We must all work to maximize profits, but, at the same time, do so in strict compliance with all laws and regulations applicable to our activities in which we are doing business. Everyone must comply with both the letter of the law and the spirit of the law that governs your actions and those of our Company. In addition to observing applicable laws and regulations, each employee must adhere to and comply with the moral and ethical standards of society in the conduct of business in the employee’s country, as well as have an appreciation for the moral and ethical standards of those other countries with which we are associated. AisA’ interests can never be served by an individual’s unethical or illegal behavior producing a quick profit or temporary advantage. AisA’ aim is to provide quality services and to promote such services to the public in a manner that informs the public without misleading it. All services that AisA provides need to be in compliance with applicable governmental laws and regulations, must be economically viable and must meet the Company’s marketing objectives. Each employee’s cooperation is essential to enable AisA to meet these goals and to deal with the problems that arise should it fail to meet them.

AisA prohibits employees from requesting or accepting for personal benefit any service, money or other consideration, directly or indirectly, in exchange for influence in any part of AisA business. Further, employees are prohibited from engaging in conduct that is, or appears to be, in conflict with the interests of AisA or its customers. In particular, no director, officer or employee shall: •Be a consultant to, or a director, officer or employee of, or otherwise operate an outside business that: •markets products or services in competition with our current or potential products and services; •supplies products or services to AisA ; or •purchases products or services from AisA ; •Seek or accept any personal loan or services from any entity with which we do business, except from financial institutions or service providers offering similar loans or services to third parties under similar terms in the ordinary course of their respective businesses; •Be a consultant to, or a director, officer or employee of, or otherwise operate an outside business if the demands of the outside business would interfere with the director’s, officer’s or employee’s responsibilities to us (if in doubt, consult your supervisor or the Company’s General Counsel’s office); •Accept any personal loan or guarantee of obligations from AisA , except to the extent such arrangements are legally permissible; or •Conduct business on behalf of AisA with immediate family members, which include spouses, children, parents, siblings and persons sharing the same home (whether or not such a person is a legal relative). Directors, officers and employees must promptly notify the Chief Executive Officer, Chief Operating Officer, Chief Financial Officer, General Counsel or the Chair of the Audit Committee of any actual or potential conflict of interest

AisA is morally and legally committed to providing all persons an equal employment opportunity and equitable treatment based solely on merit and the valid requirements of the position. AisA’ equal employment opportunity policy prohibits unlawful discrimination with respect to race, sex, sexual orientation, marital status, age, color, religion, creed, national origin, disability, veteran or other status protected by applicable law. This policy relates to all employment decisions, including those in connection with recruitment, hiring, training, promotion, compensation, benefits, termination and all other terms and conditions of employment. While supervisors and managers are charged with the responsibility of preventing discrimination, the success of AisA’ equal employment opportunity policy really depends on the unbiased attitudes and actions of each and every employee throughout the Company. AisA will not tolerate any conduct calculated to intimidate, harass or otherwise discriminate against any person on the grounds listed above.

AisA believes all employees must be allowed to work in an environment free of harassment or discrimination. We want an open, friendly and non-coercive environment for all employees. If you believe that you have or another employee has been subjected to harassment or discrimination, we urge you to report it immediately to your manager or to an officer of the Company. If you are not satisfied with that person’s response, or if a report to that person would not be appropriate, it is your responsibility to make your report to an executive officer. This is your obligation as an employee. Your report will be taken seriously and will be investigated. The Company will protect the confidentiality of those involved to the extent consistent with the need to investigate and resolve any problem. Disciplinary action, including termination, will be taken against those who violate AisA’ policy against harassment or discrimination and against others who condone such conduct. You will not be retaliated against for your good-faith efforts to comply with this Company policy.

AisA will not tolerate abuses of labor standards. AisA prohibits forced, bonded or compulsory labor. AisA will not employ workers below the minimum legal age for employment. Employees are not required to lodge monetary deposits or identity documentation (such as passports or other government-issued identification cards) with AisA. AisA employees are entitled to all rights and remedies available under applicable labor and employment laws.

