Code of Ethics

A. Business Ethics and Conduct . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 TABLE OF CONTENTS

1. General Business Conduct . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
2. Compliance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
3. Reporting Violations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
B. Conflicts of Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
1. General Policy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
2. Ownership or Financial Interests in Other Businesses . . . . . . . . . . . . . . . . . . . . . . . 3
3. Employment by, or Rendering Services to, Other Organizations . . . . . . . . . . . . . . 3
4. Interests in Transactions with Other Persons or Organizations . . . . . . . . . . . . . . . . 3
5. Acceptance of Gifts, Gratuities or Other Favors. . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
6. Trading in Company Securities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
7. Loans to Executive Officers and Directors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
C. Employment Policies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
1. Equal Employment Opportunity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
2. Discrimination or Harassment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
3. Health and Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
4. Drug and Alcohol Abuse . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
5. Employee Personal Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
D. Protection of Assets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
1. Tangible Assets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
2. Patents, Trademarks and Copyrights . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
3. Confidential Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
E. Business Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
1. Accounting Practices. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2. Product Quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
3. Regulatory Compliance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
4. Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
5. Improper Payments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
6. Use of Consultants, Representatives and Agents . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
7. Suppliers, Vendors and Subcontractors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
8. Government Contracting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
9. Business Records. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
F. International Business Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
1. Export Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
2. Compliance with U.S. Laws . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
3. Local Laws and Customs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
G. Government Relations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
1. Political Contributions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
2. Employee Involvement in the Political Process. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
3. Providing Information to Governments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
H. Public Relations and Communications. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
1. Community Support . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
2. Shareholder Communications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
3. Communications with the Press and Public. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
I. Competition . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
1. Compliance with Antitrust Laws . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
2. Marketing, Selling and Advertising . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
3. Competitive Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

® IDEXX Laboratories, Inc. All rights reserved. • 64482 (April 2003) 1

BUSINESS ETHICS 1. General Business Conduct
AND CONDUCT IDEXX Laboratories, Inc. (“IDEXX” or the “Company”) is committed to conducting
its business affairs ethically and in full compliance with the laws and regulations of all
jurisdictions in which we do business. In addition, IDEXX’s employees are expected
to avoid any activity that is in conflict with, or might reflect adversely on the Company.
We believe that conducting our business with the highest ethical and legal standards,
and without actual or apparent conflict of interest, is in the best interests of the
Company and all of its constituents, including employees, customers, shareholders,
vendors and the communities in which we live and work.
The policies and practices described in this Code of Ethics are an expression of our
fundamental values and principles and are designed to help employees to meet our
Standards of Conduct. This Code of Ethics is not all-encompassing. Rather, it
represents a framework for individual and corporate decision-making. The Code
should be interpreted and followed in the context of applicable laws and regulations,
the further policies and procedures adopted from time to time by the Company and
good common sense.
This Code of Ethics applies to all of IDEXX’s operations worldwide. In addition, we
expect that third parties who act as agents or representatives of IDEXX will conduct
themselves in a manner consistent with this Code when acting for, on behalf of or in
the name of IDEXX, including when selling IDEXX products and services.

2. Compliance
It is the responsibility of all IDEXX employees worldwide to comply with this Code of
Ethics. Failure to comply with this Code and related IDEXX policies will result in
disciplinary action up to and including termination.

3. Reporting Violations
It is the personal responsibility of each employee to report any violations or suspected
violations of the Code of Ethics to his or her supervisor, the General Counsel or the
Chief Executive Officer or, in the case of violations of the Company’s employment
policies, to appropriate Human Resources personnel. In addition, the Company may
provide other means of reporting violations or suspected violations, the establishment
of which will be communicated to employees.
Investigations will be conducted by or under the supervision of the General Counsel.
It is imperative that persons who report violations or to whom reports are made
(other than the General Counsel) not conduct their own preliminary investigations,
unless instructed to do so by the General Counsel or another member of the Legal
Department. In reporting any violation, an employee should provide a description of
the factual basis for the allegation that is sufficient to permit the conduct of an
appropriate investigation. It is IDEXX’s policy that no retaliation may be made
against an employee as a result of his or her reporting of any violation or suspected
violation as provided above.

