BorrowMoney.com Announces 5 for 1 Stock Split

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About BorrowMoney.com, Inc.

 Fort Lauderdale, FL – June 19, 2020 – BorrowMoney.com, Inc. (“BorrowMoney.com” (OTC: BWMY, the “Company”, “we” or “us”) operates  a recognized Fintech online loan marketplace for consumers seeking loans and other credit-based offerings. Its internet portal provides  services to lending institutions, generating qualified leads for local mortgage and lending professionals. Through its proprietary platform, it offers institutional lenders the digital solution of technologically gathered leads. The Company also generates revenues by selling  advertising space on its website to various industries, including the real estate industry with  membership fees and lead packages.

Borrowmoney.com’s  marketplace encompasses most consumer credit categories, including mortgages, home equity loans, automobile loans, and personal loans, and it also has category for submissions to lenders for business loans. Its proprietary internet platform  allows consumers to find  realtors within a desired  geographic area for the purchase, sale or rental of  rent real property.

What may not be obvious from the company’s name, Borrymoney.com’s technology powers  lead generation campaigns for many types of business, enabling them to span digital and traditional media acquisition channels, promoting their brand and product offerings. . The BorrowMoney.com platform and “smart” back-office proprietary technology is capable of dispatching, tracking and tracing a live person in the same manner as it tracks its financial leads.

Its most recent milestone involved BorrowMoney.com’s  response to the significant demand for dispatching live nurses for a program entailing a high demand testing service during the COVID-19 pandemic.  With its streamlined functioning and efficient technology solution, Borrowmoney.com provided an expedited  solution filling this growing need.

For further details, visit www.BorrowMoney.com

Aldo Piscitello, Chairman of the Board, President & CEO said: “This stock split is intended to further improve our liquidity and to make our shares more accessible, both to institutions and to the individual shareholders." 

                              Contacts: Lana Coliban (media)                                     Aldo Piscitello CFA (investors) 

                              Lana@Borrowmoney.com                                              Ir@aborrowmoney.com  

The BorrowMoney.com Company Adds  Robert Carrington to Board of Directors 

May 14, 2020 - The BorrowMoney.com Company (OTC: BWMY) (“BorrowMoney.com, Inc”) announced today the election of Robert Carrington to its Board of Directors. “We selected Robert because we value his deep financial acumen, his passion for technology and his strong belief in growing a better world,” said Ado Piscitello, Chairman of the Board of Directors. “These are the same qualities we value on our Board and within The BorrowMoney.com Company. We welcome Robert and look forward to gaining from his innovative and global perspective. I am confident that he will be a positive addition to our Board and to BorrowMoney.com.”

Robert

CAREER HIGHLIGHTS 

Knights of Malta minister of Trade, finance and banking 2020

Experienced International banking executive with a demonstrated history of working in the banking industry globally. Skilled in Negotiation, Budgeting, Business Planning, and Banking. Certification in Banking, Corporate Finance, and Securities Law.  A heart and desire to serve humanities greatest good. Basel 1,2,3,4 trained, Swift system certified, with a full understanding of global monetary compliance. I have represented several large institutional investors on mergers and acquisitions in several international locations on infrastructure projects. Expert in project finance and bank instrument leverage. Relationships at Hong Kong Monetary Authority, World Bank, AAIB, and Central Banks. 

 

PROFESSIONAL EXPERIENCE

 

 

 

Investors Bank VP Market Manager 2018 – 2020

North Jersey Federal Credit Union Director of Retail Banking 2016 - 2018 

Energy International CEO 2012- 2016 

McAdoo Police Department Police Officer - Detective 1995-2005 

PA Department of Correction 1994-1995

 

EDUCATION

 

 

 

Bachelor of Science Degree, Penn State - Criminal Justice

Lackawanna College

Bucks county Community College

Commerce University 

 

CERTIFICATIONS

 

 

 

Certified Commercial Lender and Financial Services Trainer

Certified Compliance Officer, AML, Finsen Commerce University

ASE Certified Commercial and Consuming Lending

Certified Emergency Medical Technician 

Certified Municipal Police Officer

 

SAFE HARBOR REGARDING FORWARD-LOOKING STATEMENTS

As used herein, the terms “BorrowMoney.com,” “the Company,” “we,” “our” and “us” refer to BorrowMoney.com, Inc., a Florida corporation, and its consolidated subsidiaries as a combined entity, except where it is clear that the terms mean only BorrowMoney.com, Inc.

The information contained in this Press Release contains forward-looking statements and information within the "safe harbor" provisions of the Private Securities Litigation Reform Act of 1995, Section 27A of the Securities Act of 1933, and Section 21E of the Securities Exchange Act of 1934. This information includes assumptions made by, and information currently available to management, including statements regarding future economic performance and financial condition, liquidity and capital resources, acceptance of the Company's products by the market, and management's plans and objectives. In addition, certain statements included in this and our future filings with the Securities and Exchange Commission ("SEC"), in press releases, and in oral and written statements made by us or with our approval, which are not statements of historical fact, are forward-looking statements. Words such as "may," "could," "should," "would," "believe," "expect," "anticipate," "estimate," "intend," "seeks," "plan," "project," "continue," "predict," "will," "should," and other words or expressions of similar meaning are intended by the Company to identify forward-looking statements, although not all forward-looking statements contain these identifying words. These forward-looking statements are found at various places throughout this report and in the documents incorporated herein by reference. These statements are based on our current expectations about future events or results and information that is currently available to us, involve assumptions, risks, and uncertainties, and speak only as of the date on which such statements are made. 

Our actual results may differ materially from those expressed or implied in these forward-looking statements. Factors that may cause such a difference, include, but are not limited to those discussed in our Annual Report on Form 10-K and subsequent reports filed with the SEC, as well as: the approval of the shareholders of the amendment to the Certificate of Incorporation, the risk of an unfavorable outcome of the pending governmental investigations or shareholder class action lawsuits, reputational harm caused by such investigations and lawsuits, the willingness of independent insurance agencies to outsource their computer and other processing needs to third parties; pricing and other competitive pressures and the Company's ability to gain or maintain share of sales as a result of actions by competitors and others; changes in estimates in critical accounting judgments; changes in or failure to comply with laws and regulations, including accounting standards, taxation requirements (including tax rate changes, new tax laws and revised tax interpretations) in domestic or foreign jurisdictions; exchange rate fluctuations and other risks associated with investments and operations in foreign countries.

Except as expressly required by the federal securities laws, the Company undertakes no obligation to update any such factors, or to publicly announce the results of, or changes to any of the forward-looking statements contained herein to reflect future events, developments, changed circumstances, or for any other reason.

