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EWRX Internet Systems, Inc.

CODE OF ETHICS

As a public company, it is of critical importance that EWR
Internet Systems, Inc. (EWRX) filings with the Securities and Exchange
Commission be accurate and timely. Depending on their position with EWRX,
employees may be called upon to provide information to assure that EWRXs public
reports are complete, fair, and understandable. EWRX expects all of its
employees to take this responsibility seriously and to provide prompt and
accurate answers to inquiries related to EWRXs public disclosure
requirements.

EWRXs Finance Department bears a special responsibility for
promoting integrity throughout EWRX, with responsibilities to stakeholders both
inside and outside of EWRX. The Chief Executive Officer (CEO), Chief Financial
Officer (CFO), and Finance Department personnel have a special role both to
adhere to the principles of integrity and also to ensure that a culture exists
throughout EWRX as a whole that ensures the fair and timely reporting of EWRXs
financial results and conditions. Because of this special role, the CEO, CFO,
and all members of EWRXs Finance Department are bound by EWRXs Financial Code
of Ethics, and by accepting the Financial Code of Ethics, each agrees that they
will:

- Act with honesty and integrity, avoiding actual or actual conflicts of
  interest in personal and professional relationships.
- Provide information that is accurate, complete, objective, relevant, timely
  and understandable to ensure full, fair, accurate, timely, and understandable
  disclosure in the reports and documents that EWRX files with, or submits to,
  government agencies and in other public communications.
- Comply with the rules and regulations of federal, state and local
  governments, and other appropriate private and public regulatory agencies.
- Act in good faith, responsibly, with due care, competence and diligence,
  without misrepresenting material facts or allowing ones independent judgment
  to be subordinated.
- Respect the confidentiality of information acquired in the course of ones
  work, except when authorized or otherwise legally obligated to disclose.
  Confidential information acquired in the course of ones work will not be used
  for personal advantage.
- Share job knowledge and maintain skills important and relevant to
  stakeholders needs.
- Proactively promote and be an example of ethical behavior as a responsible
  partner among peers, in the work environment and in the community.
- Achieve responsible use of, and control over, all EWRX assets and resources
  employed by, or entrusted to yourself, and your department.
- Receive the full and active support and cooperation of EWRXs Officers, Sr.
  Staff, and all employees in the adherence to this Financial Code of Ethics.
- Promptly report to the CEO or CFO any conduct believed to be in violation
  of law or business ethics or in violation of any provision of this Code of
  Ethics, including any transaction or relationship that reasonably could be
  expected to give rise to such a conflict. Further, to promptly report to the
  Chair of EWRXs Audit Committee such conduct if by the CEO or CFO or if they
  fail to correct such conduct by others in a reasonable period of time.

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