Vangent Code of Ethics

This Code of Ethics establishes standards of business conduct for all employees. A fundamental rule for Vangent is that its business affairs must be conducted in a manner designed to protect and enhance the long-term reputation of the business.

It is the responsibility of every Vangent employee to uphold these standards and discharge their duties in accordance with Vangent policies and procedures. Vangent employees must adhere to applicable laws and regulations everywhere we do business.

All Vangent employees will participate in Code of Ethics training during their first year of employment as well as annual refresher training.

Vangent chooses the best candidate for employment without regard for race, color, religion, national origin, age, sex, disability, or veteran status. Vangent applies that same standard when choosing partners and with anyone else we conduct business. Additionally, Vangent will not hire or conduct any business transaction with person or vendors under excluded, debarred, or other similar status. Vangent has specific policies pertaining to hiring current or former government employees (including members of the military).

Vangent is committed to a policy of equal opportunity and treatment for all employees and prospective employees. Vangent will vigorously maintain a working environment free from harassment or discrimination due to race, color, religion, national origin, age, sex, disability or veteran status or any other protected class under relevant Federal, state, and local laws. All employees are expected to treat their colleagues, subordinates, customers, and suppliers with respect and dignity, and in a professional manner so as not to offend or create a hostile environment for others.

Vangent employees must scrupulously maintain books and records, to fairly reflect business transactions as they occur, and must follow all our control and financial policies.

Vangent employees may not disclose trade secrets outside of Vangent unless absolutely necessary, and then only if they are clearly protected by a non-disclosure agreement. Vangent creates and owns rights in certain information, products, printed and electronic content, software, and other content that are protected by copyright laws. Such materials must be marked with an appropriate copyright notice, and, if being provided to others for use, must be provided only pursuant to a proper licensing agreement. Vangent may develop unique and valuable designs, processes, business methods, or systems. Vangent employees, agency employees, and vendors supporting Vangent and anyone else that we do business with are prohibited from disclosing proprietary data without proper prior authorization. Vangent property (hardware, software, equipment, supplies, and facilities) may only be used for conducting business or for purposes authorized by management. Customer, U.S. Government, or supplier provided property must be used for purposes specified in the relevant contract, agreement, or by U.S. Government regulation.

We respect all patents, trademarks, copyrights, and proprietary information or trade secrets, as well as the confidentiality of anyone with whom we do business. Employees are reminded that all communications are property of Vangent and subject to review at anytime.

All employees are responsible for the protection and confidentiality of computer passwords, IDs, and other system and network access information. Also, all employees must protect client or vendor personal information under that employee's control, and may not provide such information except as specifically authorized by law or contract. Vangent employees must carefully maintain customer proprietary information, and may not disclose the information to people inside or outside the company unless it is necessary and Vangent is authorized to do so by the client. Vangent employees will respect all patents, trademarks, copyrights, proprietary information, and trade secrets that they may be privy to as a result of their employment.

Vangent respects the right of employees to be involved in political activities and make political contributions. Except as authorized by appropriate management, such activity, however, must not take place on company time or property nor involve the Vangent name or resources. Laws in most countries prohibit Vangent from contributing to political candidates, political parties, or party officials.

Vangent does not seek to gain any advantage through improper use of business courtesies or other inducements. Except as permitted by policy, Vangent employees and members of their immediate families may not accept any compensation, advance, loans, gifts, entertainment, or other favors of any kind from an actual or prospective client or supplier of Vangent.

Vangent employees must not put themselves in a situation where there is even the appearance of a conflict of interest. A Vangent employee must notify his or her supervisor if the employee is aware that the employee (or close family member) has a significant financial interest in any company supplying (or proposing to supply) goods or services to Vangent.

Vangent and its employees will communicate honestly with colleagues, suppliers, customers, and shareholders. Employees may not discuss any Vangent matters with the media. All media inquiries must be directed to the Vangent VP of Communications at (703) 284-5674. Without specific prior approval of the V.P. of Contracts, Vangent employees may not provide Vangent customers, suppliers, vendors (or others) with endorsements, testimonials, or past performance references. Except when specifically authorized, no Vangent employee may contact any government personnel for the purpose of influencing legislation or executive branch rule making. If an employee has contact with a public official outside of ordinary work duties, such employee should make it clear that he or she is not representing Vangent if there is any chance of doubt or confusion.

Vangent should always portray its products, services, and capabilities truthfully and never misrepresent the goods, services, or capabilities of competitors. Employees must report any request to participate in any activity that could have the effect of promoting a boycott or restrictive trade practice fostered by a foreign country against customers or suppliers located in another country. During U.S. government procurement, Vangent employees and contractors must not solicit, obtain, or disclose bid and proposal information or proprietary or source selection information. Vangent employees shall avoid taking actions that could create an actual or potential conflict of interest with respect to procurements in which Vangent desires to compete. Vangent employees responsible for negotiation of U.S. government contracts (including negotiations for modifications of existing U.S. government contracts) must ensure compliance with the Truth in Negotiations Act (TINA), where the act is applicable.

The FCPA prohibits United States companies or its officers, directors, employees, or agents from making improper offers, gifts, promise to give, or authorization of the giving of anything of value to foreign government officials, politicians, political parties, any candidate for political office, or any person for the purpose of influencing any act or decision in official capacity.

Vangent is subject to laws and regulations that restrict export of certain tangible items, knowledge, or services to certain countries, or to citizens of those countries (whether or not the person is in that country at the time.) To export items or knowledge into those countries, or provide those services to nationals of such countries, Vangent must first obtain government permission in the form of a license or written approval.

Employees must report behavior inconsistent with this Code of Ethics to their local management or the Vangent Ethics Hotline toll free (800) 342-8261.

	All calls to the Ethics Hotline will be investigated by the Ethics Committee using any required internal or external resources. These investigations will be kept confidential to the extent possible and the results may be reported to the operating company board and/or the appropriate senior management.
	Calls to the Hotline may be anonymous.
	Appropriate management will take whatever actions are warranted to prevent or stop business practices or behaviors that are inconsistent with this Code of Ethics.
	No action will be taken against any employee for reporting actual or suspected wrongdoing.