Readers should carefully review the disclosures and the risk factors described in the documents we file from time to time with the SEC, including future reports on Forms 10-Q and 8-K, and any amendments thereto. You may obtain our SEC filings at our website,  www.BorrowMoney.com under the "Investor Information" section, or over the Internet at the SEC's web site www.sec.gov.

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For any additional new and current investor's information, Please contact Us' We're available 24 hours a day / 7 days a week to answer any of your questions or concerns.

Tel. 212-265-2525  E-Mail ir@borrowmoney.com 

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"Our Subsidiaries Domains "

CommercialMortgages.com       CreditAgencies.com       Myrealestatemls.com      RentmyApartment.com 

SearchOpenhouse.com       VerifyLenders.com      VerifyRealtor.com 

The following summary is a shortened version of more detailed information, exhibits and financial statements appearing elsewhere in this prospectus. Prospective investors are urged to read this prospectus in its entirety of our public filing at the (SEC) U.S. Securities And Exchange Commission.

BorrowMoney.com, Inc. (Filer) CIK0001656501 (see all company filings)

PROSPECTUS SUMMARY

Our Company  

        BorrowMoney.com, Inc. was incorporated in the state of Florida on January 27, 2000, has the company conducted an active business. On May 4, 2015, the New York Corporation becoming a wholly owned subsidiary of the Florida Corporation. Unless the context otherwise requires, all references to the “Company,” “we,” “our” “BorrowMoney” or “us” and other similar terms collectively means BorrowMoney.com, Inc.

The Company has created an Internet-based loan marketplace for consumers and our customers, which are lenders. Our fintech technology is now operational and we are able to collect consumer credit requests and compare those requests and related credit information for submission to lenders which have joined our technology platform. We are not a lender. We currently can intake consumer applications and inquiries for submission to participating lenders who receive consumer credit requests that are received online from consumers. We have minimal revenues and must have additional lenders join our marketplace to generate significant revenues. As more lenders join our network within a consumer’s geographic areas within the United States, consumers will receive up to three (3) offers in response to a single credit request and then be able to compare, review, and except the offer that best suits their needs. Lenders can generate new business that meets their specific underwriting criteria at a cost that is lower than the costs associated with off-line loan originations. Our marketplace encompasses most consumer credit categories, including mortgages, home equity loans, automobile loans, and personal loans. We have an additional category for submissions to lenders for business loans. We recently added capabilities to our technology and proprietary Internet platform for a consumer to find a realtor within the geographic area that the consumer is attempting to either purchase or sell property.

BorrowMoney.com, Inc.’s main objective is to provide a service for the internet mortgage and loan provider business. BorrowMoney.com, Inc.’s business model envisions providing current, qualified leads to local lending institutions who are currently members of the National Mortgage Listing Service. These leads will represent qualified borrowers in targeted zip code locations where the lender conducts business. Our internet platform offers a portal geared toward providing services to lending institutions who would be our customers. The key function of our platform is to provide qualified leads to local mortgage and lending professionals. The Company expects to monetize customer inquiries through the use of various advertising methods. The Company will sell advertising space on its website and anticipates it will be able to create revenue through the sale of advertisement space, membership fees and lead packages.

We are a fintech lending exchange empowering consumers, lenders and related service providers. We are not a lender; instead we attract consumers to our Website through various forms of advertising and send their loan requests to subscribed lenders and loan brokers ("Lenders") participating on our exchange.  Our technology platform is the technology that powers our Internet based lending exchange at www.borrowmoney.com. Consumers begin the Borrowmoney.com process by completing a simple on-line credit request (which we refer to as a "qualification form"). After the consumer completes the qualification form the consumers' data is automatically compared to the underwriting criteria of the subscribed Lenders participating on our lending exchange. Qualified consumers can receive multiple loan offers on-line in response to a single credit request and then compare, review, and accept the offer that best suits their needs. Lenders can generate new business that meets their specific underwriting criteria at a lower cost of acquisition than traditional marketing channels. Our lending exchange encompasses most consumer credit categories, including mortgages, home equity loans, automobile loans, credit cards, and personal loans. Additionally, through our Website we also provide access to other Realty Services related to owning, maintaining and buying and selling a home, including a network of real estate brokers.

We earn revenue from the Lenders on our exchange which pay us fees for qualification forms that meet they're underwriting criteria and are transmitted to them ("transmission fees"). Since a qualification form can be transmitted to more than one lender, we may generate multiple transmission fees for the same form. We also earn revenue for loans that the Lenders on our exchange close with consumers that we referred to them ("closed-loan fees"). Additionally, in most states, real estate brokers participating in our exchange pay us a fee when consumers' requests that we transmit to them result in a purchase or sale of a home ("realty services fees"). We refer to the aggregate of these fees as our Exchange revenue.

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Industry Background  

        For Lenders, the traditional loan origination process is paper-intensive, time-consuming, and usually accompanied by high fixed costs and labor expense. This inefficient process often involves significant marketing and origination costs.

For consumers, the traditional loan process is time-consuming, requires completion of multiple forms, and can often be frustrating and confusing. Consumers typically search through a variety of loan products from many different lenders, apply to one lender at a time for that lender's offered terms, and then wait for that lender to approve or reject the application. Competing online lending sites generally mirror the traditional loan origination process. Consumers visit the Website, view a list of loan products, apply for one product from one lender, and are either given an offer or rate quote or are rejected by the lender. While the consumer proposition presented by online lending Websites is the same as the traditional offline process, the business models for online lending Websites generally fall into the following two categories:

Lender/Broker Model. 

The operators of Websites such as Mortgagebot.com and QuickenLoans and Ditech generate a large portion of revenue in the same way as traditional lenders, from a mark-up over their cost of capital, whether the source of capital is a lender, secondary market purchaser, or warehouse line of credit. In exchange for these mark-ups, the lender/broker undertakes all of the document processing, verification, and customer interaction. In addition, to the extent the lenders/brokers fund originated loans with their own capital, they are often directly exposed to interest rate risk, credit risk, liquidity risk and must also effectively manage their loan pipeline.

Referral Agent Model. 

The operators of Websites such as Providian's GetSmart typically generate revenue by providing referrals to lenders. Because referral agents typically do not generate any revenue upon loan closings, there is little incentive for these  companies to ensure that lenders and consumers consummate the loan transaction. Additionally, because referral Websites do not offer the consumers multiple offers on their sites, they are not able to continually give bestpractices and pricing data to lender participants.

