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Table of Contents

Message from the Chief Executive Officer .................................................................. 3

Message from the Ethics and Compliance Officer ..................................................... 4

Living up to Our Code ................................................................................................... 5

How does the Code Apply to Me? ........................................................................................................... 5 The Headline Test .................................................................................................................................... 5 Special Requirements Applicable to the Chief Executive Officer, President, and Chief Financial

Officer ................................................................................................................................................. 6 Special Requirements Applicable to the Board of Directors .................................................................... 6 Special Requirements Applicable to Managers ....................................................................................... 7

Our Company ................................................................................................................ 8

Sexual Harassment, Non-Discrimination, and Non-Aggression .............................................................. 8 Intellectual Property ................................................................................................................................. 8 Confidential Information ........................................................................................................................... 8 Corporate Disclosures ............................................................................................................................. 9 Personal Information .............................................................................................................................. 10 BFDX's Assets ....................................................................................................................................... 10 Appropriate Use of Information Systems ............................................................................................... 10 Accurate Books and Records ................................................................................................................ 10 Record Retention ................................................................................................................................... 11

Our Marketplace and Community .............................................................................. 12

Promoting Our Products ........................................................................................................................ 12 Gifts and Entertainment; Ethical Purchasing ......................................................................................... 12 Business Intelligence ............................................................................................................................. 13 Conflicts of Interest ................................................................................................................................ 13 Organizational Conflicts of Interest ........................................................................................................ 14 Insider Trading ....................................................................................................................................... 15 Political Contributions ............................................................................................................................ 15

Our Regulatory Environment ..................................................................................... 16

Complying with Federal Regulations ..................................................................................................... 16 Antibribery and Anticorruption ............................................................................................................... 16 Antitrust and Unfair Competition ............................................................................................................ 16 International Business Laws .................................................................................................................. 17 International Boycotts and Restrictive Trade Practices ......................................................................... 17 Bidding, Negotiation, and Performance of Government Contracts ....................................................... 17 Government Requests and Investigations ............................................................................................. 18 Prompt Reporting of Environmental Hazards ........................................................................................ 18

Resources .................................................................................................................... 19

No Retaliation ........................................................................................................................................ 19

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Message from the Chief Executive Officer

Here at BFDX, we find solutions to difficult problems, and we’re dedicated to doing

so in a way that upholds the highest standards of personal integrity and business

conduct. These standards are based on upholding the law everywhere we do

business, taking individual and collective accountability for our behavior, and

treating our customers, our partners and each other with courtesy and respect.

Our Code of Business Conduct defines our individual and corporate responsibilities

and embodies our shared values. This document is critically important to the success

of BFDX because it sets the tone and standards for our growing company. We

expect you to read and take advantage of the Code because it will guide you in your understanding of how

we can most effectively work as a team.

The manner in which we conduct ourselves defines who we are and how others perceive us. So please

join me in committing to each other and to our customers in making BFDX a leader in ethical behavior

and a great place to work.

Kirk Ririe

Chief Executive Officer

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Message from the Ethics and Compliance

Officer

Our Code of Business Conduct defines and reflects our commitment to ethical

business practices and compliance with the law. While the Code is an important

part of our new ethics and compliance program, it’s not the most important part.

You are. Policies are meaningless without action. Each BFDX employee is

responsible for understanding the Code, as well as the policies, procedures and

applicable laws and regulations that apply to your work. And each of us is responsible for living up to the

letter and spirit of our Code.

No code of conduct can anticipate every situation we might face as a company. Instead, the Code is

intended as a resource to guide us in exercising good judgment, asking questions when uncertain, and

speaking up when needed. I’m here to help you understand your obligations, to make sure that BFDX

responds appropriately and with a consistent process to complaints regarding Code violations, and to help

BFDX promote its culture of integrity. Please speak with me at any time regarding Code questions,

violations concerns, or any ideas for helping to bring our Code to life.

Kristin Rabkin

Ethics and Compliance Officer

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Living up to Our Code

How does the Code Apply to Me?

The Code of Conduct applies to all employees, officers, and directors of BFDX. We also expect our

suppliers and those who represent BFDX or act on our behalf, such as agents, consultants, distributors,

and independent contractors, to live up to the principles of the Code. Each of us is responsible for:

Obeying the law.

