ETHICS, INTEGRITY, AND ACCOUNTABILITY IN EVERYTHING WE DO

WE ALWAYS ACT ETHICALLY, MORALLY, AND LEGALLY

Our Code Our values of integrity, excellence, and collaboration are the foundation of our Code of Conduct, and they define the way we do business. Our success depends upon our unwavering commitment to conducting business ethically and in compliance with all laws and regulations, state and federal. As part of this commitment, we are expected to comply with this Code of Conduct ("Code").

Why We Do It We follow both the letter and the spirit of the laws and regulations that govern our business. Doing so protects Strategic ACI and it’s customer’s assets, fosters a safe and healthy work environment, and protects employees from discrimination, harassment, and retaliation.

Scope This Code applies to all employees, managers, and executives of Strategic ACI. Certain business partners and third parties, such as suppliers, agents, representatives, contractors, subcontractors, and consultants serve as an extension of Strategic ACI and as such, are expected to conduct themselves according to our values and standard of ethics when working on behalf of Strategic ACI.

Our Mission Our mission at Strategic ACI is simple - To provide exceptional quality professional services focused on customer needs. We accomplish this by building a team of knowledgeable and motivated professionals who are passionate about exceeding customer expectations. Our team prescribes to the high standards of ethics, honesty, and integrity and strive to be known for providing professional services excellence and value.

Our Vision At Strategic ACI, our vision is to be a well-established professional services firm recognized by our clients for consistently delivering excellence and value - a trusted advisor to our clients.

Our Values Our goals are accomplished through the adoption of our core values by every employee:

• Employee First - Supporting our employees, above all else. If we take care of employees, the employees will take care of the customers, and the customers will take care of the company.

• Customer Focus - We take ownership of customer challenges and operate with a sense of urgency regarding our customer's requirements. We provide value by exceeding their expectations in affordability, quality, and on-time delivery.

• Integrity - Having the courage to make tough ethical decisions, taking pride in our work, being transparent with our teams, and being respectful of everyone.

• Excellence - Belief in our mission. The value of what we do demands persistent and significant dedication.

• Collaboration - We are inclusive, team-oriented, and proactively engaging, building relationships by staying connected with each other and our customers.

Strategic ACI has a zero-tolerance policy regarding trafficking in persons. Strategic ACI opposes any form of prostitution and related activities because these activities are inherently harmful, dehumanizing, and contribute to human trafficking. No employee nor any Strategic ACI consultant, contractor, subcontractor, vendor, or supplier shall be involved in the following activities: trafficking in persons, soliciting or obtaining prostitution or any commercial sex act, or using debt bondage, slave, forced, or child labor.

Strategic ACI fully supports the US Government's policy and requirements to prohibit trafficking in persons, which prohibits Government contractors, contractor employees, and their agents from:

• Engaging in any form of trafficking in persons during the period of performance of the contract.

• Procuring commercial sex acts during the period of performance of the contract.

• Using forced labor in the performance of the contract.

• Destroying, concealing, confiscating, or otherwise denying access by an employee to the employee's identity or immigration documents, such as passports or drivers' licenses, regardless of issuing authority.

• Using misleading or fraudulent practices during the recruitment of employees or offering of employment, such as failing to disclose, in a format and language accessible to the worker, basic information or making material misrepresentations during the recruitment of employees regarding the key terms and conditions of employment, including wages and fringe benefits, the location of work, the living conditions, housing and associated costs (if employer or agent provided or arranged), any significant cost to be charged to the employee, and, if applicable, the hazardous nature of the work.

• Charging employees recruitment fees or using recruiters that do not comply with the country's local labor laws in which the recruiting takes place.