Borrowmoney.com believes that the inefficiencies of the traditional lending process and the shortcomings of other online business models, combined with the large and recurring nature of consumer loan demand, offer a substantial opportunity for its lead processing business model.

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The Borrowmoney.com Process

       Our process consists of the following steps: Credit Request. Consumers access our exchange at www.BorrowMoney.com or sites and select a loan product from our multiple loan categories.Consumers complete a single qualification form for the selected loan product with information such as income, assets and liabilities, loan preferences and other data. Consumers also consent to our retrieval of their credit report. Qualification Form Filtering and Transmission. Our filtering process matches the consumer's qualification form data, credit profile, and geographic location to the preset underwriting criteria provided by participating Lenders. Lenders are able to modify their underwriting criteria in real-time directly through a password-protected Website upon our proprietary platform. Once qualification forms pass the filters, they are transmitted to up to three Lenders who have subscribed to our marketplace whose lending criteria match that of the consumers' profile and location.

Lender Evaluation and Response. 

        Lenders evaluate and respond to the qualification forms that pass their filters.This response takes place on the automated interface technology that we have developed.

Communication of Offer.

        Once a Lender evaluates a qualification form, renders a decision, and responds with an offer, our system automatically notifies the consumer via e-mail and displays the offers on the Website where the request originated. The e-mail contains instructions to return to our Website and provides instructions directing the consumer to the Check Status page where consumers can view and compare the terms of each offer including: interest rate, closing costs, monthly payment amount, lender fees and other information.

Offer Acceptance. 

        The consumer has the ability to accept, reject or request more information about any particular loan offer. When the consumer selects one of these options, our system automatically notifies the chosen lender and the remainder of the process is conducted offline.

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Ongoing Consumer and Lender Support.

        We provide active email and telephone follow-up and support to both Lenders and consumers during the loan transaction process. This follow-up and support is designed to provide technical support and increase overall satisfaction of the participants in our exchange, as well as increase the percentage of consumers who accept and close a loan from our lending exchange.

Customers

        Borrowmoney.com Customers Our on-line exchange offers consumers the opportunity to obtain the loan products and other services listed below. We do not charge consumers a fee to use our services and our network of Lenders and real estate brokers ("our customers") pay us fees for closed loans or closed real estate transactions.

In addition to these loan products, Borrowmoney.com offers other services to our consumers:

  Real Estate Services

        We refer consumers from our exchange or various third party sites to participants in our network of real estate agents located in most states. As of December 31, 2017, we had relationships with approximately 700 real estate brokerages or agents to support referrals supplied by us. in addition we offer nationwide Realestate sales and rental listings service to realtors, at a monthly charge, pay as you go  package, quarterly and annual listing service packages, at discount price based on the amount spent and a one time setup fee, plus in house ad design service.

  Advertising and Banner Services

         Borrowmoney.com offers various advertising services which are displayed on the website. Advertising prices on the Borrowmoney site are based on several industry methods, as described below.Our advertising rates are among the lowest within the industry. Borrowmoney’s  advertising rates are based on either a pay-per-click basis, ad display basis , or on a flat rate basis.  Pay-per-click and ad display advertisers are only charged when a prospective customer visits the borrowmoney.com site and the ad is displayed or clicked on the viewing page by the person presently on the site.

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Advertising charges  

        Borowmoney advertising packages can be tailored to fits any customer’s budget and needs. Flat rate and monthly charges are based on size of ad banners, Tier and page positions. Borrowmoney currently has more than 77,000 pages being viewed and more than 27,000 individual users organically on Borrowmoney site since sept, 2017 through December 31, 2017 The company offers more than just placement of ads on its site. If a customer requests ad design services, Borrowmoney offers this to its customers. Charges are based upon the type of ad requested as well as a fixed per hour cost for design services. Advertising revenue generated since Dec, 2017 was $7000.  The Company is projecting ad revenues  of $ 2.5 for year-end 2019.

 Lenders Service

        Borrowmoney.com has provided through its proprietary technology a system for lenders to electronically join the system as a subscribed lender providing quotes after final approval by a borrowmoney.com. To become a subscribed lender, a representative of the Company first logs into www.borrowmoney.com. There a potential lender will provide basic account information, contact information, lender information regarding licensing, loans loan types, such as automobile loans, real estate loans, commercial loans, personal loans, construction loans, and others, for electronic submittal to borrow money.com. At this same time, the lender will submit their pricing package, which initially established as a no-cost trial period and a monthly marketing budget, if they so choose. Upon receipt of the lender registration, borrow money.com verifies the information and contacts the lender for final negotiations regarding the pricing packages selected. These pricing packages currently are as follows, to wit: Lender will select one of five budged amount they wish to allocate to borrowmoney lead generation campaign,

 Lender service

  lender package

Based on the package amount selected by the lender and mortgage offering landing rates disclosure, borrowmoney negotiates the demographic where the lender wish to run the campaign, and return on investment expected by the lender, Borrowmoney will charge the lender a flat fee or a % percentage of the loan amount requested by our costume lead referred to the lender

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 Borrowmoney fees are 50% cheeper then all competition 

        Upon agreement and expectance from the lender Borrowmoney creates several leads advertising ad banners to be placed on borrowmoney site, and social networks and creates awareness,  in the demographic requested by lender Consumer clicks on the ad Consumer is directed to my borrowmoney site to create on account Consumer lead is dispersed to 3 different lenders associated with borrowmoney using a secure mortgage engine lead dispersement registered with borrowmoney. consumer will receive a minimum of 3 loan offers from 3 lenders  competing for the loan in to borrowmoney.com  consumer account up on consumer selection, the selected lender finalize the deal with consumer and a % percentage or flat fee is paid to borrowmoney.com inc by lender based on agreement Our marketplace provides important benefits to lenders, including:New Business. Leveraging the reach of the Internet, we provide lenders with access to a significantly larger audience of qualified consumers. Lower Acquisition Costs. Our fees are designed to be less than the cost of acquiring customers through traditional and other online channels. Our [i]close technology enables lenders to process credit requests more efficiently and at significantly reduced costs. Market Information. We collect and distribute to our lenders valuable information about the online lending marketplace. This information enables our lenders to refine and improve their Internet lending strategies and quickly respond to changing market conditions.

  Customer Service

        We employ a staff of _3 _customer service Angela Piscitello, Norma Vally, lana coliban,  and  E-wiz solution IT Department with a staff of 8_technical support personnel who provide support to all users of our services. They provide support via email and telephone. The responsibilities of the customer service and technical support personnel include: Responding to consumers' questions about the status of theircredit request, how to use our Website, and other frequently asked questions. Acting as a liaison between consumers and Lenders, to ensure Consumers receive prompt service from Lenders. Providing technical support to lender technical and systems Questions 24 hours a day, seven days per week.

