ENVIRONMENTAL POLICY GUIDELINES

Boundless is committed to protecting our natural environment and resources in all areas where we conduct business. Implementation of this policy is a primary management objective and is the responsibility of every employee.

It is Boundless' policy to:

• Comply with all applicable environmental laws and regulations and cooperate with local, state and federal agencies in their inspection and enforcement activities.
• Incorporate environmental considerations in the company's planning and operational decisions. Boundless has operated a paperless factory floor for more than ten years and continues to develop processes to eliminate waste product.
• Boundless has processes in place for recycling of all Boundless products. All products comply with both the WEEE and RoHS regulations. Boundless Technology will pay freight for all thin clients sold after 2006 back to the factory in New York for recycling. 
• Promote and encourage energy efficiency and environmental protection through new and existing technologies.
• Develop and communicate environmental objectives throughout the company so that all employees understand their individual responsibilities and are appropriately trained in carrying out these objectives.
• Manage operations in a responsible manner and respond effectively to avoid and/or mitigate adverse environmental impacts associated with operations.
• In the event of an environmental mishap, report and disclose to the appropriate authorities information concerning the situation so as to guarantee a prompt and appropriate response.
• Conduct periodic assessments of operations to evaluate, measure and assure environmental performance and compliance.
• Participate in the formulation of prudent and responsible environmental laws and regulations that may impact our business and foster a constructive working relationship with environmental organizations and agencies.
• Commit the resources needed to implement these principles.
  
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CONFLICT OF INTEREST GUIDELINES

Boundless recognizes and respects the right of its directors, officers and employees to engage in outside financial, business or other activities as long as these activities are legal and do not impair or interfere with the conscientious performance of company duties and do not involve the misuse of Boundless' name, reputation, influence, facilities or other resources. While specific provisions cannot be made for each situation that might confront an individual, the following Policy Statement and Guidelines govern certain matters of particular concern.

Policy Statement. No director, officer or employee of Boundless shall have any position with or a substantial interest in any other business enterprise operated for a profit, the existence of which would conflict or might conflict with the proper performance of his duties or responsibilities, or which might tend to affect independence of judgment or action with respect to transactions between Boundless and such other business enterprise, without full and complete disclosure thereof. No director, officer or employee of Boundless should derive personal economic gain (directly, through a family member or otherwise) from a transaction to which Boundless is a party unless Boundless is advised of such director's, officer's or employee's potential to benefit from the transaction. Any director, officer or employee who has such a conflicting or possibly conflicting interest with respect to any transaction which is known to be under consideration by Boundless, or any of its affiliates, is required to make timely disclosure thereof so it may be part of Boundless' consideration of the transaction.

Boundless is also sensitive to undertakings or affiliations with non-profit organizations. While Boundless encourages participation with worthwhile non-profit organizations, each employee must take care that his or her participation does not adversely impact or reflect unfavorably upon Boundless. For example, circumstances could occur where a non-profit organization's mission was in conflict with Boundless' mission or otherwise worked against Boundless' interests. Accordingly, if there is any question in your mind about your participation or affiliation with a non-profit organization, you should bring it to the attention of the Officers.

 
Guidelines. In order to implement the foregoing Policy Statement, but without limiting its intent, the following Guidelines are adopted:

