BUSINESS CONDUCT POLICIES

PROMOTING A CULTURE OF PERFORMANCE WITH INTEGRITY

Business Conduct Policies Summary

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Table of Contents

Introduction................................................................................................................................................. 1

Ethical & Legal Business Conduct ............................................................................................................ 2

Accounting Matters & Complaints/Books & Records ................................................................................ 3

Anti-Bribery/Anti-Corruption ...................................................................................................................... 3

Antitrust & Fair Competition ...................................................................................................................... 3

Confidential Information ............................................................................................................................. 3

Conflict of Interest ...................................................................................................................................... 3

Corporate Responsibility ............................................................................................................................ 4

Discrimination ............................................................................................................................................. 4

Environmental, Health & Safety ................................................................................................................ 4

Export Control & Illegal Boycott ................................................................................................................. 4

Gifts, Favors, & Entertainment ................................................................................................................... 4

Government Contracting ............................................................................................................................ 5

Harassment ................................................................................................................................................ 5

Improper Use or Theft of Company Property or Resources ...................................................................... 6

Insider Trading & Securities Law ............................................................................................................... 6

Lobbying/Political Contributions ................................................................................................................. 6

Privacy & Data Protection ......................................................................................................................... 6

Records & Information Management ......................................................................................................... 6

Retaliatory Behavior ................................................................................................................................... 6

Substance Abuse ....................................................................................................................................... 6

Timekeeping Practices ............................................................................................................................... 7

Workplace Violence ................................................................................................................................... 7

Resources .................................................................................................................................................. 8

Business Conduct Policies Summary

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Introduction

How This Document Will Help You At CSC, we strive to create and maintain a culture of integrity and compliance in all business activities. As part of our commitment to a culture of integrity, we must know and understand CSC policies that address business conduct. We must recognize the boundaries of our actions, perform with integrity, and take every precaution to ensure that misconduct does not occur.

CSC’s business conduct policies describe our position on the many ethics and compliance subjects addressed in our Code of Business Conduct. They are intended to set expectations, drive consistent behaviors, and establish certain standards of employee conduct. When we follow the business conduct policies, we do our part to sustain a culture of performance with integrity, and to reduce the risk of unlawful or otherwise noncompliant actions in the workplace.

This document summarizes the policies incorporated into CSC’s Code of Business Conduct (Code) that are specific to addressing conduct for ethical and legal compliance. Like the Code, this summary of Business Conduct Policies will help you stay informed about policies, which impact your daily work activities and position responsibilities, and help you make the right decisions. Speak Up and Make a Difference Our Code applies equally to all CSC directors, officers, and employees. The Code also applies to our subsidiaries, business partners, suppliers, agents or others acting on the company’s behalf. Anyone who is involved with CSC’s business is responsible to report known or suspected ethical and/or legal misconduct, including violations of the Code, noncompliance with CSC policy, and violations of the law in any jurisdiction where CSC operates. The following channels are available for ethical advice, reporting misconduct, or questions about BusinessConduct Policies:

• Your CSC supervisor or manager (employees) • Your CSC department or function head (employees) • Your CSC human resources representative (employees) • CSC’s Ethics and Compliance Office, ethics@csc.com • The CSC OpenLine, by phone or Web at www.cscopenline.ethicspoint.com (OpenLine is a 24/7

confidential resource for ethics advice and reporting misconduct) CSC policy forbids retaliation of any kind, either direct or indirect, toward any employee who in good faith uses CSC OpenLine or any other reporting method to raise compliance and ethics-related issues, or to question any other employee's professional or personal conduct. Questions Contact CSC’s Ethics and Compliance Office (ECO) at ethics@csc.com. The ECO is committed to promoting throughout the global CSC community a culture of performance with integrity that encourages ethical conduct, reinforces the CLEAR corporate values, and drives compliance with the Code of Business Conduct, internal policies, and the law.

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Note: If a specific provision of a Business Conduct Policy directly conflicts with applicable country law, regulation, or labor agreement, then the relevant country law, regulation, or labor agreement, will supersede that section, but the remainder of the Policy will remain in effect.

