Code ofConduct

2 Code of Conduct

Table of Contents

03 A Message From Our President and CEO.

04 Introduction

09 We Do Not Engage in Bribery or Corrupt Activities.

05 We Report Ethical Concerns.

06 We Maintain a Respectful, Inclusive, and Safe Work Environment.

07 We Conduct Business with Integrity.

1 1 We Comply with Export Control and Sanctions Laws.

14 We Protect the Guidehouse Reputation.

12 We Safeguard the Information and Assets Entrusted to Us.

3 Code of Conduct

At Guidehouse, our values of Integrity, Excellence, Innovation and Teamwork are the core to our culture and establish our standards of expected ethical behavior. The WAY we conduct our business is as important as the services we provide. We will not compromise our values to achieve our business objectives. By embodying these values into our business, we are helping to ensure our continued success and reputation.

This Code of Conduct provides guidance on critical policies and regulations that impact our business operations. At Guidehouse, we are all expected to abide by our Code and be accountable for our actions. While the Code cannot answer every question, it does show you where to go for guidance when the answer is not clear. If you are ever in doubt about the right course of action, or observe an action inconsistent with our values or Code, I strongly encourage you to raise the issue with your supervisor or to any of the many other resources available to you. Know that Guidehouse will not tolerate retaliation against anyone for asking questions or raising concerns in good faith.

Thank you for your ongoing commitment to living our values every day. I am proud of all that we have accomplished together and know that, together, we’ll continue to make a positive difference while building trust and preserving our reputation.

Scott McIntyre President and Chief Executive Officer

A Message From Our President and CEO.

4 Code of Conduct

Our values of Integrity, Excellence, Innovation and Teamwork are the foundation for the way we do business and our success depends on our unwavering commitment to conducting business ethically and in compliance with laws and regulations where we operate. As part of this commitment, all of us are expected to comply with the Guidehouse Code of Conduct.

Our Code provides a frame of reference that underpins the high standards of ethical behavior expected of all Guidehouse professionals. It is an important resource to assist us in navigating the professional standards, laws, regulations, and Guidehouse policies and practices that govern the way we conduct our business and work together to serve our clients and communities.

It is important to know that this Code applies to all Guidehouse personnel in every part of the business, level or area. In addition to our Code, our business partners and suppliers are subject to our Supplier Code of Conduct which is based on the same values as this Code.

Introduction All Guidehouse professionals are expected to read and be familiar with the content of this policy, which includes references to other Guidehouse policies and guidance that you must be familiar. All personnel have the responsibility to report concerns about possible violations of the Code, company policy, laws and regulations.

Guidehouse leaders, supervisors, and managers have the additional responsibilities of leading by example, creating a work environment that reflects our values of Integrity, Excellence, Innovation and Teamwork, holding their teams accountable for maintaining compliance, and strictly avoiding acts of retaliation or behavior that may be perceived by others as retaliation.

Violations of this policy may result in disciplinary action depending on the nature and severity of the violation, up to and including termination of employment.

5 Code of Conduct

We all have the obligation to speak up when something that doesn’t feel right. If you observe or suspect illegal or unethical behavior, you are expected to raise the issue to your engagement leader, sector leader, Human Capital representative, the Ethics Office, or the Office of General Counsel (OGC).

The Ethics Hotline is another resource for asking a question or raising a concern. All matters are taken seriously and handled confidentially—discussed only on a need-to-know basis. If you prefer, you may submit your report or concern anonymously to the Ethics Hotline.

You can contact the Ethics Hotline by calling 1-833-770-0009 (inside the US) or 1-800-603-2869 (outside the US).

You can also submit an anonymous report our hotline provider’s website at www.lighthouse-services.com/guidehouse.

• While Guidehouse offers these multiple channels to encourage open dialogue internally, you are also free to raise concerns or participate in an investigation by a federal, state or local agency or commission, as well as any self-regulatory authority.

• In addition, employees may use the Department of Defense Inspector General (DoD IG) Hotline at www.dodig.mil/hotline to report issues related to fraud, waste, abuse, and mismanagement for programs and personnel under the purview of the U. S. Department of Defense.

