Code of Ethics (Cont'd)

Accordingly, no employee, officer or director of Innodata Isogen may: (a) trade securities of Innodata Isogen or any other company while in possession of material inside information with respect to that company; (b) recommend or suggest that anyone else buy, sell, or hold securities of any company while the employee is in possession of material inside information with respect to that company (this includes formal or informal advice given to family, household members and friends); and (c) disclose material inside information to anyone, other than those persons who need to know such information in order for Innodata Isogen to properly and effectively carry out its business (e.g., to lawyers, advisers and other Innodata Isogen employees working on the matter). Of course, where material inside information is permitted to be disclosed, the recipient should be advised of its non-public nature and the limitations on its use. Any questions as to whether information is material or non-public should be directed to Innodata Isogen's General Counsel. For additional information, refer to Innodata Isogen’s "Trading Policy for Innodata Isogen Stock."

Additionally, all employees, officers and directors must provide full, fair and accurate disclosure in all government filings and public communications.

Inquiries from the Media and Public

Innodata Isogen is committed to providing full, fair and accurate disclosure in all public communications and in compliance with all applicable laws, regulations and rules. Consistent with this commitment and Innodata Isogen’s policies regarding Insider Trading and Fair Disclosure (see above), employees, officers and directors (other than the Chief Executive Officer, the Chief Accounting Officer, and the principal investor relations contact) are not authorized to answer questions from the media, analysts, investors or any other members of the public pertaining to the financial condition of Innodata Isogen, anticipated financial results of Innodata Isogen, or otherwise related to the disclosure contained (or anticipated to be contained) in periodic reports filed with the Securities and Exchange Commission (U.S.). If you should receive such an inquiry, you must record the name of the person and immediately notify the Chief Executive Officer, the Chief Accounting Officer, or Innodata Isogen’s investor relations contact as set forth at www.innodata-isogen.com.

Political Contributions and Activities

In the United States, federal and many state laws prohibit corporations from making political contributions. No direct or indirect political contribution (including the use of Company property, equipment, funds or other assets) of any kind may be made in the name of Innodata Isogen, or by using Company funds, unless Innodata Isogen's Board of Directors has approved of such contribution and its General Counsel or legal counsel has certified in writing that such political contribution complies with applicable law. When such permission is given, such contributions shall be by check to the order of the political candidate or party involved, or by such other means as will readily enable Innodata Isogen to verify, at any given time, the amount and origin of the contribution.

Foreign Corrupt Practices Act

Innodata Isogen strictly prohibits giving anything of value directly or indirectly, to a governmental official, agent or employee anywhere in the world in consideration for such official's, agent's or employee's assistance or influence (including the failure by such individual to perform his/her official duty), the purpose of which is to obtain favored treatment with respect to obtaining, retaining or directing business to Innodata Isogen.