1. Under no circumstances will any director, officer or employee of Boundless accept or give cash for the purpose of influencing a business decision, or which could be construed as having been given or received for that purpose.
2. Without prior approval in the manner described in paragraph (11) below, no director, officer or employee, personally, through a family member or otherwise shall serve as a director, officer, employee or consultant to companies which directly compete with Boundless or which provide services to Boundless or its affiliates.
3. Directors, officers and employees may not take or use for themselves any business opportunity which may come to them individually but which might be of interest to Boundless. Any such opportunity in a line of business in which Boundless or an affiliate has, or can reasonably be expected to have an interest, must be disclosed to Corporate Compliance Officer and made available to Boundless.
4. No director, officer or employee shall accept gifts from any person, firm or corporation doing business with Boundless under any circumstances from which it could be reasonably inferred that the purpose of the gift could be to influence the director, officer or employee in the conduct of Boundless transactions with the donor. A gift includes anything of value that is transferred to another for which no specific service or compensation is expected or received. This policy does not preclude business or seasonal gifts of nominal value. It is also permissible for a director, officer or employee to give or receive entertainment of moderate value, assuming a legitimate business purpose is being served. However, it is the responsibility of every director, officer and employee to avoid even the appearance of impropriety. If there is any doubt about whether a gift is of nominal value or whether a particular entertainment activity complies with this policy, a director or executive officer should contact the Corporate Compliance Officer for guidance and any other officer or employee should contact the senior manager in charge of his/her business unit or department for guidance.
5. No director, officer or employee shall, either directly or indirectly, invest in (i) any real property in which he knows that Boundless or any affiliate has, or is considering any investment or a tenancy, or (ii) any real property, the value of which may be affected by any action of Boundless of which he has special knowledge.
6. No director, officer or employee shall purchase stocks, bonds, or other investment interests or securities where such purchase is based on information obtained by reason of his official position in Boundless, unless he shall have first secured permission to make such purchase from the acting chief executive officer.
7. Any director, officer or employee concerned with investment or acquisition activities, who has any investment, either directly or indirectly, in any corporation or business enterprise which is under consideration for acquisition by Boundless or any affiliate must make full disclosure of the circumstances of any investment held in such corporation or enterprise to the Corporate Compliance Officer, who shall then report such information to the Audit Committee of the Board of Directors.
8. All directors, officers and employees shall treat as confidential any information which they receive about the financial condition and business activities of Boundless, or any affiliate or any company which Boundless or any affiliate, has under consideration for acquisition.
9. All directors, officers and employees shall make timely disclosure to the Corporate Compliance Officer of any situation which creates a conflict of interest or which could give the perception of a conflict of interest (whether relating to a for-profit or non-profit entity) between Boundless and an individual's duties and responsibilities. All such situations disclosed to the Corporate Compliance Officer shall be reported to the Audit Committee of the Board of Directors.
10. All directors, officers and employees shall make timely disclosure to the Corporate Compliance Officer of any situation which creates or could give the perception of creating an indirect conflict of interest between Boundless and an individual's duties and responsibilities as a result of transactions involving such individual's family members or business associates. The disclosure should in all cases be sufficient to enable Boundless to determine the effect of any such indirect conflict of interest on the performance of the individual's duties and responsibilities. All such situations disclosed to the Corporate Compliance Officer shall be reported to the Audit Committee of the Board of Directors.
11. Prior to engaging in any activity that could result in a direct or indirect conflict of interest, all directors, officers and employees are required to review the proposed activity with the appropriate individual or group of individuals described below, and such individual or group of individuals shall make a written record of the manner in which the question is resolved and forward a copy of such record to the Corporate Compliance Officer. Directors and officers shall disclose any such activity to the Board of Directors. Employees shall disclose any such activity to their immediate supervisor, who shall promptly discuss such disclosure with the senior manager in charge of his business unit or department. In all such cases, the senior manager shall be responsible for generating the written record described above. The Corporate Compliance Officer shall forward a copy of all such written records to the Audit Committee of the Board of Directors.
12. Any waiver of these Guidelines for executive officers or directors may be made only by the Board of Directors and shall be promptly disclosed to Boundless' shareholders.
    
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GUIDELINES CONCERNING INTERACTIONS WITH GOVERNMENT OFFICIALS OR EMPLOYEES

Because Boundless and its subsidiaries often interact with public employees and officials, including regulatory bodies, all directors, officers and employees must be familiar with the requirements and restrictions imposed by the various lobbying activity and government interaction statutes of states in which Boundless does business (collectively, the "Government Interaction Statutes"). This section will briefly set out some of the main provisions of the Government Interaction Statutes which could have an effect on our business. As with any other matter, any question concerning the application of the Government Interaction Statutes to your activities should be referred to the Corporate Compliance Officer.
 
Certain Government Interaction Statutes apply to all persons. These Statutes take more or less a common sense approach, with their focus on prohibiting any improper influence on the official actions of a public official or public employee. All directors, officers and employees are forbidden from:

• Soliciting a public official or employee to use or cause to be used equipment, facilities, time, materials, labor or other public property for your private or business benefit.
• Offering or giving a public official or employee or one of their family members any thing of value for the purpose of influencing official action.
• Making any false statement or misrepresentation of facts to a member of the legislative or executive branch.
• Causing a document containing a false statement to be received by a member of the legislative or executive branch.

