Spectrum has developed a policy to administer the regulatory elements of the Business Ethics Program (BEP). Primary elements of the Ethics policy include:

• Establish and maintain Code of Business Ethics & Conduct
• Design internal controls to prevent and identify violations
• Conduct annual internal review of Spectrum ethics policy, procedures and internal controls Ethics reporting and fraud hotline posters prominently displayed in employee common areas at all locations where government contract work is performed
• Investigation of all potential violations of the ethics policy and program

To ensure that we are meeting our objective to integrate the Business Ethics Program into our culture, evaluation and training tools have been implemented.

Note that the Code of Conduct is intended to guide behaviors, while company policies and procedures dictate requirements. Every employee must read through the following material and understand what it means to work as a representative of Spectrum. All employees are responsible for knowing and adhering to policies related to our ethical standards at Spectrum.