• Failing to provide return transportation or pay for the cost of return transportation upon the end of employment- (A) For an employee who is not a national of the country in which the work is taking place and who was brought into that country to work on a U.S. Government contract or subcontract (for portions of contracts performed outside the United States); or (B) For an employee who is not a United States national and who was brought into the United States to work on a U.S. Government contract or subcontract, if the payment of such costs is required under existing temporary worker programs or pursuant to a written agreement with the employee (for portions of contracts performed inside the United States); except that- (ii) The requirements of paragraphs (b)(7)(i) of this clause shall not apply to an employee who is- (A) Legally permitted to remain in the country of employment and who chooses to do so; or (B) Exempted by an authorized official of the contracting agency from the requirement to provide return transportation or pay for the cost of return transportation; (iii) The requirements of paragraph (b)(7)(i) of this clause are modified for a victim of trafficking in persons who is seeking victim services or legal redress in the country of employment, or for a witness in an enforcement action related to trafficking in persons. The contractor shall provide the return transportation or pay the cost of return transportation in a way that does not obstruct the victim's services, legal redress, or witness activity. For example, the contractor shall not only offer return transportation to a witness at a time when the witness is still needed to testify. This paragraph does not apply when the exemptions at paragraph (b)(7)(ii) of this clause apply.

• Providing or arrange housing that fails to meet the host country housing and safety standards.

• If required by law or contract, failing to provide an employment contract, recruitment agreement, or other required work documents in writing. Such written work documents shall be in a language the employee understands. If the employee must relocate to perform the work, the work document shall be provided to the employee at least five days prior to the employee relocating. The employee's work document shall include but is not limited to details about work description, wages, prohibition on charging recruitment fees, work location(s), living accommodations and associated costs, time off, roundtrip transportation arrangements, grievance process, and the content of applicable laws and regulations that prohibit trafficking in persons.

Strategic ACI will monitor its agents and subcontractors across all tiers and dollar values from engaging in trafficking in persons and terminate any agents, subcontracts, or subcontractor employees engaged in such activities.

Strategic ACI will not tolerate retaliation against an employee for reporting a concern in good faith or cooperating with a compliance investigation, even when no evidence is found to substantiate the report.

DISCIPLINARY ACTIONS Any violation of this policy may be grounds for disciplinary action, up to and including termination. Violation of the U.S. Government's policy against human trafficking may also result in responsible individuals' criminal prosecution.

REPORTING

Employees are required to report any conduct they believe violates this policy to their manager or Human Resources, or the Global Human Trafficking Hotline at 888-373-7888 or online at humantraffickinghotline.org.

If, for any reason, the employee does not feel comfortable with the procedures for reporting or is reporting an incident involving their immediate manager, the employee should contact the Strategic ACI CEO directly. Employees can also report information anonymously by browsing to https://www.strategicaci.com/anonymous-reporting.

Employees who fail to report actual or suspected misconduct may be deemed in violation of this policy.

BACKGROUND Strategic ACI has developed this Anti-Trafficking Compliance Plan in accordance with FAR 52.222-50, Combating Trafficking in Persons. The plan sets out the requirements and procedures for:

• Making employees aware of the conduct prohibited under the Combatting Trafficking in Persons policy and the actions that may be taken in the event of non-compliance or violation of the policy.

• Housing practices and safety standards.

• Preventing prohibited trafficking activity by sub-contractors and suppliers.

• Monitoring, detecting, and terminating those who engage in such activities.

SCOPE This Compliance Plan sets out Strategic ACI’s baseline standards for anti-trafficking compliance and applies to any portion of a U.S. Government contracts, sub-contracts, awards and sub-awards that:

• Is for supplies, other than commercially available off-the-shelf items, acquired outside the United States, or services to be performed outside the United States; and

• The overseas portion has an estimated value that exceeds $500,000.

This plan may need to be adapted or modified for projects that are larger, more complex, or involve greater risk of trafficking activity. For all covered contracts/agreements, Strategic ACI employees engaged in the project must examine each one individually to assess the risk of trafficking activity, based on whether the contract or award will involve services or supplies susceptible to trafficking in persons. Strategic ACI employees must adapt or modify the plan as necessary to ensure that it is appropriate to the size and complexity of the contract or award and the nature and scope of the activities to be performed.

EMPLOYEE AWARENESS PROGRAM Strategic ACI has adopted, in its Employee Handbook, a policy on Combatting Trafficking in Persons that reflects the Anti-Trafficking provisions prohibiting trafficking-related activities, describes the actions Strategic ACI may take against employees, subcontractors, and suppliers who violate the policy, and sets out the procedure for reporting and investigating Policy violations.

