Leading with Integrity

Leading with Code of Integrity Conduct Dear Sprint team ,

Success is only meaningful when it is achieved the right way, with the right values. It’s more important than ever that we act with integrity, put our customers first and adhere to high ethical standards in our business conduct. I’m proud that we’re known as a trustworthy company, which requires each of us to do the right thing every day.

The Sprint Code of Conduct outlines our ethical and legal responsibilities as employees, as well as our interactions with customers, competitors and suppliers. One of our most valuable assets is our reputation for honesty and fairness, and I appreciate your commitment to uphold this responsibility.

By creating an environment of trust and understanding, we also are respecting each other. When in doubt, don’t hesitate to speak up, ask questions and take action.

Thank you for everything you do to take pride in your work and help Sprint stand out as an ethical leader.

Page 2 Ethics Helpline: 913-794-1666 or 800-788-7844 Table of Contents

Leading with Integrity – Employee Privacy 12 Investments and Financial Opportunities 22 The Way We Do Business Employee Relations and Discrimination 12 Investments in Competitors 22 Investments in Other Companies 23 Harassment 13 Initial Public Offerings or 23 Workplace Safety 13 Foundation of Integrity 4 Preferential Allocations Safety and Health 13 Sprint Code of Conduct 4 Procurement 23 Drugs and Alcohol 14 Making Ethical Decisions 4 Violations and Consequences 5 Integrity with Our Customers Integrity in Our Communities Raising Issues and Concerns 5 Retaliation 5 Environment 26 Customer Privacy 16 Chief Ethics Officer 5 Community Support 26 Government Customers 16 Non-Exclusivity 5 Governmental Business Practices 16 Personal Community Activities 26 Waivers 5 Books and Records 16 Political Activity and Lobbying 26 Accurate and Reliable Business Records 16 Inquiries from the Government 27 Integrity in our Workplace Reporting of Financial and 17 Inquiries from the Media and Analysts 27 Non-financial Information Tone at the Top 8 Accounting, Internal Controls, 17 Speak Up. Take Action. Supervisor Responsibility 8 Auditing and Tax Matters The Open Door Policy 8 Raising Issues and Concerns 30 Conflicts of Interest 8 Integrity in the Marketplace Disclosure 9 Retaliation 30 Corporate Opportunity 9 International Business 20 Contacting the Ethics and 31 Relatives and Friends 9 International Business Practices 20 Compliance Program Board Memberships 10 Foreign Corrupt Practices Act 20 Other Contact Information 31 Outside Employment and 10 Export Control 20 Activities of Employees 10 Transactions with Prohibited 20 Gifts, Entertainment and Travel 10 Persons or Sanctioned Countries Company Assets 11 Anti-boycott 21 Confidential and Proprietary Information 11 Competition Law and Business Conduct 21 Intellectual Property 11 Competitive Information 21 Computer and Network Security 11 Business Records and Communications 21 Compliance and Reporting of 12 Material Nonpublic Information and 22 Security Information Insider Trading

Effective May 21, 2015 Page 3 Ethics Helpline: 913-794-1666 or 800-788-7844 We are responsible for: • Complying both with the letter and the spirit of all applicable laws, rules and regulations. • Observing high ethical standards when conducting business on Sprint’s behalf. • Asking questions when in doubt about the appropriateness of a situation. • Reporting known or suspected violations of any applicable laws, rules, regulations, policies and procedures. • Certifying familiarity and compliance with the Code, its standards, policies and procedures.

Foundation of Integrity these traits, integrity and ethics are critical success Making Ethical Decisions: When in factors. Amidst unprecedented change and techno- Throughout its proud history, Sprint has continually Doubt, Ask Yourself … logical advancement, acting with integrity is not just been an innovator in the telecommunications indus- • Is it ethical? Is it also legal? the right thing to do, it is the unwavering foundation try, driven by a legacy of integrity, accountability and • Could it harm Sprint’s reputation? for Sprint. service. Today, Sprint delivers amazing technology, • What would my family and friends say? service and experiences to our customers, communi- • How would it look in the newspaper? Sprint Code of Conduct ties, employees and shareholders (stakeholders). And, • Would I risk my job for it? along the way, we take great pride in our high-caliber The Sprint Code of Conduct (the Code) is applicable Failure to abide by any laws or policies, including the workforce, our outstanding corporate citizenship and to employees of Sprint and its controlled subsidiar- Code, can result in monetary damages, governmental our industry-leading environmental sustainability ac- ies, the Sprint Board of Directors (Board Members), sanctions and compromise Sprint’s reputation. Viola- complishments and commitments. and anyone we authorize to act on Sprint’s behalf. tions of laws, policies or the Code may result in disci- The Code establishes the basic foundation of Sprint’s As we look to the future, we recognize that our capac- plinary action, up to and including termination of your ethics by communicating our philosophy and com- ity to continuously incorporate better experiences service and, in some cases, could lead to civil and mitment to all of our employees, customers, other for our stakeholders hinges entirely on our collective criminal actions against the individual and Sprint. You stakeholders and the communities in which we do ability to perform at the highest level – from the retail are responsible for your own actions. You are never business. The Code should be used as a resource store to the customer service center to the office of authorized to commit, or direct someone to commit, a when questions of legal or ethical appropriateness the CEO. A high-performance culture is the path to a violation of the Code or an illegal act. Additionally, you arise on the job. It is not a comprehensive rulebook, bright future. At Sprint, our high-performance culture cannot use a contractor, agent, consultant, broker, but rather a statement of how Sprint commits to do focuses on accountability, first and foremost, along distributor or other third party to perform any act business. We are bound by the Code and the specific with open communication and innovation. Within prohibited by the Code or the law. operational policies of Sprint.

