Hughes Telematics, Inc. (the "Corporation") conducts all aspects of company business with the highest standards of integrity, honesty, and fair dealing. The Corporation requires that all officers, employees, directors, consultants, and representatives avoid activities that involve or might appear to involve a conflict of interest between personal and professional relationships. The Corporation also requires compliance with both the letter and the spirit of the laws and regulations of the United States as well as other countries and jurisdictions in which the Corporation operates.

All employees are required to:

• Avoid even the appearance of misconduct or impropriety.
• Conduct all dealings with customers, contractors or subcontractors, suppliers, and competitors with honesty and fairness, exercising good judgment and the highest ethical standards in business or personal interactions that may reflect upon the Corporation in any way.
• Avoid actual or apparent conflicts of interest between personal and professional relationships, including, but not limited to any investment, interest, or association that interferes, or potentially could interfere with independent exercise of judgment in the best interest of the Corporation.
• Never use the assets, information, or relationships of the Corporation or any of the Corporation's affiliates for personal gain.
• Know, understand, and comply with all applicable U.S. and non-U.S. laws, regulations, rules, and policies governing the conduct of the Corporation's business, both domestic and foreign, including all export laws and regulations (e.g., the Foreign Corrupt Practices Act), employment issues, marketing activities, and insider trading restrictions.
• Assist the Corporation in complying with its obligations under the U.S. Federal Securities Laws to provide full, fair, accurate, timely, and understandable disclosure in each report or other document filed with or submitted to the SEC and in any other public communication made by or on behalf of the Corporation or any of its affiliates.
• Ensure that all transactions are handled honestly, are compliant with acceptable accounting principles, and are recorded fully and accurately in the books and records of the Corporation as well as on the books and records of any of the Corporation's affiliates.
• Respect the right of all employees to fair treatment and equal opportunity, free from discrimination, retaliation, or harassment of any type.
• Safeguard information that belongs to the Corporation and affiliates of the Corporation. Treat all such information as confidential and do not disclose it outside of the Corporation except when specifically authorized.
• Except under a non-disclosure agreement entered into in accordance with the Corporation's information protection policies, not solicit, obtain, or disclose any proprietary data concerning suppliers, contractors or subcontractors, customers, or competitors.
• Avoid any conduct that could potentially obstruct a government proceeding or investigation, including falsifying or failing to maintain or produce records, documents, and information.
• Promptly report any perceived violation of this Policy by any director, officer, or other employee, or any consultant to your manager or to the Corporation's Corporate Ethics Officer. A manager of the Corporation who receives a report of a perceived violation is required to advise the Corporation's Corporate Ethics Officer of such perceived violation.

If you are an executive officer or director of the Corporation, your request to waive any provision of this Code may be approved only by the Board of Directors of the Corporation and must be disclosed to shareholders, along with the reasons for the waiver

Any director, officer or employee who violates any laws, governmental regulations or this Code will face appropriate, case specific disciplinary action, which may include demotion or immediate discharge.