THE GALAXE GROUP POLICIES AND PROCEDURES

Please read all policies and procedures enclosed and sign and return the last page

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 SEXUAL HARASSMENT
It is illegal for any employee – male or female – to harass another employee by (a) making
unwelcome sexual advances or requests for sexual favors, or other verbal or physical conduct of a
sexual nature, as a condition of an employee’s continued employment, or (b) making submission to
or rejection of such conduct a basis for employment decisions affecting any employee, or (c)
creating an intimidating, hostile, or offensive work environment for employees on account of their
sex. Sexually suggestive pictures, behaviors, and language, whether written, verbal, or otherwise
will not be tolerated.

Sexual harassment is not only detrimental to the working environment but also demoralizing for
everyone involved. Such harassment is illegal and a violation of the Company’s policy prohibiting any
and all forms of discrimination.

Sexual harassment is defined as unwelcome sexual advances, requests for sexual favors and other
verbal, visual or physical conduct of a sexual, sexist or sex-based nature. The following are
considered illegal and policy violations:

1) Sexual flirtations, advances, or propositions.

2) Verbal abuse directed at an employee because of their sex.
3) Subtle pressure or requests for sexual activities.
4) Unnecessary touching of an individual.
5) Graphic verbal commentaries about an individual’s body.
6) Sexually degrading or suggestive words used to describe an individual.
7) A display in the workplace of sexually suggestive objects or pictures.
8) Sexually explicit, offensive or sexist jokes.
9) Physical assault of any type.
10) Any request for sexual favors for any type of reward or to avoid adverse consequences.

Upon joining the Company, all employees have previously been made aware of the
Company’s sexual harassment policy and have signed the Sexual Harassment Policy attesting
to the understanding of the same.

This list does not serve to define all possible infractions or actions of an inappropriate nature.

All Forms of Harassment:

GalaxE also prohibits other forms of harassment of any kind. This prohibition includes but is not
limited to, harassment on the basis of race, religion, gender, color, citizenship status, sexual
orientation, age, physical or mental disability or handicap, marital status, national origin, creed,
veteran status, atypical genetic or hereditary trait or any other characteristic protected under
federal, state or local law.

Employees who believe they are victims of sexual harassment or any other type of unlawful
harassment should immediately report the matter to the Human Resources Department or to any
executive level Manager (Vice President & above). A prompt inquiry of the complaint will be
undertaken. No retaliation against an employee who files a complaint or who assists in the
investigation of said complaint will be tolerated
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It is the responsibility of everyone, not simply management, to prevent and eliminate such
destructive behaviors. If you feel that you have experienced or witnessed such actions, you should
immediately notify the Human Resources Department or to any executive level Manager (Vice
President & above).

In accordance with recent case law, failure to promptly utilize the Complaint Procedure laid out in
this document could limit future action on employee complaints.

Completing, filing, and/or investigating a report of inappropriate conduct do not validate the
complaint. The GalaxE Group will promptly conduct an inquiry into any complaint brought to
light through the Complaint Procedure.

Understanding the extremely sensitive nature of such a claim, GalaxE will maintain the highest
degree of confidentiality possible in conducting a harassment inquiry. All reports and information
submitted are kept confidential to the highest degree possible subject to the law and to the extent
consistent with an adequate inquiry and appropriate corrective action. The Company cannot
guarantee absolute confidentiality.

Management reserves the right at any time during an inquiry, or its conclusion, to exercise its
discretion in taking whatever action it deems necessary. These actions may include but are not
limited to placing an employee on leave of absence, reassignment, suspension, demotion and/or
termination. Management also reserves the right to require counseling, training and/or monitoring
as a condition of continued employment.

This policy serves to assist management in its goal to achieve zero tolerance of harassment. It is
however not written nor intended to restrict management’s authority regarding disciplinary or
employment decisions concerning employee behavior that is deemed unacceptable regardless of
whether the behavior constitutes harassment.