Page 4 Ethics Helpline: 913-794-1666 or 800-788-7844 Violations and Consequences managing the Ethics Helpline, developing policies, procedures and training, as well as implementing a Leading with Integrity – Failure to abide by any laws or policies, including system for evaluating the compliance activities of the Code, can compromise the reputation of Sprint The Way We Do Business each employee. and may also result in disciplinary action, up to and Our reputation as an ethical including termination of employment. Violations of On matters of the Code that require disclosure, the company is a valuable asset. the Code or illegal acts cannot be justified by saying CEO and Board Members should disclose those items that they “helped the bottom line,” or were directed by to, and seek guidance from, the Chief Ethics Officer. The Code is intended to help us a higher authority in the organization. Each employee understand our responsibilities is responsible for his or her actions. You are never Non-Exclusivity and guide us in making the right authorized to commit, or direct someone to commit, a The Code cannot explicitly cover all situations or choices. We are obligated to violation of the Code or an illegal act. Additionally, you circumstances that an employee may face. It is not uphold our ethical and legal cannot use a contractor, agent, consultant, broker, a comprehensive, full, or complete explanation of responsibilities and conduct distributor or other third party to perform any act all the laws and regulations that apply to Sprint and our day to day business in prohibited by the Code or the law. its employees. The Code does not constitute a contract compliance with the letter and of employment or create other contractual rights. spirit of those requirements. Raising Issues and Concerns Many of the issues are discussed in greater detail in You are obligated to report violations of the Code, the other Sprint materials such as the Employee Guide law or any other company policy or procedure. If you and company policies. All employees have a continu- have questions, concerns, or need to report a known ing obligation to familiarize themselves with any appli- or suspected violation, you should discuss it with your cable laws or company policies; however, nothing can supervisor, any member of your management team, serve as a substitute for good judgment. a Human Resources representative or contact the Sprint established this Code for company-wide Ethics Helpline where you can report your concern application and any direct conflict between any other confidentially or anonymously. You may be subject to policy and the letter or spirit of the Code is to be discipline, up to and including termination, for your resolved in favor of the Code. failure to do so.

Retaliation Waivers Sprint does not expect to grant waivers of provisions Sprint forbids any form of retaliation or adverse action of the Code to employees or Board Members. Disclo- against any employee for reporting in good faith a sus- sure of a waiver, if any, will be made as mandated by pected violation of the law or the Code or for assisting applicable law, rules of The New York Stock Exchange, in an investigation. Violators are subject to corrective regulations of the Securities Exchange Commission action up to and including termination. and any other exchange or quotation system appli- Chief Ethics Officer cable to Sprint. The Sprint Board of Directors has charged the Chief Ethics Officer with implementing the Ethics and Compliance Program. This responsibility includes

Page 5 Ethics Helpline: 913-794-1666 or 800-788-7844 Page 6 Ethics Helpline: 913-794-1666 or 800-788-7844 Tone at the Top

Supervisor Responsibility

The Open Door Policy

Conflicts of Interest

Company Assets

Computer and Network Security

Employee Privacy

Employee Relations and Discrimination

Harassment

Workplace Safety

Integrity in our workplace Tone at the Top their organization receives proper training, completes annual i-Comply certification and clearly understands Sprint leaders have a responsibility to understand and the legal and ethical expectations of working for uphold the Code as you play a key role in setting the Sprint. This includes any aspect of the Code, policies, right ethical tone for your organization. training or law with particular applicability to their Leaders must be particularly careful with their words business operations. It is incumbent upon supervisors and conduct with respect to placing, or seeming to to take every opportunity to model behaviors consis- place, pressure on subordinates that could cause tent with our values and the Code. them to perform in a way that is contrary to the Supervisors are encouraged to work with Human ethical standards set forth in this Code or our com- Resources or contact the Ethics Helpline for assis- pany policies. Additionally, they must be cognizant of tance with reports made by employees. All levels of their actions and dealings with customers, suppliers management are obligated to report and partner with and employees to create an atmosphere of ethical Sprint leaders uphold Human Resources or any other corporate investiga- leadership and integrity. the Code as individuals tors, to investigate Code violations or determine the and demonstrate a As a Sprint leader, if someone approaches you with a appropriate consequence or corrective action. visible commitment by: question or concern relating to the Code, listen care- fully and ask for clarification and additional informa- The Open Door Policy • Being a positive role model. tion to ensure that you fully understand the question Sprint’s “open door” philosophy encourages employ- • Explaining the Code to or concern. Answer any question that you can, but ees to take any problems, disagreements, questions, your team and ensure they do not feel that you must provide an immediate recommendations or comments to their immediate complete ethics training in response. If necessary, seek help or guidance from supervisor or another member of their management a timely manner. others, including your Human Resources representa- chain. Sprint has established the Open Door Policy • Upholding compliance to tive and the Ethics Helpline. which communicates the process for addressing the Code. You are expected to perform all of your duties concerns in an efficient and systematic manner. • Creating an environment on behalf of Sprint in compliance with all laws, where employees can regulations and company policies. The Legal Depart- Conflicts of Interest speak up. ment is always available to help you understand the We will conduct ourselves with high standards of in- laws and regulations that apply to your job; however, tegrity, honesty and fair dealing and should avoid any it should be understood that upholding our Code may conflicts of interest with Sprint. A conflict of interest require more than mere compliance with the laws and occurs when an individual’s personal interests either regulations. interfere or could reasonably appear to interfere with Supervisor Responsibility the interests of Sprint. We will always work solely in the best interests of Sprint when conducting com- Supervisors should exemplify the highest standards of pany business. We will not compete with Sprint, take ethical business conduct by integrating the ethics and advantage of our position or misuse confidential or compliance program into all aspects of their opera- proprietary information for personal gain or any other tions, and by encouraging open and frank discussion reason. Relationships with prospective or existing sup- of the ethical and legal implications of business deci- pliers, contractors, consultants, customers, competi- sions. Supervisors should also ensure that everyone in tors or regulators should be structured so that they

Integrity in our workplace Page 8 Ethics Helpline: 913-794-1666 or 800-788-7844 Conflict of interest can occur when our personal activities, investments or associations compromise our judgment or ability to act in Sprint’s best interests. Conflicts can arise through: • Board memberships • Business ventures • Investments • Outside employment • Personal relationships • Gifts, entertainment and travel