These Guidelines are not intended to limit an individual's right of free speech and political activity. Boundless employees are encouraged to take part in the political process as they see fit, but always be aware that certain activities may subject you to compliance with the Government Interaction Statutes. Questions concerning application of the Government Interaction Statutes to certain circumstances should be referred to the Corporate Compliance Officer.

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GUIDELINES CONCERNING PAYMENTS TO GOVERNMENT OFFICIALS OR EMPLOYEES

This point should be obvious from the preceding discussion concerning interactions with government officials or employees, but it is so important as to be worth restating here. Payments of corporate, subsidiary or affiliate, or personal funds, or anything of value to a government official or employee of a political party or candidate for the purpose of obtaining or retaining business for Boundless, or obtaining favorable governmental action, or to direct business to any other person are strictly prohibited. Indirect payments of this kind through a third person, such as a sales representative, distributor or consultant are also prohibited. Moreover, the Foreign Corrupt Practices Act prohibits such payments by Boundless and its subsidiaries to government officials outside the United States even if the payment would be legal under the laws of the country where it is made. That Act also prohibits taking any action to assist or further any payments by third persons, even if not authorized, where there is "reason to know" that the payment will be used for any such purpose.

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GUIDELINES CONCERNING EMPLOYEE RELATIONSHIPS

Sound relationships among Boundless employees are essential to achieving and maintaining productivity and a high level of business conduct. Basic to these relationships is Boundless' recognition of the personal value of every employee. Boundless pledges that every employee will be treated and judged as an individual, on the basis of qualifications to perform jobs, without regard to race, color, religion, sex (including condition of pregnancy), age, national origin, veteran' s status, or status as qualified individual with a disability.

Likewise, Boundless is committed to providing a work environment in which employees are free from sexual harassment. As such, the following specific policy regarding sexual harassment has been adopted:

• It is in violation of Boundless policy for any employee or supervisor, male or female, to sexually harass another employee or supervisor.
• It is also a violation of Boundless policy for a non-employee who does business with this company to sexually harass an employee, as well as for an employee to sexually harass a non-employee who does business with Boundless.

For purposes of this policy, sexual harassment includes, but is not limited to, the following:

1. Making unwelcome sexual advances or requests for sexual favors a condition of an employee's continued employment;
2. Making other verbal or physical conduct of a sexual nature a condition of an employee's continued employment;
3. Making submission to or rejection of such conduct the basis for employment decisions affecting the employee, i.e., promotion, demotion, transfer, etc.; or
4. Behavior that has the purpose or effect of creating an intimidating, hostile or offensive working environment.

These guidelines supplement and should be read in conjunction with, but do not replace, Boundless' existing Policy on Sexual Harassment.

Boundless views sexual harassment as a very serious matter. Any employee or supervisor who is found, after appropriate investigation, to be guilty of sexual harassment will be disciplined or discharged, depending on the circumstances involved.

Of course, Boundless cannot respond to sexual harassment matters that are not brought to its attention. Any employee or supervisor who believes he or she has been subject to sexual harassment should report the alleged act as soon as possible to either his or her immediate supervisor, the Corporate Compliance Officer or the acting chief executive officer. An investigation of all complaints will be undertaken immediately.

All complaints will be held in confidence to the extent possible and at no time will an employee be retaliated against for reporting violations of this policy.

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GUIDELINES FOR PROTECTING BOUNDLESS ASSETS

Boundless has many valued assets, including its employees, physical property, proprietary trade secrets and confidential information. Protecting these assets against loss, theft and misuse is everyone's responsibility. These guidelines supplement and should be read in conjunction with, but do not replace, Boundless' Policy on Information Security. These guidelines and the Policy on Information Security are not intended to hinder any employee in the performance of assigned duties, but rather to ensure that employees may continue to rely on the availability of physical resources and information assets necessary in their assignments.

Boundless assets must be used for proper purposes during and following employment with the company. Improper use includes unauthorized personal appropriation or use of Boundless assets, data or resources, including computer equipment, software and data.