We Report Ethical Concerns.

For Further Guidance: Reporting Concerns Policy

Always keep in mind that it’s safe to speak

up at Guidehouse.

Retaliation against employees who raise concerns in good faith is strictly prohibited. If you report a concern, it will be handled with appropriate confidentiality and discussed with others only as needed or advisable under the circumstances.

6 Code of Conduct

Diversity, Equal Opportunity and Inclusion — We bring together employees with a wide variety of backgrounds, skills and cultures. We value different ideas, opinions, and experiences and are committed to sustaining a culture of inclusion and diversity. Combining a wealth of talent and resources creates the diverse and dynamic teams that consistently drive outstanding results. Diversity alone is not sufficient. Inclusion leverages the power of our differences to achieve our goals.

Equal Employment Opportunity — Guidehouse is an Equal Opportunity/Affirmative Action employer and committed to providing Equal Opportunity in Employment to all applicants and employees regardless of race, color, religion, sex, age, national origin, military status, veteran status, handicap, physical or mental disability, sexual orientation, gender identity, genetic information or any other characteristic protected by law. This commitment must be followed in all aspects of employment and personnel practices.

Promoting a Respectful, Harassment-Free Work Environment — Treating each other with respect, courtesy, and dignity is as important as the quality of our interactions with clients and business associates. We do not tolerate harassment, discrimination or retaliation.

We Maintain a Respectful, Inclusive, and Safe Work Environment.

Drugs and Alcohol in the Workplace — The firm is committed to providing and maintaining a safe, drug-free work environment that fosters productivity and service to our clients. Abuse of alcohol or any drug or other substance, whether legal or illegal, interferes with our professional responsibilities and obligations. It endangers ours and others’ health and safety, and it harms our purpose, reputation, and business.

Workplace Violence — Violent acts or threats of violence (whether directly or indirectly or made by words, gestures, or symbols) will not be tolerated. Workplace violence infringes on Guidehouse’s ability to provide a safe, productive workplace. This applies to threats made on firm or client property, anywhere on firm business, or at firm-sponsored events.

• If you have been the target of violence or threats of violence or have witnessed or learned of violent conduct or threats, please talk to a Human Capital representative or the Chief Human Capital Officer. If the situation is urgent and your personal safety is at risk, call 911 immediately and then alert Guidehouse Security and your local building security.

For Further Guidance: Drugs and Alcohol in the Workplace Policy

For Further Guidance: Non-Discrimination and Anti-Harassment PolicyEqual Employment Opportunity Policy

7 Code of Conduct

We Conduct Business with Integrity.

Our commitment to deliver excellence in a competitive business environment presents

challenges that we must meet with integrity. In all of our business conduct we must adhere

to both the letter and spirit of all applicable laws, regulations and firm policies.

Conflicts of Interest — Business relationships with clients, colleagues and business associates are encouraged, provided they do not violate the firm’s Relationships or Personal Conflicts of Interest policies or create real or perceived conflicts of interest. Conflicts of interest can also arise from outside activities and volunteerism, or through other market-facing relationships. Conflicts of interest can negatively impact our work, impair service quality, and lead to questions about our objectivity, particularly in the eyes of our regulators and the public.

• Guidehouse policy requires immediate disclosure of any relationships that may raise issues about objectivity, confidentiality, conflicts of interest, or favoritism. Should a situation or relationship present an actual, potential, or perceived conflict, take action. Disclose the facts, seek advice, and consult with the partner in charge of your business unit, office, or engagement, an appropriate Human Capital representative, or by contacting the Ethics Office.

For Further Guidance: Personal Conflicts of Interests PolicyRelationships Policy

Fair Competition — We promote our services through fair and accurate competitive comparisons. We exercise sound judgment and integrity, drawing the line between fair and unfair competitive practices. When gathering competitive data, we collect information from publicly available sources, but do not exchange sensitive information with competitors, such as pricing policies or salary data.

For Further Guidance: Anti-Trust and Fair Competition Policy

Insider Trading Laws — We do not engage in insider trading or tipping others. Inside information is nonpublic information about a company. It is illegal to trade securities on the basis of inside information or to advise others to do so based on information that you have obtained.