This policy against workplace harassment applies not only to employees, but also to vendors,
customers, visitors, and others alike who associate with The GalaxE Group.

Report Harassment and Discrimination:

Since bystander support can encourage harassment or discrimination, The GalaxE Group prohibits
both active and passive support for acts of harassment or discrimination. Employees should either
walk away from these acts when they see them, or constructively attempt to stop them when it is
reasonably feasible and safe to do so. In either case, employees must report incidents to the
designated authority according to the Company’s Complaint Procedure (Click Here). All employees
are required to honestly and promptly participate in or respond to inquiries and investigations
conducted by the Company.

Retaliation:
No retaliation against an employee who complains about violations under this policy or who assists
in the investigation of said complaint will be tolerated. Any supervisor, agent, or other employee
who is found, as a result of the investigation, to have engaged in harassment of another employee
will be subject to disciplinary action, up to and including termination of employment.
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 CLIENT CONFIDENTIALITY PROTECTION POLICY
GalaxE.Solutions (the “Company”) is committed to protecting and securely isolating all
proprietary or confidential information (including, but not limited to, data, processes, programs,
software, intellectual property and any other information provided by, to or for any client)
entrusted to it by client organizations. The Company assigns the highest level of importance to
maintaining clear and distinct separation of such organizations’ information assets and project
deliverables. In support of this, we have formally adopted this Client Confidentiality Protection
Policy to be implemented immediately by all Company personnel:

The purposeful or inadvertent disclosure of any client’s proprietary or confidential information by

Company workforce members to persons outside of authorized internal project team members is a
violation of this policy. Co-mingling of clients’ proprietary or confidential information, whether
in hardcopy or electronic form, is equally a violation of this policy. The Company and its
management reject as unacceptable any such instances, and recognize the following principles as a
basis for preventing their occurrence:

• A culture of compliance is strongly supported by the Company and its management.

The Company and its management will ensure that up-to-date, comprehensive security
policies and procedures are always in-place to protect the confidentiality of customers’
information. All Company workforce members are required to support and follow those
policies and procedures, and are rated as to their level of compliance as part of regular
performance reviews.

• The Company and its management will facilitate positive photo identification of Company
workforce members serving on each client’s development staff. Company and its
management will ensure their physical segregation. Access will be monitored and logged.
Collaboration and/or general communication between staff members and their respective
managers working on other projects is strictly forbidden and will only be allowed between
client projects where there is the express written permission from Executive Management
for such collaboration and/or general communication.

• Company and its management will ensure that access to customers’ confidential information
by Company workforce members is fully authorized, and only on a “minimum necessary”
basis, limiting access to only that information needed to perform the required work.

• Company and its management will ensure appropriate segregation of customers’

information between Company’s servers, networks and printers.

• Company and its management will enforce the above and additional internal controls to
prevent the disclosure and/or co-mingling of client information, including effective
measures to verify compliance with these standards.

• Company will take appropriate disciplinary measures for violation of any of the foregoing
policies and standards, commensurate with the seriousness of any infractions, up to and
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 including termination of employment, criminal prosecution and civil liability as necessary.

Any Company workforce member that suspects a violation of any of the foregoing should
immediately inform their Manager and Company’s General Counsel in writing of such suspected
violation.

OPERATING PRINCIPLES
Purpose

Operating Principles are about creating customer value by adhering to common organizational and
corporate level standards. This relationship brings a uniform behavior that will result in market
access, new prospects, and client recognition value. As a representative of Galaxy Systems, we
have a desire to request from our consultants’ full collaboration and cooperation that will result in
total delivery service excellence. These principles are offered to maximize customer value,
minimize misunderstandings, and support sales objectives and set expectations both within Galaxy
Systems and the client.

The Operating Principles

These Principles are established to improve client satisfaction, maximize personal potential and
promote Galaxy Systems recognition and visibility in the marketplace in addition to showcasing
Galaxy Systems thought leadership.

