EMPLOYEE CODE OF
Medis Technologies Ltd. (the "Company") expects all of its
employees, including its principal executive officer, principal financial officer
and principal accounting officer, as well as the members of its board of
directors and the employees of its direct and indirect subsidiaries, to act
in accordance with the highest standards of personal and professional
integrity in all aspects of their activities, to comply with all applicable
laws, rules and regulations, to deter wrongdoing and to abide by other
policies and procedures adopted by the Company that govern the conduct of its
employees and directors. This Code of Conduct is intended to supplement any
other policies and procedures adopted by the Company.
(a) Engage in and promote honest and ethical conduct, including the ethical
handling of actual or apparent conflicts of interest between personal and
(b) Take all reasonable measures to protect the confidentiality of non-public
information about the Company and its subsidiaries and their customers
obtained or created in connection with your activities and to prevent the
unauthorized disclosure of such information unless required by applicable law
or regulation or legal or regulatory process;
(c) Produce full, fair, accurate, timely, and understandable disclosure in
reports and documents that the Company and its subsidiaries files with, or
submits to, the Securities and Exchange Commission and other regulators and
in other public communications made by the Company and its subsidiaries;
(d) Comply with applicable governmental laws, rules and regulations, as well
as the rules and regulations of self-regulatory organizations of which the
Company or its subsidiaries is a member; and
(e) Promptly report any possible violation of this Code of Conduct to the
Chairman of the Company's Audit Committee.
prohibited from directly or indirectly taking any action to fraudulently
influence, coerce, manipulate or mislead the Company's or its subsidiariesí
independent public auditors for the purpose of rendering the financial
statements of the Company or its subsidiaries misleading.
understand that you will be held accountable for your adherence to this Code
of Conduct. Your failure to observe the terms of this Code of Conduct may
result in disciplinary action, up to and including termination of employment.
Violations of this Code of Conduct may also constitute violations of law and
may result in civil and criminal penalties for you, your supervisors and/or
have any questions regarding the best course of action in a particular
situation, you should promptly contact a member of the Company's Audit
Committee. You may choose to remain anonymous in reporting any possible
violation of this Code of Conduct.