ATN Holdings Inc.

The purpose of this Code of Business Conduct & Ethics is to preserve the reputation and integrity of ATN HOLDINGS, INC. Group of Companies as well as that of all persons affiliated with it. All employees of the Company have ethical and legal responsibilities to maintain the confidentiality of material, non-public information and sustaining a work environment we can all be proud of.

The Code of Business Conduct is our guide to appropriate conduct to ensure consistency in how employees conduct themselves within the Company, and in their dealings outside of the Company. This includes a commitment to comply with all applicable laws, rules & regulations that govern our business activities.

ATN HOLDINGS, INC. exercises responsibility towards its shareholders, business partners, communities, employees and the government. Engaging in activities prejudicial to company's interest or affect work efficiency is strictly prohibited and monitored in the workplace.