Follow Client Hours

• On client engagements, you will generally follow the client’s normal work hours and
holiday schedule. If in doubt, contact your assigned AE.

Review and sign your agreement

• Take the time to review the Galaxy documents, which include your Contract, Internet/Phone
Usage Form, Sexual Harassment Form, and Referral Program.

Consistently Record Your Professional Time

• Please keep track of your time and have your manager approve the timesheet in a timely
fashion.

Provide Value Added Support that Contributes to the Success of our Clients.
• Ensure that all project tasks for which you are responsible are consistently delivered on time
and within budget.
• Ensure we have quality deliverables in place, which are in accordance with Galaxy Systems
guidelines presented to you at the start of your engagement.

Demonstrate Knowledge Sharing with other Members of Your Team.

• If you are a subject matter expert, share your knowledge.
• Create an environment where innovation can thrive. It reflects well on Galaxy Systems as a
place where bright minds come alive.
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 • Demonstrate Thought Leadership and seek out information from your peers.

Understand Galaxy Service Offerings and the People Supporting them.

• You are expected to convey who we are, what we do, and the capabilities we possess. We
offer end-to-end solutions for our clients, from Solutions in Web Services, Security
Services, Application Development and Integration to a full suite of Consulting and
Managed Services.

Assist the AE in Building Relationships.

• Our clients expect us to be as focused on their business as if it were our own. We must prove
to them, every day that we’re committed to their success. That’s how we move from
relationships to partnerships. They expect us to not only deliver, but also transfer knowledge
to their staff so they learn as well.
• Leverage Galaxy’s expertise and service offerings within the client organization
• Engage clients in a way that builds “trusted advisor” relationships with people you deal with
on a daily basis.
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Be Responsive.
• Personally answer your phones and respond to e-mails promptly.
• Listen to your Clients and address their needs. If you don’t know the answer, find out.
• Be accountable.
• Do not, under any circumstances, discuss your individual compensation with Galaxy
customers (your rate to Galaxy or the bill rate to the customer).

Leverage Our Strengths and Be Assertive

• Now, more than ever, we’ll have to work as one team. We have to work more effectively
together. Join forces with your Account Executive on follow up. Remember that everything
you do, and the passion and enthusiasm with which you do it, says more about you and
Galaxy Systems than any advertisement ever could.

Care for Clients and Each Other

• Let’s treat each other with dignity and common courtesy. The pressure to perform shouldn’t
override the need we all have to respect the individual and his and/or her contribution.

New Business Opportunities

• Contact or submit an e-mail to your AE with a description of the new business opportunity
along with the customer contact.
• Be on the lookout for new opportunities that may include identifying additional business for
an existing project such as further enhancements and identifying new business based on a
planned project.

Keep Us Informed
• Keep your AE informed of your progress on a regular basis.

RECORDING AND STORAGE COMPANY INFORMATION POLICY

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This Policy is issued in furtherance of GalaxE.Solutions’ (the “Company”) commitment to
protecting and securely isolating all proprietary or confidential information (collectively, the
“Information”) of the Company and its clients. For the purposes of this Policy, Information shall
include, but shall not be limited to: (a) Proprietary Methods; (b) customer and prospective
customer lists, and details of agreements with customers; (c) acquisition, expansion, marketing,
financial and other business information and plans; (d) research and development data; (e) any
data or information compiled by the Company’s clients or any of their affiliates; (f) computer
programs; (g) information concerning sources of supply; (h) information regarding the identity of
specialized consultants and contractors and Confidential Information developed by them for the
Company and/or its affiliates; (i) purchasing, operating and other cost data; (j) special client
needs, cost and pricing data; and (k) employee information (including, but not limited to,
personnel, payroll, compensation and benefit data and plans). For the purposes of this Policy, the
term “Proprietary Methods” shall be defined as the Company’s software, including source code
and executables, architectures, applications, libraries, components, programming, design, testing,
evaluation and other methods, project plans, project deliverables, technology plans, intermediate
work products, techniques, tools and know-how that the Company owns or has developed.

