Code of Conduct

Preserving a Culture of Integrity and Safeguarding Our Reputation

We, leaders and team members across the APS organization, are individually and collectively responsible and accountable for preserving a culture of integrity and safeguarding the company’s reputation by maintaining APS’s financial, legal and service integrity.

We fulfill this goal by upholding our core values in dealing with our key stakeholder groups: our employees, our customers, our business partners and suppliers, our shareholders, and the community at large.

We strive to build an organizational culture that guides our actions and decision-making in a way that is rooted in what we consider to be fair and honest, and what promotes a dignified life for all people.

To achieve these goals, leaders must ensure that all employees in his/her constituency are made aware of their rights and commitments under this Code of Conduct and that APS’s values are upheld at all times. Each employee is responsible for ensuring that s/he fully understands the principles and ethical guidelines that are enunciated in the Code and the related APS policies and regulations, in order to deal with ethical dilemmas that may arise. Where policies, procedures and internal controls do not offer clear guidance for a particular course of action, employees and leaders are expected to honor the spirit of the Code and/or to seek advice.

The Code that follows provides only broad guidelines, and cannot cover all potential issues. It describes the standards of integrity to which we hold ourselves. Further, while these standards strive to establish the highest level of integrity, we recognize that various countries in which we operate may have laws and regulations that establish different requirements for corporate integrity. Whenever that is the case, APS foreign subsidiaries and employees are required to comply with all applicable local laws.

APS’s Core Values and Organizational Culture

Our core values guide our commitment to ethical and responsible conduct. We at APS believe in excellence in the provision of our services and strive to create lasting stakeholder perceptions of our commitment to this overriding value. We encourage entrepreneurship and the embrace of challenge by our employees as a path to innovation, value team work and collaborative relations, promote diversity and respect for the individual and stand in solidarity with the communities in which we operate by acting as a socially responsible and active corporate citizen. We strive to uphold these values in every action we take and every decision we make, and in defining what we commit to and expect from our stakeholders.

We aspire to build a culture of integrity. We manage our relations with our stakeholder groups in a manner that is consistent with our core values and conducive to nurturing a lasting conviction on their part, and of the public at large, that “we do the right thing.”

Service Integrity:

The reputation of the APS brand depends on the trust of the general public in our service integrity. Customers need to be able to trust the credibility of the information they are given. Official authorities such as customs and security officials should be able to trust in APS’s legal and regulatory compliance, discipline and diligence. APS employees must be aware of and diligent about the factors that affect our service reputation and must work individually and collectively to guard and protect it. Specific areas of attention include: over-promising, relationships with customs and enforcement authorities, and security concerns.

Financial Integrity

The financial integrity of APS’s operations concerns all of our stakeholders: shareholders, government authorities, suppliers, business partners, customers and employees. Our financial reputation is affected by our actual and perceived integrity by all of them. Our reputation for financial integrity depends on our consistency in providing complete, timely and accurate payments, billing and reporting, and keeping accurate and complete records at all times. All APS employees have a role in ensuring the integrity of our financial transactions, records, and financial and non-financial reporting.

Legal Integrity

APS respects all international, national, state and local laws and regulations. Litigation and fines negatively affects our reputation. APS employees must commit to and help ensure compliance with laws and regulations including but not limited to those relating to copyrights and the intellectual property rights of others.

Stakeholder Relations

APS People APS commits to providing a supportive and healthy working environment based on fairness and honesty with our employees, one that rewards achievement, dedication, teamwork, attitudes and personal skills that embody the spirit of our corporate values. We expect our people to fulfill their responsibilities and empower themselves to protect and strengthen this environment.

We commit to establishing a working environment based on the following tenets and expect our people to join us in this effort:

• Equal employment opportunities

• Equitable and fair treatment and advancement opportunities for all employees

• Safe, secure and healthy working conditions and environment

• Respect for colleagues and their diversity

• Accountability

• Respect for universal human and labor rights

• Support for our people during crises and emergencies

• Open communication and an open-door policy

• Avoidance of and transparency concerning conflicts of interest

• Protection and efficient use of company assets and property

• Protection of all confidential information including APS trade secrets and intellectual property

• Adherence to company policies regarding business gifts and entertainment

• Not tolerating or accommodating bribery and corruption