Ethics

Below please find a synopsis of the extensive Ethics Program in place within NYF Corp. The following material is intended to provide a flavor of our Business Ethics Program. To receive a complete copy of the Business Ethics Program, please contact our Corporate Business Ethics Officer.

The Board of Directors of NYF Corp. has established the NYF Business Ethics Program. The President of NYF Corp., reporting to the Board of Directors, shall be responsible for the implementation of the NYF Business Ethics Program. The Business Ethics Program shall be maintained so as to insure that the Company and each of its officers, employees and consultants maintains the business honesty and integrity required by a Government contractor and that the Company's performance of each Government contract is in strict compliance with all applicable laws, regulations, and the terms of the contract.

The NYF Business Ethics Program includes the following components:

• The NYF Corp. Code of Integrity
• Ongoing information and education of all NYF employees as it relates to Ethical Business Standards
• A "Hotline", and centrally located posters and notices detailing appropriate reporting channels

The NYF Code of Integrity

Part I: Policy

NYF Corp. is committed to comply with all applicable laws and regulations in the conduct of its business. The Board of Directors has adopted the NYF Code of Integrity as a component of the Business Ethics Program, to specify such compliance.

Part II: Purpose of Code

This code establishes standards of ethics and business conduct, guidelines, and specific operating policies to be followed by all employees of the Company to foster an environment in which compliance with Federal procurement laws and regulations, and the report of violations, is a responsibility of every employee.

Part III: Scope of Code

This code applies to directors, officers, employees, agents, and other representatives of NYF Corp. et al. and all affiliates (referred to as The Company).

Part IV: General Principles

• The Company will conduct its business with the highest standards of honesty and integrity and comply with all governing laws, regulations, other legal obligations, and corporate policies. This code reflects the high standards the Company desires to maintain in its relationships with Government and commercial customers, suppliers and employees.
• No one shall take, recommend, or cause any action to be taken on behalf of the Company which is known or believed to be in violation of applicable law, regulation or corporate policy.
• No one shall use his/her position with the Company to force, coerce, or in any manner influence any person, including subordinates, to provide any favor, gift or benefit, whether financial or otherwise, to himself/herself or others.
• In business dealings with Federal, state, and local Government entities, no one shall provide, or offer to provide, any gratuity, favor or other benefit to Governmental employees which could improperly influence, or reasonably be interpreted as improperly influencing, their decisions or activities. No one shall engage in any other activity which could improperly influence, or reasonably be interpreted as improperly influencing such decisions.
• When representing the Company, employees must make every effort to avoid being placed in a position in which an actual or apparent conflict of interest exists. Such conflict of interest may arise, or appear to arise, by reason of acceptance of gratuities, or favors or other valuable benefits which could improperly influence or reasonably be interpreted as improperly influencing your sound business decision.
• The Company will not attempt to sell products by disparaging competitors. Instead, in selling products, the Company will rely on the merits of its own products and services.