Knowing and following our policies and procedures.

Being honest and telling the truth.

Treating others with respect.

Promptly reporting concerns about possible violations of this Code or applicable laws and

regulations.

Cooperating fully with investigations.

Never compromising our own good name or the company's.

The Headline Test

The Headline Test is designed to make sure we appropriately consider the soundness and impact of our

decisions and actions on behalf of BFDX. The Headline Test is as follows: “Before I act or make a

decision on behalf of BFDX, I should consider how it would look if it were disclosed on the front page of

the newspaper (or on Facebook, YouTube, Twitter, etc.).” The below chart is another way to envision the

Headline Test and use it in your everyday decision-making process:

NO UNSURE YES

1 Is it legal?

Don't do it. Consult with your supervisor or the Ethics and Compliance Officer.

Proceed to next question

2 Is it consistent with our Code of Conduct and BFDX Policy?

Proceed to next question

3 Would it be okay as a headline?

Passed the Headline Test!

Most of the time, this Code, our policies and your good judgment will provide sufficient guidance. In

difficult situations, use the Headline Test and consult with your resources (see the “Resources” section).

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Special Requirements Applicable to the Chief Executive Officer, President,

and Chief Financial Officer

We expect honest and ethical conduct from all of our employees here at BFDX, no matter what their job

title. However, due to their increased responsibilities, the Chief Executive Officer, President, and Chief

Financial Officer are held to an additional standard of conduct. These officers have important roles in

BFDX's governance, financial reporting and legal compliance that we expect them to fulfill with integrity

at all times. All of the provisions of this Code apply to BFDX’s senior officers; in addition, BFDX's

senior officers are obligated to:

Set a “tone at the top” by acting with honesty and integrity in accordance with this Code,

including avoiding conflicts of interest.

Promote a culture throughout BFDX in which all employees are encouraged to act with integrity.

Take all steps necessary to promote compliance with applicable governmental laws, rules and

regulations.

Take all steps necessary to promote prompt internal reporting of violations of this Code to

appropriate employees, and to promote accountability for adherence to this Code.

Special Requirements Applicable to the Board of Directors

Directors must act in good faith, with due care, and on an informed basis so that they can make decisions

which they reasonably and honestly believe to be in the best interests of BFDX and its stockholders. In

addition, Directors owe a duty of loyalty to the Company. This duty of loyalty mandates that the best

interest of BFDX take precedence over any interest possessed by the Director. Each Director must

promptly advise the Chairman of the Board and, if the Board has appointed a Lead Independent Director,

the Lead Independent Director, of any actual or potential conflict of interest of which such Director is

aware on any issue under discussion or being voted upon by the Board. Some of the more common

conflicts which Directors must avoid are listed below:

Relationship of BFDX with Third Parties. Directors may not receive a personal benefit from a

person or firm which is seeking to do business or to retain business with BFDX. A director shall

recuse him- or herself from any BFDX Board decision involving another firm or company with

which the director is affiliated.

Compensation from Non-BFDX Sources. Directors may not accept compensation (in any form)

for services performed for the Company from any source other than the Company.

Gifts. Directors may not offer, give or receive gifts from persons or entities who deal with BFDX

in those cases where any such gift is being made in order to influence the Directors’ actions as

members of the Board, or where acceptance of the gifts could create the appearance of a conflict

of interest.

Personal Use of Company Assets. Directors may not use Company assets, labor or information

for personal use unless approved by the Board or as part of a compensation or expense

reimbursement program available to all Directors.

Corporate Opportunities. Directors are prohibited from: (i) taking for themselves or their

companies opportunities that are discovered through the use of BFDX property, BFDX

information, or their position as a director; (ii) using the BFDX’s property or information for

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personal gain; or (iii) competing with BFDX for business opportunities unless BFDX’s

disinterested directors determine that BFDX will not pursue such opportunity.

Fair Dealing. Directors must deal fairly, and must oversee fair dealing by employees and

officers, with the Company’s customers, suppliers, competitors, and employees.

Communication. Directors must communicate any suspected violations of this Code promptly to

the Chairman of the Board or the General Counsel.

