 Telephone Corp. policy and law. We will not use a third party to perform any
 act prohibited by law or by the Breda Telephone Corp. Code of Conduct or
 other policies.o
Agent and Consultants: Commission rates or fees paid to
 dealers, distributors, agents, finders or consultants must be reasonable in
 relation to the value of the product or work that is actually being done. We
 will not pay commissions or fees that we have reason to believe will become
 bribes.o
Subcontractors: Subcontractors play a vital role in the
fulfillment of many
 of our contracts. In some cases, the subcontractor is highly visible to our
 customers. It is therefore very important to ensure that our subcontractors
 preserve and strengthen Breda Telephone Corp.s reputation by acting
 consistently with our Code of Conduct.o
Joint Ventures and Alliances: Breda Telephone Corp. will
strive to
 ally with companies that share our commitment to ethics. We will also work to
 make the standards of our joint ventures compatible with our own.E-4

340 Code of Conduct (continued)Effective
Date: 4/1/2009
Purchasing Practices: Purchasing decisions
 must be made based solely on Breda Telephone Corp.s best interest. Suppliers
 win Breda Telephone Corp.s business based on product or service suitability,
 price, delivery and quality. Purchasing agreements should be documented and
 clearly identify the services or products to be provided, the basis for
 earning payment, and the applicable rate or fee. The amount of payment must
 be commensurate with the services or products provided.Our Responsibility to Shareholders
Protecting Company Assets: We have a
 responsibility to protect the Breda Telephone Corp. assets entrusted to us
 from loss, damage, misuse or theft. Breda Telephone Corp. assets, such as
 funds, products, or computers, may only be used for business purposes and
 other purposes approved by management. Breda Telephone Corp. assets may never
 be used for illegal purposes.
Proprietary Information: We will safeguard all proprietary
 information by marking information accordingly, keeping it secure, and
 limiting access to those who have a need to know in order to do their jobs.
 Proprietary information includes any information that is not generally known
 to the public and/or is helpful to Breda Telephone Corp. and would be helpful
 to competitors. It also includes information that suppliers and customers
 have entrusted to us. The obligation to preserve propriety information
 continues even after employment ends.
Inside Information and Securities Trading: You are not allowed to trade in securities or any other kind of property
 based on knowledge that comes from your job if that information has not been
 reported publicly. It is against the law of the United States of America to
 trade or to tip others who might make an investment decision based on
 inside job information. For example, using non-public information to buy or
 sell Breda Telephone Corp. stock, or the stock of a Breda Telephone Corp.
 supplier, or customer is prohibited.
Accuracy of Company Records: We require
 honest and accurate recording and reporting of information in order to make
 responsible business decisions. This includes such data as quality, safety,
 and personnel records, as well as financial records. All financial books,
 records and accounts must accurately reflect transactions and events, and
 conform both in required principles and Breda Telephone Corp.s system of
 internal controls. No false or artificial entries may be made. When a payment
 is made, it can only be used for the purpose spelled out on the supporting
 document.E-5

340 Code of Conduct (continued)Effective
Date: 4/1/2009
Recording and Retaining Business Communications: All business records and communications should be clear, truthful and
 accurate. Business records and communications often become public through
 litigation, government investigations and the media. We will avoid
 exaggeration, colorful language, guesswork, legal conclusions, and derogatory
 remarks or characterizations of people and companies. This applies to
 communications of all kinds, including e-mail and informal notes or memos.
 Records should always be retained and destroyed according to Breda Telephone
 Corp.s record retention policies.Our Responsibilities to Competitors
Competitive Information: We must never use
 any illegal or unethical methods to gather competitive information. Stealing
 proprietary information, possessing trade secret information that was
 obtained without the owners consent, or using such disclosures by past or
 present employees of other companies if prohibited. If information is
 obtained by mistake that may constitute a trade secret or confidential
 information of another business, or if we have questions about the legality
 of information gathering, we should consult management or the board who may
 also consult legal counsel.
Fair Competition and Antitrust: Breda
 Telephone Corp. and all our employees are required to comply with the
 antitrust and unfair competition laws of the United States of America. These
 laws generally concern:o
Agreements with competitors that harm customers, including price
 fixing and allocations of customers or contacts.o
Agreements that unduly limit a customers ability to sell a
product,
 including establishing the resale price of a product or service, or
 conditioning the sale of products on an agreement by others to Breda Telephone
 Corp. products and services.Our Responsibility to Communities
Community Service: We serve society by
 providing life-enhancing products and services at a fair price and by
 actively supporting the communities in which we operate. Breda Telephone Corp.
 provides generous financial and voluntary support to many worthwhile
 community programs.E-6