could not reasonably appear to affect your indepen- Human Resources representative or contact the should not attempt to use your position to influence dent and sound judgment on behalf of Sprint. Ethics Helpline. the decision making in any way. If you are either directly involved in the procurement process or could Disclosure Corporate Opportunity potentially be involved in the management of the To avoid conflict of interest situations, we will disclose You owe a duty to advance the legitimate interests any relationships that have the potential to be misin- relationship in the future, you should disclose the of Sprint at all times. You should not take personal relationship immediately to your supervisor. What we terpreted by others. Should you need guidance and advantage of opportunities or favors offered to you help to identify these situations, you should complete are prohibited from doing directly should not be done by virtue of your position with Sprint. For instance indirectly through others. a “Conflict of Interest Questionnaire” and ask your you should not: (a) take for personal gain opportuni- supervisor or another member of your management ties that are discovered through the use of corporate The potential for conflict of interest also exists if your team, your Human Resources representative or the Eth- property, information or position, or (b) accept spouse, partner or other person with whom you have ics Helpline for guidance to determine if any additional discounts on personal purchases of a supplier’s or a close personal relationship also works at Sprint action is warranted. Please note that you have a duty to customer’s products or services unless such and is in a reporting relationship to you. Employees update the form any time your circumstances change. discounts are offered to all employees in general. should not supervise or be in a position to influence It is not possible to list all cases in which a conflict the hiring, work assignments or assessments of such of interest may exist. We rely on your integrity and Relatives and Friends persons. If a close personal relationship exists or de- good judgment to avoid situations that may create a A conflict of interest may arise when doing business, velops in the course of your employment, you should conflict of interest. If you are unsure about a particular seeking to do business or competing with organiza- immediately disclose the relationship to your supervi- situation, you should discuss it with your supervisor or tions that either employ or are owned (including sor so that appropriate action can be taken, which another member of your management team, your partial ownership) by relatives, friends, or others with may include other work arrangements. whom you have a close personal relationship. You

Integrity in our workplace Page 9 Ethics Helpline: 913-794-1666 or 800-788-7844 The Gift, Entertainment and Travel Policy states: • Accepting or offering cash and cash equivalents, such as gift cards, is prohibited. • Management approval must be obtained in writing for any item above a retail value of $150 prior to accepting. • Items below a retail value of $150 may be accepted. You are encouraged to disclose these items to management. • All gifts, business entertainment and travel during contract negotiations with suppliers are to be declined. • Offering or accepting bribes, kickbacks, payoffs or other unusual or improper payment to obtain business is unethical, illegal and strictly forbidden.

Board Memberships munity or non-profit organizations if the board service Gifts, Entertainment and Travel You may not serve on the board of directors of a does not diminish your ability to perform your duties Gifts, entertainment and travel have the potential to company or organization that raises the potential for for Sprint. To make sure these activities do not create create a conflict of interest with your obligation to a significant conflict of interest (e.g., certain competi- a conflict of interest or other problem, you should no- Sprint. While each is often an integral part of building tive, supplier or customer relationships). tify your supervisor of your prospective membership and maintaining business relationships and advancing before you agree to the board service. the interests of Sprint, it is essential that we conduct For-Profit: Subject to the standard above, you are per- each in such a manner as to avoid even the reason- mitted to serve on the board of directors or advisory Outside Employment and Activities of Employees able appearance of a conflict. The Code incorporates committee of a for-profit company or organization only You should not provide services to any business entity by reference the Sprint Gift, Entertainment and Travel if the requested service has been approved and if the that competes with Sprint. A conflict of interest also Policy, which explains the policy in detail. board service does not diminish your ability to perform may arise if an employee’s outside employment activities impair his or her timely and effective performance If you are ever in doubt as to how accepting or giving your duties for Sprint. Before agreeing to become a a gift, favor, travel or entertainment might appear, you member of the board of directors or an advisory com- for Sprint. You should ensure that any outside activity is strictly separated from your employment. You are encouraged to speak with your supervisor or an- mittee of any for-profit organization, employees should other member of your management chain, your complete a “Board Membership Request for Informa- should not use any Sprint resources or personnel for non-Sprint activities. You may engage in outside em- Human Resources representative or contact the tion” form. Among other things, the form will be used Ethics Helpline. to determine the relationship, if any, existing between ployment or business ventures if that activity does not Sprint and the for-profit organization. compete against Sprint, does not provide goods or Notwithstanding anything in this Code of Conduct to services to Sprint or does not violate your confidenti- the contrary, conflicts of interest, including corporate Non-Profit: Subject to the standard above you are ality or other obligations to Sprint. opportunities, and similar provisions of this Code permitted to serve on the board of directors of com- of Conduct involving any member of the Board of

Integrity in our workplace Page 10 Ethics Helpline: 913-794-1666 or 800-788-7844 The Gift, Entertainment and Travel Policy states: Directors or their affiliates shall be addressed (i) by the obligation to keep proprietary or competitive informa- Board of Directors or applicable committee thereof in tion confidential continues after your employment accordance with Sprint’s certificate of incorporation with Sprint ends. It is never appropriate to photo- and bylaws, as in effect from time to time, and the graph, copy or otherwise disseminate Sprint docu- other policies and procedures followed by the Board ments for personal gain. All documents should be of Directors from time to time, and (ii) in a manner that managed according to a business “need to know.” is consistent with the discharge by the members of the Board of Directors of their fiduciary duties. Intellectual Property Sprint values and encourages the protection of its Company Assets intellectual property (such as patents, trade secrets, copyrights and trademarks) and proprietary informa- You have a responsibility to protect Sprint assets, tion while simultaneously respecting the valid intel- including both tangible and intangible property, from lectual property rights of third parties. Intellectual loss, damage, misuse and theft. Failure to protect property laws protect many materials used by Sprint company assets may subject you to disciplinary ac- employees in the course of their work. Copyright laws tion up to and including termination of employment. protect materials such as computer software, music, In some cases, e.g. fraud or theft, the matter may be artwork, audio and videotapes, books, presentations referred to law enforcement agencies for prosecution. and training materials. Patent laws protect inventions, Information is one of our key corporate assets and trade secret laws protect proprietary information and the future success of Sprint depends in part on our trademark laws protect product and services names. ability to develop and deploy technical information Sprint’s trade secrets are proprietary and confiden- and know-how ahead of our competitors. All com- tial and should not be disclosed outside of Sprint. pany assets should be used for legitimate business or Employees must not knowingly infringe on the valid authorized purposes, including customer proprietary intellectual property rights of others. Employees must information, Customer Proprietary Network Informa- also identify any agreements they may have with past tion (CPNI) and account details. employers and notify their supervisors or Human Resources. Employees should direct any intellectual Confidential and Proprietary Information property questions or concerns to the Legal Depart- All information related to Sprint’s business should ment. Employees should promptly notify the Legal be considered proprietary and confidential unless it Department of any innovative processes, methods and has been released in public authorized public docu- technologies that may be eligible for patent protection. ments. You must take steps to protect confidential and proprietary information. You should not discuss confidential or competitive information with family, Computer and Network Security acquaintances or at social gatherings, when in public Our computer systems, network and electronic data areas such as elevators, restaurants and airplanes, as are an essential part of our business. Their continu- well as online bulletin boards, chat rooms, personal ous availability and efficient use play a critical role in Web pages, blogs, or any other form of social media our success. We should do our part to safeguard the (e.g., Facebook, Twitter, etc.) For additional guidance, confidentiality, integrity and availability of our systems, review the Sprint Social Media Policy. In addition, your network and electronic data processes by protecting user IDs, passwords and access to our facilities.