Special Requirements Applicable to Managers

Managers also have special obligations and responsibilities for ensuring compliance with the Code.

Employees look to managers to be role models for the highest ethical standards and sustainers of a culture

of honesty, integrity and respect. Managers at all levels within BFDX are obligated to:

Be a resource for employees. Ensure that employees are aware of, understand, and know how to

apply BFDX’s policies and the Code in their daily work.

Seek assistance when unsure of the best response to a situation. There are many resources

available, including other managers, the Ethics and Compliance Officer, HR, and the Legal

Department.

Be proactive. Take actions to prevent and identify misconduct, and report situations that might

impact the ability of employees to act ethically on behalf of BFDX.

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Our Company

Sexual Harassment, Non-Discrimination, and Non-Aggression

Sexual harassment is a violation of federal law under Title VII of the Civil Rights Act of 1964, as

amended, and is also against state law. BFDX does not tolerate or permit sexual harassment in any form.

BFDX also does not tolerate discrimination because of race, color, sex, sexual orientation, pregnancy,

childbirth or pregnancy-related conditions, age, religion, national origin, disability, veteran status, or any

other unlawful bases.

BFDX prohibits intimidation, harassment, and violent behavior in the workplace. Furthermore, weapons

of any kind (knives, hunting knives, rifles, guns, etc.) are strictly prohibited on BFDX property, including

in parking lots where employees park their vehicles.

Please refer to the Employee Manual or speak with HR for more information.

Intellectual Property

We’re a company built upon innovation, and protecting our intellectual property is essential to

maintaining our competitive advantage. Intellectual property includes ideas, strategies, patents,

copyrights, inventions, trademarks, and trade secrets. Examples of intellectual property are non-public

scientific and technical knowledge, know-how and experience; trade secrets; patents; trademarks;

copyrights; research and technical data; results of clinical trials; and manufacturing techniques. All

research and intellectual property generated in the course of employment at BFDX are the property of

BFDX and must be maintained in accordance with BFDX policy. To that end, lab scientists are required

to follow BFDX notebook procedures, and development teams in the Software and Engineering

Departments are required to protect their work product using source code control and similar tools. If you

suspect that any intellectual property has been disclosed inappropriately, stolen, or lost, report it

immediately to the Ethics and Compliance Officer.

Confidential Information

Confidential information is one of our most important assets. If you have received, or have access to,

confidential information, you must take every precaution to keep this information confidential.

Confidential information includes non-public business, marketing and service plans; financial

information; product architecture; source and object codes; engineering ideas; designs; databases;

customer lists; pricing strategies; employee data; personally identifiable information pertaining to our

employees, customers or other individuals (including, for example, names, addresses, telephone numbers

and social security numbers); and similar types of information provided to us by our customers, vendors

and partners.

Except when disclosure is authorized or legally mandated, you must not share confidential information of

BFDX, or its suppliers or customers, with third parties, or with others within BFDX, who have no

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legitimate business purpose for receiving that information. Unauthorized posting or discussion of any

information concerning our business, information or prospects on the Internet is also prohibited.

Corporate Disclosures

As discussed above, maintaining the confidentiality of material non-public information until publicly

disclosed is essential for both legal and practical reasons. BFDX prohibits employees from disclosing

material, non-public company matters or developments to persons or sources outside the Company

(including family members, relatives or friends), except as permitted herein.

It is impossible to provide a complete definition of what constitutes “material” information. The

following is a list of information that may be considered material: (i) financial results of the Company,

including earnings or operating results; (ii) significant litigation or disputes; (iii) entry into or termination

of a significant contract; (iv) acquisition, divestiture, merger or consolidation proposals or agreements; (v)

major changes in corporate structure, changes in control or amendments to bylaws; (vi) significant

changes in Company personnel; (vii) significant expansion or reduction of operations; (viii) significant

new products, services or marketing plans; (ix) write-ups or write-downs of assets or changes in

accounting methods; (x) costs associated with exit or disposal activities; (xi) actual or projected changes

in industry circumstances or competitive conditions that could significantly affect the Company’s

revenues, earnings, financial position or future prospects; (xii) information that could be very useful to a

competitor, to someone negotiating with BFDX, or to someone in litigation with BFDX; (xiii)

information related to senior management statements on strategy, the state of current business, or the

business outlook.

