Code of Conduct

Leaders and managers must model expected behavior and demonstrate ethical leadership

• Lead by example. Act with integrity at all times.
• Act within the law at all times.
• Encourage reporting of all violations of the Code and assist fully and timely in any investigations as requested.

Raise concerns

If you suspect that there has been a violation of IXS' policies, the Code or the law, report it by contacting your manager or your Human Resources representative. For those who may be uncomfortable reporting through established internal channels, reports can be made by calling our IXS Ethics Line and speaking to trained, non-IXS personnel who are available 24 hours a day, seven days a week, or via our web-based reporting system. Most countries encourage anonymous reporting therefore our systems allow for anonymous reporting where permitted. Unless it is part of your assigned job function, do not conduct your own investigation. All investigations are confidential and conducted on a "need to know" basis. We do not allow retaliation or adverse action against any associate who reports a suspected violation in good faith or cooperates in an investigation. Retaliation itself is a violation of the Code, and we will respond accordingly. In some locations outside of the United States, anonymous reporting may not be allowed or reporting of suspected violations may be limited to certain areas of concern. If there are limitations that exist in your location, our IXS Ethics Line complies with the requirements of local laws.

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Investigations

When you come forward, you make a difference. All reports are followed up promptly, professionally and diligently with the highest degree of confidentiality possible. Every reported concern is investigated and reviewed. Corrective action is taken as appropriate. Reports should only be made in good faith. This means that you believe the information provided is truthful and you are not intentionally making any false or misleading statements. Like any other misconduct, intentionally filing a report in bad faith may result in disciplinary action.

We are committed to honest and ethical business practices

We win business by competing lawfully in the marketplace. Our reputation as an honest competitor is very important. Our commitment to fairness includes respecting the rights of our competitors, as well as the expectation that our competitors will respect our rights. We compete aggressively based on the merits of our products and services. We do not make misleading statements about our competitors' products or services, but rather focus our efforts on the benefits our customers receive by partnering with us.

Competition laws regulate our relationships with our customers as well as our competitors. As a general rule, we limit our contact with competitors. We do not discuss our pricing, bids, terms of sale or territories with any competitor. Collusion among competitors is illegal in almost all countries and violations carry serious penalties such as fines and imprisonment. Suppliers can also be competitors. Use extra caution in such situations. The laws related to fair competition are many, complicated and vary by region. We never solicit employees of competitors or other companies for the purpose of gaining access to their proprietary information.

We support human rights around the world, and will comply with all applicable laws regarding the treatment of our associates and other stakeholders. We will not tolerate child or forced labor anywhere and we will not do business with any company that does. We respect associates' freedom of association and all other workplace rights.

Our suppliers are essential partners in our success. The quality of our supplier relationships affects the quality of our customer relationships. Supplier relationships must be honest and fair. Accordingly, we select suppliers, subcontractors and vendors on the basis of quality, technical excellence, price, delivery, service and maintenance of adequate sources of supply. We also expect our suppliers to comply with laws and our standards relating to labor, environment, health and safety, intellectual property rights, anti-corruption and other matters.

We respect the intellectual property rights of others

Intellectual property includes trademarks, copyrights, patents and trade secrets. Trade secrets can include proprietary information and know-how. We will not use the intellectual property of another without the right to do so. If a customer or other party entrusts us with their intellectual property, we will comply with all contractual commitments and restrictions regarding its use. We do not attempt to obtain the confidential intellectual property of another for inappropriate use.

We prevent bribery

We never offer or make bribes to secure business. Anything of value can be considered a bribe if it is intended or could be perceived to influence a business or governmental decision or action. Bribes are not just money. Trips, jobs, favors and similar valuable considerations can be bribes. We are committed to complying with anti-corruption laws that prohibit bribes, kickbacks or other corrupt actions to obtain or retain business or obtain improper advantage. Many countries in which we do business have specific laws against bribery. All associates, as well as our Board of Directors, are expected to comply with applicable anti-corruption laws. Suppliers, agents and consultants hired to act on our behalf are prohibited from directly or indirectly receiving or offering any form of bribe, kickback or other corrupt payment, to or from our associates, public officials or other private or public actors, with the intention to obtain or retain business or any other improper advantage.

