CODE OF BUSINESS ETHICS AND CONDUCT

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1 CODE OF BUSINESS ETHICS AND CONDUCT OUR CORE VALUES AT WORK

2 LGS innovations 2

3 Table of Contents A Message from Our CEO Why We Have a Code of Business Ethics and Conduct 4 Taking P.R.I.D.E. in Our Work How To Use The LGS Code of Business Ethics and Conduct 6 Our Core Values At Work Passion 8 Respect 10 Innovation 12 Diligence 14 Ethics 16 MethodS TO REPORT ETHICS CONCERNS 18 LGS Policy AGAINST RETALIATION 19 LGS innovations 3

4 A Message from Our CEO: Why We Have a Code of Business Ethics and Conduct Our colleagues are our most important assets. As a community of innovators and professionals, we rely on each other s talents and abilities to satisfy our customers requirements and serve our customers missions. Our ability to deliver our individual excellence depends on our achieving success as a unified team. The sum is, in fact, bigger than the parts. Our teamwork is only valuable if we effectively collaborate at all levels. Our mutual success relies heavily on a healthy dose of trust that is eventually earned over time through the consistent ethical and trustworthy actions of both individuals and teams. LGS innovations 4 This Code of Business Ethics and Conduct ( Code of Conduct ) is designed to assist us in aligning our actions and decisions with our core values and help us maintain a workplace with the highest levels of business ethics and personal integrity. LGS is committed to acting in accordance with our core values of Passion, Respect, Innovation, Diligence, and Ethics (PRIDE). Both as individuals and as a company, LGS routinely demonstrates PRIDE in everything that we do. That PRIDE extends beyond our internal relationships and into our interactions with customers, business partners, suppliers, competitors, and stakeholders. I encourage each of you to familiarize yourself with this Code of Conduct as it is designed to serve as a guide for each of us to use while observing our various corporate policies in the execution of our daily jobs. While reading the Code, you will

5 notice that we chose to write it in a way that encourages the type of behavior and conduct that we feel best serves us as a company. Accordingly, it is not an all-inclusive rule book for personnel behavior. So in the event that anyone encounters a business situation that you feel the Code does not adequately address, please consult with your supervisor, another person within your line of management, or the LGS Office of Business Ethics and Conduct to determine the appropriate course of action. Lastly, I would like to remind you that we all are reflections of LGS and its brand and play a critical and essential role in our collective success by upholding our core values and the highest standards of business integrity and ethics in everything we do. Thank you for your efforts to follow and embrace the principles in this Code of Conduct. Kevin Kelly LGS innovations 5

6 Taking P.R.I.D.E. in Our Work How To Use The LGS Code of Business Ethics and Conduct The LGS Code of Business Ethics and Conduct is an expression of our culture. It is meant to inspire all of us to make principles-based decisions in accordance with our five LGS core values of Passion, Respect, Innovation, Diligence, and Ethics. By working and acting in accordance with the principles and guidance in this Code of Conduct, we connect with each other, create trust and confidence among us, and make LGS a great place to work. LGS innovations 6 The Code of Conduct is organized by each individual LGS core value with supporting aspirational and positive behaviors that we should expect and encourage of all our colleagues and personnel, regardless of business unit or company function that we may support. Within each core value, the Code of Conduct also addresses certain situations and risk areas applicable to our business and the manner in which we can best act when faced with those situations and risks. While the Code of Conduct principally focuses on exemplary behaviors that we should aim to practice, it also describes, in certain places, actions that are not allowed under any circumstance. Please do not engage in such prohibited conduct.

