Purpose

ACS Technologies Group, Inc. ("ACST") respects the intellectual property ("IP") rights of others and expects others to respect our IP rights. Compliance with federal copyright law is expected of all employees, contractors, and any third parties.

Scope and Applicability

This policy applies to all ACST employees, contractors, and vendors.

Policy

Assignment of Intellectual Property - All employees, contractors, consultants, temporary employees and third parties grant to ACST exclusive rights to patents, copyrights, inventions or other intellectual property they originate and/or develop for the benefit of ACST during which time a relationship with ACST exists and for which services were provided for ACST. Without specific written exceptions, all programs and documentation generated by, or provided by employees, contractors, consultants, temporary employees and third-parties for the benefit of ACST are the property of ACST.

Protection of Intellectual Property Rights - ACST intellectual property includes but is not limited to:

• Source code for all ACST products

• Electronic communications that facilitated the concept and design of IP and CI;

• Tools created for data conversions;

• Unpublished financial information;

• Data of ACST Customers/Partners/Vendors;

• Patents, formulas or new technologies;

• Customer lists (existing and prospective);

• Data entrusted to ACST by external parties;

• Pricing/marketing and other undisclosed strategies;

• Documents and processes explicitly marked as confidential;

• Unpublished goals, forecasts and initiatives marked as confidential;

• Other information explicitly marked as confidential.

Software Licensing Agreements -Third-party software in the possession of ACST must not be copied unless such copying is consistent with relevant license agreements. The agreements for all computer programs licensed from third parties must be periodically reviewed for ACST compliance.

Prohibition Against Use of Names/Logos - No employee, contractor, consultant, temporary employee or third-party may use the ACST or subsidiaries names or logos unless the permission of the Marketing Director or Executive Leadership Team ("ELT") has first been obtained.

• Software - Purchase or license all commercial software. Do not copy commercial software unless the software license expressly permits copying.

  Journals & Publications - Purchase multiple copies of trade journals and other similar periodicals. Do not copy significant portions of such materials, unless prior permission has been obtained from the copyright holder.

  Pictures, Music & Videos - License the use of pictures, music or videos. Do not use commercial music or video CDs and DVDs in ACST’s business, without first obtaining a license or other permission from the copyright holder.

  Customer Confidential Information - Information obtained from customers under a nondisclosure agreement should be kept confidential using efforts similar to what ACST uses for its own information. Customer confidential information should not be used for any purpose other than what the customer clearly permits.

  Trademarks & Logos - Permission should always be obtained, before using the trademarks and logos of others.

You may "use" all or part of a copyrighted work only if (a) you have the copyright owner's permission (in writing, either email or letter), or (b) you qualify for a legal exception. The most common exception is called "fair use". "Use" of a work is defined for copyright purposes as copying, distributing, making derivative works, publicly displaying, or publicly performing the work.

Copying, distributing, downloading, and uploading information on the Internet may infringe the copyright for that information. Even an innocent, unintentional infringement may violate the law. Violations of copyright law that occur on or over ACST's networks or other computer resources may create liability for ACST as well as the computer user, and are not acceptable.

Enforcement

Any employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment. Service Providers found to have violated this policy may be subject to financial penalties, and termination of contract.

Variance Process

The Chief Ventures Officer is responsible for the review, documentation, and management of any and all exceptions to this policy.