We conduct reasonable hospitality

Hospitality in the form of gifts and entertainment are common in the business setting. We use moderation and discretion when giving or accepting them. Items of nominal value, such as cab fare, reasonable meals and entertainment expenses, or company promotional items are generally acceptable. The larger the gift, however, the more likely it will be viewed as given with an improper purpose. We may not give or accept any gift if it is intended, or could be perceived, to influence business or governmental decisions or actions. For example, payment of travel costs associated with training or facility inspections are generally viewed as appropriate, even where modest entertainment is provided. However, including the travel costs of accompanying family members or friends, or payment for lavish meals or sightseeing trips would not be appropriate.

We also take it upon ourselves to understand any limitations placed on our customers or others with whom we interact to be sure we abide by their policies as well.

We avoid conflicts of interest

Sometimes our personal circumstances can inadvertently affect our objectivity in performing our duties and responsibilities. Even the perception of a conflict could negatively affect you and our company, causing severe reputational harm. You are expected to disclose any potential conflicts to ensure transparency and to determine whether there is an actual conflict. Your disclosure of a potential conflict provides your management with information to clarify potential conflicts and resolve as appropriate.

We comply with export controls and customs laws

The ability to ship internationally is critical to our success. The United States and other governments impose legal restrictions on exports, re-exports and imports of goods. Accordingly, we comply with all U.S. export control laws as well as applicable laws of countries in which we do business.

Export controls apply not only to the physical shipment of goods, but also to the transfer or release of technical information, software or source code to foreign nationals in the U.S. or abroad. We always obtain export licenses when required by U.S. law or by the laws of countries in which we do business. The U.S. and other governments impose trade sanctions or embargoes on certain countries and regions as a matter of foreign policy. We will not conduct business with any sanctioned or embargoed regions unless the transactions are permissible under the laws of the U.S. and other applicable jurisdictions. Governments also prohibit business transactions with certain restricted parties that have been identified as being involved in terrorist and other illegal activities. We will not conduct business with any restricted parties.

We create business records that reflect the true nature of transactions and events

We rely on the accuracy of business transaction records to analyze and report our operations and make sound business decisions. It is also possible that our business records could end up being disclosed through litigation, government investigation or for other reasons. We never deliberately create a false record, falsify an existing record, or try to disguise what really happened. We also stick to the facts we know. Exaggeration, speculation and legal conclusions should be avoided. Our business records are used when we prepare our financial statements, tax returns and other regulatory and statistical reports. We comply with US Generally Accepted Accounting Principles (GAAP) and local accounting rules for our non-US financial reporting requirements. Any associate who supplies information for financial or tax purposes must provide it in a timely manner and certify the accuracy of the information.

We value and protect our ideas

Innovation is a differentiator in our industry. We will win new business when we have products that our competitors cannot offer due to intellectual property that we have developed and protected with patents, copyrights and trademarks. To protect our intellectual property, never disclose it to anyone outside of IXS unless you have prior written approval and it is covered by a non-disclosure agreement. Even within IXS, disclosure should be limited to those in a need-to-know position based on their job duties.

We respect each other

Our workforce allows us to compete in a global marketplace. We value a work environment that is free from intimidation or harassment. Harassment can take many forms, such as sexual advances or inappropriate comments, jokes, language or gestures. Harassment may also occur when the behavior of one or more associates creates a hostile or offensive work environment for others. Any form of harassment is unacceptable and must be reported immediately so corrective action can be taken.

We value equal opportunity

We select and place associates based on their qualifications for the work to be performed, considering accommodations as appropriate and needed, without regard to characteristics protected by law. We prohibit unlawful discrimination in full compliance with applicable laws.

We promote health and safety

We are committed to providing a reasonably safe and healthy work environment for our associates and visitors at all of our facilities. Our health and safety programs are based on the following principles:

• An active commitment to health and safety excellence.
• A business strategy using health and safety to create a competitive advantage.
• Compliance with all applicable laws and regulations and implementing prudent standards where none exist.
• Requiring each associate, contractor and visitor to take reasonable care of their own health and safety as well as that of others and to cooperate with health and safety programs that are in place.
• Striving for continuous improvement in our health and safety programs.