CSC shall pursue and conduct all of its business everywhere in strict accordance with the highest standards of ethics and laws of the United States and other nations, and their states and localities. CSC’s standing as an ethical company is a critical asset that all directors, officers, managers, and employees are to protect at all times. Officers, executives, managers, and supervisors of the company shall strive as ethical leaders to create and maintain a culture of integrity and compliance in all business activities, in all places, and at all times. The ECO, under the authority of the Chief Ethics and Compliance Officer, is chartered by the Board of Directors to carry out the following responsibilities:

Ethical & Legal Business Conduct

• Ethical Culture – Promote an organizational culture that encourages ethical conduct and a commitment to compliance with CSC’s Code of Business Conduct, with internal company policies, and with the law.

• Prevention, Detection, Investigation – Exercise due diligence to prevent and detect criminal and unethical conduct; coordinate investigations of known or suspected criminal and unethical conduct.

• Code of Business Conduct – Create, maintain, distribute, and enforce CSC’s Code Business Conduct, which shall apply equally to all directors, officers/executives, managers, employees, and representatives of CSC and its subsidiaries around the world.

• Business Conduct Policies – Create, maintain, distribute, and enforce business conduct and other applicable management policy statements, standards, guidelines, and related procedures.

• Communications and Training – Publicize and make available to all directors, officers/ executives, managers, employees, and representatives of CSC and its subsidiaries awareness and training programs focusing on the Code, on the business conduct policies, and on other relevant policies.

• Compliance Risk Assessment and Effectiveness – Monitor, audit, assess risk, and otherwise evaluate global Program effectiveness. Provide risk assessment, policy, training, effectiveness, and other support to ensure the appropriate capability and maturity of CSC’s several compliance functions.

• OpenLine Administration – Operate and publicize globally CSC’s OpenLine, which shall be made available for all directors, officers/executives, managers, employees, and representatives of CSC around the world to report known or suspected violations of the Code, internal policy, and the law and/or to seek ethical advice and guidance.

• Management and Board Reporting – Report to management and the Board on the activities and effectiveness of the Ethics and Compliance Program.

CSC’s management shall establish and periodically convene an Ethics Committee to review ethics and compliance program activities, to monitor the operation and activity of CSC’s OpenLine, to direct and/or monitor ethics and compliance audits and investigations, and to be knowledgeable about ECO operations. All CSC employees shall observe and preserve CSC’s CLEAR Values, make decisions and choices that are consistent with these values, and comply with applicable internal policies and the law in all places where CSC does or seeks to do business.

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CSC maintains a finance and accounting manual that addresses expectations for accounting and financial reporting practices that meet the highest standards of professional ethics, and which comply strictly with the laws and regulations of the United States and other applicable legal regimes in jurisdictions throughout the global CSC community. This manual contains many accounting policies, related procedures, and guidelines that reflect, at a minimum, generally accepted accounting principles as well as a number of standard practices, developed and audited over time, that reflect the proper accounting treatment of circumstances unique to our business. Our suite of accounting and financial reporting policies cover all the topics germane to CSC’s business as a multinational provider of IT services and solutions.

Accounting Matters & Complaints/Books & Records

CSC will compete fairly for business solely on the merits of its competitive offerings. Employees are prohibited from bribing anyone to obtain, retain, or direct business, or to secure any other improper advantage.

Anti-Bribery/Anti-Corruption

Neither CSC nor any of its associated persons, commercial intermediaries, or other third-parties will make or be a party to any improper payments. Third-party commercial intermediaries will be engaged only with a written agreement and only after a satisfactory evaluation of a comprehensive, risk-based, independent due diligence inquiry regarding business integrity.

CSC policy requires that all business development gift and/or hospitality expenditures be recorded accurately and completely in CSC’s books and records, where no false, misleading, incomplete, inaccurate, or artificial entries are to be knowingly be made for any reason. All gifts and expenditures must comply with CSC’s Mandatory Business Development Gift and Hospitality Expenditure Rules and must follow a detailed authorization and approval process.

The offering or accepting of a kickback is a violation of CSC's Code of Business Conduct.