7 The Code of Conduct does not address every circumstance that you may encounter at LGS or describe how to comply with many of the complex legal and regulatory requirements applicable to our business. In those circumstances not addressed by the Code of Conduct or where you are unsure of what to do, talk with your colleagues, supervisors, other managers, or the LGS Office of Business Ethics and Conduct about the right behavior for the situation. Because our personnel are our lifeblood, we care much more about understanding why circumstances that may not be in accordance with the Code of Conduct occurred rather than take any disciplinary action. Although intentional violation or disregard of the Core Values as expressed in this Code of Conduct or provisions of a supporting LGS policy can result in actions up to, and including, termination of employment or engagement, we address innocent mistakes through positive discussion and counseling. There is nothing wrong with asking about or reporting behavior that appears to be inconsistent with the Code of Conduct. Indeed, we do not tolerate any retaliation against personnel who make such inquiries or reports. Tools for inquiring about or reporting personnel actions concerning the Code of Conduct and the company s Zero Tolerance Policy Against Retaliation are set forth at the end of the Code. Furthermore, LGS various organizational policies and procedures in support of this Code of Conduct may be found on the LGS Intranet at the following page: Home.aspx. LGS innovations 7

8 Core Value: Passion for our customers, our staff, and other key stakeholders We are an intensely customer-focused company committed to earning and maintaining our customers trust and respect. We re passionate about our crafts and always take initiative to develop our skillsets in order to serve our customers and each other. We are a unified team and support each other through both our many achievements and occasional failures and we provide each other with a safe and secure work environment, filled with dignity and integrity. We maximize our value as a company by being reliable, attentively listening to our customers and personnel, timely responding to all parties with whom we interact, proactively assuming responsibility for our conduct, and engaging in the following behaviors as we passionately perform our work: Fair and Honest Dealing We compete fairly and never engage in corrupt, illegal, dishonest, or deceptive business practices. We accurately and fairly describe our solutions and offerings and make sure that our products, services, or capabilities are not misrepresented, even if it means losing a LGS innovations 8

9 sale. We win business based upon our merit and not through bribes, gratuities, or gift-giving. As a company principally focused on our U.S. Federal Government customers, we foster strong and enduring relationships by respecting our customers missions while upholding the highest standards of ethics and trustworthiness in the formation and maintenance of those relationships. Maintenance of a Safe Work Environment We ensure that all our personnel are provided a safe and secure working environment and adhere to our policies and procedures concerning workplace health and safety. We do not tolerate any type of workplace violence against our colleagues and foster a collaborative spirit without threats or intimidation. Integrity with Stakeholders We select our business partners, including suppliers, consultants, and contractors, based solely upon their merit, reputation, and ability to lawfully help our company meet its business objectives. We compete fairly with our competitors and engage in only lawful means of obtaining information about them. Moreover, we provide timely, accurate, and honest information to our management, ownership, and other stakeholders in order to help them make informed decisions about the company. LGS innovations 9

10 Core Value: Respect and fair treatment of all individuals a n d i d e a s Our success as a company is built upon a foundation of respectful and fair treatment of our colleagues, their functions, and their opinions. We treat our co-workers with dignity and we support them in their efforts to perform their roles and functions. We believe in collaborating with our personnel, communicating effectively, listening to and considering the opinions of others, and engaging in open dialogue on matters and decisions impacting our colleagues. In the pursuit of a respectful work environment, we also adhere to the following behaviors: Equal and Non-Discriminatory Treatment LGS innovations 10 We are committed to maintaining a work environment that is free from all forms of discrimination, harassment, and retaliation. We treat our personnel equally regardless of their gender, race, color, national origin, sexual orientation, religious beliefs, marital status, age, physical or mental disability, veteran status, or other personnel traits or attributes unassociated with performance of work for our company. We never harass or intimidate our colleagues or condition employment or work engagements upon these traits or attributes. We encourage constructive expressions of opinion and never retaliate against our co-workers because of those opinions. Commitment to Diversity We promote a work environment that is culturally diverse and compliant with all applicable civil rights, human rights, and employment laws. We are an equal opportunity employer committed to our affirmative action programs and we hire and advance qualified individuals with disabilities, service disabled veterans, veterans of the Vietnam era, and other covered veterans without discrimination. Our company also provides reasonable accommodations that do not impose undue hardship