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1. General Policy CONFLICTS OF
It is the duty of every IDEXX employee to avoid any situation that is, or may appear INTEREST
to be, a conflict of interest between the personal interests of the employee and the
interests of the Company. While it is impossible to anticipate every situation that
might create or lead to such a conflict, certain specific conflicts are addressed below.
If any employee is unsure whether a situation involves, or has the potential to involve,
a conflict of interest with the Company, the employee should consult his or her
supervisor, the General Counsel or the Chief Executive Officer. If an actual or
potential conflict of interest is found to exist, the employee must promptly and
satisfactorily resolve the conflict. Failure to resolve the conflict to the satisfaction of
the Company may be cause for termination.

2. Ownership or Financial Interests in Other Businesses

An employee must disclose to his or her supervisor, the General Counsel or Chief
Executive Officer any significant direct or indirect ownership or other financial
interest of the employee or any member of his or her immediate family in any
supplier, customer or other party with which the Company transacts business, or any
competitor of the Company. Generally, a financial interest will be deemed to be
significant if it is material to either the employee or the party in which the employee
has the interest. In determining whether a conflict exists, consideration will be given
to whether the employee’s role at IDEXX gives him or her control or influence over
the business relationship in question (e.g., the selection of a supplier).

3. Employment by, or Rendering Services to, Other Organizations

Employees may not engage in outside work or services that would create a conflict of
interest with the work they perform for IDEXX. Generally, a conflict of interest will
exist if the performance of such work or services would either (a) potentially make it
difficult for the employee to act in the best interests of IDEXX at all times, or (b)
otherwise interfere with the employee’s performance of work on behalf of IDEXX. If
an employee is uncertain whether the performance of certain outside work or services
creates a conflict of interest, he or she should discuss the matter with his or her
supervisor or the General Counsel.

4. Interests in Transactions with Other Persons or Organizations

An employee must disclose to his or her supervisor, the General Counsel or the Chief
Executive Officer any material direct or indirect interest of the employee or any
member of the employee’s immediate family in any transaction to which the Company
is a party. Among the factors to be considered in determining the materiality of an
interest will be the significance of the transaction to the employee or family member,
the nature of the transaction, the size of the transaction, and whether the employee is
likely to be involved in the transaction.

5. Acceptance of Gifts, Gratuities or Other Favors

Seeking or accepting gifts, gratuities, entertainment or other favors by employees or
members of their immediate family from present or potential customers, suppliers or
others doing or seeking to do business with the Company may create a conflict of
interest. Employees and members of their immediate families should not accept any
such gifts, gratuities, entertainment or other favors unless they are made in the
ordinary course of business, are of a nominal or token amount, and are not received
on a regular or frequent basis. Employees should never accept gifts, gratuities,
entertainment or other favors that might reasonably be deemed to affect their
judgment or actions in the performance of their duties for IDEXX.

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 6. Trading in Company Securities
Each employee of IDEXX must comply with IDEXX’s Insider Trading Policy. Under
this policy, IDEXX employees are prohibited from trading IDEXX’s stock at any time
that they possess material information concerning the Company that has not yet been
disclosed to the public. In addition, quiet periods, notification requirements and other
restrictions on trading in IDEXX securities are applicable to certain finance, legal and
senior management employees.

7. Loans to Executive Officers and Directors

The Company will not, directly or indirectly, extend or maintain credit or arrange for
a personal loan to any executive officer or director.

EMPLOYMENT 1. Equal Employment Opportunity

POLICIES It is IDEXX’s policy to afford equal employment opportunity to qualified individuals
regardless of their race, religion, gender identity, sexual orientation, HIV status,
national origin, age, physical or mental disability, veteran status or membership in any
other categories protected by law.
This policy applies to all phases of the employment relationship, including selection,
job assignment, transfer, promotion, promotional opportunities, compensation,
benefits, discipline, termination and access to training.

2. Discrimination or Harassment
IDEXX is committed to providing a workplace that is free from discrimination and
unlawful harassment. We will not tolerate actions, words, jokes or comments that are
based on an individual’s race, religion, gender identity, sexual orientation, HIV status,
national origin, age, physical or mental disability, veteran status or membership in any
other category protected by law and which tend to create an intimidating, hostile or
offensive work environment.