The foregoing list is merely illustrative and is not exhaustive. Other types of information may be material

at any particular time depending on the circumstances. In the event there is any question regarding the

materiality of information, it is best to assume the information is material. The Company’s General

Counsel (Eric Gorrell, x803) is available to provide guidance on whether information may be material.

Only the following authorized spokespersons may discuss material information with the media, analysts,

and members of the investment community: Kirk Ririe, Randy Rasmussen, Carl Wittwer, Eric Gorrell,

and Rachel Jones. Other employees may be designated by the above-authorized spokespersons for a

limited, specific communication only. Following the occurrence of the limited, specific communication,

the employee's designation shall expire. Employees and company representatives (other than the above

authorized spokespersons) receiving any inquiries from the media or the investment community shall not

respond to such inquiries other than to refer the inquirer to one of the above-listed employees.

It is not advisable to respond to market rumors (to confirm or deny) and the most appropriate response is

“it is BFDX’s longstanding policy not to respond to market rumors.” The one exception to this rule is

when the rumor is both: a) long-standing; and b) extremely damaging to the Company. All responses to

such queries, and all determinations on how to respond, should be made only by a senior officer of the

Company or by an authorized spokesperson. Non-authorized personnel should forward any such queries

to the General Counsel or a designated media/investor spokesperson for handling. Rumors about BFDX

that are posted on Internet chat rooms or bulletin boards are covered by this policy. Employees should

not engage in postings of information or opinion to Internet chat rooms or bulletin boards related to

BFDX under any circumstances.

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Nothing in this policy should be construed as prohibiting an employee from complying with local, state

and federal laws and regulations, including those dealing with reporting illegal activities or emergencies,

to appropriate non-company agencies.

Personal Information

If you handle personal information as part of your work at or for BFDX, you must:

Collect, retain, and disclose personal information only when there is a legitimate business need

and always in accordance with applicable laws.

Guard the confidentiality of all personal information to which you have access.

Only share personal information if it is permitted by law and internal policy, and then only with

people who have a legitimate need to know, and only if you are reasonably assured that they will

appropriately protect the information.

Destroy personal information once its purpose has been fulfilled and in accordance with BFDX’s

records retention policy.

BFDX's Assets

Each of us is charged with the duty to preserve BFDX’s assets, property, and equipment, and any

equipment that has been furnished by our customers, suppliers, or contracting partners. In practice, this

means that you do not use BFDX assets (computers, phones, copiers, printers, postage machines, etc.) for

personal purposes, or allow non-BFDX employees to use BFDX assets, without first obtaining

appropriate approvals.

Appropriate Use of Information Systems

BFDX maintains information systems, including email, voicemail, BFDX's intranet, and access to the

Internet through BFDX's network. Any communication you send through these systems should be

respectful, courteous, and appropriate to our professional environment. Never use BFDX's information

systems for any illegal or illicit activity, any activity that violates BFDX policy, or any activity which

would damage BFDX's reputation or create liability.

Accurate Books and Records

Our books, records and financial statements must be honest, accurate, objective, complete and timely in

order to ensure we make sound business decisions and truthfully reflect our business. In order to achieve

this, you must:

Create business records and financial statements that accurately reflect the truth of the underlying

transaction or event and that comply with our policies and Generally Accepted Accounting

Principles.

Only sign, approve, or transmit financial transactions, financial statements, records and

information if you believe they are truthful and accurate and you are authorized to do so.

Provide timely and candid forecasts and assessments to management, without omitting or

misrepresenting relevant or material information.

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Remember that memos, email, voice mail, social network postings and instant messaging may all

be considered to be business records. Avoid exaggeration, derogatory language and other

expressions that could be taken out of context.

Record Retention

BFDX business records should be retained or destroyed according to federal, state, and local laws and

regulations; applicable licensing, accreditation, and contractual requirements; and applicable BFDX

policy. Speak with your manager about the retention policies applicable to your department's records.

Never destroy, change, or conceal any record if you have been instructed to keep it, or if you know or

think it is possible the record may be involved in an investigation or litigation.