CSC is committed to the principles of fair competition and the regulation of activities that would violate long-standing antitrust protections. As such, CSC’s policy requires compliance with the laws governing economic regulation and the preservation of a competitive and free enterprise system.

Antitrust & Fair Competition

CSC policy requires that all of the company’s public disclosures and all contact between CSC and the news media or industry analysts be overseen by Corporate Communications. Employees are expected to be aware of and to manage security, reputational, and legal risks associated with their communications—including on social media—to prevent (i) the misuse, loss, or other unauthorized disclosure of any sensitive data of CSC, our employees, or our customers, vendors, and business partners, (ii) violations of law, or (iii) breaches of contract related to the compromise of confidential customer information.

Confidential Information

CSC employees are required to avoid situations that cause a conflict between their personal interest and the interests of the company, as this may compromise their objectivity and judgment with CSC business. Employees must investigate their own affairs and ask questions to their managers, Human Resources, or the

Conflict of Interest

Ethics and Compliance Office (ECO) when there is uncertainty about a situation. When these situations or similar ones arise, employees must promptly disclose the potential conflict to avoid any problems. CSC employees who are involved in the procurement of goods and services shall make reasonable efforts to determine that CSC approved vendors are not owned or controlled by CSC employees or relatives of CSC employees.

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CSC will conduct our business in a sustainable and profitable way for all internal and external company shareholders and stakeholders. Our shared values guide the choices we make each day, and support our commitment to a responsible, sustainable global business operation. A record of our global corporate responsibility activities are captured in our

Corporate Responsibility

annual report. DiscriminationCSC policy prohibits unlawful discrimination in its management practices on the basis of race, color, religious creed, national origin, citizenship, marital status, sex, sexual orientation/gender identity, being over age forty, disability, and protected veteran status. These management practices include, but are not limited to, recruitment, selection, job assignment, subcontracting/procurement of goods and services, transfer, promotion/demotion, layoff, return from layoff, discipline including termination, training, education, tuition, social and recreational programs, compensation and benefits.

Environmental, Health & SafetyCSC will comply with all laws and government regulations addressing the environment and the health and safety of its employees and other persons visiting or working at its sites.

CSC is also committed to maintaining the environmental sustainability of its work locations and the communities in which they are situated. The company will actively sponsor, design, implement, and maintain programs to address environmental, health, and safety management and compliance, and environmental sustainability and green initiatives.

CSC’s role as a global provider of information technology services and products requires an awareness for and compliance with international trade laws. This includes laws covering the export, re-export and import of technology, data, goods, software and hardware, and prohibitions on observance of boycott practices of certain countries. As such, CSC policy requires compliance with the laws, regulations, and directives concerning international trade in all jurisdictions throughout the global CSC community.

Export Control & Illegal Boycott

All employees must conduct company business in an ethical manner and avoid situations in which their individual interests conflict with or appear to conflict with the interests of the company. Employees may accept modest meals, refreshments, entertainment, or gifts, but must not accept anything that might be considered excessive or intended to influence. Employees with direct procurement-related responsibilities may not accept any items from suppliers or vendors other than token marketing items. The following exchange practices are generally considered acceptable:

Gifts, Favors, & Entertainment

• The exchange is neither illegal nor a violation of either party’s internal policy

• The exchange is a modest show of courtesy appropriate to the relationship shared

• The exchange is infrequent and unsolicited

• The exchange is not one of cash or cash equivalents, including loans

• CSC is not participating in a public tender or commercial bid process at the time of the exchange

• Personal funds of CSC employees are not used to pay for the exchange

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CSC requires that all business development gift and/or hospitality expenditures be recorded accurately and completely in CSC’s books and records, where no false, misleading, incomplete, inaccurate, or artificial entries are to be knowingly be made for any reason. All gifts and expenditures must comply with CSC’s Mandatory Business Development Gift and Hospitality Expenditure Rules:

• Gifts and hospitality must never violate the local laws or regulations of the jurisdiction in which they are offered. They must never violate the ethics, gift, and hospitality rules by which local government officials are to abide. As well, they must never violate the internal rules or policies of any commercial customer or prospective customer.