Integrity in our workplace Page 11 Ethics Helpline: 913-794-1666 or 800-788-7844 Use of our electronic mail, Internet access, telephone instant messages, social media or other electronic systems, computer systems and network should gen- messages, computer storage and voicemail) as well as erally be limited to Sprint-related business purposes. employees’ company-provided workspace at any time. Any non-business use should be incidental, occa- Sprint is committed to protecting employees’ privacy sional and reasonable. You should not send inappro- in regards to medical, family and personal information priate messages or email (including, but not limited by refraining from discussing private matters when to, harassing, threatening or discriminatory messages) there is not a valid business “need to know.” or use our intranet or the Internet in an inappropriate manner. Electronic messages are subject to the same Employee Relations and Discrimination records retention requirements as other communications. Due care and common sense should govern At Sprint, we thrive on creativity and innovation. the use of our computer systems and access to our We believe that new ideas from diverse perspec- electronic data. tives lead to better business results. Diversity is just good business. We embrace diversity of ethnicity, Sprint is obligated You should refer to the Sprint Information Security gender, generation, geography and thought. Differ- under the National Policy for additional information. Security Agreement to: ent perspectives enable us to better understand the • Separate SoftBank and Compliance and Reporting of Security Information complexity of our customers’ needs and to deliver Sprint telecommunications As part of a national security agreement with the U.S. high-value solutions in innovative ways. It is criti- networks and corporate government, Sprint must be vigilant in meeting its cal that every Sprint employee feel valued and be networks obligations under the agreement. provided with opportunities to contribute value to the • Restrict SoftBank’s access business. If you believe your rights have been violated Any complaints or concerns regarding these mandated to Sprint’s communications or if you have any other workplace concerns, you obligations must be reported by using the Ethics equipment, facilities, and should consult the Employee Guide, your supervisor Helpline or by contacting (1) the General Counsel, (2) infrastructure or another member of your management chain, or the Vice President Corporate Security/Chief Security • Limit access to U.S. govern- call your Human Resources representative directly. If Officer, or (3) the Sprint Security Director on the Board ment customer information you do not receive a clear explanation or believe you of Directors. Any such reports will be treated confi- and sensitive information may not receive an objective or adequate review of dentially and investigated fully. This special agree- the issue from your supervisor or Human Resources, ment with the government protects “whistleblowers” call the Ethics Helpline. that report these types of complaints in good faith and prohibits any retaliation against such individuals. Sprint does not tolerate discrimination. We recognize that highly productive and diverse employees are Employee Privacy essential to our success and should be given opportunities to flourish in a barrier-free, non-discriminatory Employees should have no expectation of privacy in environment. We will conduct all employment prac- information they send, receive, access or store on any tices (including activities relating to recruiting, hiring, of Sprint’s computer systems or network. Electronic benefits, leaves of absence, training, transfer, promo- message traffic that interferes with the network or its tion, job assignments, compensation, corrective ac- interconnected systems is prohibited. Sprint reserves tion and termination) in a non-discriminatory manner. the right to review workplace communications (including but not limited to Internet activity, email,

Integrity in our workplace Page 12 Ethics Helpline: 913-794-1666 or 800-788-7844 We conduct business without regard to, and do not race, color, religion, creed, sex, gender identity, sexual Workplace Safety discriminate because of, an employee’s race, color, orientation, age, disability, national origin or ancestry, religion, creed, sex, gender identity, sexual orienta- as well as citizenship, marital, veteran, and family and Safety and Health tion, age, disability, pregnancy, national origin, genetic medical leave status, or any other status protected Sprint strives to provide a safe and healthy workplace information or ancestry, as well as citizenship, marital, by law. Sexual harassment includes harassment of a for employees, customers and visitors to its premises. veteran, and family and medical leave status or any sexual nature of a person of the same or opposite sex All managers have responsibility for ensuring proper other status protected by law. Consult the Employee as the harasser. Employees should refer to the Sprint safety and health conditions for their employees. Guide for more information. Non-Harassment Policy for more information. Management is committed to maintaining industry standards in all areas of employee safety and health, As is the case with any violation of the Code, you have including industrial hygiene, ergonomics and safety. Harassment a responsibility to report any harassing behavior or To support this commitment, employees are respon- Every employee has a right to a work environment condition regardless of if you are directly involved sible for observing all safety and health rules, prac- free from harassment, regardless of whether the or just a witness. Retaliation for making a complaint tices and laws that apply to their jobs, and for taking harasser is a co-worker, supervisor, manager, cus- in good faith or for assisting in the investigation of a precautions necessary to protect themselves, their tomer, vendor or visitor. Harassment can include any discrimination or harassment complaint is prohibited. co-workers and visitors. Employees are also respon- behavior (verbal, visual or physical) that creates an in- Report the offending behavior to your supervisor or sible for immediately reporting accidents, injuries, timidating, offensive, abusive or hostile work environ- another member of your management chain, your occupational illnesses and unsafe practices or condi- ment. In addition, any harassment that either impacts Human Resources representative or contact the Ethics tions to their supervisor, who is required to provide or influences wages, hours, working conditions or Helpline. this information to Sprint’s Risk Management employment advantages is specifically prohibited. Department. Unlawful harassment includes harassment based on

Page 13 Ethics Helpline: 913-794-1666 or 800-788-7844 Threats, acts of violence and physical intimidation are strictly prohibited. Sprint prohibits the possession of weapons on Sprint property (Sprint offices, retail loca- tions, or other Sprint premises). No talk of violence or joking about violence will be tolerated. Any instance of violence, hostile behavior, possession of weapons on Sprint property or unsafe behavior should be reported to a member of management or Corporate Security. If you believe there is imminent danger or illegal conduct, contact 911 or local law enforcement first. You have a responsibility to report any unsafe behavior or condition regardless of whether you are directly involved or a witness.

Drugs and Alcohol Sprint requires employees to work free from the influence of any substance, including drugs and alcohol, preventing them from conducting work activities safely Corporate Security and effectively. Sprint reserves the right to have any Hotline: 800-877-7330 employee tested if there is reasonable suspicion that he or she is under the influence of drugs or alcohol. If you are using prescription or non-prescription drugs that may impair alertness or judgment, or witness an employee impaired and therefore possibly jeopardizing the safety of others or Sprint’s business interests, you should report it immediately. If you have a problem related to alcohol or drugs, you are encouraged to seek assistance from the Employee Assistance Program or other qualified professionals and review the Sprint Substance Abuse Policy.