3. Health and Safety

IDEXX is committed to providing its employees a workplace that is free from
recognized safety and health hazards. Each IDEXX operating unit is responsible for
establishing policies and procedures that are reasonably designed to create a safe and
healthy workplace, and to comply with all applicable laws and regulations. At the
same time, health and safety are important aspects of job performance. Employees
have an obligation to learn the safety procedures applicable to their jobs and to
follow them.

4. Drug and Alcohol Abuse

IDEXX’s policy is to maintain a work environment that is free from the effects of
drug and alcohol abuse. All IDEXX entities worldwide will abide by applicable laws
and regulations relative to the use, sale, manufacture, distribution, dispensation, or
transfer of alcohol, drugs and other controlled substances on the job or on IDEXX’s
premises. IDEXX’s policy prohibits the possession or presence in one’s system of
illegal drugs while on Company premises.
Similarly, IDEXX’s policy prohibits the use, sale, purchase, transfer or possession of
alcoholic beverages by employees while on Company premises, except as authorized
by the Company.

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5. Employee Personal Information
IDEXX operates on the firm belief of respect for employee privacy and dignity. It is
IDEXX’s policy to acquire and retain only employee personal information that is
required for effective operation of the Company or that is required by law in the
jurisdictions in which we operate. Access to such information will be restricted
internally to those with a recognized need to know to perform their responsibilities for
the Company.
IDEXX will comply with all applicable laws regulating the disclosure of personal
information about employees. In any location where applicable law does not regulate
the release of such information, the Company will have policies designed to protect
such information from unreasonable disclosure.
The Company’s respect for employee privacy dictates that the Company normally will
not be concerned with personal conduct off the job, unless such conduct impairs the
employee’s work performance, affects the safety of other IDEXX employees or affects
the reputation or legitimate business interests of the Company.

1. Tangible Assets PROTECTION

Every IDEXX employee is responsible for the proper use, conservation and OF ASSETS
protection of the Company’s assets, including its property, plants and equipment. The
management of each IDEXX entity is responsible for establishing and communicating
to employees the policies and procedures necessary to meet these responsibilities.

2. Patents, Trademarks and Copyrights

Protection of IDEXX’s intellectual property – including its patents, trademarks,
copyrights, and trade secrets – is essential to the success of the Company. It is the
responsibility of each IDEXX employee to preserve the value of IDEXX’s intellectual
property. Employees should refer to IDEXX’s Intellectual Property Handbook for a
full discussion of IDEXX’s policies regarding protection of intellectual property. It is
also IDEXX’s policy to respect the intellectual property rights of third parties.

3. Confidential Information
IDEXX’s competitive advantage is highly dependent upon its confidential business
information and trade secrets. Each IDEXX employee is required to sign an
Invention and Non-Disclosure Agreement under which the employee agrees to
maintain such information in confidence and to disclose and assign to the Company
any inventions made by such employee in the course of his or her employment with
the Company.
Employees should take all practicable steps to protect IDEXX’s confidential business
information, as well as the confidential information of third parties that is in our
possession. Such confidential information should not be disclosed to any person
outside the Company unless and until an appropriate confidentiality agreement has
been signed by such person. Confidentiality agreements involving the Company may
be signed only by authorized employees. Employees should refer to the Company’s
Contract Signing Guidelines for guidance regarding signing authority.
Additionally, employees should take appropriate precautions to ensure that
confidential or sensitive business information, whether such information is proprietary
to IDEXX or a third party, is not communicated within the Company except to
employees who have a need to know such information to perform their responsibilities
for the Company. Care should be taken that any permitted communications are made
in a manner that is reasonably designed to ensure that such information remains
confidential and is not disclosed to anyone inside or outside the Company who does
not have a need to know such information or who is not obligated to protect
such information. 5
BUSINESS 1. Accounting Practices
PRACTICES The Company will follow generally accepted accounting principles and will maintain
appropriate controls to ensure accurate and timely recording of accounting
transactions. The books of account, budgets, investment evaluations, employee
expense accounts and other similar records must accurately reflect the matters to
which they relate. All assets and liabilities and equity, revenue and expense
transactions of the Company must be carefully and properly accounted for. No
payment of funds of the Company shall be approved or made with the intention or
understanding that any part of such funds shall be used in any manner contrary to the
policies stated herein, or of the supporting documents therefor.
Furthermore, the independent auditors of the Company must have access to all
necessary information to permit them to conduct audits properly. The books and
records of the Company must fully and accurately report the transactions that they
purport to reflect. Supporting and background information, which such auditors may
properly request, must be fully and accurately supplied to them.