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Marketing

        Our principal marketing objectives are to maintain our leading brand awareness position and to increase volume on our exchange. These efforts include offline advertising, online advertising and direct marketing. We also collect and analyze consumer data to enhance our consumer marketing programs, subject to compliance with our privacy policy.

 Online Advertising

        Online Advertising and Sponsorships. Online advertising and sponsorships play an important role in our overall effort to reach potential consumers. We focus on those portals and Websites havin a high affinity to consumer lending, such as real estate, persona Finance and automobile-related Websites. We have also partnere with major search engine companies such as Google and incorporated banner advertising into our online strategy to maximize consumer reach at relatively low cost

 Direct Marketing 

        We believe that direct marketing is an effective means of increase loan requests and closure rates, and a way to develop more sustainable relation with consumers. our direct marketing initiatives have been executed through both offline and online channel within the guidelines of our privacy policy Our direct marketing initiative include: Direct Email. We use email to encourage customers to visit our website, complete the loan request process, communicate with consumers throughout the lending process, offer additional product And service value and facilitate consumers' ability to obtain loans. We use direct mail to compliment our online ema Efforts to build brand equity and increase overall transaction volume. Our goal is to be the predominant loan marketplace on the Internet. The key elements of our strategy are to: strengthen our position as an online marketplace offering multiple loan products from a wide variety of lenders;

  • increase brand awareness and transaction volume;
  • attract lenders offering an array of products across a wide range of consumer credit profiles and geographic  locations; expand transaction volume through online relationships;establish [i]close as the dominant loan marketplace technology; and Assist our network lenders to increase their loan closing rates.

We are an “Fintec emerging growth company,” as defined in Section 2(a) of the Securities Act, as modified by the Jumpstart Our Business Startups Act of 2012, or the JOBS Act. As such, we are eligible to take advantage of certain exemptions from various reporting requirements that are applicable to other public companies that are not “emerging growth companies” including, but not limited to, not being required to comply with the auditor attestation requirements of Section 404 of the Sarbanes-Oxley Act of 2002, or the Sarbanes-Oxley Act, reduced disclosure obligations regarding executive compensation in our periodic reports and proxy statements, and exemptions from the requirements of holding a non-binding advisory vote on executive compensation and stockholder approval of any golden parachute payments not previously approved. If some investors find our securities less attractive as a result, there may be a less active trading market for our securities and the prices of our securities may be more volatile.

In addition, Section 107 of the JOBS Act also provides that an “emerging growth company” can take advantage of the extended transition period provided in Section 7(a)(2)(B) of the Securities Act for complying with new or revised accounting standards. In other words, an “emerging growth company” can delay the adoption of certain accounting standards until those standards would otherwise apply to private companies. We intend to take advantage of the benefits of this extended transition period until we are no longer an “emerging growth company.”

We will remain an emerging growth company until the earlier of (1) the last day of the fiscal year (a) following the fifth anniversary of the completion of this offering, (b) in which we have total annual gross revenue of at least $1.0 billion, or (c) in which we are deemed to be a large accelerated filer, which means the market value of our common stock that is held by non-affiliates exceeds $700 million as of the prior June 30th, and (2) the date on which we have issued more than $1.0 billion in non-convertible debt during the prior three-year period. References herein to “emerging growth company” shall have the meaning associated with it in the JOBS Act.  

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IRS No.475168940 | State of Incorp.: FL | Fiscal Year End: 0815

Type: S-1/A | Act: 33 | File No.: 333-208854 | Film No.: 161904250
SIC7389 Services-Business Services, NEC
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Borrowmoney.com, Inc. Code of business conduct and ethics


OUR tecnology

  

BorrowMoney.com - Project Detailed Summary

All of the rights, concept, design, and technology crated and described here enclosed, are the property and ownership of Borrowmoney.com, Inc. not limited to any copyrights or patents.

Since February ,2014 

Summary: E-Wiz Solutions, Inc. was awarded the design and development of the website "BorrowMoney.com" for their extensive coding experience, qualifications and reputation as a professional services company specializing in dynamically driven mission critical applications requiring above average level of complexity.  E-Wiz Solutions, Inc. is a development firm located within the United States of America and warrants that the work outlined herein amounts to approximately $1,250,000.00 and is justified in terms of our having to develop a fully-automated, self-manageable, secure and highly competitive website that adheres to our clients’ needs and intended project scope.  Any assumption of what the site BorrowMoney.com should and/or could have cost without first having a clear understanding the intricate details behind the development and deployment of BorrowMoney.com can only be flawed.  As such, we have provided the following as an outline including in detail the procedures and developmental methodologies implemented by E-Wiz Solutions, Inc. in fulfilling the requirements set forth as per client correspondence, relayed concepts and project scope.

Design Considerations: 

BorrowMoney.com at its core is an online lending service designed to match borrowers with local lenders.  Facilitating this process requires the collection of financial data from online visitors thereby allowing the online retrieval by lending institutions.  Given that BorrowMoney.com's core service involves the handling of secure information (i.e. social security numbers and financial data), protecting this data from an unwarranted data breach is the utmost priority and therefore a major factor in determining an appropriate methodology for development.  During the initial design consideration, there was no known commercial 3rd party solution available at the time that could satisfy the unique set of features or level of security required for this project.  As a result, the only option available was to perform custom design and development (further explanation/ logic which lead to this decision can be found in appendix A).

Project Scope: 

To provide the website owner with the ability to fully administer its services and self-expand from its core service offering as necessary from day one without the need for developer intervention.  To accomplish this task, the owner required the capability to configure, manage and monitor all aspects of its online service offering via a very advanced and carefully designed back-end administrative portal.

  • Configurable aspects include but are not limited to: member types and member registration forms; multi-purpose forms including loan forms; member type access restrictions to content, forms and/or services; subscription-based services, packaged services and costs; email templates for member correspondence; 
  • Manageable aspects include but are not limited to: maintenance of all configurable aspects; website pages and content; bulk email communications for CRM/Marketing; customize login screen dashboard for various member types;
  • Monitoring aspects include but are not limited to: member accounts, member submitted content and member activities; visitor feedback & live chat; 

It should be noted that as part of this project, E-Wiz Solutions, Inc. performed a majority of the initial configuration and quality assurance required to initiate/launch BorrowMoney.com core services and site wide features prior to site owner training and administrative hand off. 