340 Code of Conduct (continued)Effective
Date: 4/1/2009
Personal Community Activities: You are free
 to support community, charity and political organizations and causes of your
 choice, as long as you make it clear that your views and actions are not
 those of Breda Telephone Corp. We must ensure that our outside activities do
 not interfere with our job performance. You may not pressure another employee
 to express a view that is contrary to a personal belief, or to contribute to
 or support political, religious or charitable causes.
Environment: We will respect the environment
 by complying with all applicable environmental laws of the United States of
 America. Breda Telephone Corp. is committed to the protection of the
 environment by minimizing the environmental impact of our operations and
 operating our businesses in ways that will foster a sustainable use of the
 countrys natural resources. We need to support this commitment by complying
 with Breda Telephone Corp.s environmental policies and programs. Notify
 management if hazardous materials come into contact with the environment or
 are improperly handled or discarded.
Communicating to External Audiences: To
 ensure professional and consistent handling, requests from the media should
 be forwarded to Breda Telephone Corp.s CEO. Unfortunately, many
 well-intentioned interviewees have had their version of stories
 misinterpreted by reports. Let the experts handle such situations. You are
 expected to cooperate with reasonable requests for information from
 government agencies and regulators, and to consult with the appropriate
 manager, who may speak with legal counsel, before responding to any non-routine
 requests. All information provided must be truthful and accurate. We will not
 alter or destroy documents or records in response to an investigation or
 other lawful request. Requests from financial analysts and shareholders
 should be forwarded to Breda Telephone Corp.s CEO or CFO.Our Responsibility to Government
Compliance with the Law: You are required to
 comply with all applicable laws and regulations wherever we do business.
 Perceived pressures from supervisors or demands due to business conditions
 are not excuses for violating the law. When we have any questions or concerns
 about the legality of an action, we are responsible for consulting with
 management or the board, who may consult with legal counsel.
Company Political Activities: You may not,
 except with approval from the CEO, make any political contribution for Breda
 Telephone Corp. or use Breda Telephone Corp.s name, funds, property,
 equipment or services for the support of political parties, initiative,
 committees or candidates. This includes any contribution of value.
 Additionally, lobbying activities or government contacts on behalf of Breda
 Telephone Corp., other than sales activities, must be coordinated with the
 CEO.E-7

340 Code of Conduct (continued)Effective Date:
4/1/2009Conflicts of Interests
General Guidance: Business decisions and
 actions must be based on the best interests of Breda Telephone Corp., and
 must not be motivated by personal considerations or relationships.
 Relationships with prospective or existing suppliers, contractors, customers,
 competitors or regulators must not affect our independent and sound judgment
 on behalf of Breda Telephone Corp. General guidelines to help you better
 understand several of the most common examples of situations that may cause a
 conflict of interest are listed below. However, you are required to disclose
 to management any situation that may be, or appear to be, a conflict of
 interest. When in doubt, it is best to disclose.
Outside Employment: You may not work for or
 receive payments for services from any competitor, customer, distributor or
 supplier of Breda Telephone Corp. without approval of management. Any outside
 activity must be strictly separated from Breda Telephone Corp. employment and
 should not harm job performance at Breda Telephone Corp. We must make sure
 that the skills we learn and use at Breda Telephone Corp. are not used in
 such a way that could hurt the business of Breda Telephone Corp.
Board Memberships: Serving on the Board of
 Directors or a similar body for an outside company or government agency
 requires the advanced approval of management. Helping the community by
 serving on boards of nonprofit or community organizations is encouraged, and
 does not require prior approval.
Family members and Close Personal Relationships: We may not use personal influence to get Breda Telephone Corp. to do business
 with a company in which our family members or friends have an interest.
Investments: You may not allow your
 investments to influence, or appear to influence, your independent judgment
 on behalf of Breda Telephone Corp. This could happen in may ways, but it is
 most likely to create the appearance of a conflict of interest if you have an
 investment in a competitor, supplier, customer, or distributor and/or its
 decisions which may have a business impact on either party. If there is any
 doubt about the way an investment might be perceived, it should be disclosed
 to management. We are also prohibited from directly or indirectly buying, or otherwise
 acquiring rights to any property or materials, when we know that Breda
 Telephone Corp. may be interested in pursuing such an opportunity and the
 information is not public.
Gifts: Gifts are not always physical objects
  they might also be services, favors, or other items of value.E-8