Any individual aware of the loss or misuse of assets should report it to the appropriate supervisors. Supervisors receiving such reports will handle them in a careful and thorough manner. Investigations will be conducted confidentially and in a way that will avoid recrimination. If the violation potentially involves stolen assets or fraud, it should also be reported to the Corporate Compliance Officer.

Boundless' assets, however, are not limited to physical property. Each employee has access to intangible assets belonging to Boundless, which consists of intellectual property, such as trademarks and copyrights, and proprietary information and trade secrets, such as confidential data, computer programs, designs, business expertise and unsecured business opportunities. Employees must protect these intangible assets as carefully as the company's physical property.

Boundless' information has economic value. The company has developed products, processes, services and business practices over many years at considerable expense. Because of this effort, Boundless now possesses considerable confidential information. Unauthorized disclosure of this information could destroy its value to the company and give unfair advantage to others.

To ensure confidentiality of Boundless information, employees must adhere to the following principles in addition to the specific policies set forth in the Policy on Information Security:

1. Employees must not disclose any confidential information, either during or after employment, except to people authorized by Boundless and bound by confidentiality to the company. Confidential Information means information that (i) is disclosed to or known by an employee as a consequence of employment with Boundless, (ii) is not generally known outside the employment and (iii) relates to Boundless' business. The term "confidential information" is intended to include Boundless' trade secrets as well as information relating to products, processes or ideas developed for or used by Boundless.
2. Similar restrictions, usually spelled out in contracts, apply to information obtained from Boundless' customers and suppliers. Boundless' customers and suppliers have placed their trust in Boundless in revealing their confidential information, and Boundless employees must comply with these restrictions.
   
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INFORMATION TECHNOLOGY GUIDELINES

Computer systems are an important tool of Boundless' business, and employees are expected to avoid misuse of the Company's computers and software by:

• Installing only software approved/purchased by Boundless for which a license is maintained.
• Never copying software or related documentation.
• Reporting misuse of software or related documentation to the Corporate Compliance Officer.

Employees with Internet access should not:

• Upload/download files except for work-related reasons.
• Represent Boundless in on-line correspondence or post information about Boundless unless specifically authorized.
• Post threatening or racially, ethically or sexually offensive messages.
• Attempt unauthorized access to any computer or communications systems.
• Access pornographic or sexually explicit materials in any way.

All files, e-mail or voice-mail messages, disks, desks, work or storage areas, mail, telephones, faxes, copiers, printers, etc. are not private but are subject to monitoring and search at any time by authorized Company personnel.

These guidelines supplement and should be read in conjunction with the Company's Policy on Information Security and Electronic Communications Policy.

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GUIDELINES FOR TRADING IN SECURITIES

It is generally illegal for any person, either personally or on behalf of others, to trade in securities on the basis of material, nonpublic information. It is also generally illegal to communicate (or "tip") material, nonpublic information to others who may trade in securities on the basis of that information. These illegal activities are commonly referred to as "insider trading". Penalties for insider trading violations include imprisonment for up to 10 years, civil fines of up to three times the profit gained or the loss avoided by trading, and criminal fines of up to $1 million. There also may be liability to those damaged by the trading. A company whose employee violates the insider trading prohibitions may be liable for a civil fine of up to the greater of $1 million or three times the profit gained or the loss avoided as a result of the employee's insider trading violation.

A. General Statement

It is Boundless' policy that no director, officer or employee are prohibited from trading or tipping others who may trade in the securities of another company if you learn material, nonpublic information about the other company in connection with your employment or position at Boundless.

What information is material? All information that a reasonable investor would consider important in deciding whether to buy, sell or hold securities is considered material. Information that is likely to affect the price of a company's securities is almost always material. Examples of some types of possible material information are:

• significant safety or environmental issues or claims
• possible strategic partnerships to explore for and/or to market production
• important exploration and/or production developments
• financial results for the quarter or the year
• financial forecasts and budgets
• possible mergers, acquisitions, joint ventures and other purchases and sales of companies, or investments in companies
• significant asset acquisitions or divestitures
• changes in supplier arrangements and relationships
• changes in relationships with significant customers or partners
• the gain or loss of important contracts
• major financing developments
• major personnel changes
• major patent developments
• major litigation developments
• changes in dividends