The Company treats all Information as highly valuable Company assets that are proprietary to the
Company. The Company has a fiduciary responsibility to its clients to treat all of their
Information with the same level of security as Company Information. Accordingly, all
Information must remain exclusively in the Company’s possession and control. This means that
all Information is only to be memorialized using approved technologies and related equipment and
operational guidelines, and stored on or in Company- approved storage repositories.

In addition to traditional machine-readable files such as spreadsheets and word processing

documents, also included and regarded as Information are audio or video recordings or still
pictures of meetings, discussions, phone conversations, sales presentations, training programs, and
similar Company proceedings.

Any audio or video recording must be done with the full awareness of all in attendance. Audio,
video or still picture recordings are not authorized within certain secured Company facilities.
Check with senior management first to obtain approval.

No form of Information, whether machine-readable documents or audio or video recordings, is to

be stored, even temporarily, except as otherwise approved by the Company’s General Counsel in
writing, on anyone’s personal-property “home” PCs, USB storage drives, digital cameras, PDAs,
cell phones, future recording technologies, or within any email system other than the Company or
an approved client email system.

Contact your management and IT Infrastructure and Security management with all questions.

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 SOFTWARE CODE OF ETHICS
As part of Galaxy’s continuing commitment to maintain an environment free of intellectual property
infringement, we have formally adopted the following Software Code of Ethics to be implemented
immediately by all GalaxE personnel:

Unauthorized duplication of copyrighted computer software violates the law and is contrary to our
organization's standards of conduct. We disapprove of such copying and recognize the following
principles as a basis for preventing its occurrences:

• We will neither engage in nor tolerate the making or using of unauthorized software
copies under any circumstances.

• We will provide legally acquired software to meet the legitimate software needs in a timely
fashion and in sufficient quantities for all our computers.

• We will comply with all license or purchase terms regulating the use of any software we
acquire or use.

• We will enforce strong internal controls to prevent the making or using of unauthorized
software copies, including effective measures to verify compliance with these standards and
appropriate disciplinary measures for violation of these standards.

Any GalaxE personnel that suspect a violation of the foregoing policy should immediately inform
their Manager and GalaxE’s General Counsel in writing of such suspected violation.

INTERNET, E-MAIL AND TELEPHONIC USAGE POLICY

I. USAGE POLICY

Galaxy’s and its Clients’ (each an “Owner” and collectively referred to as the “Entity”) computers,
computer files and software, electronic mail, telephones and access to the internet are the sole and
exclusive property of the relevant Owner and are intended for business purposes only.

Consultants are prohibited from using each Owner’s computers, electronic mail or telephone
systems for any activity unrelated to such Owner’s business (i.e., the Owner’s computers,
electronic mail and telephone are not to be used for personal reasons including personal gain,
advancement of individual views, or solicitation of non-business and use of the Owner’s
computers must not interfere with or disrupt the operations of the Owner). To ensure compliance
with this policy, each Owner reserves the right to monitor its computers, electronic mail and
telephones and to discipline or discharge any consultant who may be found to be using the
Entity’s computers, electronic mail, telephones or Internet access for reasons other than business
purposes.

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The Entity also strives to maintain a workplace that is free of harassment and a workplace
that is sensitive to the diversity of the Entity’s employees. Therefore, each Owner also prohibits
the use of its computers, electronic mail, telephones and its Internet access for purposes that
may be disruptive, vulgar or offensive to others, or harmful to morale. In addition, each Owner’s
computers, electronic mail or telephones may not be used to solicit others for any commercial
ventures or for religious or political reasons or for any other non-business related matter.

