The Prometric Commitment

Dear Prometric colleague,

Prometric LLC maintains the highest ethical standards in conducting company affairs and in our relationships with customers, suppliers, employees, advisors and the communities in which our operations are located. The purpose of this Code of Business Conduct and Ethics is to affirm our strong commitment to the highest standards of legal and ethical conduct in our business practices. This Code provides you with an understanding of the conduct and standards of behavior expected of all of us as Prometric employees.

This Code applies to all officers, directors and employees of Prometric and its subsidiaries – no matter where you work. We also expect that those with whom we do business will adhere to the standards set forth in this Code. Please take the time to review this Code carefully – both at this time, and periodically throughout your employment with Prometric. The Code does not anticipate every ethical decision that you may face as a Prometric employee. So if you have any questions, please ask for guidance.

Your dedication to the principles embodied in this document will ensure that we all continue to enjoy a reputation for personal integrity, ethics and professional excellence.

Sincerely

ROY SIMRELL

PRESIDENT and CHIEF EXECUTIVE OFFICER

PROMETRIC LLC

Overview

When you are faced with a situation and you are not clear as to what action you should take, ask yourself the following questions:

  • Is the action legal?
  • Is the action ethical?
  • Does the action comply with this Code and other policies and laws applicable to my job?
  • How will my decision affect others, including our customers, shareholders, employees and the community?
  • How will my decision look to others? If your action is legal but can result in the appearance of wrongdoing, consider taking alternative steps.
  • How would I feel if my decision were made public? Could the decision be honestly explained and defended?
  • Should I contact my manager, my Human Resources department or the Prometric legal department regarding the action?

Please refer to the section “Questions & How to Report Concerns & Violations” of this Code for more information about how to ask questions and/or report any possible Code violations, including how to do so anonymously and confidentially.

New employees will receive a copy of the Code and are required to certify in writing that they understand the Code and their obligation to conform to its obligations. This will be done as part of their new hire orientation. Thank you for your adherence to this requirement.

Employee Acknowledgment Requirement

After reading this Code, we request that you acknowledge that you have received access to and read this Code and that you understand your obligations to comply with the Code. This will be done as part of annual training and recertification. You are required to recertify that you understand your obligations under the Code.

Prometric Ethics Code

US Foreign Policy Compliance Statement

Safeguarding Policy Statement