We value product integrity

Ensuring product integrity is essential. Our expectation is that you will speak up when becoming aware of a concern regarding our products and services. Ensuring we have a culture in which associates know they can bring such issues forward is essential.

You can bring product integrity concerns via our IXS Ethics Line. Reports can be made by calling IXS Ethics Line and speaking to trained, non-IXS personnel who are available 24 hours a day, seven days a week, or via our web-based reporting system. Both systems allow for anonymous reporting where permitted by local law.

We do not tolerate possession or use of alcohol, illegal drugs or controlled substances

For everyone's safety, using, possessing or being under the influence of alcohol, illegal drugs or controlled substances without a prescription while engaged in any job-related activity is strictly prohibited. Being at work in an unfit condition due to misuse of legal drugs is also unacceptable.

We respect associate privacy

We are committed to protecting associates' confidential, personal information as defined by applicable law. Access to confidential, personal information and records is limited to our associates whose function and responsibilities include the handling of such personal data, and who have a business need for that information.

We promote the safe use of technology

We discourage the use of any phone or other handheld electronic device or any other object if it will distract you from driving, operating equipment, or otherwise acting in a safe and responsible manner.

We cooperate responsibly with law enforcement and government

If any disclosure about IXS is requested by a government or law enforcement officer, you must promptly notify and consult with your BU President. It is our policy to deal honestly with government representatives and to comply with reasonable and valid government requests for information and processes. Associates must be truthful in their dealings with the government and must not direct or encourage anyone to give false or misleading information to any government representative.

We comply with all applicable laws wherever IXS does business

We operate businesses in many countries and are subject to the laws of many jurisdictions. Some laws extend beyond the border of a specific country. For example, US laws concerning imports and exports, bribery and trade sanctions apply not only to our US operations, but to our operations around the world. We are each responsible for following all of the laws that apply to our businesses. This obligation extends to our activities with others. At no time will we act in a manner that would assist another party to engage in illegal activity. We cannot take actions which we know, or ought to know, will assist others in violating the law.

We comply with international business regulations

As our business becomes more global and complex, full compliance with import and export regulations becomes a common issue. Accurate classification, value and country of origin documentation is required for all cross-border transactions.

Many countries maintain trade sanctions restricting with whom we may do business or where we may do business. We should never engage in a cross-border transaction without first having a full understanding of how these trade laws affect us. Even the shipment of test parts, software or data across a border is highly regulated. Depending on the circumstances, an export license may be required before we can:

• Conduct a plant tour with a foreign national present.
• Provide training courses or materials overseas or to foreign nationals visiting your location (for example, a foreign national visiting in the US).
• Send electronic information to a foreign national.
• Present at a meeting with a foreign national present.

From time to time, the U.S., the European Union, and other countries will impose trade embargoes and other trade restrictions against specific countries. We will abide by all such restrictions. US law also prohibits us from participating in any foreign boycott or embargo that is not approved by the US government. We must report any requests to participate in boycotts or embargoes to the US authorities. Not doing business with a "blacklisted" company is one example. Sales of products or services intended for military purposes receive special attention. If any such transaction is contemplated, prior review is required before any discussions are conducted or actions taken.

We use social media responsibly

We have the ability to connect with everyone, everywhere throughout the world. We can communicate and share ideas with the touch of a button. We should always ensure that our use of personal wireless devices and the participation in online social networking show professional judgment, responsibility and consideration for others. Do not let it interfere with your productivity. Before posting content, consider if you would find it acceptable if the information was published in a major newspaper. Never imply that you have the authority to speak for IXS. And never disclose company confidential information in social media.

We support the communities where we live and work

We can make a difference in the communities where we live and work. The contribution of our time, talent and resources can assist in making measurable progress against difficult issues. We hold ourselves to high standards and encourage others to do the same.

We strive to reduce the environmental impact of our operations

We aim to go beyond environmental compliance. We strive to help conserve natural resources and act to continuously improve our performance through waste minimization, efficient resource usage and other measures relevant to our business.