Code of Business Conduct and Ethics

Table of Contents

    1)         Introduction

  2)         Compliance with Laws and Regulations

  3)         Fair Dealing

  4)         Opportunity and Loyalty

  5)         Confidential Information

  6)         Payments to Government Officials

  7)         Protection and Proper Use of Company Assets

  8)         Intellectual Property

  9)         Employee Relations

  10)       Compliance With This Code

1) Introduction This code applies to all Home Tech Showroom employees as well as all contractors (here by referred to as membership holders) with Home Tech Showroom’s website. Home Tech Showroom requires that both employees as well as membership holders adhere to this code of ethics verbatim. Some parts of this code may be more relevant to certain employees or membership holders. All employees and membership holders should read, review, and understand these standards, however, because both as an employee as well as a membership holder you must conduct yourself in accordance with this Code and help ensure others do as well. If objections, conflicts or even possible conflicts, or disagreements with this Code do arise or if you become aware of violations or potential violations of this Code, it is important you resolve them promptly following the guidelines of this Code. Both employees as well as membership holders are encouraged to talk to supervisors, managers, or other appropriate personal about observed illegal or unethical behavior and, when in doubt, about the best course of action in a particular situation.

This code provides a broad framework of principles of conduct and ethics to guide both employees as well as membership holders in their day to day activities. This code is not a comprehensive document that provides specific guidance on how to handle every situation that one might encounter. Further guidance on what one should do in certain situations that may arise can be found in various specific policies and procedures posted on HomeTechShowroomOnline.com under the policies and procedures section. Both employees and membership holders may from time to time encounter a situation which requires interpretation of the provisions of this code or other applicable policies and procedures. You should not proceed with any activities to which you have unanswered questions or concerns until proper clarification is received. Any questions regarding interpretation of this code in its application in a certain instance that you cannot resolve either by consulting Home Tech Showroom’s specific policies and procedures posted on HomeTechShowroomOnline.com or by consulting with a supervisor should be directed to the company’s chief compliance officer.

2) Compliance with Laws and Regulations Home Tech Showroom values its reputation for complying with applicable governmental laws, rules, and regulations in the conduct of its business. Therefore every employee and membership holder, while acting on behalf of the company, shall comply with all applicable government laws, rules, and regulations, and should avoid engaging in any conduct that, even though it may be legally permissible, is inconsistent with the code of ethics to which Home Tech Showroom adheres.

If there is any uncertainty about what is required or prohibited by law or by regulations adopted by federal, state, or local government agencies, employees and membership holders should consult with the chief compliance officer.

3) Fair Dealing Each employee and membership holder will conduct all dealings with customers fairly and will compete honestly and ethically.

4) Opportunity and Loyalty Employees are prohibited from competing with Home Tech Showroom or taking for themselves opportunities that properly belong to Home Tech Showroom or are discovered through the use of Home Tech Showrooms property or information or the employee’s position with Home Tech Showroom. Employees should not use Home Tech Showrooms property or information or their position with Home Tech Showroom for personal gain or for the personal gain of their immediate families. Employees owe a duty to Home Tech Showroom to advance its legitimate interests when the opportunity to do so arises, as apposed to their own interests or the interests of a third party.

5) Confidential Information Employees must maintain the confidentiality of information entrusted to them by Home Tech Showroom or its membership holders, except when disclosure is authorized by Home Tech Showrooms general counsel or chief compliance officer, or disclosure is required by law, applicable regulations, or legal proceedings. Whenever feasible, employees should consult with the general counsel or chief compliance officer before disclosing confidential information if they believe they have a legal obligation to do so.

Confidential information includes all non-public information that might be of use to competitors of the company, or harmful to Home Tech Showroom or its members if disclosed. It includes all propriety information relating to Home Tech Showroom’s business such as member, budget, financial, credit, marketing, pricing, personnel, and salary information.

6) Payments to Government Officials The U.S. Foreign Corrupt Acts prohibits giving anything of value, directly or indirectly, to foreign government officials or foreign political candidates in order to obtain or retain business. It is strictly prohibited to make illegal payments to government officials or foreign government officials of any country. In addition the U.S. government has a number of laws and regulations regarding business gratitude which may be accepted by U.S. government personnel. The promise, offer or delivery to an official or employee of the U.S. government of a gift, favor, or other gratuity in violation of these rules would not only violate company policy but could also be a criminal offense. State and local government, as well as foreign governments, may have similar rules. Governmental officials include elected or appointed officials of any foreign or domestic federal, state, county, municipal, or other political subdivision, agencies thereof, and their families and employees. If any questions arise about such matters, you should seek guidance from the company’s general counsel and chief compliance officer.

7) Protection and Proper Use of Company Assets Employees should protect Home Tech Showrooms assets and ensure their efficient use. Theft, carelessness, and waste have a direct impact on Home Tech Showrooms’ profitability. Company assets may only be used for legitimate business purposes.

8) Intellectual Property Intellectual property, including the Home Tech Showroom logo, trade secrets, copyrights and other proprietary information must be used properly and protected from infringement by others. Ideas, concepts, written material and trade secrets which are created by an employee using company time, resources, or materials are the property of Home Tech Showroom. Employees must cooperate in documenting such ownership.

9) Employee Relations Home Tech Showroom adheres to the employment polices and practices of non-discrimination as it relates to sex, race, religion, color, natural origin, age, handicap or sexual orientation. All employees are expected to conduct themselves in such a manner as to maintain a working environment free of discrimination of any kind.

10) Compliance With This Code Any employee or membership holder having information or knowledge of any actual or contemplated transaction or conduct that appears to violate this code or who becomes aware of an actual or potential conflict of interest shall promptly inform his or her supervisor or report the matter by calling 518-505-0305 If the actual or contemplated violations of this code, or actual or potential conflicts of interest, involve Home Tech Showrooms principal executive officer, principal financial officer, principal accounting officer, or persons performing similar functions, such actions should be reported to the Home Tech Showroom general counsel or chief compliance officer. The company will not tolerate retaliation against employees or membership holders for reporting, in good faith, suspected infringements of this code.   The failure of any employee or membership holder to comply with this code will result in disciplinary action, which, depending on the seriousness of the matter, may include reprimand, probation, suspension, demotion or dismissal and possible civil or criminal action including reporting un-ethical behavior to the appropriate authorities.