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Our Marketplace and Community

Promoting Our Products

Our commitment to honesty and integrity includes our marketing and promotional activities. Product

marketing for regulated products must be supported by scientific evidence and consistent with all

applicable laws, regulations and marketing codes. As you interact with current or potential customers,

you must:

Promote our products in an ethical and truthful fashion.

Use only promotional materials and other product information that have been approved through

BFDX’s internal review process.

Only publish information about our products that is consistent with BFDX standards and

procedures.

Never use false or misleading information or make any other form of misrepresentation.

Never promote products for uses other than their approved label uses.

Never provide training materials that include off-label uses.

Never promote off-label use with healthcare professionals.

Ensure that grants are for appropriate medical education only, and not illegal inducements to

promote off-label product uses.

Ensure that products are exported in accordance with Department of Commerce Export

Administration Regulations (EAR) Department of State International Traffic in Arms Regulations

(ITAR), as applicable.

Gifts and Entertainment; Ethical Purchasing

The sale of BFDX products and services should always be free from even the inference or perception that

favorable treatment was sought, received or given on the basis of the furnishing or receipt of gifts,

entertainment, favors, hospitality or other gratuities. Similarly, purchase of supplies, materials, and

services from vendors, suppliers, and subcontractors must be accomplished in a manner that preserves the

integrity of a procurement process based on quality and performance. BFDX prohibits offering, giving,

soliciting or receiving any form of bribe or kickback from business partners (customers, suppliers,

collaborators, etc.). Further, depending on the type of business partner, additional restrictions or

disclosures may apply:

The Government. Federal, state, and local government agencies have regulations concerning

acceptance by their employees of entertainment, meals, and gifts from firms and persons with

whom the departments and agencies do business or over whom they have regulatory authority.

Do not give, or offer to give, to such government employees any entertainment, meal, gift, loan,

guarantee or payment. However, promotional items with a value below $25 (e.g., caps, models, t-

shirts, pens and similar items), and items with an intrinsic lack of value (e.g., greeting cards), are

permissible. You may entertain relatives or friends employed by government agencies. But it

should be clear that the entertainment is not related to the business of BFDX, and no such

expenditures are reimbursable by BFDX.

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Physicians and Teaching Hospitals. The new Physician Payments Sunshine Act requires

BFDX, as a manufacturer of medical devices eligible for reimbursement under Medicare,

Medicaid or the Children’s Health Insurance Program, to annually disclose to Health and Human

Services all payments to physicians and teaching hospitals. Payments requiring disclosure include

all cash or inkind transfers (compensation, food, entertainment, gifts, travel, consulting fees,

honoraria, research funding or grants, education or conference funding, stocks or stock options,

ownership or investment interest, royalties or licenses, charitable contributions, and any other

transfer of value). The law exempts payments less than $10 until the aggregate annual total per

recipient reaches $100, at which point all payments (retroactively) must be disclosed. Beginning

January 1, 2013, therefore, employees must provide the Ethics and Compliance Officer (through

their applicable VP) with a quarterly report of all covered payments made, no matter how small

(if such payments have been made that quarter).

All Other Business Partners. Furnishing meals, refreshments and entertainment in conjunction

with business discussions is a commonly accepted business practice, and you are generally

permitted to engage in this practice. However, the furnishing of meals, refreshments, gifts, or

entertainment should not violate the standards of conduct of the recipient's organization.

Employees who make and supervisors who approve expenditures for meals, refreshments or

entertainment must use discretion and care to ensure that such expenditures are in the proper

course of business and could not reasonably be construed as bribes or improper inducements.

Receipt of Entertainment, Gifts, or Loans. You may accept meals, refreshments or entertainment of

nominal value in connection with business discussions. The term “nominal” is not defined in terms of a

specific dollar limitation, but rather a common sense determination should dictate what one would

consider lavish, extravagant or frequent. You are personally responsible for ensuring that your

acceptance of such meals, refreshments or entertainment is proper and cannot reasonably be construed as

an attempt by the offering party to secure favorable treatment.

Ethical Purchasing. If you purchase products or services on behalf of BFDX, you should be especially

sensitive to the above obligations and restrictions. In addition, as an BFDX purchaser you must enter into

contracts or purchasing arrangements with vendors based on the fact that such vendors are the most

qualified source of product or service for BFDX; if you have a preexisting affiliation with a vendor, any

proposed purchasing arrangement must first be approved by your immediate supervisor. (See the below

“Conflicts of Interest” section for more information.)

