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Standards of Business Conduct

Dear Fellow Employee,

Letter from Kurt Frohlich

When I started Apex in 2001, I believed the company could make a difference and affect positive change for our customers through training and technology. That belief holds true today and together we are empowering people to do more with the services, tools, and knowledge we provide. Our focus, simply put, is to help our customers and partners thrive in a competitive, data driven, and fast-paced world.

Living in such a technology and data-driven era means asking people and organizations to trust us with their information and data. Trust is paramount in how we operate and conduct business with individuals, companies, and governments. We build and maintain trust through our shared commitment to ethical behavior and by acting with honesty and integrity.

Our success depends on you. We set high ethical standards at Apex and we expect every employee to live up to them. Complying with the law and company policies is the first and most important job of every Apex employee. A momentary lapse in judgment by a single employee has the potential to erode the value and the trust we bring to customers. As an Apex employee, you are expected to maintain a commitment to high ethical standards and conduct Apex’s business with integrity.

The Standards of Business Conduct are an extension of Apex’s values and reflect our continued commitment to ethical business practices and complying with the law. We expect you to be well informed and exercise good judgment when making business decisions, and the Standards are designed to help you make the right decisions for yourself and Apex.

The Standards are not intended to cover every issue or situation you may face as an Apex employee. These Standards summarize, and are supported by, the principles and policies that govern our company. You should use the Standards, in conjunction with our corporate policies, to guide and inform your conduct. Please use the resources described in the Standards to help answer your questions or address your concerns. In addition, managers should use the Standards to foster and reward a culture of accountability and integrity within their groups.

All Apex employees are responsible for understanding and complying with the Standards, Apex policies, laws, and regulations. We all have a responsibility to raise compliance and ethics concerns, and we want to hear from you if you have a concern. Apex prohibits retaliation against any employee who in good faith seeks guidance or reports a possible violation of the Standards.

I firmly believe that Apex is a “best in class” company for employees who want to innovate, drive change, make a difference, and do their best work. Thank you for living our core values and your commitment to ethical and legal behavior. There must be integrity in everything we do.

Kurt Frohlich

Standards of Business Conduct (PDF)