AisA views the pursuit of health and safety as a business priority. AisA believes that providing a safe working environment for our employees –AisA most important asset — promotes operational excellence and quality customer service. AisA believes most workplace injuries and illnesses are preventable. Accordingly, to protect our employees, it is AisA policy to provide a safe workplace for all employees based on appropriate risk assessments and to comply with all applicable health and safety laws and regulations. Furthermore, AisA is committed to the integration of AisA’ basic safety principles and processes into our company. Each employee has responsibility for maintaining a safe and healthy workplace. Employees are expected to immediately report any accidents, injuries and/or unsafe working conditions. All forms of unlawful conduct, including workplace violence and threatening behavior, are strictly prohibited. AisA encourages all employees to share in the Company’s commitment to health and safety.

AisA views the pursuit of environmental quality as a business priority in all jurisdictions where we have employees and service providers conducting business on our behalf. Accordingly, to protect our communities, AisA complies with all environmental laws and regulations that apply to our business. AisA is also committed to maintaining a corporate consciousness that is sensitive to environmental matters. Operational improvements and innovative developments that reduce adverse impacts on the environment are encouraged. AISA follows all applicable laws and regulations designed to protect and conserve vital natural resources. AisA encourages all employees and service providers to share in this commitment to environmental quality. AisA offers many opportunities for its employees and service providers to participate in this pursuit, including: •Providing training to employees on how to comply with this commitment; •Encouraging employees to join our environmental project teams; •Communicating our environmental expectations with our partners; •Encouraging a work environment in which all employees may share in the compliance with our policies.

Our directors, officers and employees are entrusted with our confidential information and with the confidential information of our suppliers, customers and other business partners. This information may include: (1) technical or proprietary information about current and future businesses, (2) business or marketing plans or projections, (3) earnings and other internal financial data, (4) personnel information, (5) supply and customer lists and (6) other non-public information that, if disclosed, might be of use to our competitors, or harmful to our customers or other business partners. This information is our property, or the property of our suppliers, customers or business partners, and in many cases was developed at great expense. All AisA employees therefore shall: •Not discuss confidential information with or in the presence of any unauthorized persons, including family members and friends; •Use confidential information only for our legitimate business purposes and not for personal gain; and •Not disclose confidential information to third parties. Only certain individuals are authorized to speak for AisA in response to requests for information about the Company from investors, the press or other third parties. Always refer any such requests for information to the Chief Executive Officer.

AisA maintains an open door policy with its employees. If you disagree with a decision of your supervisor and cannot satisfactorily resolve that disagreement with your supervisor, you should feel free to bring it to the attention of a manager or an executive officer of AisA. The open door policy should be used when you have any concerns about your employment. It should also be used whenever you have concerns or suggestions with respect to this Code or any of AisA’ policies — or have a creative idea that could assist our operations.

Compliance with anti-corruption policy is part of this responsibility. All employees of AisA must comply with our anti-corruption policy. To be clear: AisA’ anti-corruption policy applies to AisA and its joint venture partners, subsidiaries, divisions and to all directors, officers and employees acting for or on behalf of AisA. Everyone at AisA from the Board of Directors and the Chief Executive Officer to desk-level employees must comply with this anti-corruption policy. Improper Payments All directors, officers, employees and joint venture partners are prohibited from offering, paying or receiving kickbacks, bribes or undisclosed commissions; making other unlawful special payments; giving lavish gifts or offering excessive entertainment in kind and consideration for a business advantage; giving unlawful discounts; or performing any unlawful special services to or for governmental officials or private parties. All directors, officers, employees and joint venture partners acting for or on behalf of AisA are prohibited from making any such payments or performing such services for third parties for the purpose of obtaining favors, treatment that such party typically would not be entitled to receive, contracts or sales from others. Similarly, no such person acting for or on behalf of AisA should solicit or accept such payments or services.

It is AisA’ policy not to offer, give or accept gifts of significant value unless specifically authorized by an executive officer of the Company. While AisA discourages offering, giving or accepting gifts of even nominal value, such conduct will not constitute a violation of Company policy if it is a customary practice and does not violate the law or any other provisions of this Code. You should entertain and be entertained only at times and in circumstances authorized by Company policy and never in a manner that creates an appearance of impropriety. Any giving or receiving of gifts or entertainment of even nominal value must be approved by your direct supervisor. Remember that, as discussed in Section 1.11, certain types of gifts to, and entertainment of, government officials, employees of a state-owned or -controlled business, political party officials or candidates for political office or officials of an international organization are never permissible. For further guidance on AisA’ gifts and entertainment policy, please refer to Section 1.11 of the Code.

