Code of Ethics

The Board of Directors of Cyber-dynamics believes strongly that ethical conduct is for the common good. Accordingly, our policies and procedures include a code of ethics, which is divided into seven sections:

• Introduction
• Honest and Ethical Conduct
• Conflicts of Interest
• Disclosure to the Public
• Compliance
• Violations
• Acknowledgement

The first section of our Code of Ethics (the Introduction) is reproduced below.

  Introduction

This Code of Ethics (the "Code") for Executives and Officers helps maintain the standards of business conduct for the Cyber-dynamics Group (the "Group"), and ensures compliance with international legal requirements and codes of best practice, exemplified by Section 406 of the US Sarbanes-Oxley Act of 2002, and the SEC rules promulgated thereunder.

The purpose of the Code is to promote ethical conduct, which is of the utmost importance to the Group, our business partners and our shareholders.

This Code supplements other Code of Conduct issued by the Group.

The Code is applicable to the following persons, referred to as Officers:

• Managing director/chief executive officer
• Chief financial officer
• Financial controller
• All members of board of directors and board committees
• All senior management
• All other professionals serving in the roles of finance, tax, accounting, purchase, treasury, internal audit, financial analyst and investor relations.

Ethical business conduct is critical to our business. Accordingly, Officers are expected to read and understand this Code, uphold these standards in day-to-day activities, and comply with: all applicable laws; rules and regulations; and all applicable policies and procedures adopted by the Company that govern the conduct of its employees.

Because the principles described in this Code are general in nature, Officers should also review the Company's other applicable policies and procedures for more specific instruction.

Nothing in this Code, in any Company policies and procedures, or ill other related communications (verbal or written), creates or implies an employment contract or term of employment.

Officers should sign the acknowledgment form at the end of this Code and return the form to the HR department indicating that they have received, read and understood, and agree to comply with the Code. The signed acknowledgment form will be located in each Officer's personnel files. Each year, as part of their annual review, Officers will be asked to sign an acknowledgment indicating their continued understanding of the Code.