Business Intelligence

BFDX only uses lawful and ethical means to gather business intelligence. As a part of our team, you

must:

Never use or ask any third party to use any form of misrepresentation, deception, theft, spying or

bribery to gather competitive intelligence.

Never request or receive confidential information of other companies from their current or former

employees.

Conflicts of Interest

Each of us must ensure that our decisions are made in the best interests of BFDX.

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Avoid situations that would impair your ability to make objective business decisions on behalf of

BFDX.

Discuss with your supervisor or the Ethics and Compliance Officer any situation that could be

perceived as a potential conflict of interest.

Proactively address situations that may put your interests or those of a family member in potential

conflict with BFDX.

Here are some ways a conflict of interest could arise:

Ownership by you or a family member of an interest in a company that is a competitor, vendor,

supplier, customer, or partner of BFDX.

Being employed by, serving on the board or as an officer of, or acting as a consultant or providing

services to, a customer, vendor, supplier, competitor, or partner of BFDX or having a family

member who has such a relationship.

Placement of business with a firm owned or controlled by, or that will benefit, an employee or

family member.

Acceptance by you or a family member of gifts greater than token or nominal value or acceptance

of payments, personal discounts or services from those doing or seeking to do business with

BFDX.

Using knowledge, resources, or information belonging to BFDX for personal gain.

Organizational Conflicts of Interest

In accordance with its government contracting requirements, BFDX must comply with Federal

Acquisition Regulation (“FAR”) Subpart 9.5. FAR 9.5 prescribes general rules and procedures for

identifying, evaluating, and resolving conflicts of interest within BFDX in its role as a government

contractor. While a large part of FAR 9.5 focuses on the government contracting officer’s role in

detecting and preventing organizational conflicts of interest with its contracting partners, the following

four points are important to BFDX, its employees, and its contracting partners:

An “organizational conflict of interest” means that, because of other activities or relationships

with other persons or entities, BFDX is unable, or potentially unable to render impartial

assistance or advice to the government, or BFDX’s objectivity in performing the contract work is,

or might be otherwise impaired, or BFDX has an “unfair competitive advantage” (see below). An

organizational conflict of interest exists when BFDX’s capacity (or the capacity of BFDX's

executives, directors, consultants, or subcontractors) to give impartial, technically sound advice

or objective assistance is or may be impaired or may otherwise result in a biased work product

because of any past, present or planned interest (financial or otherwise).

An “unfair competitive advantage” exists if BFDX, in competing for award of a government

contract, possesses (1) proprietary information that was obtained from a government official

without proper authorization; or (2) source selection information that is relevant to the contract

but is not available to all competitors, and such information would assist BFDX in obtaining the

contract.

The government’s goals are to prevent the existence of organizational conflicts of interest and

unfair competitive advantage in its contracting partners.

As a contracting partner of the government, the government’s goals are BFDX’s goals.

Therefore, if you have any reason to believe that an actual or potential organizational conflict of

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interest exists, or that BFDX may have an unfair competitive advantage, with regard to any of its

current or upcoming government contracts, please speak with your manager or the Ethics and

Compliance Officer.

Insider Trading

Federal laws and BFDX policy prohibit an employee from buying or selling, or advising others to buy or

sell any security (e.g., a stock or bond) of any company whose securities are publicly traded while the

employee is in possession of material information about the issuer not available to the general public. It is

also illegal and against BFDX policy to disclose (or “tip”) material, nonpublic information that has

become known to the employee while conducting BFDX business to another person who subsequently

uses that information to buy or sell any security. These restrictions apply until the information has been

publicly disclosed and adequately disseminated over a sufficient period of time so that the market has had

a chance to react. Examples of sufficient public disclosure and dissemination include public filing with

securities or regulatory authorities and issuance of press releases.

Whether information is “material”, in this context, depends upon whether it would be important to an

investor in determining whether to trade in the security. Information that may be considered material

includes: financial results, earnings and financial projections, changes in dividends, significant

acquisitions or divestitures, joint ventures and other purchases and sales of or investments in companies,

obtaining or losing important contracts, information concerning significant scientific discoveries,

important product developments, major litigation developments, and major changes in business direction.

