Code of Ethics

TurboSonic Technologies, Inc. and its subsidiaries strive to maintain their reputation for integrity and a high standard of business conduct. TurboSonic Technologies, Inc. and its subsidiaries, expects all of its employees, including its principal executive officer, principal financial officer and principal accounting officer, as well as the members of its board of directors, to act in accordance with the highest standards of personal and professional integrity in all aspects of their activities, to comply with all applicable laws, rules and regulations, to deter wrongdoing and abide by other policies and procedures adopted by TurboSonic that govern the conduct of its employees and directors. This Code of Ethics is intended to supplement any other policies and procedures adopted by TurboSonic.

You agree to:

1. Engage in and promote honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships.


2. Take all reasonable measures to protect the confidentiality of non-public information about TurboSonic and its subsidiaries and their customers obtained or created in connection with your activities and to prevent the unauthorized disclosure of such information unless required by applicable law or regulation or legal or regulatory process.


3. Do not pass or disclose inside information unless necessary for the conduct of TurboSonic business.


4. Respect valid patents, copyrighted materials and other protected intellectual property of others.


5. Produce full, fair, accurate, timely, and understandable disclosure in reports and documents that TurboSonic and its subsidiaries files with, or submits to, the Securities and Exchange Commission and other regulators and in other public communications made by TurboSonic and its subsidiaries.


6. Comply with applicable governmental laws, rules and regulations, as well as the rules and regulations of self-regulatory organizations of which TurboSonic or its subsidiaries is a member.


7. Never buy, sell or suggest to someone else that they should buy or sell stock or other securities (including TurboSonic), while you are aware of significant or material non-public information (inside information).


8. Strive to create a safe workplace and to protect the environment.


9. Assist TurboSonic in sustaining a culture where ethical conduct is recognized, valued and exemplified.


10. Promptly report any possible violation of this Code of Ethics to the Chairman of TurboSonic’s Audit Committee.

Bribery

You are prohibited from directly or indirectly taking any action to fraudulently influence, coerce, manipulate or mislead TurboSonic’s or its subsidiaries’ independent public auditors for the purpose of rendering the financial statements of TurboSonic or its subsidiaries misleading.

You understand that you will be held accountable for your adherence to this Code of Ethics. Your failure to observe the terms of this Code of Ethics may result in disciplinary action, up to and including termination of employment. Violations of this Code of Ethics may also constitute violations of law and may result in civil and criminal penalties for you, your supervisors and/or TurboSonic.

If you have any questions regarding the best course of action in a particular situation, you should promptly contact the Chairman of TurboSonic’s Audit Committee. The Audit Committee chairperson can be reached by e-mail at whistleblower@turbosonic.com. You may choose to remain anonymous in reporting any possible violation of this Code of Ethics.