Integrity with our Customers Integrity in our workplace Page 14 Ethics Helpline: 913-794-1666 or 800-788-7844 Customer Privacy

Government Customers

Books and Records

Integrity with our Customers You are obligated to protect customers’ information, including: Personally identifiable information (e.g., customer name, Social Security Number, contact information) • Billing information (e.g., credit card number) • Customer Proprietary Network Information (CPNI) which includes customer account and usage information • Location information • Sensitive information, such as Protected Health Information (PHI)

Customer Privacy For more information, please review the Sprint employee by means of payments, gifts or other favors Privacy Policy. are strictly prohibited. Failure to avoid these activities Sprint takes the protection of its customers’ privacy may expose the government agency, the government very seriously. Every Sprint employee should become Although privacy is important and protected by law, if employee, Sprint and the Sprint employee to substan- familiar with Sprint’s Privacy Policy (and affiliates as you suspect a customer is using Sprint’s products or tial fines and penalties. For these reasons, any sale of needed). Customer information should only be used services for an unlawful purpose, contact Corporate our products or services to any government entity for legitimate business purposes by employees with a Security immediately. – federal, state or local – must be in accordance with business “need to know.” In your business role, while the Sprint Financial Policy. For information on relation- carrying out your duties you are obligated to comply Government Customers ships with government representatives, please refer with all Sprint policies on honoring customer privacy Governmental Business Practices to the “Political Activity and Lobbying” section of preferences, including any Do Not Contact request. this Code. You must follow all Do Not Contact policies and pro- Special rules and regulations apply when doing cedures for marketing and non-promotional contacts business with federal, state or local governments, Books and Records to prospects and customers. Additionally, privacy so you should take extra steps to know and comply with these requirements if your assignment directly laws and regulations at the federal and state level are Accurate and Reliable Business Records becoming increasingly complex, and enforcement of involves the government or if you are responsible for Sprint and others who deal with us rely on accurate these requirements is becoming more aggressive. someone working with the government on behalf of Sprint. In addition, when dealing with govern- and reliable information to make business deci- If you learn of any unauthorized access to, or use of, ment officials and employees, avoid any conduct sions. Each employee must prepare and maintain all customer information, immediately report this to your which could appear improper. Any attempts, even if company records accurately and honestly. No false, supervisor and the Office of Privacy. well intended, to influence a government official or artificial or misleading entries should be made in any

Page 16 Ethics Helpline: 913-794-1666 or 800-788-7844 books, records or accounts of Sprint and no company of reporting information for any reason. If you have funds should be used for any purpose other than as any uncertainty about judgments concerning proper described in the documents supporting payment. This recording of our transactions or accounting or tax includes business and financial records. All books, matters, discuss them with your supervisor. records and accounts must accurately reflect trans- In addition, it is strictly prohibited to influence, coerce, actions and events, and conform both to Generally manipulate or mislead any internal or external party Accepted Accounting Principles (GAAP) and to Sprint’s engaged in the performance of an audit for the pur- system of internal controls over financial reporting. pose of rendering misleading financial statements or internal control assessments. Reporting of Financial and Non-financial Information

We have an obligation to make and keep books, Accounting, Internal Controls, Auditing and records and accounts that accurately and fairly reflect Tax Matters our transactions and to prepare financial reports and Any complaints or concerns regarding accounting, financial statements that are not false or misleading, internal controls, auditing or tax matters must be and that materially present full, fair, accurate, timely reported by using the Ethics Helpline or by writing to and understandable disclosure. Employees respon- (1) both the Chief Financial Officer and the General sible for any aspect of our internal controls over Counsel, (2) the Chief Ethics Officer, or (3) the Chair- financial reporting systems must be vigilant in record- man of the Audit Committee of the Board of Direc- ing entries accurately and honestly and in a manner tors. Any such reports will be treated confidentially consistent with all applicable legal and accounting and investigated according to Sprint’s Ethics Helpline requirements. and Whistleblower Procedural Process. Federal law Misrepresentation or omission of relevant financial or protects “whistleblowers” that report these types non-financial information, and improper or question- of complaints in good faith and prohibits retaliation able accounting and auditing practices may result in against such individuals. fraudulent, incomplete, inaccurate or untimely reporting. Employees should not undermine the integrity

Page 17 Ethics Helpline: 913-794-1666 or 800-788-7844 Integrity in the Marketplace Page 18 Ethics Helpline: 913-794-1666 or 800-788-7844 International Business

Competition Law and Business Conduct

Material Nonpublic Information and Insider Trading

Investments and Financial Opportunities

Procurement

Integrity in the Marketplace International Business records and accounts that accurately reflect such transactions and payments. If in doubt about making International Business Practices or authorizing any payment or gift to anyone, contact As Sprint’s presence and activities expand globally, the Legal Department. it is imperative to our success to conduct business in Any complaints or concerns about a situation in an ethical and lawful manner. It is Sprint’s policy and which bribery is suspected should be reported we are committed to conduct international business to Sprint’s International Law Group or the Ethics in accordance with the Code and the Sprint Policy for Helpline. Any such reports will be treated confiden- Conducting International Business. tially and investigated according to Sprint’s Ethics Doing so means complying at all times with applicable Helpline and Whistleblower Procedural Process. company policies as well as applicable laws in all Federal law protects “whistleblowers” that report countries where Sprint engages in business. Some of these types of complaints in good faith and prohibits the primary areas of the law applicable to international retaliation against such individuals business are summarized below. Export Controls Foreign Corrupt Practices Act/Organization for Laws in a number of countries, including the U.S, re- Economic Co-operation and Development strict the export of controlled equipment and technol- Anti-Bribery Convention Implementing Legislation ogies to certain countries or persons, especially in the The U.S. Foreign Corrupt Practices Act (FCPA) prohib- areas of encryption and advanced computing devices. its Sprint and its agents, officers and employees from Employees of Sprint who are involved in the export of directly or indirectly offering anything of value (e.g., equipment or technologies should contact the Legal gifts, money or promises) to a foreign government Department if they are uncertain of the legal status of official, political party or candidate to influence or any country or technology scheduled for export. induce action, or to secure an improper advantage. In other words, the FCPA prohibits bribery of foreign offi- Transactions with Prohibited Persons or cials. The scope of the FCPA is broad and what consti- Sanctioned Countries tutes a “bribe” or a “foreign official” is not always clear. The U.S., along with other foreign governments, Legislation in other countries implementing the Orga- publishes lists of countries to which they impose nization for Economic Co-operation and Development economic sanctions and other restrictions on doing (OECD) Anti-Bribery Convention has expanded upon business. Also included on restricted lists are individu- these restrictions, and often prohibits bribery with any als, groups, and entities, such as terrorists and narcot- person, not just that of foreign government officials. ics traffickers designated under programs that are not This makes it all the more important for employees necessarily country-specific, but nonetheless restrict- and agents of Sprint to take the requisite international ed. Collectively, such individuals and companies are compliance training and become familiar with the called Specially Designated Nationals (SDNs). Their as- Sprint Policy for Conducting International Business sets are blocked and U.S. companies are generally pro- before conducting business internationally. hibited from dealing with SDNs. Thus, it is important to The FCPA and many other countries have accounting perform due diligence at the onset of any international requirements that govern international transactions transaction. Determine what countries will be involved and payments. This means Sprint must keep books, and the specific parties. Employees should contact

