UNIVERSAL CODE OF BUSINESS ETHICS, CONDUCT AND INTEGRITY

WACP and each of its Associates and Affiliates, wherever they may be located, must conduct their affairs with uncompromising honesty and integrity. Business ethics are no different than personal ethics. The same high standard applies to both. As a WACP associate, you are required to adhere to the highest standard regardless of local custom.

Affiliates are expected to be honest and ethical in dealing with each other, with clients, vendors and all other third parties. Doing the right thing means doing it right on time every time with minimal excuses.

We must also respect the rights of our fellow Affiliates and third parties. Our actions must be free from discrimination, libel, slander or harassment. Each person must be accorded equal opportunity, regardless of age, race, sex, sexual preference, color, creed, religion, national origin, marital status, veteran's status, handicap or disability. However, we do recognize and adhere to Affirmative Action as it relates to repairing the effects of past inhumanities and discrimination in social and economic issues.

Misconduct cannot be excused because it was directed or requested by another. In this regard, you are expected to alert management whenever an illegal, dishonest or unethical act is discovered or suspected. You will never be penalized for reporting your discoveries or suspicions.

WACP conducts its affairs consistent with the applicable laws and regulations of the territories where it does business. Business practices, customs and laws differ from country to country. When conflicts arise between WACP's ethical practices, and the practices, customs, and the laws of a country, WACP seeks to resolve them consistent with its ethical beliefs. If the conflict cannot be resolved consistent with its ethical beliefs, WACP will not proceed with the proposed action giving rise to the conflict. These ethical standards reflect who we are and are the standards by which we choose to be judged.

Conflicts of Interest

We must avoid any personal activity, investment or association which could appear to interfere with good judgment concerning WACP's best interests. You may not exploit your position or relationship with WACP for personal gain. You should avoid even the appearance of such a conflict. For example, there is a likely conflict of interest if you:

use nonpublic WACP, client or vendor information for personal gain by you, relatives or friends (including securities transactions based on such information);

     compete, or prepare to compete, with WACP while still employed by or an Affiliate of WACP.

     post, display or advertise similar project, programs or opportunities. Similar means Media based with advertising       

     slogans pertaining to Getting Paid to promote or Advertise yourself.  

A violation of the standards contained in this Code of Business Conduct, Ethics & Integrity will result in corrective action, including possible dismissal, banning form on-line services and legal action in extreme cases.