Site Security:

The BorrowMoney.com core would contain specific core coding architecture and safety features designed to ensure proper and secure member authentication and member access to content and services in accordance with rules set forth via administrative portal configurations.  Core security features include but are not limited to the following:

  1. Access control mechanisms for understanding rule sets configured for created member types (anonymous, borrowers, lenders, realtors, advertisers, administrators, etc...).
  2. Login session handling, auto log out, login activity logs, session and IP address tracking for all successful and failed logins, forgot login handling, SQL error tracking and administrative email notification;
  3. Intrusion detection and protection against SQL injection and cross-site-scripting.
  4. Multilevel administrative access setup & configuration (super user, administrator, limited administrator, etc...)
  5. Encrypted data storage of sensitive data (TID, SS#, Credit Card Data, Passwords, etc...)
  6. HTTPS encrypted protocols implemented for all site access in addition to installation of GeoTrust SSL Certificate for authenticity.
  7. Initial configuration of Linux server, services, utilities, LAMP and hosting environment to create a secure hosting environment.
  8. Initial configuration of Amazon Web Services to facilitate safe, efficient and effective deployment of BorrowMoney.com operations. 

Site Administration:

The following are some features that have been created for administrative purposes.  Note: To better understand functionality pertaining to features we are about to discuss, it is important to note that most functionality pertinent to the site can be affiliated with tracking and/or handling of any one of four action types (Form Submission; Submission Association; Ad Clicks; and Ad Impressions;).  These action types can be triggered by various members -or- member types via their use of BorrowMoney.com.   

  1. Member Types - Ability to configure member types including member registration fields; Configure member type access restrictions to subscriptions, member submitted data, submission forms and other site functionality;
  2. Service creation - Ability to create services, configure specific member type access and service costs in accordance with a core action completed upon using the service (i.e. click, impression, form submission, form association).
  3. Package creation - Ability to create subscription-based packages for specific member types; Configure cost of package subscription, payment structure (auto replenish/ pay as you go) and services to be included and/or optional.
  4. Submission Form - Ability for administrator to create database tables (forms for submission by specific member types); Configure rule sets dictating whether a form submitted by a specific member type should be associated -or- viewable by another member type; Specify whether access to submit -or- view other member submissions should require a service-based subscription.
  5. Form Builder - An advanced form builder provides a wide variety of form fields from a pre-canned list of over 70 field types (many of which are pre-loaded with a specific set of options tailored for client, others field types even smarter such that field options can be dynamically configured for a specific form).  The administrator associates a field type from the pre-canned list for each field it adds while creating and configuring a submission form.  In addition to configuring what fields will be present within a submission form, the administrator can separate fields into tabbed question groups in addition to setup advanced field restrictions.  Advanced field restrictions allow the administrator to specify precisely how a specific value entered for a given field should dictate the availability or requirement of other fields throughout the current form -or- other submission forms entirely.  Give the many pre-canned field types needed for form configurations, an extensive amount of coding was required for creating these field types in addition to field value validation rules.  This coding necessary was two-fold as it required that validation rules be written in both PHP and jQuery to account for both post submission and real-time field value validation. 
  6. Integrate billing mechanisms with USA-EPay to bill subscription-based members credit cards as needed for services rendered.
  7. Complex Triggering Mechanisms - BorrowMoney.com administrators have the ability to configure complex triggering mechanisms for invoking a specific event in response to an action -or- action criteria.  Examples: 1) An administrator can configure a specific email template to be delivered to an individual who enters a specific value within a field upon member registration or other form submission.  Example 2: Administrator can create a trigger that associates loan requests from borrowers to a specific group of lenders based on lender matching criteria. 
  8. Ability to clone submission forms for easy and fast creation of similar applications.
  9. Advanced Communications - automated communications with members via various forms (email, text to speech robot call and automated input response, fax transmission, tweets, SMS, MMS) whereby the details of communications can be configured via a token-based template creation facility.
  10. Bulk email functionality for communicating with members and prospects including email receipt for performance tracking.
  11. Ability to create and manage page content - CMS like capability via WYSIWYG Editor
  12. Administrative settings page - Configurable site-wide settings to provide administrators to tweak core functionality.
  13. Ability for administrator to configure custom dashboard (home screen) for various member types.
  14. Site activity tracker will display activities or actions performed in regard to a specific submission form if table setting enabled.
  15. SEO Manager - Enables administrator to configure Page Title, Meta Description, Meta Keywords and Clean URL for specific website pages and submission forms.
  16. Staff activity monitor to track most recent access by administrative staff members.

Site Configuration:

  1. Configure all member types, account registration details, access restrictions, subscription packages & pricing, and services pertinent to borrowers, lenders, lender sub-accounts, advertisers, realtors, etc...
  2. Create 19 loan request forms (table fields within each form, field order, field options pertinent to each field, field text & popup help messages).  Note, some forms contain over 100 fields (i.e. health insurance), and many forms fields allow for complex data selection (i.e. vehicle type and make).  Some complex data fields such as location and/or vehicle type require manual import (huge quantities of data) simply to enhance user experience and ensure accuracy and consistency of data (i.e. 50,000+ zip codes and states for the U.S. / All Car Make and Affiliated Models).
  3. Configure all email templates including (forgot login, new registration, submission confirmation, submission association, loan assignment for lender sub-account, payment processed at the time of package signup, renewal or auto-replenishment and more.
  4. Configure all website content via administrative page manager - WYSIWYG (loan interim pages, advice pages, article pages and main site pages - about us, contact us, FAQs, careers, terms of use, etc.)
  5. Optimization of All Website Content, Page Titles & Meta Data.  Create sitemap.xml and submit to major search engines.

Site Features:

  1. Member signup which can include payment processing for enrolled subscription (borrowers, lenders, advertisers, realtors)
  2. Loan request submission and account access for borrowers to monitor submission statuses.
  3. Advertiser account setup and campaign administration.  Advertisers can upload various sized ads and create an unlimited number of advertising campaigns to includes campaign specific geo-targeting by City, State & Zip code.
  4. Lender account administration to: view associated leads; follow up with borrowers; create "sub accounts" - additional login credentials for sub-lenders to login, view and follow up on leads assigned by lender;
  5. Realtor account administration to create and manage real-estate for sale, rental listings and receive prospective communications.
  6. Search real estate for "for sale/rental" listings.  Details include property pictures, features, school and neighborhood details, history, agent details and agent contact form.
  7. Verify a Broker / Lender - Import customer supplied data to allow broker / lender to search along with detailed information.
  8. Create calculators for various loan types: mortgage, auto, personal & commercial.
  9. Integrate w/ 3rd-party mortgage feed provider to display recent and weekly national mortgage, house price index & prime rates.
  10. Create site wide search allowing website visitors to search all website content.
  11. Report an issue feature for enhanced user experience, issue tracking and escalation as necessary.
  12. Integrated live chat for enhanced user experience and support.
  13. Geo-targeted ad display and ad rotation targeting website visitors according to derived location, or location details specified during application processes.  Develop click tracking mechanisms for billing advertisers.  