• Gifts and hospitality must never be offered to gain an improper business advantage or to influence official action/inaction.

• Gifts and hospitality must always be provided in connection with a bona fide and legitimate business purpose.

• In the case specifically of gifts, absent a bona fide and legitimate business purpose, they may also be given in connection with a commonly recognized gift-giving holiday or event provided they are reasonable, customary, and commensurate with generally accepted standards for professional courtesy in the country where they are given.

• Gifts and hospitality must always be provided openly and transparently. They must always be given in good faith and without the expectation of reciprocity. Un-reimbursed personal funds of CSC employees must never be used to provide gifts and/or hospitality that would otherwise be prohibited by this policy and implementing procedure.

• Gifts and hospitality must never be provided with such regularity or frequency that: − They create an appearance of impropriety − Their intent may be reasonably misunderstood by the recipient or by others − They undermine the purposes of these mandatory rules, this policy and implementing

procedure, or transnational bribery and anti-corruption statutes

• Gifts and hospitality must always be recorded accurately and fairly in CSC’s books and records

CSC is committed to compliance with the many laws and regulatory compliance obligations that govern the procurement, accounting, billing,

Government Contracting

political contributions, anticorruption rules, and other unique requirements specific to our public sector clients. Our policies require all CSC employees who are responsible for relationships with government customers and who work on government contracts to adhere to these requirements, in all CSC jurisdictions. Our policies remind CSC employees that they must not make any attempt to influence a government employee or member of a governmental body other than through the standard preparation and discussion of CSC cost and technical proposals in conformance with procurement regulations. As well, employees must not discuss employment opportunities with government personnel without first seeking guidance and approval from CSC’s Legal Department.

CSC commits to ensure an environment free from sexual harassment as well as harassment on account of an individual's race, color, religious creed, national origin, citizenship, marital status, sex, sexual orientation/gender identity, being over age forty, genetic information, disability, and protected veteran status. Such harassment, whether verbal, physical or visual, is prohibited by the company.

Harassment

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Employees are prohibited from the unauthorized removal, use, alteration, duplication, consumption, discarding, or other misuse of any CSC facility, equipment, supplies or property on CSC or client premises or without proper prior authorization. CSC resources include the use of electronic communication and computers.

Improper Use or Theft of Company Property or Resources

CSC is committed to preserving confidentiality of material, nonpublic company and client information. Our policy prohibits unlawful tipping, recommendations, or other “insider trading” activity while in possession of material nonpublic information regarding the issuer of those securities. Information (either positive or negative) is considered “material” if it could reasonably be expected to affect a stock or other security’s market price and is helpful to an investor in advance of making an investment decision.

Insider Trading

Lobbying/Political ContributionsConsistent with federal law, CSC does not contribute corporate funds to federal candidates, national political party committees or other federal political committees. Such contributions may be made only by the CSC Political Action Committee (PAC). Company funds may be used, where legally permissible and with managerial authorization, to participate in the election of state and local candidates who share CSC’s public policy views or in support of state and local ballot measures having an impact on the industry.

CSC and its employees shall comply with all privacy and data protection laws and regulations in the jurisdictions where CSC conducts business, and will monitor and otherwise protect the confidential employee, client, and business partner data to which we are entrusted. This commitment reflects the value we place on earning and maintaining the trust of our employees, clients, business partners, and others whose personal data or other confidential information is shared with us.

Privacy & Data Protection

All of CSC’s records and information assets shall be managed in a legally valid manner from the point of creation or receipt to the point of final disposition.

Records & Information Management

CSC is committed to engaging in ethical business practices, complying with the laws in all countries where CSC conducts business, and providing a proper and professional work environment. The company requires its management and supervisory personnel to foster a culture of integrity that encourages employees to feel comfortable speaking up about known or suspected Code of Business Conduct or policy violations and non-compliance with legal or regulatory obligations. In many circumstances and in many countries in which CSC does business, it is illegal to retaliate against employees who report instances of misconduct or who participate in internal investigations. In keeping with the obligation to speak up, CSC policy forbids any direct or indirect retaliation against employees who, in good faith, report a known or suspected violation or who participate in a management-led internal investigation.