Strategic ACI has also posted on its Employee Resources site (Intranet) where it can be accessed by Strategic ACI Staff at any time and incorporates it by reference into subcontracts of covered contracts/agreements for Strategic ACI subcontractors and suppliers.

All new Strategic ACI Staff are required to acknowledge that they have familiarized themselves with the policies contained in the Employee Handbook. Onboarding and refresher trainings on the Strategic ACI Code of Conduct, including the Combatting Trafficking in Persons policy, are provided as needed and on an ongoing basis by Human Resources. Individuals may contact Human Resources at any time for questions, clarifications, or further discussion.

STRATEGIC ACI'S COMBATING TRAFFICKING IN PERSON POLICY Strategic ACI supports the zero-tolerance policy adopted by the United States government to combat human trafficking and forced labor. We are committed to high standards of ethics and integrity and compliance with all applicable local laws across our global operations, including prohibition of actions that facilitate trafficking in persons. Strategic ACI’s work outside of the United States potentially exposes employees and subcontractors to issues of human trafficking and forced labor.

The policy applies to all employees, as well as subcontractors, suppliers, consultants, at any tier, as well as their employees, labor recruiters, brokers, and agents engaged by Strategic ACI for the performance of U.S. federal government contracts, awards or other applicable agreements (Government Contracts).

In addition, this policy establishes a program compliant with U.S. Federal Government regulations which prohibits Strategic ACI, its subcontractors, at any tier, or their employees, labor recruiters, brokers or other agents from the following prohibited activities:

• Trafficking in Persons during the period of a Government Contract.

• Procuring Commercial Sex Acts during the period of a Government Contract.

• Using Forced Labor in the performance of a Government Contract.

• Destroying, concealing, confiscating or otherwise denying any employee access to his or her identity or immigration documents, such as a passport or driver's license.

• Using misleading or fraudulent recruiting practices during the recruitment of employees or offering of employment to employees, such as failing to disclose (in a format and language accessible to the employee) or making material misrepresentations about the key terms and conditions of employment, including wage and benefits, work location, living conditions, housing and associated costs, significant costs to be charged to the employee and hazardous nature of the work (if applicable).

• Failing to provide or pay the cost of return transportation at the end of employment for an employee who is not a national of the country where the work took place and who was sent to that country for purposes of working on a Government Contract.

• Providing or arranging housing that fails to meet the host country housing and safety standards.

All agreements with Strategic ACI suppliers and subcontractors under Government Contracts will include a provision prescribing the above prohibited activities.

HOUSING PLAN If Strategic ACI provides or is arranging for housing facilities to employees, the housing will meet host country housing and safety standards.

SUBCONTRACTOR/SUPPLIER COMPLIANCE All Strategic ACI subcontractors, suppliers, consultants, at any tier, engaged in the performance of a covered contracts/agreements must agree to comply with the policy and all applicable Anti-Trafficking provisions. Strategic ACI will include language to that effect in all covered contracts/agreements, including inserting FAR 52.222-50, FAR 52.222-56 where applicable.

All Strategic ACI suppliers and subcontractors engaged to perform under covered contracts/agreements must have a compliance plan to prevent prohibited trafficking-related activities and to monitor, detect and terminate any of its contractors, consultants, suppliers, sub-contractors or sub-recipients engaging in prohibited trafficking-relating activities, and provide a copy of its plan to Strategic ACI.

The Subcontractor's/Supplier’s compliance plan must meet the minimum requirements in the Anti-Trafficking Provisions and be appropriate to the size and complexity of the contract and the nature of the activities to be performed under it.

Prior to the award of any subcontract, and on an annual basis thereafter, all Strategic ACI subcontractors must submit a certification to Strategic ACI:

• That the subcontractor has implemented a compliance plan and has complied with its compliance plan; and

• That after conducting due diligence, to the best of the subcontractor’s knowledge and belief, neither it nor any of its employees, or its contractors, consultants, suppliers, sub-contractors, sub-recipients or their employees, have engaged in any prohibited trafficking-related activities, or if any abuses relating to prohibited trafficking-related activities have been found, the subcontractor has taken appropriate remedial and referral actions.

