Code of Conduct

All Reality IMT employees will observe and maintain high standards of ethical conduct in their relationships with clients, suppliers, subcontractors, communities, fellow employees, and others, wherever they work. Any action taken by Reality IMT or its employees, representatives, or agents must be fully justifiable and not raise questions as to the company’s honesty, impartiality, or reputation, or otherwise cause embarrassment to the company. Reality IMT employees must avoid any interest, relationship or outside activity that could affect the employee’s objectivity in making decisions concerning his or her Reality IMT duties and responsibilities.

Ethics and Compliance Program

Reality IMT will maintain an ethics and compliance program to maintain integrity in accordance with the company’s values, and to ensure compliance with all applicable laws, rules, and regulations. This program will inform employees of Reality IMT policies and management instructions concerning ethical business conduct and help them resolve questions and report suspected violations. The reporting process will provide a confidential means of communication separate from line management. Retaliation against employees who come forward to raise concerns will not be tolerated.

This policy, the Reality IMT Code of Conduct, constitute the Reality IMT standards of conduct. Failure to comply with these standards may result in discipline, including termination.

Responsibilities

The Chief Executive Officer Manages and maintains Reality IMT ethics and compliance program.

Ensures that policies and procedures are in place to help employees comply with Reality IMT’s expectations for ethical business conduct.

Provides final and dispositive interpretation of Reality IMT’s standards of conduct to resolve employee questions and confidential inquiries.

Comply with the Reality IMT standards of conduct and, in so doing, reject any plan, transaction or arrangement involving unlawful or unethical conduct or the appearance of impropriety.

Raise questions if the employee is concerned that the standards of conduct are not being met.

Avoid any arrangement, agreement, investment, employment, relationship, or activity which is or appears to be contrary to the best interests of Reality IMT or its clients or might in any way impair the objective performance of duties or the exercise of independent judgment or action with respect to Reality IMT or its clients’ interests.

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