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Code of Business Conduct and Ethics

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Title:

Code of Business Conduct and Ethics

Entities:

PacificNet Inc.

Date:

2004

Size:

Preview shows 2KB of 10KB total

Price:

$39

ID:

#1230288

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CODE OF ETHICS



                                 PACIFICNET INC.

                       CODE OF BUSINESS CONDUCT AND ETHICS

                      For Employees, Officers and Directors



INTRODUCTION

                  To further PacificNet's fundamental principles of honesty,

loyalty, fairness and forthrightness we have established the PacificNet Inc.

Code of Business Conduct and Ethics. Our Code strives to deter wrongdoing and

promote the following six objectives:



o    Honest and ethical conduct;

o    Avoidance of conflicts of interest between personal and professional

     relationships;

o    Full, fair, accurate, timely and transparent disclosure in periodic reports

     required to be filed by PacificNet with the Securities and Exchange

     Commission and in other public communications made by PacificNet;

o    Compliance with the applicable government regulations;

o    Prompt internal reporting of Code violations; and

o    Accountability for compliance with the Code.



ACCOUNTING CONTROLS, PROCEDURES & RECORDS

                  Applicable laws and company policy require PacificNet to keep

books and records that accurately and fairly reflect its transactions and the

dispositions of its assets. In this regard, our financial executives shall:



o    Provide information that is accurate, complete, objective, relevant, timely

     and understandable.

o    Comply with rules and regulations of federal, state, provincial and local

     governments, and other appropriate private and public regulatory agencies.

o    Act in good faith, responsibly, with due care, competence and diligence,

     without misrepresenting material facts or allowing independent judgment to

     be subordinated.

                  All directors, officers, employees and other persons are

prohibited from directly or indirectly falsifying or causing to be false or

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