11 on the operation of the business for the physical and/or mental limitations of otherwise qualified employees or applicants with disabilities, and we offer maximum opportunity to minority, women, and disabled veteran-owned business enterprises to participate as suppliers, contractors, and subcontractors of goods and services. Keeping a Drug-Free Workplace We maintain a safe, secure, and effective work environment free from the manufacture, distribution, dispensing, possession, or use of drugs and alcohol in accordance with our drug-free workplace policy, and we perform our job duties unimpaired by drugs and alcohol. We avoid engaging in alcohol and drug-related activities regardless of location if the activities threaten our company s personnel, property, or business, or impact the ability to perform our jobs. LGS innovations 11

12 Core Value: Innovation and creative thinking in the pursuit of solutions Our ability to provide groundbreaking research and advanced communications solutions and services to our customers stems from our unrivaled ingenuity and initiative to introduce new concepts and capabilities in our solutions and operations generally. We encourage continuing education and training and the development of skills that differentiate LGS from our competition. In seeking to advance the state of the art and position our company with innovations to address the future needs of our customers and stakeholders, we are committed to: LGS innovations 12 Safeguarding Protected Information and Assets We diligently protect from disclosure information that our customers, business partners, suppliers, and other stakeholders entrust to us to hold in confidence. We strictly guard the integrity and safety of any U.S. Federal Government classified information in our possession and follow associated requirements concerning the handling of such information. We carefully safeguard and protect our company s intellectual property, proprietary information, and physical assets and we use and access company assets, networks, and information solely in accordance with our information security and technology policies and procedures. We comply with all applicable data privacy laws, regulations, and company policies in

13 the protection and management of personal information, and we safely handle, track, and maintain government and stakeholder property in our possession. Respecting the Intellectual Property Rights of Others We never use, disseminate, reference, or try to gain access to another party s proprietary information, intellectual property, or trade secrets, including bid or proposal information, unless we legally obtain this information from a publicly available source or through appropriate non-disclosure or other agreements. In the event of any improper access to or use of another party s proprietary information, we immediately cease such access or use and inform the LGS Legal Department for guidance on the handling, return, and/or destruction of such information and proper notification to the owner of such information. Accurate Representation of LGS We make only truthful and accurate statements concerning our company, personnel, and solutions. We do not provide any untruthful or inaccurate statement, communication, representation, or certification or fail to disclose required information concerning our company. We also ensure that our external messaging is consistent with company policies, procedures, and guidance and coordinated as appropriate with the LGS Marketing Department. LGS innovations 13

14 Core Value: Diligence and care in the performance of tasks and responsibilities We are problem-solvers who efficiently perform our work responsibilities with the utmost degree of care while often balancing simultaneous demands. We take responsibility for our decisions and are willing to embrace and adopt appropriate alternatives and solutions, consistent with this Code of Conduct and company policies and procedures. In the diligent pursuit of our work, we also are committed to ensuring: Maintenance of Proper Records We maintain accurate books, records, accounts, and financial statements in accordance with our company policies and procedures, and we never alter or adjust company records in a manner that misrepresents the underlying transaction. We enter our time sheets daily and accurately and charge our expenses to the correct expense account. We accurately record charges LGS innovations 14

15 incurred for travel, lodging, and other activities and maintain appropriate receipts or other supporting data to prove the validity of these charges. We submit to our customers only accurate invoices, billed to the correct customer and program, with charges that are verifiable and consistent with the terms of the customer engagement. We also immediately return any overpayments that we receive from our customers. Accuracy in Financial Reporting We ensure complete, accurate, and timely internal and external reporting of financial information within our spheres of influence and in accordance with applicable accounting standards. Our forecasts, projections, and financial plans are based upon accurate records and realistic financial assumptions. We never exert unreasonable pressure or coercion for certain accounting results or circumvent required financial review, approval, and control processes. Furthermore, our revenue is only recognized in accordance with company financial policies and in compliance with applicable accounting standards. Adherence to Contractual Commitments We comply with all contractual commitments and honor our contractual obligations. In circumstances where there may be a dispute or issue with a contracting party, we work diligently and in good faith to resolve the dispute while also protecting the company s interests. We do not make illusory or false promises to our customers or business partners, and we are vigilant in complying with the Letter of Assurances that we submitted to the U.S. Federal Government concerning our continuing relationship with Alcatel-Lucent under the purview of the Alcatel-Lucent National Security Agreement. LGS innovations 15

