THE OGILVY GROUP, INC.

STATEMENT OF BUSINESS ETHICS

Purpose
This policy is written to reaffirm the position taken by The Ogilvy Group, Inc. (the "Company") since its founding that, in
its business dealings, it will be governed by the highest level of business ethics. By the same token, those individuals who
in a sense represent and are identified with the Company even when not engaged in Company business, namely the
Directors, Officers and Professional employees, must be governed by similar ethical standards in their own business
relationships with the Company and with outsiders.
By strict adherence to these policies, the Company, the companies associated with it and the Ogilvy people have, over the
years, earned the reputation of being an honest group with which to do business. This is a valuable asset and must be
preserved.
Scope
All Director, Officers and Professional employees of The Ogilvy Group, Inc. and its subsidiaries.
Statement of Policy
Each Director, Officer and Professional employee, when representing the Company, and in all actions taken on behalf of
the Company, and in his or her business and professional relationships with the Company, Governmental agencies and
other persons, shall act in accordance with the highest level of business ethics and in complete compliance with, and
respect for, the law.
Procedures And Implementation
Without limiting the scope of this general precept, each Director, Officer and Professional employee shall act to ensure
that:
a)

All contracts and agreements to which the Company and its subsidiaries are parties, are carried out and performed
in accordance with the spirit as well as the letter of their terms and conditions;

b)

All services sold are delivered as agreed, and deficiencies or omissions, if any, are corrected promptly to the parties'
mutual satisfaction.

c)

Any conflicts or potential conflicts of interest are fully and promptly disclosed to his / her supervisors (see Policy
on "Conflicts of Interest" for further guidance);

d)

The Company and its subsidiaries do not conspire to fix prices, restrain trade, or otherwise violate the antitrust
laws;

e)

The Company and its subsidiaries do not make any improper, disguised, or questionable payments of any kind, or
prepare any accounting records or financial report which incorporate or reflect false or misleading information;

f)

No corporate funds or assets are contributed, directly or indirectly, in connection with political campaigns at any
governmental level, either in the United States or in other countries, except that lawful contributions may be made
if approved in advance by the Board of Directors of the Ogilvy Group, Inc. (This is intended to relate solely to the
use of corporate funds and is not intended to discourage employees from making personal contributions to
candidates or political parties of their choice);

g)

Corporate funds may be used for lawful legislative activities on matters of interest to The Ogilvy Group, including
expression of The Ogilvy Group's view in legislative forums by employees or trade associations or lawful
contributions to committees or organizations in support of or in opposition to public issues, but in each case only
with the prior approval of the Chairman of The Ogilvy Group, Inc.