TOKWIRO ENTERPRISES, ENRG: ETHICS POLICY AND CODE OF CONDUCT FOR EMPLOYEES AND CONTRACTORS

POLICY: All Employees and Contractors providing services directly or indirectly to or for the benefit of Tokwiro Enterprises, ENRG ("Tokwiro") must abide by the highest standards of business ethics and avoid any actual or apparent conflict of interest with respect to play on any Tokwiro web site, as described in this Policy. This Policy establishes minimum standards required of all Employees and Contractors, which are in addition to the requirements of other policies governing those Employees and Contractors. Tokwiro requires that upon commencement of employment or contracting services, each Employee and Contractor must read, understand, and abide by the terms of this Policy. Failure to comply with this Policy and the procedures established to implement it can result in disciplinary action, termination from employment, termination of contracting relationship, and/or initiation of appropriate legal action, as Tokwiro deems appropriate.

PURPOSE:Violations of this Policy could expose Tokwiro and the individual involved to allegations of impropriety that negatively impact the Tokwiro brand and/or legal remedies.

DEFINITIONS:

• "DEO" – Designated Ethics Officer. Each Employee's and Consultant's DEO shall be the person designated to him or her by Tokwiro or by his or her direct manager as approved by Tokwiro.
• "Consultants" – All persons of any nature that directly or indirectly provides services to Tokwiro. Consultants shall include Employees or other service providers to any company, entity, or business that provides services to Tokwiro.
• "Employees" - All Employees of Tokwiro of any nature.
• "Policy" - This Ethics Policy and Code of Conduct, as may be amended from time to time.

PROHIBITIONS:

• Except as expressly permitted by this Policy, Employees and members of their households are prohibited from playing poker or any other game on any Tokwiro site for real money, for reward points offered by any Tokwiro site, or for any other consideration of value.
• Except as expressly permitted by this Policy, Employees and members of Employee households are prohibited from being paid any prize or monies from Tokwiro with respect to game play.
• Employees and members of Employee households may not withdraw any funds from any Tokwiro site for any reason, other than with the prior written consent of the Employee’s DEO.

EXCEPTIONS:

• Employees and members of Employee households are permitted to play on any Tokwiro site for "play" chips that have no value.
• Employees and members of Employee households are permitted to play on any Tokwiro site and receive prizes in any tournaments that are limited to designated Employees and Consultants, that are sanctioned by any Tokwiro site, and that are approved in writing by an Employee’s DEO. Any such tournaments may not include participants who are not designated Employees or Consultants.
• Employees and members of Employee households may play on any Tokwiro site for bona fide reasons related to an Employee’s job duties, provided that all such play shall be pre-approved by the Employee’s DEO, including the specific times and reasons for such play. The DEO shall ensure that all such play is properly logged and maintained by Tokwiro. Any withdrawals resulting from such play must be pre-approved in writing by the Employee’s DEO.
• Certain Consultants whose play on any Tokwiro site pose no risk to compromising the purposes of this Policy (such as third party paid poker professionals, third party affiliates, and third party hosts/prop players all of whom have no access to Tokwiro’s back-end systems) may be excluded from this Policy to the extent provided in writing by Tokwiro. Any such Consultants shall have not the ability to compromise play on any Tokwiro site.

DISCLOSURE: Except as specifically set forth in the above “EXCEPTIONS”, an Employee must fully disclose details when the Employee or a member of the Employee’s household play on any Tokwiro site or withdraws funds from any Tokwiro site, or when the Employee becomes aware that any Employee or consultant or member of that Employee or consultant’s household plays on any Tokwiro site or withdraws from any Tokwiro site, to the Employee’s DEO.

REVISIONS: Tokwiro reserves the right to revise, amend, or modify this Policy at any time and in any manner.

Effective: 10/21/2007