Page 20 Ethics Helpline: 913-794-1666 or 800-788-7844 The following actions should never be taken:

• Never discuss prices, terms of sale or other competitive information with competitors. • Never disclose a confidential bid proposal or engage in bid rigging. • Never divide customers, markets or territories with competitors. • Do not attend meetings with competitors where any of these actions are on the agenda and leave immediately if such topics arise during the meeting.

the Legal Department to ensure that all such transac- in business were developed to encourage healthy Competitive Information tions are properly evaluated and screened against competition among businesses and to protect con- Sprint’s policy is to respect the trade secrets of others. these prohibited country and party lists. sumers against anti-competitive activities. While it Employees should not reveal or encourage others to is beyond the scope of the Code to explain each of reveal or use any trade secrets of a former employer or Anti-boycott these laws in detail, compliance with them is critical competitor in connection with their employment with You must not cooperate with foreign boycotts that as the penalties for violations may be substantial – up Sprint. Trade secrets may include, for example, cus- are not approved by the U.S. government, You should to and including imprisonment. If you have questions tomer lists, technical developments, operational data, not respond to any oral or written request for informa- or are unsure how to handle competitive information, sales strategies or pricing information. If information tion, proposed contract provisions or other action that contact the Legal Department or the Ethics Helpline. that might constitute a trade secret or proprietary infor- seems to be related to a boycott. If you receive Sales initiatives with direct and indirect dealers mation of another company is obtained by mistake, do a request related to any boycott, contact the Legal should have contracts in place; offers, terms, restric- not use it and consult the Legal Department. Department, as Sprint is required by law to report tions, product handlings and dealer negotiations Sprint prohibits making false or misleading state- those requests. should be communicated through and approved by ments or material misstatements that could impact the Legal Department. Sprint, its suppliers, or its competitors. For example, Competition Law and Business Conduct Statements about Sprint products and services, and posting a false statement online regarding a Sprint or It is in Sprint’s best interest to compete on a level competitors’ products and services should be ap- competitor’s major product launch is prohibited. playing field; our differentiated products and services proved by Sprint Marketing, Corporate Communica- speak for themselves when competition is free and tions and the Legal departments before release to Business Records and Communications open. The antitrust and fair competition laws of the external channels. Sprint’s records are its corporate memory, providing U.S. and of many other countries where we engage evidence of actions and decisions, and represent a

Page 21 Ethics Helpline: 913-794-1666 or 800-788-7844 vital asset that supports daily functions and opera- business. You violate the insider trading provisions of tions. Records consist of all forms of information creat- securities laws and regulations if, while aware of mate- ed or received by Sprint, whether originals or copies, rial nonpublic information about a public company, regardless of media. A record may be as obvious whether Sprint or another company, you trade on that as a memorandum, email, contract or presentation, information, disclose or “tip” it to others before the or something not as obvious, such as a digital desk information is public. calendar, appointment book or voice mail. Other ex- “Material nonpublic information” is information that amples of business records include but are not limited has not been publicly disclosed and that could affect to the following: quality, safety or personnel records an investor’s decision to buy or sell securities. Ex- or operational metrics. All records are the property of amples of material nonpublic information include, but Sprint and should be retained in accordance with the are not limited to, sales and earnings figures, plans Sprint Records Retention Compliance Policy. It a criminal act to for stock splits or dividends, proposed acquisitions knowingly alter, destroy, All records and communications have the potential for or mergers, or new product and service offerings. or falsify documents in an being publicly disclosed through litigation, govern- Securities laws and Sprint policy require that you do effort to impede, obstruct, mental investigations or outside parties such as the not trade in Sprint stock and other securities based on or influence any type of news media. Therefore, business records and com- material not public information. Sprint’s policy against government investigation. munications should be clear, concise, truthful and insider trading and disclosure of material nonpublic in- as accurate as possible. Avoid exaggeration, colorful formation is explained in detail in the Sprint Securities language, guesswork, legal speculations and deroga- Law Compliance Policy. tory characterizations of people or their motives. Often, company records must be retained in connec- Investments and Financial tion with litigation (potential or actual), investigations Opportunities or audits. When this becomes necessary, the Legal A financial investment that compromises or could Department will issue a records hold notice to the reasonably appear to compromise your independent appropriate departments and individuals. Records judgment or work at Sprint is a conflict of interest. subject to a records hold notice cannot be destroyed The term “financial investment” means stock, options until the Legal Department removes the hold notice. If to buy or sell stock, other ownership interests or debt a department or individual has knowledge of potential securities in a company but does not include mutual litigation, audit or governmental investigation, they funds or other investment portfolios where investment should immediately notify the Legal Department. decisions are made by an independent fund manager.