Visual Interface:

  1. Design website shell / cosmetic structural aspects, front-end pages and back-end member access portals.  
  2. Create jQuery slideshow and integrate with core form field restrictions for a more simplified form submission experience.
  3. Write CSS to enable responsiveness - proper rendering of front and back end on all devices (iPhone, Android, Tablet, & PCs/Mac).

Documentation:

  1. Create detailed user manuals including text and visual depictions to assist Borrowers, Lenders, Lender Sub-Accounts, Advertisers and Site Administrators with back end account administration features and functionality.
  2. All development has been accompanied with limited inline coding documentation as is typical with professional development.

Quality Assurance:

  1. Test registration functionality for all members, registration follow-up email containing member login credentials, and verify login success via credentials provided.
  2. Test forgot login functionality and email to client with credentials upon client verification.
  3. Test loan form submissions to ensure proper association with lenders in accordance with matching lender prospect criteria.  Verify lender account balance is updated to reflect cost of lead.  Verify emails to sub-lenders upon lead assignment by lenders.
  4. Test payment processes to ensure proper billing and email of payment receipts to customers and copy to administrators upon initiation of billing processes pertinent to member activities.
  5. Evaluate all other site front and back end features & functionality, configurations, page conformity, links and content display. 

Customer Training:

  1. In depth training session with website owner regarding all website features and functionality including administrative processes respect to all configurable, manageable and monitored aspects.
  2. Provided support as needed during the initial launch to assist with configuration questions and/or issues.

Beta Support:

  1. Issue core code modifications to address apparent bugs following initial launch as well as issue minor enhancements necessary to effectively facilitate proof of concept and smooth transition from beta phase to full production.

Appendix A: The question we were faced with initially was whether to develop BorrowMoney.com via "Custom Design & Development" -OR- "Commercially Available 3rd Party Product".  At the time of the initial development, unfortunately there were no 3rd party application available for commercial use on the market that inherently possessed the type of unique functionality required by the BorrowMoney.com concept.  Even if such an application would have existed, the idea of deploying a widely utilized commercially available application presented a significant security risk for us - as everyone knows that most vulnerabilities pertinent to 3rd party applications (i.e. CMS Joomla/WordPress/Drupal) are discovered as a result of a data breach in addition to the fact that most vulnerabilities are widely publicized among hacker communities.  Relying on a 3rd party product presented an elevated level of vulnerability and risk that BorrowMoney.com could not afford to take, leaving custom design and development as the most secure option for us.                           

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BORROWMONEY.COM,  INC.

CODE OF BUSINESS CONDUCT AND ETHICS

 

Jannuary 2020

Introduction and Scope

The Board of Directors of BorrowMoney.com, Inc. (together with any subsidiaries, the “Company”) established this Code of Business Conduct and Ethics (this “Code”) to aid the Company’s directors, officers, employees and consultants in conducting the Company’s business affairs in accordance with standards of ethical conduct that will maintain and foster the Company’s reputation for honest and straightforward business dealings.

The Company’s Board of Directors or any committee designated by the Board of Directors is responsible for administering this Code. The Board of Directors has delegated day-to-day responsibility for administering and interpreting this code to a Compliance Officer. The Company’s General Counsel has been appointed as the Compliance Officer under this Code.

Every director, officer, employee and consultant of the Company (each a “Covered Person,” and collectively the “Covered Persons”) is subject to and must abide by this Code. Covered Persons are expected to exercise reasonable judgment when conducting the Company’s business.

Nothing in this Code alters the at-will status of any employee or consultant of the Company.

Honest, Lawful and Ethical Conduct

The conduct of Covered Persons in performing their duties on behalf of the Company should in all situations, as to all matters and at all times, be honest, lawful and in accordance with high ethical and professional standards. In addition, the conduct of Covered Persons should at all times be respectful of the rights of others and in the best interests of the Company.

The requirements of honest, lawful and ethical conduct are broad and stated in general terms. As such, this Code does not cover every issue that may arise, but instead sets out basic principles. The Company encourages Covered Persons to refer to this Code frequently to ensure that they are acting within both the letter and the spirit  of this Code.  The Company understands that this Code will not contain the answer to every situation that a Covered Person may encounter or every concern you may have about conducting the Company’s business ethically and legally. In these situations, or if a Covered Person has other questions or concerns about this Code, the Company encourages such Covered Person to speak with his or her immediate supervisor (if applicable) or, if he or she is uncomfortable doing so, with the Compliance Officer under this Code. Covered Persons may also utilize  the procedures established from time to time by the Audit Committee of the Board of Directors (the “Audit Committee”) for the receipt, retention and treatment of complaints received by the Company regarding accounting, internal accounting controls or auditing matters. Such procedures are currently set forth below in this Code.

Contents of this Code

This Code has two sections which follow this Introduction. The first section, “Standards of Conduct,” contains the actual guidelines that Covered Persons are expected to adhere to in the conduct of the Company’s business. The second section, “Compliance Procedures,” contains specific information about how this Code functions, including who administers the Code, who can provide guidance under the Code and how violations may be reported, investigated and resolved. This section also contains a discussion about waivers of and amendments to this Code.

A Note About Other Obligations

Covered Persons generally have other legal and contractual obligations to the Company. This Code is not intended to reduce or limit such obligations. Instead, the standards in this Code should be viewed as the minimum standards that the Company expects from Covered Persons. In the event that a law conflicts with a policy in this Code, Covered Persons must comply with the law.

Covered Persons who are in or aware of a situation which may violate or lead to a violation of this Code should follow the guidelines described in this policy.

Standards  of Conduct

Conflicts of Interest

The Company respects the privacy of Covered Persons and their right to engage in outside activities that do not conflict with the interests of the Company or impair or interfere with the performance of a Covered Person’s duties to the Company.

