Code of Ethics and Business Conduct

Financial Records

Each of us must be accurate and complete when making or reporting financial entries or transactions. We must disclose problems and discrepancies promptly and never falsify financial records. None of us should sign documents if we do not have proper authority. We should never make or approve payments on behalf of the Company if they will be used, or might be used, for something other than the stated approved business purpose. We must all be responsible for ensuring that travel, material and other expenses are recorded truthfully and correctly.

SGT is required to maintain sound processes and controls so that transactions are executed according to management’s authorization. We must also prevent and detect unauthorized use of SGT assets. All SGT employees are required to make sure that the SGT books and records they create, or are otherwise responsible for, are:

• complete
• accurate
• honestly reflect each transaction or expenditure, and
• are timely and in accordance with applicable accounting rules and standards

Such books and records include all data, certifications and other written materials provided for financial reporting and disclosure purposes as well as materials collected for other purposes. These also include internal expense records (such as expense account reports).

Commitment to Quality

SGT provides product and service excellence by understanding and meeting customer and stakeholder needs through a commitment to continual improvement of our quality management system, all while maintaining the highest standards of ethics and compliance.

We strive to do the job right, on time, and always according to the contractual requirements of our customer. We must also report any discrepancy, deviation, mistake or failure related to our products or services. We must never falsify documents or conceal operational or component problems. Each of us should always seek and receive proper approvals before deviating from any requirement, never improperly substitute materials, never utilize lower quality or unapproved materials, and always conduct all tests and inspections as required.

Our commitment to quality is unwavering, which is why we seek recurring external verification for our compliance with the ISO 9001: 2015 Quality Standard.

Responsibility for the Reputation of Siemens Government Technologies

To a substantial degree, the reputation of SGT is determined by our actions and the way each and every one of us presents and conducts himself/herself. Illegal or inappropriate behavior or actions on the part of even a single employee can cause the Company considerable damage. Each of us has a responsibility to recognize our impact on the Company’s reputation and to behave in a manner that appropriately demonstrates the Company’s commitment to our Code of Ethics and Business Conduct, as well as the fundamental principles and values when representing the Company.

Timekeeping

Each of us must accurately and honestly record time spent each day on each job on which we work. In addition to recording your attendance and hours worked for computing your pay, time records are the basis for billing our customers. Falsifying time records is fraud and may be a criminal offense. You are responsible for the accuracy of your individual time records and by signing your timesheet; you are certifying that it is true and accurate.

Employees should note that several times per year you may be requested to submit your timesheet early. These occasions are associated with Federal holidays or specific financial events. These occasions are approved and reviewed by the Defense Contract Audit Agency (DCAA). If you have questions about this process, consult your manager.

Competitive Sensitive Data

No SGT employee, consultant or representative may solicit, obtain or utilize source selection information relating to government procurements. In addition to materials so marked by the Government, source selection information includes bid prices submitted in response to a solicitation, source selection plans, technical evaluation plans, technical evaluation of competing proposals, cost or price evaluations of competing proposals, competitive range determinations, ranking of competitors and reports and evaluations of source selection boards. Similarly, no SGT employee, consultant or representative may solicit, receive, or utilize any other company’s proprietary material other than as authorized by that company with SGT.

Gifts, Entertainment & Hospitality

Business entertainment, gifts, and hospitality, where appropriate, are meant to create brand recognition, goodwill, and establish or maintain sound working relationships. They shall not be offered or received to gain improper advantage with customers or suppliers, to facilitate approval from Government officials, or where otherwise illegal or where they might result in an actual or potential appearance of impropriety. As a result, no employee may directly or indirectly offer, promise, grant, or authorize (directly or indirectly) the giving of money or anything else of value to a government official to influence official action or obtain an improper advantage. The same applies to a private commercial counterparty in a business transaction in consideration for an improper advantage. Any offer, promise, grant or gift must comply with applicable laws and SGT policies, and must not raise an appearance of bad faith or unsuitableness. This means that no such offer, promise, grant or gift may be made if it could reasonably be understood as an effort to improperly influence a government official or as a bribe to a commercial counterparty to grant SGT a business advantage.

Employees must understand that the term “government official” is defined broadly to include officials or employees of any government or other public body, agency, or legal entity, at any level, including officers or employees of state- owned or county-owned enterprises, municipalities, and public international organizations. It also includes candidates for political office, political party officials and employees, as well as political parties.

In addition, employees may not give money or anything of value indirectly (for example, to a consultant, agent, intermediary, business partner or other third party) if the circumstances indicate that all or part of may be directly or indirectly passed on to a government official to influence official action or obtain an improper advantage or to a private commercial counterparty in consideration for an unfair advantage in a business transaction. For that reason, employees responsible for hiring consultants, agents, partners in joint ventures or other business partners must take action as appropriate to:

• ensure that those third parties understand and will abide by SGT’s anti-corruption policies;
• evaluate the qualifications and reputation of such third parties; and
• include appropriate provisions in agreements and contracts designed to protect SGT.

Entertainment and gifts cannot be accepted by any employee unless of nominal or token value or express written permission is received by their manager and the SGT Chief Compliance Officer.