Any questions related to records retention or destruc- Investments in Competitors tion should be directed to the Legal Department. Financial investment in a company that Sprint consid- ers a competitor is strongly discouraged and as an Material Nonpublic Information and employee you should not make such investments. Insider Trading Small (less than 5 percent of your total portfolio), pre- Federal and state securities laws and regulations gov- existing financial investments in competitors should ern transactions in securities (e.g., stocks and bonds) not be a problem. If an employee’s pre-existing invest- of Sprint and other companies, including our custom- ment in a competitor is not small, full disclosure to ers, suppliers and other companies with which we do your supervisor is an important first step in ensuring

Page 22 Ethics Helpline: 913-794-1666 or 800-788-7844 that your integrity is not questioned. If the supervisor and similar provisions of this Code of Conduct involv- supplier, customer, potential supplier or candidate, or is not at least a director-level employee, please notify ing any member of the Board of Directors or their af- own any interest in that business, you should disclose your director as well. filiates shall be addressed (i) by the Board of Directors this relationship to your supervisor and take appro- or applicable committee thereof in accordance with priate steps to ensure that decisions affecting these Investments in Other Companies Sprint’s certificate of incorporation and bylaws, as in companies are based solely on objective input and If you will be involved in either the selection or man- effect from time to time, and the other policies and judgment. You can refer to the “Conflicts of Interest” agement of a supplier, you should not hold or pur- procedures followed by the Board of Directors from section of the Code for further guidance. chase investments in current or prospective suppliers time to time, and (ii) in a manner that is consistent or other companies, which could reasonably appear Procurement decisions should be based on obtaining with the discharge by the members of the Board of to influence your business objectivity with which the best overall value for Sprint. Obtaining competi- Directors of their fiduciary duties. Sprint is contemplating a transaction. tive bids, verifying quality and service claims, and confirming the financial and legal condition of the Procurement Initial Public Offerings or Preferential Allocations supplier are all important steps in a good procure- Preferential allocations of stock or an offer to partici- Sprint believes in doing business with suppliers that ment decision. Under no circumstances should an pate in an Initial Public Offering (IPO) from a company embrace and demonstrate high principles of ethical agreement be made with a supplier, dealer, distributor with whom Sprint either conducts or could be ex- business behavior. As part of their contract, all per- or other third party that provides for payment that is pected to conduct business can create or could reasons or companies engaging in business relationships not reasonable and commensurate with the func- sonably appear to create a conflict of interest. Such with Sprint should receive and abide by the Sprint tions or services to be performed or the goods to be situations should be avoided and disclosed to your Code of Supplier Conduct. acquired. It is also inappropriate to unlawfully inter- supervisor. If the supervisor is not at least a director- Any employees responsible for buying, selling or leas- fere with contractual relations between other parties, level employee, please notify the director as well. ing materials or services on behalf of Sprint should even if one of those parties wishes to do business Notwithstanding anything in this Code of Conduct to consciously and consistently guard their objectivity. with Sprint. the contrary, investments and financial opportunities If you have a personal or family relationship with a

Page 23 Ethics Helpline: 913-794-1666 or 800-788-7844 Integrity in Our Communities Page 24 Ethics Helpline: 913-794-1666 or 800-788-7844 Environment

Community Support

Personal Community Activities

Political Activity and Lobbying

Inquiries from the Government

Inquiries from the Media and Analysts

Integrity in Our Communities Good does indeed work.™

Environment Community Support for non-Sprint charitable organizations. Employees should not pressure other employees to contribute to Sprint is committed to being a corporate leader in Sprint has contributed to the economic and social any charitable organization. Sprint reserves the right environmental responsibility. Sprint is a recognized development of its communities for many years. In to solicit employees to contribute to Sprint-sponsored industry leader through its commitment to reduce addition to the jobs created and the services provid- charitable organizations. greenhouse gas emissions, deployment of renew- ed, Sprint encourages employees and business units able energy, and our aggressive cell phone recycling to become actively involved in their communities. Political Activity and Lobbying efforts. These efforts are bolstered by environmentally The Sprint Foundation and many Sprint employees responsible building practices, “green” IT, waste- provide financial support to thousands of worthwhile Employees should not make any contribution on reduction efforts, ebilling practices, environmentally community organizations. The community leadership behalf of Sprint or use its name, funds, personnel, beneficial products and services, and a strong envi- offered by thousands of Sprint employees around the property or services for the support of political parties ronmental employee-engagement program. world is another example of Sprint’s long-standing or candidates unless the contribution is permitted by law and authorized in advance by the Sprint Govern- Sprint has established an environmental guidelines civic commitment. ment Affairs group within the Legal department. policy that provides specific measures guidelines for employees and suppliers to ensure their actions Personal Community Activities Employees should not pressure other employees to support Sprint’s environmental objectives, including Employees are encouraged to participate in the com- express a political view or to contribute to a political the meeting of all regulatory compliance, and federal, munity activities of their choice. However, you should action committee, political party or candidate. U.S. state and local environmental laws. Should you wish to make it clear that your views, actions and support are law and the laws of many state and local govern- communicate a potential violation of Sprint’s environ- your own, and not those of Sprint. In addition, em- ments restrict companies from making contributions ment guidance or environmental legal statute, contact ployees should ensure that outside activities do not of money, goods or services to political candidates, the Environmental, Health and Safety (EHS) team. interfere with their job performance. All employees except for administrative support of organizations should be aware of, and abide by, the Sprint Solici- such as the Sprint PAC, which is funded solely through tation Policy which generally prohibits solicitation Sprint employee donations.

Page 26 Ethics Helpline: 913-794-1666 or 800-788-7844 Relationships with a government representative Inquiries from the Media and Analyst should be conducted in a manner that would not Sprint employees are not authorized to speak with the embarrass Sprint or the official if publicly disclosed. news media and analysts. To ensure professional han- Activities with the potential to influence government dling, all media requests should be directed to Corpo- officials are strictly regulated. Persons representing rate Communications Media Relations, and requests Sprint should be extremely careful to avoid even the from financial analysts and stockholders should be reasonable appearance of impropriety. Reasonable forwarded to Investor Relations, and requests from entertainment and courtesies should be extended industry analysts should be sent to Analyst Relations. only if not prohibited by law and then only to the ex- Contact information can be found in the Newsroom tent that is customary and appropriate. Any questions section of www.sprint.com. on this matter should be directed to the Sprint Gov- ernment Affairs group within the Legal Department.

Inquiries from the Government Sprint cooperates with appropriate requests from government authorities. All information provided by employees must be truthful and accurate. It is never appropriate to mislead an investigator or to alter or destroy documents or records in response to an investigation. If you are asked by a law enforcement agency to testify as a witness in a deposition or other type of proceeding, contact Corporate Security. If you receive a subpoena, court order or other non- routine request for information from a law enforcement agency, you should contact Corporate Security. This includes requests for customer information, such as call detail records. If you receive a request from a government agency other than law enforcement, contact Corporate Security.