A “conflict of interest” exists when a Covered Person’s personal interest interferes with the interests of the Company. Conflicts of interest may arise in many situations. For example, a conflict of interest may arise when a Covered Person takes actions or has interests that may make it difficult to perform his or her work for the Company objectively and effectively. It is almost always a conflict of interest for a Covered Person to work simultaneously for a competitor, customer or supplier. Covered Persons should avoid any material business relationship with the Company’s customers, suppliers and competitors, except when acting on the Company’s behalf. A conflict of interest may also arise when any Covered Person, or any member of his or her immediate family, receives improper personal benefits as a result of the Covered Person’s position with the Company. If a Covered Person’s spouse or other immediate family member works for a firm that does business with or competes against the Company, the Compliance Officer should be advised of the situation in writing.

The Company has the right and obligation to determine whether conflicts of interest exist and to take appropriate action to address them. Any Covered Person who has a question about whether or not he or she has a conflict of interest should bring it to the attention of his or her immediate supervisor or the Compliance Officer. Before engaging in  any material transaction or relationship that  reasonably could give rise to a conflict of interest, each Covered Person must provide full and fair disclosure of all relevant facts and circumstances to the Compliance Officer. If the Covered Person is a director, executive officer or other person subject to the Company’s Related Persons Transaction Policy, the Compliance Officer

will review the transaction or relationship in accordance with the Related Persons Transaction Policy and determine whether to submit the relationship or transaction for review and approval by the Audit Committee or another independent body of the Company’s Board of Directors. In the case of any other Covered Person or in the case where the Compliance Officer determines that the relationship or

transaction does not require the review and approval of the Audit Committee or another independent body, the Compliance Officer will determine whether or not to approve the relationship or transaction.

Compliance with Laws, Rules and Regulations

The Company seeks to conduct its business in compliance with applicable laws, rules and regulations. No Covered Person should engage in any unlawful activity in conducting the Company’s business or in performing his or her day-to-day duties, nor should any Covered Person instruct others to do so. This Code should be read in conjunction with the Company’s Employee Resource Guide and other existing policies, practices and procedures, including but not limited to the LendingTree Securities Trading Policy, the Policy Regarding Employee Reporting of Financial & Audit  Related  Concerns, and the Company’s policies and agreements concerning proprietary inventions, trade secrets and employee conduct.

Protection and Proper Use of the Company’s Assets

Loss, theft and misuse of the Company’s assets has a direct impact on the Company’s business and its profitability. Covered Persons are expected to protect the Company’s assets that are entrusted to them and to protect the Company’s assets in general. Covered Persons are also expected to take steps to ensure that the Company’s assets are used only for legitimate business purposes.

Confidentiality

Confidential information generated and gathered in the Company’s business plays a vital role in the Company’s business, prospects and ability to compete. “Confidential information” includes all non- public information that might be of use to competitors, or harmful to the Company or its customers or suppliers, if disclosed. It can also include information entrusted to the Company by its suppliers or customers. Covered Persons must maintain the confidentiality of such confidential information, except when disclosure is authorized by the Company or required by applicable law, rule or regulation or pursuant to an applicable legal proceeding. Covered Persons may only use confidential information for legitimate Company purposes.

Covered Persons must return all of the Company’s confidential and/or proprietary information in their possession to the Company when they cease to be employed by or otherwise serve the Company.

Fair Dealing

Competing vigorously, yet lawfully, with competitors and establishing advantageous, but fair, business relationships with consumers, vendors, lenders, other customers, third-party intermediaries and suppliers is a part of the foundation for long-term success. Unlawful and unethical conduct, even if it leads to short-term gains, may damage a company’s reputation and long-term business prospects.

Accordingly, it is the Company’s policy that Covered Persons endeavor to deal ethically and lawfully with the Company’s consumers, vendors, lenders, other customers, third-party intermediaries, suppliers and competitors and their respective employees in all business dealings on the Company’s behalf. 

Accuracy of Records

It is the Company’s policy to maintain its books, records, accounts and financial statements in reasonable detail so that they appropriately reflect the Company’s transactions and conform both to applicable legal requirements and to the Company’s system of internal controls. No Covered Person may cause the Company to enter into a transaction with the intent to document it or record it in a deceptive or


unlawful manner. No Covered Person may create any false or artificial documentation for any transaction entered into by the Company. Unrecorded or “off the books” funds or assets should not be maintained unless permitted by applicable law or regulation and brought to the attention of the Company’s Chief Accounting Officer.

Disclosure and Financial Reporting

The Company is committed to providing full, fair, accurate, timely and understandable disclosure in all reports and documents filed with or submitted to the Securities and Exchange Commission (“SEC”) and in all other public communications made by the Company. It is the Company’s policy to maintain disclosure controls and procedures that are designed to ensure that the information required to be disclosed by the Company in the reports it files with or submits to the SEC is recorded, processed, summarized and reported accurately, within the time periods specified in the SEC’s rules and forms.

Covered Persons responsible for SEC filings and submissions and other public disclosures should report financial results in a way that enables the Company to fairly present the consolidated financial position and the consolidated results of operations and cash flows of the Company in conformity with accounting principles generally accepted in the United States, applied on a consistent basis.

Any Covered Person who learns of any material information affecting or potentially affecting the accuracy or adequacy of the disclosures made by the Company in its SEC filings, submissions or other public statements should report the same to the Compliance Officer or through the procedures established from time to time by the Audit Committee for the receipt, retention, and treatment of complaints received by the Company regarding accounting, internal accounting controls or auditing matters, as set forth below.

Improper Influence of Auditors

No Covered Person may take any action to fraudulently influence, coerce, manipulate or mislead the Company’s auditor of the Company’s financial statements for the purpose of rendering those financial statements materially misleading. 

Accepting or Offering Gifts and Gratuities

No Covered Person may offer or give (directly or indirectly) any improper gift, favor, kickback or other improper payment or consideration to any customer, supplier, government official, including, without limitation, any foreign government official, or any other person for assistance or influence concerning any transaction affecting the Company. No Covered Person may ask for or accept (directly or indirectly) any improper gift, favor, kickback or other improper payment or consideration from a  customer, government official or any other person in consideration for assistance or influence concerning any transaction affecting the Company.  Any Covered Person aware of a person offering, giving, asking for or accepting an offer of a gift, gratuity or other personal consideration to influence a business transaction affecting the Company should report the same to the Compliance Officer or through the procedures established from time to time by the Audit Committee for the receipt, retention, and treatment  of complaints received by the Company regarding accounting, internal accounting controls or auditing matters, as set forth below.

These provisions are not intended to apply to routine, reasonable business entertainment or gifts of minor value customary in local business relationships, provided that no laws or Company policies, including but not limited to, the Company’s Gifts and Gratuities Policy, are violated.

