iPayment Code of Ethics and Conduct

iPayment's Code of Business Conduct and Ethics documents the principles of conduct and ethics to be followed by the Company's employees, officers and directors. Its purpose is to:

•  Promote honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships,
•  Promote full, fair, accurate, timely, and understandable disclosure in the periodic reports required to be filed by the Company,
•  Promote compliance with applicable governmental rules and regulations,
•  Provide guidance to directors, officers and employees to help them recognize and deal with ethical issues,
•  Provide mechanisms to report unethical conduct, and
•  Help foster a culture of honesty and accountability.

The Company expects its employees, officers and directors to comply at all times with the principles in this Code. A violation of this Code by an employee, officer or director is grounds for disciplinary action up to and including discharge and possible legal prosecution.

Report Concerns About Business, Financial or Ethical Issues If you have concerns or complaints relating to business conduct, internal controls, auditing matters or other financial issues at iPayment, or relating to illegal or unethical activity you believe has occurred at iPayment, please call the following phone number: 1-866-220-1775. This phone number will connect you to a third party service, which was established to provide a single point of contact for individuals to report the types of concerns described above. Your report will be received, retained and addressed according to policies and procedures iPayment has adopted to ensure your concern is appropriately addressed.