Page 27 Ethics Helpline: 913-794-1666 or 800-788-7844 Speak up. Take Action. Page 28 Ethics Helpline: 913-794-1666 or 800-788-7844 Raising Issues and Concerns

Retaliation

Contacting the Ethics and Compliance Program

Other Contact Information

Speak up. Take Action. Raising Issues and Concerns • Contact Human Resources. If your supervisor or This should not be construed to restrict or interfere another member of your management is unavail- with any employees’ federal or state labor law rights, You are obligated to report violations of the Code, able, contact your Human Resources representative. including those under the National Labor Relations the law or any other company policy or procedure. • Contact the Ethics Helpline. The Ethics Helpline Act. This specifically means that employees may You may be subject to discipline, up to and includ- is established to answer questions about Code of always engage in lawful concerted activity by discussing termination, for your failure to do so. If you have Conduct issues at work, to clarify the Code and to ing the terms and conditions of their employment. a question about the Code or you need to report a allow employees another means to report potential known or suspected violation, you should do one of wrongdoing. Employees can contact the Ethics Retaliation the following: Helpline anytime throughout the process. • Contact your supervisor. Review the matter with Sprint forbids any form of retaliation or adverse action • Contact the Sprint Audit Committee or Board of your supervisor. Supervisors are responsible for against any employee for reporting in good faith a Directors. Should you wish to communicate ap- determining how the reported matters should be suspected violation of the law, the Code or for assist- propriate matters to the Audit Committee or to the handled. ing in an investigation. Violators are subject to correc- Board of Directors. • Contact another member of your management tive action up to and including termination. chain. If your supervisor is unavailable or you do Making intentionally false reports or allegations not feel comfortable speaking with your supervi- against an employee is a violation of the Code of sor, contact the person at the next level within your Conduct. management chain.

Page 30 Ethics Helpline: 913-794-1666 or 800-788-7844 The Ethics Helpline is available 24 hours a day, 7 days a week:

Phone: Monday - Friday 8:30 to 5 p.m. Central time 913-794-1666 or 24-hour line: 800-788-7844 Email: [email protected] Fax: 913-523-9779 Mail: Ethics and Compliance Program 6200 Sprint Parkway Mailstop: KSOPHF0202-2B507 Overland Park, KS 66251

Contacting the Ethics and Other Contact Information Compliance Program Corporate Security/Legal Department: 800-877-7330 Individuals skilled in responding to your questions Employee Assistance Program: 888-303-3957 and concerns staff the Ethics Helpline. Callers have Employee Helpline: 800-697-6000 the option to remain anonymous and will be advised if additional information is required before an effec- Sprint Environmental, Health & Safety (EHS): tive investigation can take place. If necessary, the 877-347-4457 Ethics Helpline will refer concerns to the appropriate National Security Compliance: department, such as Corporate Security, Legal, Cor- [email protected] porate Audit or Human Resources, and will monitor The Sprint Board of Directors: the results of any investigations. Callers to the Eth- ics Helpline are protected by Sprint’s prohibition of http://investors.sprint.com retaliation for either reporting a suspected violation or assisting in an investigation.

Page 31 Ethics Helpline: 913-794-1666 or 800-788-7844 Code of Conduct Index

A F N S Accounting…16-17 Family Members of Employees…9, 11 National Labor Relation Act…30 Safety…13-14 Accurate Business Records…16 Financial Investments…22-23 National Security…12 Securities Law Compliance Policy…22 Alcohol and Drugs…14 Foreign Corrupt Practices Act…20 Non-Exclusivity…5 Securities Trading…22-23 Anti-boycott…21 For-profit organizations…10 Non-Profit Organizations…10, 26 Social Media…11,12, 27 Antitrust…21 Foundation of Integrity…4 Solicitation…26 O Audit Committee…5, 17, 30 Sprint Foundation…26 G Obligation to Report…5, 30 Sprint PAC…26 B Gifts, Acceptance of…10-11 Open Door Policy…8 Stockholder Inquiries…27 Board Memberships…9, 10 Gifts, Entertainment and Travel…10-11 Outside Employment…10 Subpoena…27 Board Membership Request for Information…10 Gifts, Giving of…9, 10-11 P Substance Abuse…14 Board of Directors…4, 9, 10 Government Customers…16 Patent Laws…11 Supervisor Responsibility…8 Bribes…10, 20 Government Inquiries…27 Political Activities…16, 26 Supplier Conduct…23 Business Records and Communications…21-22 H Political Contributions…26 Business Relationships…9-10 T Harassment…13 Political Views…26 Tone at the Top…8 C Non-Harassment Policy…13 Privacy – Customer…11, 16 Trade Secrets…11, 21 Chief Ethics Officer…5 Hazardous Materials…13, 26 Privacy – Employee…12 Trademarks Laws…11 Code of Supplier Conduct …23 Procedures for Compliance I Community Activities…10, 26 Regarding Accounting, Internal Initial Public Offerings (IPO)…23 Community Support…26 Accounting Controls and Auditing Insider Trading…22 V Company Assets…11 Matters…17 Intellectual Property…11 Violations and their Consequences…5 Competition Law and Business Conduct…21 Procurement Practices…23 Internal Accounting Controls…17 Violence…13-14 Competitive Information…11, 21 Prohibited Persons and Sanctioned International Business…20-21 Computer Use…11,12 Countries…20 W Investments in Competitors…22 Confidential Information…11 Proprietary Information…11, 16 Waivers…5 Investments in Other Companies…23 Conflicts of Interest…8-12 Weapons…14 R Conflicts of Interest Questionnaire…8 K Whistleblower Protection…12, 17, 20 Raising Issues and Concerns…5,30 Copyright Laws…11 Kickbacks…10, 20 Workplace Safety…13-14 Records Hold…21-22 Corporate Opportunity…9 L Records Retention…21-22 Corporate Security…14,16,27,31 Leading with Integrity…5, 8 Relatives and Friends of Employees…9, 11 Customer Privacy…11,16 Lobbying…16, 26-27 Reporting Financial and Non-Financial Information…17

D M Retaliation…5, 17, 20, 30 Disclosure of Conflicts of Interest…9 Making Ethical Decisions…When in Doubt, Ask Yourself…4 Discrimination…12,13 Manager Responsibility…8 Drugs and Alcohol…14 Material Nonpublic Information…22

E Media Inquiries…27 Employee Assistance Program…14, 31 Mutual Funds…22 Employee Privacy…12 Employee Relations…12, 30 Environment…26 Ethics Helpline - How to Contact…31 Export Control…20

Page 32 Ethics Helpline: 913-794-1666 or 800-788-7844