Other information, depending upon the circumstances, may also be material.

To ensure compliance with this policy, if you desire to buy or sell any security because of any

information that you have learned in the course of BFDX business, you should not buy or sell that

security unless you are able to verify with the General Counsel that such information is either not material

or is available to the general public.

Any purchases, sales or “tips” in violation of this practice by an employee will result in disciplinary

action, up to and including termination of employment, and may result in civil or criminal sanctions.

Political Contributions

BFDX encourages the personal and financial participation of its employees in the federal, state and local

elective processes. However, BFDX does not make political contributions in support of any party or

candidate in any U.S. election, whether federal, state or local, except in accordance with the federal

BFDX Political Action Committee (“PAC”), which is described below. For this purpose, the purchase of

tickets for dinners, advertising in political program booklets, and use of BFDX's copy machines are

considered political contributions. Compensated employee activity, employee contributions reimbursed

through expense accounts, and similar donations in kind are also considered political contributions.

BFDX has established a Political Action Committee (“PAC”) and, as permitted by law, BFDX’s funds are

used to establish and administer the PAC. Employees of BFDX are asked to consider participation in the

PAC through a payroll deduction program or otherwise. All contributions are voluntary and are not a

condition of employment. For more information on BFDX’s PAC, please contact Matt Scullion (801-736-

6354 x327).

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Our Regulatory Environment

Complying with Federal Regulations

Because of the technologically advanced and sensitive nature of BFDX's products, we are subject to

oversight by many federal agencies, including the Department of Defense, the Food and Drug

Administration, the Department of State, and the Department of Commerce. BFDX is dedicated to

regulatory compliance, upholding the highest standards of quality and safety in the research,

development, manufacture, and distribution of our products.

Antibribery and Anticorruption

Employees who make and supervisors who approve expenditures for meals, gifts or entertainment must

use discretion and care to ensure that such expenditures are in the proper course of business and cannot

reasonably be construed as bribes or improper inducements. Refer to the “Gifts and Entertainment;

Ethical Purchasing” policy for details. In addition, make sure that arrangements with third parties, such as

distributors, agents, and collaborators, are formalized in a written contract detailing the services that are to

be performed and all anticipated fees. Employees must report all forms of bribery, corruption and other

behavior that could cause, or appear to cause, improper influence.

Antitrust and Unfair Competition

Generally speaking, antitrust laws of the United States prohibit agreements or actions “in restraint of

trade” - restrictive practices that may reduce competition without providing beneficial effects to

consumers. Among those agreements and activities found to be clear violations are agreements or

understandings among competitors to fix or control prices; to boycott specified suppliers or customers; to

allocate products, territories, or markets; or to limit the production or sale of products or product lines.

Such agreements are against public policy and against the policy of BFDX. As an BFDX employee:

Do not make written or oral agreements or understandings with competitors to set prices or terms,

to limit production, or to divide up customers, suppliers or markets.

Do not engage in discussions with competitors that relate to prices, terms or conditions of sales,

costs, profits, product capacity, volume, market share, sales territories or allocation of customers,

and report to the Ethics and Compliance Officer any instance in which such discussions are

initiated by other companies.

Do not agree to limit the areas in which we do research without prior authorization.

U.S. antitrust laws also apply to international operations and transactions related to imports to, or exports

from, the United States. Moreover, the international activities of BFDX could be subject to antitrust laws

of foreign nations or organizations such as the European Economic Community.

Because of the complexity of antitrust laws, it is imperative that advice be sought on any question

regarding this subject from the Ethics and Compliance Officer.

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International Business Laws

You are expected to comply with the applicable laws in all countries to which you travel and where we do

business, including laws prohibiting bribery, corruption, or the conduct of business with specific

individuals, companies, or countries. These laws include:

The U.K. Bribery Act, which prohibits a range of bribery offenses, and which is not limited to

bribery of government officials.

The Foreign Corrupt Practices Act, which prohibits directly or indirectly giving anything of value

to any foreign official, or any foreign political party, candidate or official, or international

organization to obtain or retain business or favorable treatment, and requires the maintenance of

accurate books of account, with all company transactions being properly recorded.