Protection & Proper Use of Company Assets

Effective use of Company resources is critical to our bottom line and these resources should be used principally for business purposes that advance SGT’s company objectives. Occasionally, however, limited personal use is permitted when it does not compromise SGT interests or Company resources. Each of us should use these resources wisely, demonstrate efficiency and guard against waste. We must limit time spent on personal affairs to a reasonable duration and frequency – always incidental to your workday and never charged to the Company or customer. Personal use must not interfere with or adversely affect your job performance or that of any other person or organizational requirements. You may never use Company assets in an illegal, disruptive or offensive manner to others (e.g., involving racist or sexually explicit materials or materials that are discriminatory, hateful or threatening).

Employees should be mindful of the fact that SGT retains and exercises the right to access, review, monitor and disclose any information transmitted, received or stored using Company electronic equipment and information systems, with or without an employee’s or third party’s knowledge, consent or approval and in accordance with applicable law, at all times. Employees and third parties should have no expectation of privacy in connection with Company equipment or systems.

Proprietary Data & Confidentiality

One of SGT’s most important assets is its information. Each employee who has received or has access to proprietary information should take great care to keep this information Company private. In addition, because we interact with other companies and organizations, we may be aware or being given custody of proprietary or competition-sensitive data from customers before that information has been made available to the public. You must treat this information in the same manner as you are required to treat SGT proprietary information. There may even be times when you must treat as private the fact that we have an interest in, or are involved with, another company. In all cases, we cannot accept, use, or disclose competitive or proprietary data unless properly authorized.

Confidential or proprietary information may include, but is not limited to:

• details concerning a company’s organization and equipment, prices, sales, profits, markets, customers and other matters of business;
• information on manufacturing or research and development; and
• internal reporting figures.

The obligation to maintain confidentiality may extend beyond the termination of the relevant relationship since the disclosure of confidential information could cause harm to SGT’s business, clients or customers no matter when it is disclosed. Materials that contain proprietary information, such as memos, notebooks, computer disks and laptop computers, must be stored securely at all times.

Data Protection & Data Security

Access to the Intranet and Internet and other electronic business dealings are all crucial to the effectiveness of each and every one of us and for the success of the business as a whole. However, the advantages of electronic communication are tied to risks in terms of personal privacy protection and data security. Effective foresight with regard to these risks is an important component of data governance, information technology management, the leadership function, and also the behavior of each individual.

Personal data may only be collected, processed or used insofar as it is necessary for predetermined, clear and legitimate purposes. In addition, personal data must be maintained in a secure manner and appropriate precautions should be taken when transmitting it. High standards must be ensured with regard to data quality and technical protection against unauthorized access. The use of this data must be transparent for those concerned and the rights of those concerned must be safeguarded with regard to use and correction of information and, if applicable, to objections pertaining to blocking, and deletion of information.

In all cases, employees must be aware of – and abide by - applicable laws and obligations to protect the privacy of others.

Insider Trading Rules

People who have inside information with regard to SGT, another part of Siemens or another company, such as a customer, supplier or joint venture partner whose securities are traded on a stock are not allowed to trade in these companies securities (shares of stock). Inside information is any specific information which is not public relating to Siemens or such other issuer of securities, which, if it became publicly known, would likely have a significant effect on the price of the security. Such a situation exists if a reasonable investor would view the information as likely to have an impact on the price of the security. It would also exist if a reasonable investor would take the information into account in making an investment decision. Inside information may be acquired as a result of an employee’s position and responsibilities or inadvertently and includes non-public information about such things as:

• financial results
• financial plans or budgets
• dividend changes
• significant mergers or acquisitions
• divestitures
• particularly important contract awards or strategic plans
• major developments in litigation
• technical or product developments
• major management changes, joint ventures and major business agreements
• business relationships

Inside information must not be disclosed or made available to a third party without authority to do so. The disclosure of inside information is unauthorized whenever it is made outside the normal scope of an insider’s work functions or professional duties, or in fulfilling other duties on behalf of the issuer. This applies both to information disclosed within Siemens and to information disclosed outside Siemens, including to journalists, financial analysts, customers, consultants, family members or friends. Furthermore, employees must always make sure that insider-relevant information is secured so that unauthorized persons cannot gain access to it.

In addition, persons who have inside information are not allowed to recommend that a third party acquire or dispose securities for which that information is relevant, or to otherwise induce a third party to do so. Managers can be held personally liable for damages in some cases if an employee violates insider trading rules and proper supervision could have prevented the violation.

Management, Responsibility & Supervision

The culture of integrity and compliance in an organization starts at the top and is a key part of SGT management’s duties of motivation and supervision. Managers bear responsibility for all employees whose leadership is entrusted to them and must earn their team’s respect through exemplary personal behavior, performance, openness and social competence. This means, among other things, that each manager must emphasize the importance of ethical conduct and compliance, make them regular topics of everyday business and promote them through personal leadership and training.

SGT managers shall also be accessible in case employees wish to raise compliance concerns, ask questions or discuss a professional problem. It is the responsibility of all managers to see to it that there are no violations of laws and other regulations within their area of responsibility that their supervision could have prevented. Leaders are responsible even if they delegate certain tasks and should:

• Carefully select employees based on their personal and professional qualifications and suitability. The duty of due care increases with the significance of the task the employee must perform (duty of selection).
• Give precise, complete and binding instructions to employees, especially with regard to compliance with the policies, procedures, and government laws and regulations (duty to give instructions).
• Ensure that compliance with the law is continuously monitored (duty of monitoring).
• Clearly communicate to employees the importance of integrity and compliance in everyday business. Managers must also communicate that violations of the law are unacceptable and will have negative employment consequences (duty of communication).