Compliance Procedures 

Communications of this Code

All Covered Persons will be provided with a copy of this Code upon beginning service with the Company. Updates to this Code will be provided from time to time. The standards in this Code may be further explained or implemented through the Company’s Employee Resource Guide and other policy memoranda, including those relating to specific areas of the Company’s business. A Covered Person may obtain a copy of this Code or any such memoranda upon request to the Compliance Officer. This Code is also available via the Company’s intranet or by accessing the “Investors” section of the Company’s website at www.borrowmoney.com/investor-relations

Monitoring Compliance and Disciplinary Action

The Company’s management, under the supervision of its Board of Directors or a committee thereof or, in the case of accounting, internal accounting controls or auditing matters, the Audit Committee, will take reasonable steps from time to time to (i) monitor compliance with this Code, including the establishment of monitoring systems that are reasonably designed to investigate and detect conduct in violation of this Code and (ii) when appropriate, impose and enforce appropriate disciplinary measures for violations of this Code.

The Company’s management will periodically report to the Board of Directors or a committee thereof on these compliance efforts including, without limitation, periodic reporting of alleged violations of this Code and the actions taken with respect to any such violation.

Reporting Concerns/ Receiving Advice/ No Retaliation

Be Proactive. Every Covered Person is expected to act proactively by asking questions, seeking guidance and reporting violations of this Code and other policies and procedures of the Company, as well as any violation of applicable law, rule or regulation arising in the conduct of the Company’s business or occurring on the Company’s property. If any Covered Person believes that actions have taken place, may be taking place, or may be about to take place that violate or would violate this Code, he or she is expected to bring the matter to the attention of a supervisor, the Compliance Officer or report the matter through the procedures established from time to time by the Audit Committee for the receipt, retention, and treatment of complaints received by the Company regarding accounting, internal accounting controls or auditing matters, as set forth below.

Seeking Guidance. The best starting point for a Covered Person seeking advice on ethics-related issues or reporting potential violations of this Code will usually be his or her immediate supervisor.

However, if the conduct in question involves the Covered Person’s immediate supervisor, if the Covered Person does not have an immediate supervisor, if the Covered Person has reported the conduct in question to his or her immediate supervisor and does not believe that he or she has dealt with it properly, or if the Covered Person does not feel that he or she can discuss the matter with his or her immediate supervisor, the Covered Person may raise the matter By e-mail to lega@borrowmoney.com (anonymity cannot be maintained).

Reporting Accounting and Other Concerns. Any Covered Person who learns of any violation or potential violation concerning accounting, internal accounting controls or auditing matters should promptly bring the matter to the Audit Committee. Accounting, internal accounting control and auditing matters include but are not limited to information concerning (i) significant deficiencies or material weaknesses in the design or operation of internal controls which could adversely affect the Company’s ability to record, process, summarize and report financial data accurately, (ii) any fraud, whether or not

material, involving management or other employees who have a significant role  in  the Company’s financial reporting, disclosures or internal controls, (iii) improper influence of an  auditor of the Company’s financial statements or (iv) the accuracy or adequacy of the disclosures made by the Company in its SEC filings or submissions or other public disclosures.

Anonymity. When reporting suspected violations of this Code, the Company prefers that Covered Persons identify themselves in order to facilitate the Company’s ability to take appropriate steps to address the report, including conducting any appropriate investigation. However, the Company also recognizes that some people may feel more comfortable reporting a suspected violation anonymously. If a Covered Person wishes to remain anonymous, he or she may do so, and the Company will use reasonable efforts to protect the confidentiality of the reporting person subject to applicable law, rule or regulation or to any applicable legal proceedings. In the event the report is made anonymously, however, the Company may not have sufficient information to look into or otherwise investigate or evaluate the allegations. Accordingly, Covered Persons who make reports anonymously should provide as  much detail as is reasonably necessary to permit the Company to evaluate the matter(s) set forth in the anonymous report and, if appropriate, commence and conduct an appropriate investigation.

Protection for Reporting Violations. It is prohibited, and is a violation of this Code, for the Company or any person to retaliate in any way against any Covered Person who, acting in good faith, reports information concerning suspected misconduct.

Misuse of Reporting Channels. Covered Persons may not use these reporting channels in bad faith or in a false or frivolous manner.

Enforcement

Investigating Reports of Violations. The Company is committed to full, prompt and fair enforcement of the provisions of this Code. Upon receipt of any concern, other than an accounting, internal accounting control or auditing concern, the Compliance Officer will promptly initiate an investigation to gather the relevant facts. Upon receipt of any accounting, internal accounting control and auditing concern, the Audit Committee will promptly initiate an investigation  to gather the relevant facts. In conducting and monitoring investigations, the Compliance Officer or Audit Committee, as applicable, may consult and coordinate as appropriate with other Covered Persons, including but not limited to members of the Company’s senior management team, Internal Audit Department, Finance Department or Human Resources Department, and will seek to ensure that the provisions of this Code are applied and enforced consistently across the Company. All lawful and appropriate investigative means and methods may be utilized in the conduct of the investigation. All Covered Persons should cooperate in the investigation when called upon to do so. A failure to cooperate may itself constitute a violation of the Code.

Sanctions for Violations. Appropriate disciplinary action will be determined upon completion of the investigation, if the Compliance Officer or Audit Committee, as applicable,  concludes that a violation of the Code has been committed and disciplinary action is warranted. Any violation of this Code may result in serious sanctions by the Company, which may include but is not limited to, dismissal, suspension without pay, loss of pay or bonus, loss of benefits or demotion.

Any disciplinary action to be taken against an employee will be subject to the approval of senior management and will be carried out by the Human Resources Department.

Waivers of the Code of Business Conduct and Ethics

No waiver of any provisions of this Code for the benefit of a director or officer (which includes without limitation, for purposes of this Code, the Company’s principal executive, financial and accounting officers) will be effective unless (i) approved by the Board of Directors or, if permitted, a committee thereof, and (ii) if applicable, such waiver is promptly disclosed to the Company’s shareholders in accordance with applicable United States securities laws and/or the rules and regulations of the NASDAQ Stock Market, as the case may be.

Any waivers of this Code for other employees or consultants may be made by the Compliance Officer, the Company’s Chief Executive Officer, the Board of Directors or, if permitted, a committee thereof.

All amendments to this Code must be approved by the Board of Directors or a committee thereof and, if applicable, must be promptly disclosed to the Company’s shareholders in accordance with applicable United States securities laws and/or the rules and regulations of S.E.C.

 

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