This Code of Business Conduct and Ethics (the “Code”) covers a wide
range of business practices and procedures for Rubicon Technology, Inc. (“Rubicon,”
“we,” “us,” or “our”). This Code does not
cover every issue that may arise, but it sets out basic principles to guide
all of our employees, officers and directors.
The purpose of this Code is to promote ethical conduct and deter wrongdoing.
The policies outlined in this Code are designed to ensure that our employees,
including our officers (“employees”), and members of our board of
directors (“directors”) act in accordance with not only the letter
but also the spirit of the laws and regulations that apply to our business.
We expect our employees and directors to exercise good judgment to uphold these
standards in their day-to-day activities and to comply with all applicable policies
and procedures in the course of their relationship with us.