Compliance Program

Overview and Goals

ORBIT Communication Systems’ (“ORBIT”) success is built upon its commitment to act with the highest ethical standards and to conduct business honestly and legally. Each of you is expected to understand the importance of combining best business practices with the highest of ethical standards and to recognize ORBIT’s commitment to these values.

This Compliance Program (the “Program”) is created to establish the framework for legal and ethical compliance by ORBIT’s employees, suppliers, sub-suppliers, contractors, sub-contractors, consultants, third party agents and associates (“Associates”). It outlines the rules and guidelines that must be followed and it is essential reading for all of its employees and third party agents. This Program helps guide us and be aware of, and sensitive to, ethical concerns. Although the Program is detailed, it is not exhaustive. Should an incident arise where you are not sure what should be done, you should contact the General Counsel for answers and direction as to the appropriate action to take. Even the appearance of wrong doing can significantly damage ORBIT’s reputation.

It is ORBIT’s intention and desire to promote its commitment to honest and fair dealing by providing an effective means to prevent and detect illegal or unethical conduct. To this end, the Program sets forth expected and acceptable standards of conduct; designates oversight responsibilities and provides for compliance training. Furthermore, the Program provides channels for reporting violations of these principles in order to implement monitoring, enforcement and disciplinary procedures.

It is the responsibility of each of you to safeguard against violations and to take appropriate action if you suspect that illegal or unethical business conduct has occurred or is occurring. Failure to report improper conduct that you are aware of is in itself a violation. Engaging in illegal or unethical business conduct can have serious consequences for you, including disciplinary action up to and including termination, and even criminal or civil penalties.