Licensing and Credentialing — Many of us require licensure, certification or credentialing in order to provide services to our clients. We are each personally responsible for meeting all licensing, registration, and certification requirements wherever we provide services to clients.

8 Code of Conduct

Self-Reporting of Suspension or Debarment — As a government contractor, the firm makes certain certifications and has reporting obligations related to the suspension or debarment status of the firm and our personnel.

All Guidehouse personnel must notify the Office of the General Counsel or the Ethics Office if they are notified of being subject to a potential suspension or debarment.

Mandatory Disclosure Rule — When conducting business with the federal government we are required to “timely disclose” to the government “credible evidence” of a violation of certain federal criminal laws, a violation of the civil False Claims Act, or the receipt of “significant overpayment(s)” under a government contract. Failure to comply with this rule can result in significant consequences, including suspension or debarment to the firm and/or its personnel. Contact the Office of the General Counsel for further guidance on this rule.

Accurate Record Keeping — We comply with US laws and regulations as they relate to internal firm operating and financial matters through:

• Accurate and proper completion of firm reports, including time and expense reports, vouchers, bills, financial statements, payroll and service records, measurement and performance records, and other essential data.

• Advising clients and suppliers of any clerical or accounting errors as soon as they emerge, as well as promptly correcting errors through credits, refunds, or other mutually acceptable means.

For Further Guidance: Labor Reporting and Timekeeping PolicyTravel and Expense Policy

Time and Expense Reporting — We each have a responsibility to record our time and expenses timely and accurately. Time and expense reporting drives billing, budgeting, and overall financial operations at the firm. It is also an important measure of the quality and value we deliver to our clients based on the complexity and level of risk associated with the work we perform.

• You should never be asked or pressured—or ask or pressure others—to inaccurately report time or expenses. Nor should the quality of your work be compromised due to budgetary constraints.

We Conduct Business with Integrity.

9 Code of Conduct

We Do Not Engage in Bribery or Corrupt Activities.

All of our interactions with third parties (whether clients, suppliers, or the government)

will be free from any corruption.

For Further Guidance: Gifts and Entertainment- Commercial PolicyGifts and Entertainment- Government Policy

Gifts and Entertainment — The exchange of modest, infrequent courtesies with clients, suppliers, business affiliates, and others can create goodwill, establish trust, and strengthen important relationships. However, we must distinguish between activities that help build business relationships, and activities that are—or appear to be—excessive, inappropriate, or intended to influence decisions that should be based solely on business considerations.

In addition, federal, state, local, and foreign laws generally prohibit us from providing and accepting gifts, entertainment, or other items of value, to or from a government official or employee. We must avoid creating an actual or perceived conflict of interest. We are strictly prohibited from offering anything of value in exchange for an official act by a government official or employee. The firm has zero tolerance for bribery and any other forms of corruption.

• Before offering or receiving anything of value to or from a government official or employee (or a relative of such government official or employee or other organization or individual because of their association with such government official or employee), Guidehouse personnel must obtain approval from the Ethics Office.

Recruiting and Hiring from the Government or Multilateral Entities — Guidehouse follows all applicable conflict of interest and government ethics laws, regulations, and policies that dictate how we may recruit and hire from government and multilateral entities. This includes, but is not limited to, any government or multilateral official or employee providing you their resume or initiating an employment discussion with you. This also includes any government or multilateral official or employee providing another individual’s resume (e.g., co-worker, relative, neighbor). Consult with the Ethics Office for guidance before having a conversation with someone in the government about working at Guidehouse.

For Further Guidance: Recruiting and Hiring Current and Former Government Officials or Employees Policy

10 Code of Conduct

For Further Guidance: Pay to Play Policy

We Do Not Engage in Bribery or Corrupt Activities.

Anti-Corruption — Trust and integrity are the foundation of our firm. We have zero tolerance for bribery and any other forms of corruption. We do not bribe or engage in corrupt practices with any government official or commercial party.

