Code of Ethics
for Senior Financial Officers
and Senior Management of
Skyway Communications Holding Corp.
Skyway Communications Holding Corp. (the "Company") is committed to conducting
its business in compliance with all applicable laws and regulations and in
accordance with high standards of business conduct. The Company strives to
maintain the highest standard of accuracy, completeness, and disclosure in its
financial dealings, records, and reports. These standards serve as the basis for
managing the Company's business, for meeting the Company's duties to its
stockholders, and for maintaining compliance with financial reporting
requirements. The Company's principal executive officer and all of the Company's
senior financial executives and senior management must agree to comply with the
following principles and will promote and support this Code of Ethics, and
comply with the following principles. For the purposes of this Code of Ethics,
"senior financial officers" means the Company's principal financial officer or
principal accounting officer, senior executive officers, or persons performing
similar functions.
The principal executive officer, senior management and each senior financial
officer of the Company will adhere to and advocate the following principals and
responsibilities governing his or her professional and ethical conduct, each to
the best of his or her knowledge and ability.
1. Act with honesty and integrity and in an ethical manner, avoiding actual or
apparent conflicts of interest in personal and professional relationships.
2. Promptly disclose to the Company, through the General Counsel, Chief
Accounting Officer, or Audit Committee, any material transaction or
relationship that reasonably could be expected to give rise to a conflict
of interest between personal and professional relationships.
3. Provide full, fair, accurate, timely, and understandable disclosure in
reports and documents that the Company files with, or submits to, the SEC
and in other public communications made by the Company.
4. Provide constituents with information that is accurate, complete,
objective, relevant, timely, and understandable.
5. Comply with applicable rules and regulations of federal, state, and local
governments and other appropriate private and public regulatory agencies.
6. Act in good faith, responsibly, with due care, competence and diligence,
without misrepresenting material facts or allowing my independent judgment
to be subordinated.
7. Use good business judgment in the processing and recording of all financial
transactions.
8. Respect the confidentiality of information acquired in the course of the
Company's business, except when authorized or otherwise legally obligated
to disclose such information, and not use confidential information acquired
in the course of work for personal advantage.
9. Share knowledge and maintain skills important and relevant to his or her
constituents' needs.
10. Promote ethical behavior among constituents in the work environment.
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11. Achieve responsible use of and control over all assets and resources
employed or entrusted to him or her.
12. Comply with generally accepted accounting standards and practices, rules,
regulations and controls.
13. Ensure that accounting entries are promptly and accurately recorded and
properly documented and that no accounting entry intentionally distorts or
disguises the true nature of any business transaction.
14. Maintain books and records that fairly and accurately reflect the Company's
business transactions.
15. Sign only those documents that he or she believes to be accurate and
truthful.
16. Devise, implement, and maintain sufficient internal controls to assure that
financial record keeping objectives are met.
17. Prohibit the establishment of any undisclosed or unrecorded funds or assets
for any purpose and provide for the proper and prompt recording of all
disbursements of funds and all receipts.
18. Not knowingly be a party to any illegal activity or engage in acts that are
discreditable to my profession or the Company.
19. Respect and contribute to the legitimate and ethical objects of the
Company.
20. Engage in only those services for which he or she has the necessary
knowledge, skill, and expertise.
21. Not make, or tolerate to be made, false or artificial statements or entries
for any purpose in the books and records of the Company or in any internal
or external correspondence, memoranda, or communication of any type,
including telephone or wire communications.
22. Report to the Company, through the General Counsel, Chief Accounting
Officer, or Audit Committee any situation where the Code of Ethics, the
Company's standards, or the laws are being violated.
Those required to comply with this Code of Ethics understand that failure to
comply with this Code of Ethics will not be tolerated by the Company and that
deviations there from or violations thereof will result in serious consequences,
which may include, but may not be limited to, serious reprimand, dismissal or
other legal actions.
The parties subject to this Code of Ethics will acknowledge in writing that they
agree to comply with these requirements.
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