Vangent Code of Ethics

The Vangent 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 employees are required to follow this ethics policy and report any violations. In addition, All Vangent employees must attend Code of Ethics training during their first year of employment as well as annual refresher training.

This code of conduct outlines additional rules and responsibilitie for our executive team as they conduct Vangent company business.

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.