If any subcontractor or supplier fails to comply with the policy, applicable contractual language in the subcontract, or applicable Anti-Trafficking Provisions, Strategic ACI will take appropriate action to remediate the violation and prevent future violations, including, but not limited to:

• Requiring the subcontractor or supplier to remove an employee or agent from a project;

• Requiring the subcontractor or supplier to terminate its relationship with any Supplier contractor, consultant, supplier, sub-contractor or sub-recipient;

• Suspending payments to the subcontractor or supplier until violation is remedied;

• Terminating the subcontractor or supplier’s contract for cause with immediate effect.

REPORTING REQUIREMENTS AND PROCEDURES All Strategic ACI Staff, subcontractors, suppliers, and employees of Strategic ACI subcontractors are required to report any trafficking-in-persons related activities or violations of Strategic ACI’s Anti-Trafficking Policy to Strategic ACI. Reports may be made on a confidential basis on Strategic ACI’s website.

Any Strategic ACI Staff who receive such a report must immediately share all pertinent information with Strategic ACI Human Resources. In addition, any Strategic ACI Staff or employees of Strategic ACI suppliers or subcontractors who believe that they or others have been subjected to Prohibited Activities may submit a report as outlined above or may contact their manager or Human Resources, or the Global Human Trafficking Hotline at 888-373-7888 or online at humantraffickinghotline.org.

Strategic ACI will investigate all reports of prohibited activities and other violations of this policy and take appropriate action. In addition, Strategic ACI’s Contracts Manager will make all required disclosures as set forth in its plan.

Strategic ACI strictly prohibits retaliation against any Strategic ACI employee who report prohibited activities or other violations of this policy. Strategic ACI employees who engage in retaliation against those who report prohibited activities or other policy violations are subject to disciplinary action, up to and including termination.

INVESTIGATIONS If Strategic ACI receives credible information from an employee report or any other source alleging prohibited trafficking-related activity, Strategic ACI Human Resources will conduct an investigation and report its findings and determine what, if any, remedial action is appropriate.

Human Resources will also monitor management’s implementation of such remedial action.

The Strategic ACI Contracts Manager will be responsible for immediately notifying the contracting officer and the appropriate agency Inspector General of the information received and any resulting remedial action taken.

Strategic ACI will cooperate fully with any US Government agencies responsible for any investigations, audits or corrective actions relating to trafficking in persons, including, but not limited to, providing timely and complete responses to document requests, and providing reasonable access to Strategic ACI facilities and employees.

Strategic ACI will protect all employees suspected of being victims of or witnesses to prohibited activities and will not prevent or hinder these employees from cooperating fully with US government authorities.

POSTING

Strategic ACI will post this plan on its Employee Resources site (Intranet) and on its external website at www.strategicaci.com.

ANONYMOUS REPORTING Anyone can submit an anonymous report covering any suspected violation of Strategic ACI policy, ethics, or code of conduct violation. Reports can be submitted using our Anonymous Reporting Form.

Submit an Anonymous Report →

DoD REPORTING HOTLINE The DoD Inspector General Reporting Hotline is a confidential way to report fraud, waste, abuse and other violations of law.

The mission of the DoD Hotline is to provide a confidential, reliable means to report violations of law, rule, or regulation; fraud, waste, and abuse; mismanagement; trafficking in persons; serious security incidents; or other criminal or administrative misconduct that involve DoD personnel and operations — without fear of reprisal.

More information and ways to report can be found at: https://www.dodig.mil/components/administrative-investigations/DoD-hotline/

IC REPORTING HOTLINE The Intelligence Community (IC) Inspector General (IG) is authorized to investigate complaints or information concerning allegations of a violation of law, rule, regulation, waste, fraud, abuse of authority, or a substantial or specific danger to public health and safety in connection with ODNI and/or IC intelligence programs and activities.

More information and ways to report can be found at: https://www.dni.gov/index.php/who-we-are/organizations/icig/icig-hotline

https://www.cigna.com/legal/compliance/machine-readable-files

This link leads to the machine-readable files that are made available in response to the federal Transparency in Coverage Rule and includes negotiated service rates and out-of-network allowed amounts between health plans and healthcare providers.

The machine-readable files are formatted to allow researchers, regulators, and application developers to more easily access and analyze data.