2. Product Quality
All operating units of the Company have the responsibility to design, manufacture and
deliver quality products and services. Without limiting the foregoing, the Company’s
products and services should (a) conform to customers’ legitimate needs,
requirements and intended use, (b) comply with applicable government standards and
regulations and (c) comply with applicable industry standards and methods. All
required inspection and testing operations must be completed properly.
All phases of the Company’s product development process must be satisfactorily
completed before a new product will be launched.
These standards of product quality must be reflected in the operating policies and
procedures of all IDEXX operations worldwide.

3. Regulatory Compliance
It is the policy of the Company to conduct its business in compliance with all
applicable federal, state and local laws and regulations, as well as the laws and
regulations of countries and regions outside the United States in which we do
business. It is the responsibility of IDEXX entities worldwide to understand the laws
and regulations applicable to the conduct of their business, and to take steps that are
appropriate to ensure compliance with those laws and regulations.

4. Environment
It is IDEXX’s policy to conduct its operations in a manner that safeguards the
workplace and the natural environment. Management of each of IDEXX’s
operations (within and outside the U.S.) is responsible for establishing and
maintaining policies and procedures that satisfy this requirement.

5. Improper Payments
IDEXX employees shall not make bribes, payments, gifts or gratuities of any kind to
any government official anywhere in the world, whether or not there is an intent to
influence. All IDEXX employees worldwide will comply with the U.S. Foreign
Corrupt Practices Act, which prohibits the making or offering of a payment to any
foreign official to induce that official to affect any governmental act or decision or to
assist the Company in obtaining or retaining business.

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6. Use of Consultants, Representatives and Agents
From time to time the Company may engage consultants, representatives and agents.
Consultants, representatives and agents must agree to (a) maintain the Company’s
confidential business information in confidence, (b) act in a manner that is consistent
with the Company’s Code of Ethics and (c) comply with all laws and regulations
applicable to the performance of services on behalf of the Company.

7. Suppliers, Vendors and Subcontractors

It is IDEXX’s policy to purchase all equipment, supplies and services on the basis of
merit. IDEXX’s suppliers, vendors and subcontractors will be treated with fairness
and integrity and without discrimination.
Employees who deal with suppliers or potential suppliers will be guided by IDEXX’s
policy governing Conflicts of Interest.

8. Government Contracting
All IDEXX employees and any consultants used by the Company will comply with the
laws and regulations relating to procurements by federal, state and local government
entities.
Special care must be taken to comply with the unique and special rules of the
government procurement process and to ensure the accuracy of all data submitted to
any government entities. Violation of these rules may subject the Company and its
employees to civil and criminal penalties, including fines, debarment or suspensions or
prison sentences.
The Company also is committed to compliance with foreign government procurement
laws that are applicable to IDEXX’s business activities outside the United States.

9. Business Records
Employees shall retain and dispose of Company records in accordance with
established IDEXX policies and applicable legal and regulatory requirements.

1. Export Control INTERNATIONAL

It is the policy of IDEXX to comply fully with the export control laws of the United BUSINESS
States and all other jurisdictions in which we operate worldwide. Each IDEXX OPERATIONS
business unit worldwide is responsible for ensuring that (a) proper authorizations and
licenses are obtained for the export of products, (b) recipients of products are eligible
to receive exported products and (c) proper documentation for the export of products
is prepared, delivered and obtained.

2. Compliance with U.S. Laws

IDEXX business units located outside the United States are responsible for
complying with U.S. laws that relate to the sale of products outside the United States,
including embargoes against sales to customers in certain countries, restrictions on
sales to persons on the U.S. Commerce Department’s Denied Persons List, anti-
boycott laws and export control laws.

3. Local Laws and Customs

IDEXX’s international business operations may encounter laws, local customs and
social standards that differ widely from U.S. practice. It is IDEXX’s policy to abide by
the national and local laws of the countries in which we operate, unless prohibited by
U.S. law. It is the responsibility of each IDEXX business operation outside of the
United States to understand and comply with the laws and regulations of the countries

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 in which such operation does business. When local customs and business or social
practices vary from the standards contained in IDEXX’s Code of Ethics, it is
permissible to conform to local customs and practices when necessary for the proper
conduct of IDEXX’s business, provided that such variance does not violate the laws of
the U.S. or any other country relevant to the matter.