340 Code of Conduct (continued)Effective
Date: 4/1/2009o
Gifts to You: You may not accept kickbacks,
 lavish gifts or gratuities. We can accept items of nominal value, such as
 small promotional items bearing another companys name. We will not accept
 anything that might make it appear that our judgment for Breda Telephone
 Corp. would be compromised. In some rare situations, it would be impractical
 or harmful to refuse or return a gift. When this happens, discuss the
 situation with management.o
Gifts Given by the Company: Some business
 situations call for giving gifts. Breda Telephone Corp.s gifts must be
 legal, reasonable, and approved by management. We never pay bribes. We will
 not provide any gift if prohibited by law or the policy of the recipients
 organization. For example, the employees of many government entities are
 prohibited from accepting gifts. If in doubt, check first.
Entertainment: We consider entertainment
 to include a representative of both parties at the event.o
Entertainment of the Company: We may accept
 entertainment that is reasonable in the context of the business and that
 advances the Companys interests. For example, accompanying a business
 associate to a local cultural or sporting event, or to a business meal, would
 in most cases be acceptable. Entertainment that is lavish or frequent may
 appear to influence ones independent judgment on behalf of Breda Telephone
 Corp. If an invitation seems inappropriate, we must turn down the offer or
 pay the true value of the entertainment ourselves. Accepting entertainment
 that may appear inappropriate should be discussed with management, in advance
 if possible.o
Entertainment by the Company: We may provide
 entertainment that is reasonable in the context of the business. If we have a
 concern about whether providing entertainment is appropriate, we will discuss
 it with management in advance. Entertainment of government officials may be
 prohibited by law. Get approval from management in each instance.
Travel:o
Acceptance of Travel Expenses: You may
 accept transportation and lodging provided by a Breda Telephone Corp.
 supplier or other third party, if the trip is for business and is approved in
 advance by your supervisor. All travel accepted must be accurately recorded
 in our travel expense records.E-9

340 Code of Conduct (continued)Effective
Date: 4/1/2009o
Providing Travel: Unless prohibited by law
 or the policy of the recipients organization, Breda Telephone Corp. may pay
 the transportation and lodging expenses incurred by customers, agents or
 suppliers in connection with a visit to a Breda Telephone Corp. facility. The
 visit must be for a business purpose, for example, on-site examination of equipment,
 contract negotiations, or training. The CEO must approve in advance all
 travel by government officials that is sponsored or paid for by Breda
 Telephone Corp.Reporting Concerns
Taking action to prevent problems is part of Breda Telephone
Corp.s
 culture. If you observe possible unethical or illegal conduct, you are
 encouraged to report your concerns. Retaliation against any employee who
 reports a concern to Breda Telephone Corp. about illegal or unethical conduct
 will not be tolerated. Employees will be held accountable for their actions
 in violation of the Code of Conduct, even if they are the ones who report the
 violation. It is unacceptable to file a report knowing it to be false.How to Get Help
If you have questions about the Breda Telephone Corp.s Code
of
 Conduct, the first place to turn is your supervisor. If you are uncomfortable
 discussing the issue with your supervisor, please talk to another member of
 management, Human Resources or the Board. Our open door policy allows you the
 freedom to approach any level of management with your concerns.Key Beliefs
If would be wonderful if the right thing to do were always
perfectly
 clear. In the real world of business, however, things are not always obvious.
 If you find yourself in a situation where the right thing is unclear or
 doing the right thing is difficult, remember our key beliefs.o
We believe in integrity, honesty, and ethical standards in all that
 we do.o
We believe a customer is of primary importance and deserves our
best
 service, attitude, and consideration.o
We believe in respect.o
We believe in active participation to the continual quality-of-life
 advancements in our communities.o
We believe in being good stewards in managing our
resources.E-10