• Foreign Corrupt Practices Act — The US Foreign Corrupt Practices Act (FCPA) makes it illegal to make or offer payments or anything of value (monetary or non-monetary) to foreign government officials, directly or indirectly, to gain business or favorable government action.

Anti-Money Laundering — We do not support or engage in any form of money laundering activity. All Guidehouse personnel are expected to remain vigilant in identifying red flags and escalating them for investigation.

For Further Guidance: Anti-Money Laundering Policy

Lobbying — Guidehouse personnel that engage in lobbying activities on behalf of the firm to influence legislative, regulatory, or policy issues, including efforts to obtain contracts for the firm, must obtain

For Further Guidance: Anti-Corruption and Foreign Corrupt Practices Act Policy

pre-approval from Ethics. The firm may be required to register personnel engaging in these types of activities as lobbyists under federal, state and local laws.

Political Activities — The firm encourages our personnel to be involved in the political process—to support candidates and parties of their choice, on their own time, with their own funds and resources. However, as a contractor to federal, state, and local governments, we cannot make campaign contributions using firm funds or use firm resources to support candidates or political parties.

Political Contributions — Due to certain state and local legal requirements, there may be some restrictions and/or disclosure obligations related to personal political contributions. Therefore, the firm requires that before any partner, managing director, or Guidehouse Board member, their spouse/domestic partner or dependent children make a contribution to a political candidate that is to a current state or local official (even if running for a federal position) or someone running for a state or local position or committee, you must contact the Ethics Office to pre-clear contributions.

11 Code of Conduct

While we must respect cultural differences and business norms, we cannot violate applicable laws or regulations in the US or any jurisdiction in which we work or reside. Violation of these laws can result in fines, criminal penalties, and reputational harm for both you and the firm.

Export-Controlled Information — We will comply with regulations administered by various government agencies (including the Department of Commerce and the Department of State) related to the export of certain goods, services, technology or related “export controlled information” from the US.

For Further Guidance: Sanctions and Anti-Boycott Policy

Embargoed Countries and Restricted Parties — The US government maintains commercial embargoes against a number of countries and also restricts US persons from conducting business with certain restricted persons and entities.

• Since the lists of embargoed countries and restricted persons and entities change frequently, consult the Ethics Office if you have any questions about the firm’s ability to do business in a particular country or with a particular person or entity.

Cooperation with Boycotts — We comply with US laws that prohibit cooperation with foreign economic boycotts of countries friendly to the US. If you receive a boycott-related request, whether orally or in a transaction document such as a contract or a request for proposal (RFP), you should not respond to the request in any way, and should immediately contact the Ethics Office.

Complying with Sanctions and Anti-Boycott laws

Guidehouse will comply with all applicable economic sanctions and anti-boycott laws and regulations. Guidehouse has zero tolerance for non-compliance with such regulations.

We Comply with Export Control and Sanctions Laws.

For Further Guidance: Export and Import Compliance policy

12 Code of Conduct

We Safeguard the Information and Assets Entrusted to Us.

Sharing Only with Those Who Need to Know — Unless authorized by clients or required by law, and in all cases only as permitted by law, regulation, contract or other agreement, we do not disclose the firm’s or our clients’ private business affairs outside the firm. Nor do we share confidential firm or client information with Guidehouse personnel or others who do not have a legitimate business need to know. We are also cautious when discussing confidential matters in public spaces.

Information Security — When collecting, transferring and otherwise handling information entrusted to Guidehouse, we must always follow the company’s information security procedures, and use secure, approved technologies.

MaintainingConfidentiality,IncludingAfterWe Leave the Firm — We must continue to protect the confidentiality of client information after engagements are completed, by, following all legal, firm and contractual retention and disposal requirements. Guidehouse’s proprietary and client information must never be used for personal gain or advantage, including after we leave the firm. When you leave Guidehouse, you must return all originals and copies of documents and information (both electronic and physical) belonging to Guidehouse or related to its clients.

Information Retention — Our Record Retention Policy sets out the retention and disposition requirements and respective responsibilities for information created, received or maintained for client and firm business purposes.