Retaliatory Behavior

CSC policy reflects a commitment to maintaining a productive workforce and safe work environment that is free of illegal or unauthorized use of controlled substances or alcohol in the workplace.

Substance Abuse

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Employees will observe the highest standards of business and ethical conduct when recording work time, and must personally complete an accurate weekly time record.

Timekeeping Practices

CSC does not allow threatening behavior (physical, verbal, written, or electronic) in the workplace. Employees and our visitors at all of our worksites are encouraged to report to a member of management, Security, or Human Resources, any unusual behavior, which could be considered threatening or indicative of potential violence, or any behavior that might pose a potential threat of harm to any person or property, even though an actual threat may not be apparent.

Workplace Violence

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Contact the Ethics and Compliance Office

Resources

ethics@csc.com Employees can learn more about Ethics and Compliance programs on C3 https://c3.csc.com/groups/ethics Link to CSC’s Code of Business Conduct http://assets1.csc.com/governance/downloads/EthicsStandards.pdf Link to the CSC OpenLine http://www.cscopenline.ethicspoint.com

Business Conduct Policies Management Policy Statements • MPS 001 - Ethical and Legal Business

Conduct • MPS 003 - Acceptance of Gifts and Gratuities

by CSC Employees • MPS 005 - Corporate Responsibility • MPS 010 - Global Anti-Corruption and

Improper Payments • MPS 030 - Social Media • MPS 301 - Environmental, Health and Safety

Programs • MPS 404 - Third-Party Commercial

Intermediary Selection – Due Diligence – Contracting – and Administration

• MPS 408 - Business Development Gift and Hospitality Expenditures and Related Bookkeeping

• MPS 503 - Political Contributions • MPS 505 - Compliance with Antitrust Laws • MPS 506 - International Trade • MPS 507 - Data Protection • MPS 508 - Insider Trading • MPS 509 - Integrity in Government

Procurements: Employment Discussions with and Hiring of Federal Employees as Employees or Consultants

• MPS 609 - Encryption of Critical or Sensitive Information

• MPS 706 - Financial Disclosures to the Public • MPS 714 - Employee Timekeeping • MPS 715 - Summary of Internal Control

Policies • MPS 802 - Conflicts of Interest • MPS 804 - Acceptance of Gifts and Gratuities • MPS 810 - Ethics of Buying • MPS 814 - Improper Business Practices –

Kickbacks • MPS 902 - Records and Information

Management Human Resources Policies • HRMP 202 - Equal Employment Opportunity • HRMP 203 - Harassment • HRMP 205 - Open Door Policy • HRMP 209 - Personal Conflict of Interest • HRMP 210 - Employment of Relatives • HRMP 222 - Drug and Alcohol Abuse • HRMP 223 - Use of Electronic Communication

Media

Dec 2013

© 2013 Computer Sciences Corporation. All rights reserved December 2013

Business Unit Name Business Address City, State, Zip Code Country +0.000.000.000

World CSC Headquarters

The Americas 3170 Fairview Park Drive Falls Church, Virginia 22042 United States +1.703.876.1000

Asia 20 Anson Road #11-01 Twenty Anson Singapore 079912 Republic of Singapore +65.6221.9095

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Europe, Middle East, Africa Royal Pavilion Wellesley Road Aldershot, Hampshire GU11 1PZ United Kingdom +44(0)1252.534000

About CSC The mission of CSC is to be a global leader in providing technology-enabled business solutions and services.

With the broadest range of capabilities, CSC offers clients the solutions they need to manage complexity, focus on core businesses, collaborate with partners and clients and improve operations.

CSC makes a special point of understanding its clients and provides experts with real-world experience to work with them. CSC leads with an informed point of view while still offering client choice.

For more than 50 years, clients in industries and governments worldwide have trusted CSC with their business process and information systems outsourcing, systems integration and consulting needs.

The company trades on the New York Stock Exchange under the symbol “CSC.”