Table of Contents

• General Provisions
• Compliance

• Compliance Guidelines

  1. Public Posting
  2. Conference Call
  3. Presentations
  4. Authorized Spokespersons
  5. Quiet Period

General Provisions

PacificNet is committed to full and fair disclosure of information that outsiders need to make reasonable investment decisions about our securities. Our policy is to provide factual information about our businesses and our strategic objectives, on a consistent basis, to enable investors to reasonably evaluate the performance of the company as a whole.

It is PacificNet's policy to maintain an active and open public dialogue with shareholders, institutional investors, broker/dealers, and sell-side analysts (collectively, "Securities Market Participants"), that provides full, fair, accurate, timely and understandable disclosure of PacificNet's historical performance and future prospects in accordance with generally accepted accounting principles, and with all applicable securities laws. PacificNet further believes that the market for its securities is best served when its strategies, business strengths, risks, and growth opportunities are publicly articulated.

This disclosure policy applies to all employees, officers, consultants and directors of PacificNet, and addresses both oral and written communications with financial analysts, existing and potential investors, and the media.

Compliance

PacificNet will comply with all periodic reports and disclosure requirements contained in all applicable securities laws, including Regulation FD (Regulation Fair Disclosure). It has been, and will continue to be, our practice to disclose material information about PacificNet publicly and timely, not selectively. PacificNet expects the strictest compliance with this policy by all directors, officers, and employees. Failure to follow the letter and the spirit of this policy would be considered a matter of extreme seriousness and a basis for termination of employment.

PacificNet's employees will not disclose material non-public information about the company except as provided for by rules and regulations of Securities and Exchange Commission (SEC), including Regulation FD. If any employee determine that material non-public information has been disclosed, that employee should contact the Investor Relations organization immediately. Investor Relations top leaders will determine the appropriate public disclosure that will have to be made in accordance with SEC rules and regulations.

Compliance Guidelines

PacificNet has established the following guidelines to ensure compliance with Regulation FD and to avoid selective disclosure of non-public material information.

1. Public Posting

   We will post this policy statement to .ir.pacificnet.com and update it as necessary to ensure that Securities Market Participants are informed about PacificNet's disclosure policy.

2. Conference Call

   • We will issue annual/quarterly earnings releases.
   • Shortly after a conference call to discuss annual/quarterly earning release we will issue the results to the public, also will post to our website.
   • For those unable to attend the conference call live, an archive of the call will be available for 30 days. A replay of this call will be available and investors can access the replay by dialing the numbers we provided.
   • When we provide guidance relatives to PacificNet financial goals, all guidance, and changes to or affirmations of guidance will be provided through public disclosures.

3. Presentations

   • We will continue to participate in certain securities firm-sponsored and other conferences. It will be our practice to issue press releases in advance of those presentations.
   • We will participate in other forums at which Securities Market Participants could be present, including industry seminars, trade shows, employee, retiree, annual shareholder meetings, and meetings with business partners that are shareholders.

4. Authorized Spokespersons

   The designated company contacts for the financial community are Chairman & CEO, President, CFO, IR Director, or other top leaders in the company. They are responsible for answering inquiries or to discuss the financial or operating activities of the company with the financial community.

5. Quiet Period

   Following the end of each quarter until the announcement of our financial results we observe a "quiet period" during which we refrain from discussing PacificNet's operations, financial performance, or financial outlook.