AisA strongly believes that fair competition and a free market with minimal barriers to entry serve the best interests of AisA, our employees, shareholders and customers. It is the policy of AisISA that all directors, officers and employees shall comply with all applicable antitrust and competition laws of any country or group of countries applicable to AisA’ business. Employees who violate this policy will be subject to corrective action by AisA that may include discipline, up to and including termination. Competition and free markets are restrained and compromised when groups of competitors — large or small — engage in conspiratorial conduct to keep market forces from working. This is usually done through agreements to fix prices, allocate sales and/or standardize product offerings. It is the responsibility of every employee to comply with all antitrust and competition laws. This requires that AisA employees understand what can constitute a violation of those laws. Many people who have violated antitrust rules have done so unintentionally by (for example) attending meetings or functions organized by customers, trade associations or carriers. Any meeting with a competitor, whether in the context of a trade association meeting, customer bid meeting or otherwise, can provide a setting at which the temptation may be present for competitors to discuss matters that may constitute violation of antitrust laws. •Do not discuss, or otherwise communicate, competitively sensitive topics with a competitor. Examples of competitively sensitive topics include price, rates, terms of sale, pricing plans and specific costs. This is particularly important to refrain from doing when a customer is directing you to collaborate with a competitor; •Do not divide or otherwise allocate markets or customers with a competitor. This includes services with existing customers. •Do not collaborate or coordinate with a competitor on a competitive bid. This includes agreeing in advance which firm will win the bid, agreeing to take turns being the low bidder, agreeing to sit out a round or agreeing to provide unacceptable bids. This also includes agreeing to create a subcontracting scheme to include losing bidders or agreeing to create a joint venture to submit a single bid. •Do not agree with a competitor to boycott another business; •Ensure that your written communications in memos, email, studies or reports are clearly worded to avoid any false impression that AisA has engaged in improper activity when, in fact, it has not. For example, it is important to clearly attribute the source of any intelligence gathered on a competing firm (e.g., information reported was obtained from customer X or trade publication Y); •Do not submit or otherwise communicate statistics or other information about AisA’ pricing, fees or rates to competitors, a trade association (or any of its committees) or any other third party; •If a discussion of prices, rates or fees is begun at a meeting with a competitor or during a formal meeting of a trade association, at an informal social event or otherwise, leave the meeting/event immediately and in a conspicuous manner by announcing that you are leaving and the reason that you are leaving. If minutes are being recorded for the meeting, you should request that your departure and the reason for it be noted in the minutes; •Always report as soon as possible all suspected antitrust problems, including any invitations or offers from competitors or customers to engage in what may be illegal activity, to the Company’s General Counsel’s office; and

AisA encourages all employees to participate on an individual basis in community and political activities. However, when you are participating in such activities, you are participating and expressing your views as an individual citizen and not as a representative of AisA.

Every Company financial record — including time records, invoices, travel and entertainment receipts, sales records, receipts from governments and expense reports – must be accurate, complete, timely and in accordance with the law. These records are the basis for managing our business and for fulfilling our obligations to shareholders, other employees, customers, suppliers and regulatory authorities. AisA maintains a system of internal controls that, among other things, ensures the integrity and accuracy of our financial records. You must understand and comply with the internal controls requirements applicable to your job and make sure that all of the financial records for which you are responsible are truthful and accurately reflect the transactions being recorded. False or misleading entries (including omissions) in Company books and records are prohibited. AisA is committed to providing our shareholders and investors with full, fair, accurate, timely and understandable disclosure in the reports that the Company .To this end, our directors, officers and employees shall: •Not make false or misleading entries in our books and records for any reason. This includes items submitted for reimbursement under AisA’policies and procedures; •Comply with generally accepted accounting principles at all times; •Notify your Regional Controller and/or the Chief Financial Officer if there is an unreported transaction; •Maintain a reliable system of internal accounting controls that will provide reasonable assurances to management that all transactions are properly recorded on a timely basis; •Maintain books and records that accurately and fairly reflect our transactions; •Prohibit the establishment of any undisclosed or unrecorded bank accounts, funds or assets; •Maintain a reliable system of internal disclosure controls that will provide reasonable assurances to management that material information about AisA is made known to management, particularly during the periods in which our periodic public reports are being prepared; •Present information in a complete, clear and orderly manner and avoid the use of unnecessary legal and financial language in our periodic reports; and •Not communicate to the public any non-public information except through our Chief Executive Officer.

Any waiver of this Code for executive officers or directors may be made only by the Board of Directors and will be promptly disclosed as required by law.