BBNC Code of Ethics Code of Ethics_Light_final_joomag 2 | Page 3

Ta b l e o f CONTENTS A MESSAGE FROM JASON METROKIN 2 OUR CULTURE AND VALUES 3 HOW TO USE THE CODE TO MAKE GOOD DECISIONS 5 Purpose and Applicability 7 SPEAK UP, SPEAK OUT 8 9 9 9 [i]nfoNet NTEGRITY WITH EACH OTHER 10 Fair Employment Practices 11 12 Sexual Harassment Discrimination, Harassment or Bullying 12 Conflicts of Interest 13 NTEGRITY IN THE COMPANY 14 Drug and Alcohol-Free Workplace 15 Property of the Company 15 Government Furnished Property 15 Financial Records 16 Time Charging & Recording Costs 16 Records Management 17 Health and Safety 18 Confidential Business Information & Non-Disclosure 18 Antitrust 19 Environment 19 NTEGRITY IN TECHNOLOGY 20 Data Security 21 22 Social Media Computers & Information Technology 22 NTEGRITY IN DEALING WITH OTHERS 23 Interference With an Audit Political Contributions & Activities Contract Compliance Gratuities, Gifts & Tips Anti-Kickback Act Avoidance of Restrictions on Trade Consultant Compliance with Code of Ethics & Business Conduct Proposal Preparation NTEGRITY AROUND THE GLOBE Upholding our Integrity Worldwide Foreign Corrupt Practices Act Combatting Human Trafficking Export Control Restrictions Anti-Boycott Act NTEGRITY IN GOVERNMENT CONTRACTING Procurement Integrity Hiring of Government & Former Government Employees Prohibited Contractual Relationships Industrial Security & Classified Information Byrd Amendment False Claims / False Statements NTEGRITY WITH INVESTIGATIONS Government Investigations Investigation of Misconduct RESOURCES Policies Training BBNC Compliance Department BBNC Code of Ethics | Ethics Hotline: 1.866.513.7078 | Effective May 17, 2019 | www.bbnc.net 24 25 26 26 27 28 28 29 30 31 32 33 34 34 35 37 38 38 39 40 41 42 43 43 44 44 44 44 1