Intellectual Property — We must protect Guidehouse’s intellectual property and the intellectual property of others. Respect and comply with copyright, trademark and similar laws, and use such protected information in compliance with applicable legal standards.

For Further Guidance: Information Security PolicyRecord Retention PolicySecure Workspace Policy

Reporting Information Incidents— Each of us is responsible for promptly reporting information incidents to the Ethics Hotline or IT Support at 1-833-265-1832.

13 Code of Conduct

For Further Guidance: Information Technology Use Policy

Each of us has a personal responsibility to properly use and protect Guidehouse and our client’s information and assets.

These assets should not be used for anything other than a legitimate business purpose and in accordance with Guidehouse policies and any applicable contracts.

Use of Personal Devices and Accounts — Personal computers and personal email, social media and Internet storage accounts must not be used for Guidehouse work. All mobile devices used for Guidehouse work must be registered and secured by Guidehouse.

Using Guidehouse Technology and Assets for Personal Use — Access to the Guidehouse’s information technology is provided principally for work-related activities. Incidental and occasional personal use is permitted, so long as such use is kept to a minimum and does not interfere with your work. This privilege must not be abused, must not violate this or other Guidehouse policies, and must not affect the employee’s performance of employment-related activities.

We Safeguard the Information and Assets Entrusted to Us.

14 Code of Conduct

We Protect the Guidehouse Reputation.

Public Communications — You must seek approval from Marketing prior to developing any public communication, such as lectures, books, blogs, or thought leadership pieces.

Guidehouse centrally manages public communications and media relations through the Marketing Department in order to ensure Guidehouse’s communications are focused and consistent, preserve confidentiality obligations, and advance our brand.

For Further Guidance: Marketing and Public Communications Policy

For Further Guidance: Outside Business Activities Policy

Litigation — To protect our staff, clients, and the firm, do not communicate with or release any information related to firm legal matters to outside lawyers or the media without permission from the Office of the General Counsel.

Social Media — We must take care that when engaging on social media, we appropriately safeguard the confidentiality and privacy of the firm and its clients. You are expected to follow company policies and relevant laws in any social media activity representing or referencing Guidehouse.

Outside Activities and Business Pursuits — Guidehouse encourages our personnel to participate in outside activities that contribute to their personal and professional development. We applaud efforts that enrich the communities where we live and work, advance charitable activities or professional organizations, and participate in the political process. However, we must ensure that such activities will not put the firm’s reputation at risk, or create a conflict of interest.

15 Code of Conduct

03 A Message from Our President and CEO

04 Introduction

05 We Report Ethical Concerns.

06 We Maintain a Respectful, Inclusive, and Safe Work Environment.06 Diversity, Equal Opportunity and Inclusion06 Equal Employment Opportunity06 Promoting a Respectful, Harassment-Free Work Environment06 Drugs and Alcohol in the Workplace06 Workplace Violence

07 We Conduct Business with Integrity. 07 Conflicts of Interest07 Fair Competition07 Insider Trading07 Licensing and Credentialing08 Self-Reporting of Suspension or Debarment08 Mandatory Disclosure Rule08 Accurate Record Keeping08 Time and Expense Reporting

09 We Do Not Engage in Bribery or Corrupt Activities. 09 Gifts and Entertainment 09 Recruiting and Hiring from the Government10 Anti-Corruption 10 Foreign Corrupt Practices Act

Index 10 Ant-Money Laundering10 Lobbying10 Political Activities10 Political Contributions

11 We Comply with Export Control and Sanctions Laws.11 Export-Controlled Info11 Complying with Sanction and Anti-Boycott Laws11 Embargoed Countries and Restricted Parties11 Cooperation with Boycotts

12 We Safeguard the Information and Assets Entrusted to Us. 12 Sharing Only with Those Who Need to Know12 Information Security12 Maintaining Confidentiality, Including After We Leave the Firm12 Information Retention12 Intellectual Property13 Use of Personal Devices and Accounts13 Using Guidehouse Technology and Assets for Personal Use

14 We Protect the Guidehouse Reputation.14 Public Communications14 Litigation14 Social Media14 Outside Activities and Business Pursuits

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