GOVERNMENT 1. Political Contributions

RELATIONS IDEXX will comply with all national, state and local laws regulating its participation
in political affairs, including contributions to political parties, national political
committees, or individual candidates. No IDEXX employee shall make or authorize
any political contribution using IDEXX funds or otherwise on behalf of IDEXX
without the prior approval of the Chief Executive Officer.

2. Employee Involvement in the Political Process

IDEXX encourages all employees to be informed voters and to be involved in the
political process. Personal participation, including contributions of time or financial
support, shall be entirely voluntary.
From time to time the Company may permit political office holders or candidates for
office to visit IDEXX facilities and speak to employees. While IDEXX may reject a
request for such a visit, it is IDEXX’s policy that determinations regarding who may
visit IDEXX’s facilities will not be made on grounds of party affiliation.

3. Providing Information to Governments

It is IDEXX’s policy to fully and accurately comply with any law or regulation
requiring the Company to provide information to a government entity.
Moreover, it is the Company’s policy to voluntarily comply with any reasonable
requests for information by government entities in connection with any
governmental investigations.

PUBLIC RELATIONS AND 1. Community Support

COMMUNICATIONS It is IDEXX’s policy to support local, national and world communities in ways
aligned with our business objectives. We believe that responsible corporate citizenship
can further our business objectives by strengthening the communities in which our
facilities are located; by recognizing and rewarding employee involvement in those
communities; and by supporting programs directly aligned with IDEXX
business goals.

2. Shareholder Communications
It is the Company’s policy to comply fully with federal and state securities laws. In
this regard, periodic reports and other documents filed by the Company with the U.S.
Securities and Exchange Commission will fully, fairly, accurately and understandably
disclose the information required to be included therein. Similarly, public
communications such as press releases, investor presentations, and website disclosures
will fully, fairly, accurately and understandably describe the matters to which they
relate.

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 To enable IDEXX to meet its disclosure obligations, employees in possession of
material non-public information that they have reason to believe may not be known to
senior management have the obligation to bring such information to the attention of
the Company’s Disclosure Committee to ensure that such information is appropriately
disclosed. Material non-public information regarding the Company may only be
disclosed publicly in a manner consistent with IDEXX’s Disclosure Policy by persons
authorized to make such disclosures.

3. Communications with the Press and Public

IDEXX maintains policies and standard operating procedures regarding
communications by IDEXX employees with the public and the press that relate to the
Company or its business. These policies are intended to ensure that all public
statements made by or on behalf of the Company are consistent, accurate, appropriate
and in compliance with law and IDEXX’s legal and contractual obligations. Among
other things, the policies specify procedures for the preparation, review, approval and
public distribution of information.

1. Compliance with Antitrust Laws COMPETITION

The purpose of the federal and state antitrust laws is to promote free and vigorous
competition to ensure that consumers have access to the best combination of price
and quality in products and services. Many countries outside the U.S. also have
antitrust laws that prohibit the types of conduct that are prohibited in the U.S. In
some cases, in particular in the European Union, these laws may be stricter than laws
in the U.S. with respect to certain business practices, including: distribution
agreements; licenses; territorial restrictions; and pricing matters.
IDEXX’s Antitrust Compliance Policy provides guidance regarding a number of
competitive practices, including dealings and communications with competitors;
dealings with customers; dealings with suppliers and distributors; and mergers and
acquisitions. All IDEXX employees involved in these practices should be familiar
with IDEXX’s Antitrust Compliance Policy and should consult the Legal Department
about the compliance of any IDEXX business practice with the policy.

2. Marketing, Selling and Advertising

IDEXX will compete in the global marketplace on the basis of the merits of our
products and services. Legal and ethical considerations dictate that marketing
activities be conducted fairly and honestly. Marketing and selling practices should be
based on the superiority of our product and service offerings. Advertising must be
truthful. Statements made about the performance of a product or the benefit or value
of a service should have a documented basis in fact. In making comparisons to
competitors, care must be taken to avoid disparaging a competitor through inaccurate
or deceptive statements.

3. Competitive Information
In a highly competitive global marketplace, information about our competitors is a
necessary element of business. However, such information will be obtained only when
there is a reasonable belief that both receipt and use of the information is lawful.