16 Core Value: Ethics and integrity in every aspect of our conduct and operations Our fundamental commitment to maintaining the highest standards of ethics and promoting a culture of compliance is unwavering and remains a foundational pillar of our company s operations. We adhere to laws and regulations, contract terms, and internal business practices and policies, and seek to exercise principled and values-based judgments when making business decisions. Our ethical and compliant culture results from our adherence to the following behaviors: Compliance with Law, Policies, and Procedures LGS innovations 16 We strictly comply with all laws and regulations impacting our business and operations and particularly ensure that we conduct ourselves in accordance with all legal requirements involving doing business with the U.S. Federal Government and applicable export controls. We are dedicated to following the provisions of and processes established by company policies and we diligently complete all mandatory company training. Transparency in Business Conduct We are open and honest about business transactions that may create both personal and organizational conflicts of interest. We avoid competing with the company or improperly using our relationships with the company for personal gain. Furthermore, where legally required, we disclose all organizational conflicts that may bias our judgment or impartiality or provide us with an unfair competitive advantage on another, related business effort.

17 Reporting Suspected Misconduct or Violations We freely report suspected, observed, or discovered instances of unethical business conduct, potential violations of law, or actions possibly violating this Code of Conduct or company policies. We never remain silent about such conduct or acts and understand that ignorance of or intentionally remaining silent about instances of misconduct is unacceptable and may be grounds for termination of employment or engagement with the company. We adhere to the company s Zero Tolerance Policy Against Retaliation set forth below and never retaliate against individuals who report, in good faith, conduct which they believe constitutes unethical business conduct, potential violations of law, or actions possibly violating this Code of Conduct or company policies. LGS innovations 17

18 Methods To Inquire About or Report Personnel Actions Concerning the Code of Conduct Several methods are available for company personnel to seek guidance on or report issues concerning the Code of Conduct. Note that anonymous reporting is capable via the Code of Conduct hotline and/or intranet reporting site set forth below: The LGS Code of Conduct Hotline is where you can leave a voic message concerning a business ethics or conduct matter. The toll free number to reach the Hotline is and the local number is LGS innovations 18 The LGS Code of Conduct is the address where personnel can report ethics and compliance issues, ask Code of Conduct related questions, and make suggestions or comments. The LGS Intranet Code of Conduct Reporting Site is available to provide a detailed report of, or inquiry concerning, behavior that may not be in accordance with the LGS Code of Conduct: Pages/Home.aspx You also may directly report compliance and ethics issues to: The LGS Chief Compliance and Ethics Officer Michael Garson, (703) , and The LGS Director of the Office of Business Ethics and Conduct Thomas Boone, (703) ,

19 Zero Tolerance Policy Against Retaliation LGS maintains a zero tolerance policy against retaliation as stated below. LGS personnel who believe that they have been subject to retaliation for inquiring about or reporting a business ethics or conduct issue in good faith should immediately contact the LGS Code of Conduct Hotline. All LGS personnel are protected against retaliation by LGS when they inquire about or report, in good faith, conduct which they believe may constitute a violation of the LGS Code of Conduct, other LGS company policies, or applicable laws and regulations. No LGS personnel will be discharged, demoted, suspended, threatened, harassed, or in any other manner discriminated against in the terms and conditions of his or her employment because they, or a person acting on their behalf, make a good faith inquiry or report or are about to inquire or report, verbally or in writing, to LGS or an appropriate authority an instance of such believed inappropriate conduct. LGS personnel who believe that they have been subject to retaliation for inquiring or reporting in good faith as set forth above should immediately contact the LGS Code of Conduct Hotline. LGS innovations 19

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