BOVIE MEDICAL CORPORATION
Policy/Procedure No. 804Title: CODE OF BUSINESS CONDUCT AND ETHICS
Effective: 5/1/2006

Revision:





INTRODUCTION

























PROHIBITION AGAINST INSIDER TRADING


















BOVIE MEDICAL CORPORATION
Policy Procedure No. 804








UNCOVERING INSIDER TRADING




























·
Knowledge of financial results prior to release to public knowledge of loss·
Loss of large contract prior to release of information to public·
A company plans to register additional shares which would result in a dilution the outstanding shares




These are only examples and each case would be examined on a case-by-case study.




An individual may not make the trade but can be caught as a "tipster" who is an outsider with material nonpublic information. The tipster can also be found liable.





LEGAL INSIDER TRADING




Insiders legally buy and sell company stock; their trading is restricted and illegal only at certain times and under certain conditions.  Insiders are required to report their transactions to the S.E.C. often electronically (although not required to be filed electronically).




The law of insider trading can be summarized by stating that stock market transactions made with knowledge of nonpublic information about corporate activity is illegal and the S.E.C. regards it as unfair to investors who are not privy to such information. The S.E.C. has the authority and responsibility to prosecute cases of illegal insider trading.





BOVIE MEDICAL CORPORATION
Policy Procedure No. 804





CORPORATE OPPORTUNITIES





Employees, officers and directors are prohibited from taking for themselves personally opportunities that belong to Bovie or are discovered through the use of certain property, information or position for their personal gain.  In addition, any employee is prohibited from engaging directly or indirectly through a business associate, friend, relative or tech. Included is a business that would be classified as a competitor of Bovie, during the time of employment.  High ranked employees may enter into contracts that more clearly define limitations the company places on an individual.





CONFIDENTIALITY




Employees, officers and directors must maintain the confidentiality of all information entrusted to them by Bovie, our customers, sales brokers, or suppliers, or others with whom we may conduct business, except when disclosure of information is specifically authorized by an executive of Bovie or required as a matter of law.




Confidential information includes any information that has been made available to the public that provides knowledge of our current or anticipated business activities. It also includes important nonpublic information about firms with which we have dealings, including customers, sales brokers and suppliers.  You should not share confidential information with friends, relatives or other non-employees, or discuss any confidential matters in public places, such as elevators, transportation (including airplanes) or restaurants.





FAIR DEALING




All employees, officers, directors and consultants must endeavor to operate fairly and good faith with fellow employees and customers.  No individual employed by the Company or representing the Company shall deliberately attempt to take unfair advantage of anyone.







The Company's policy is clear:




To select, place and work with every individual in every capacity without discrimination based on race, national origin, gender, age, religion, disability or sexual orientation.







BOVIE MEDICAL CORPORATION
Policy Procedure No. 804
 
 SAFETY AND ENVIRONMENT





Safety is always a primary goal. All employees must strive to ensure that the operations of the company are conducted in a safe manner and that all corporate safety rules and practices are adhered to in the workplace. Any violations or unsafe conditions should be promptly brought to a supervisor's attention. In addition, employees must be committed to adhering to the law and taking all reasonable steps to preserve and enhance the laws of public health and safety.




PROTECTION AND PROPER USE OF COMPANY ASSETS




All employees, officers and directors must protect Bovie's assets and ensure their efficient use. Such assets include without limitation, intellectual property such as the Company's trademarks, patents, copyrights, confidential information including sales and other data, manufacturing processes and formulae, ideas, plans and strategies. Theft and waste have a direct impact on our profitability and company assets should be used only for legitimate business purposes. Any misuse or infringement of assets should be reported to the President.




WAIVERS OF THE CODE OF BUSINESS CONDUCT AND ETHICS




Any waiver of this Code for executive officers or Directors may be made only by the Board of Directors and will be promptly disclosed to stockholders as required by law or stock exchange.







Any questions about a Director's actual or potential conflict of interest with the Company should be brought promptly to the attention of the Corporate Governance Committee, which will review the question and determine an appropriate course of action, including whether consideration or action by the full board is necessary. Directors involved in any conflict or potential conflict shall excuse themselves from any decisions relating thereto.




REPORTING ANY ILLEGAL OR UNETHICAL BEHAVIOR




Employees are encouraged to talk to supervisors, managers or other appropriate personnel about observed illegal or unethical behavior and, when in doubt, about the best course of action in a particular situation. Employees, officers and directors who are concerned that violations of this Code or that other illegal or unethical conduct by employees, officers or directors of the Company have occurred or may occur should either contact their supervisor or superiors. If they do not believe it appropriate or are not comfortable approaching their supervisors or superiors about their concerns or complaints, then they may contact either the Law Department of the Company or the Audit Committee or Nominating & Governance Committee of the Board of Directors of the Company. If their concerns or complaints require confidentiality, including keeping their identity anonymous, then this confidentiality will be protected, subject to applicable law, regulation or legal proceedings.









BOVIE MEDICAL CORPORATION
Policy Procedure No. 804





PUBLIC COMPANY REPORTING









ACCOUNTING COMPLAINTS









RELATIONSHIP TO COMPANY POLICIES




This Code of Business Conduct and Ethics are statements, goals and expectations for good business conduct.




The Company's Code of Ethics is not intended nor will it supersede any local, state or federal laws.