U.S. Embargoes, which restrict or, in some cases, prohibit companies, their subsidiaries and their

employees from doing business with certain other countries identified on a list that changes

periodically (including, for example, Cuba, Iran, North Korea, Sudan and Syria) or specific

companies or individuals.

Export Controls, which restrict travel to designated countries, or prohibit or restrict the export of

goods, services and technology to designated countries, denied persons or denied entities from the

U.S., or the re-export of US. origin goods from the country of original destination to such

designated countries, denied companies or denied entities.

International Boycotts and Restrictive Trade Practices

It is illegal to enter an agreement to refuse to deal with potential or actual customers or suppliers, or

otherwise to engage in or support restrictive international trade practices. BFDX will not engage in any

activity that reasonably could have the effect of promoting a restrictive international trade practice. Since

the mere receipt of a request to engage in such activity becomes a reportable event by law, you must

immediately seek advice from the Ethics and Compliance Officer if you receive a request that even

seemingly seeks BFDX involvement in such a restrictive trade practice.

Bidding, Negotiation, and Performance of Government Contracts

BFDX strictly observes the laws, rules, and regulations that govern acquisition of goods and services by

the government. We will compete fairly and ethically for such business opportunities. Do not attempt to

obtain government information that is procurement-sensitive or security-classified, or information

regarding competitors’ bids or proposals in circumstances where there is reason to believe the release of

such information is unauthorized.

If you are involved in the negotiation of government contracts, you must ensure that all statements,

communications, and representations are accurate and truthful. Do not submit or concur in the

submission of any claims, bids, proposals, or any other documents of any kind that are false, fictitious, or

fraudulent. Such acts are felonies which could result in criminal prosecution of BFDX and the employee

involved.

You must take care to ensure proper recording and charging of all costs to the appropriate account,

regardless of the status of the budget for that account.

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Supervisors must be careful in words and conduct to avoid placing, or seeming to place, pressure on

subordinates that could cause them to deviate from acceptable norms of conduct.

Government Requests and Investigations

Each of us is responsible for cooperating with investigations initiated by government or regulatory

authorities. First and foremost, work with Legal to respond appropriately to litigation or requests from

government or other external agencies. You must cooperate fully with all investigations and audits, and

tell the whole truth without providing misleading information or omitting information when responding.

Do not alter or destroy documents or records in response to an investigation or audit, or when an

investigation or audit is anticipated. Do not discuss an investigation unless instructed to do so by Legal.

Prompt Reporting of Environmental Hazards

BFDX values its location in the foothills of the Wasatch Mountains, and we are committed to protecting

Utah’s natural resources. Notify the Ethics and Compliance Officer immediately if you know or suspect

that an environmental hazard has occurred. Ensure that any hazardous materials are disposed of properly.

Improper disposal not only is bad for the environment and those who live near us, but could also create

regulatory or legal penalties for BFDX.

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Resources

Knowing the right thing to do is sometimes a challenge, which is why it is important to reach out to the

people who can help with questions or concerns. We must each take responsibility to improve BFDX by

promptly raising questions or concerns and reporting potential misconduct or violations of our Code of

Business Conduct or any applicable laws or regulations. In addition to your supervisor, feel free to

contact the following employees:

Kristin Rabkin, Ethics and Compliance Officer, (801) 736-6354 x476

Gina Bergman, Director of Quality Assurance, (801) 736-6354 x486

Beth Lingenfelter, Director for Regulated Products, (801) 736-6354 x407

Kim David, Facility Security Officer, (801) 736-6354 x317

No Retaliation

Trust in the ability of each one of us to report concerns is very important. Therefore, retaliation is

absolutely prohibited and will not be tolerated. If you believe you have been retaliated against for

raising a concern, reporting misconduct or assisting in an investigation, please contact the Human

Resource Manager or the Ethics and Compliance Officer.

The Code of Business Conduct is for general guidance only. The policies and procedures expressed

in the Code do not create a binding contract or any other obligation or liability on BFDX. No

person or entity should interpret the Code of Conduct as a contract for any purpose. BFDX

reserves the right to change its policies and procedures at any time for any reason without prior

notice.

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