The Entity purchases and licenses the use of various computer software for business purposes and
it does not own the copyright to this software or its related documentation. Unless authorized by
the software developer, the Entity prohibits the illegal duplication of software and its related
documentation.

Consultants should notify their immediate supervisor, the Department Manager or any member of
Galaxy management upon learning of violations of this policy.

Consultants who violate this policy will be subject to disciplinary action up to and including
cessation of their relationship with Galaxy and its Clients.

II. GUIDELINES

A. GUILDELINES FOR INTERNET USAGE

The Internet is a global entity with no control of users or content. Therefore, available resources
may contain material of a controversial nature. Not all sources on the Internet provide accurate,
complete or current information. Therefore, users need to be good information consumers,
questioning the validity of the information.

Please be aware that (1) you should have no reasonable expectation of personal privacy when
using the Internet, (2) you can’t assume when you use the Internet that matters of personal privacy
are going to remain private, (3) all information transmitted by, received from, or stored in any
Owner’s internet systems is the property of such Owner and is subject to review by said Owner.

Consultants are prohibited from engaging in the inappropriate use of the Internet. Inappropriate
uses of the Internet include, but are not limited to, the following:

• Any personal, profit-oriented, commercial or business use.

• Entertainment such as Web surfing and playing games.
• Transmitting or storing of material that is obscene, libelous or defamatory.
• Obtaining unauthorized access to or alteration of either local or remote computer systems or
networks.
• Accessing sexually oriented websites or receiving, storing, or transmitting of sexually
oriented material.
• Unauthorized downloading of software.
• Posting inaccurate, inappropriate, and unlawful business information. Unauthorized
attempts to break into any computer whether it belongs to Galaxy, Client or any another
organization.
• Any use which would violate any law or infringe any copyright, trademark, trade secret,
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 right of publicity, privacy right or any other right of any person or entity.

B. GUILDELINES FOR ELECTRONIC MAIL AND TELEPHONIC SYSTEMS USAGE

Electronic mail sent from the Client site should be treated the same as any other communication
that is sent. All communications represent Galaxy as a whole, and as such, should be written in a
professional and appropriate manner.

Consultants are prohibited from engaging in the inappropriate use of electronic mail and the
telephone. Inappropriate use includes, but is not limited to:

• Transmission of obscene or harassing messages to any other individual, i.e., hate mail,
obscenity, ethnic slurs, racial comments, off-color jokes, anti-social behavior, in violation of
any state or federal law.
• Any illegal, unethical, or other activity that could adversely affect Galaxy or the Client,
including Galaxy's and the Client’s reputation or image.
• Copying, sending, or posting confidential materials of Galaxy or its Clients.
• Unauthorized access of another consultant's e-mail or voicemail account or any other
account maintained on Galaxy’s and/or the Client’s systems as well as unauthorized access
to data stored on any electronic or telephonic system. This would include any attempt to
obtain unauthorized access.
• Any effort to inhibit authorized access to data, mail, or programs stored on electronic or
telephonic systems.
• Any effort to prevent Galaxy's or the Client’s monitoring of an electronic or telephonic
system.
• Sending chain letters.
• Use of the electronic and/or telephonic communication system to violate any other policy of
Galaxy.

C. ADDITIONAL TELEPHONE USE GUIDELINES FOR PERSONAL CALLS

We all have personal obligations that sometimes require us to make personal calls while at work.
Galaxy recognizes that in some cases, a telephone call can help you take care of a personal matter
that otherwise might cause you to lose time or keep you off the job. However, Galaxy asks that
you follow these guidelines when using Galaxy’s or the Client’s telephone, including cellular
phones, for personal calls:

• Be brief. Try to keep personal calls short and infrequent during work hours. When you must
make personal calls at work, try to place your call at lunch or during times when calls are not
likely to interfere with work. Let your family and friends know not to call you at work
except when really necessary. Also, let them know what times are best to call.

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