What is nonpublic information? Information is considered to be nonpublic unless it has been disclosed effectively to the public. Examples of public disclosure include public filings with the Securities and Exchange Commission and the Company's press releases. For information to be considered public, it must not only be disclosed publicly, but adequate time must have passed for the market as a whole to assess the information. Arguably the most risky time to trade in Boundless' securities is shortly in advance of public release of important financial information or other important news, while the least risky time normally is the period shortly following the release and publication of such information (unless, of course, you are aware of other material information that has not been publicized). Even after the release of such information, sufficient time must have elapsed to enable the information to be assessed by the market as a whole. Although timing may vary depending upon the circumstances, for purposes of this Policy, information is not considered public until the third trading day after Boundless publicly discloses it. Therefore, any director, officer or employee that possesses material, nonpublic information about another company, shall wait until the third business day after the information has been publicly released before trading or recommending that others trade in the securities of such other company, as the case may be.

What transactions are prohibited? When you know material, nonpublic information about any company, then you, your spouse and people living in your house generally are prohibited from three activities:

• trading in that company's securities (including trading by or through that company's 401(k) or other employee benefit plans),
• having others trade for you in that company's securities, and
• disclosing the information to anyone else who then might trade.

You, anyone acting on your behalf, and anyone who learns the information directly or indirectly from you (including your spouse and members of your household) are prohibited from trading. The prohibition continues whenever and for as long as you know material, nonpublic information about the company.


B. Unauthorized Disclosure

As previously discussed, the disclosure of material, nonpublic information to others can lead to significant legal difficulties, fines and punishment. You should not discuss material, nonpublic information about the Company or its subsidiaries with anyone, including other employees, except as required in the performance of your regular duties on a need-to-know basis. However, if you become aware of information about Boundless that is material or may become material, you should promptly communicate the information to your supervisor and request that the supervisor communicate the information directly to the Company's General Counsel, Chief Executive Officer and Chief Financial Officer.

It is important that only a few representatives of the Company discuss the Company and its subsidiaries with the news media, securities analysis and investors. Inquiries about Boundless from these people should be referred to Boundless' Chief Financial Officer or Chief Executive Officer.

C. Confidential Information

As discussed previously in these Guidelines, Boundless has strict policies to safeguard the confidentiality of its internal, proprietary information. These include identifying, marking and safeguarding confidential information and employee confidentiality agreements. You should comply with these policies at all times.


Employees are encouraged to ask questions and seek any follow-up information that they may require about Boundless' policy for trading in securities. Please direct all questions to the Office of the Chief Financial Officer at 631-962-1470.

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ANTITRUST COMPLIANCE GUIDELINES

Compliance with the antitrust laws is a fundamental part of Boundless' overall policy to comply fully with all laws applicable to its operations. This section of these Guidelines sets forth Boundless' policies concerning antitrust compliance. When there is any doubt about any course of action that relates to these policies, Boundless' Office of General Counsel or the Corporate Compliance Officer should be consulted.

The antitrust laws, both at the federal and state level, have a pervasive influence and effect on virtually all phases of Boundless' operations. The severe consequences for companies and individuals who fail to comply with them make the antitrust laws especially important.

Simply stated, Boundless' policy is to comply fully and completely with all antitrust laws applicable to our operations. Unfortunately, in many criminal prosecutions and civil lawsuits arising under the antitrust laws, circumstantial evidence is the basis upon which antitrust liability is found. Therefore, Boundless wants to ensure that it avoids even the appearance of anti-competitive conduct.

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GOVERNANCE CONCERNING AFFILIATE TRANSACTIONS

To the extent a particular situation is not specifically addressed by these Guidelines, all officers and employees are expected to use their best judgment to conduct each affiliate transaction in a manner that is fair and reasonable to all interested parties.

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SUMMARY

It is not feasible to describe in these Business Conduct Guidelines every type of business practice that may raise problems under any of the areas that are discussed. Management is committed to enforcing these Guidelines, and expects all directors, officers and employees to abide by them. In the event of any questions about particular situations, these Guidelines provide a clear mechanism for individuals to find out how the company should react to a certain situation or how these Guidelines will be interpreted. Boundless is only as good as its people make it, and the ultimate responsibility for compliance with these Guidelines rests with you.

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