Exhibit 99.2



THE TRIZETTO GROUP, INC.  CODE OF
BUSINESS CONDUCT AND ETHICS



|I. |  | INTRODUCTION
|-- |  | ------------



Set forth herein is the Code of Business Conduct and Ethics adopted by The TriZetto Group, Inc. (TriZetto). This Code
summarizes the basic principles and standards of conduct to guide all directors, officers and employees of TriZetto in our goal to achieve the highest business and personal ethical standards as well as compliance with the laws and regulations that
apply to our business. All of our directors, officers and employees must conduct themselves accordingly in every aspect of our business and seek to avoid even the appearance of improper behavior. Our goal has been, and will continue to be, to
advance the highest standards of ethical conduct. We expect all of our agents, consultants, contractors, suppliers and representatives to be guided by the principles and standards set forth in this Code. The Code does not supersede, change or alter
existing TriZetto policies and procedures, including, but not limited to, TriZettos Employee Handbook and Insider Trading Policy.



The Code of Business Conduct and Ethics is designed to deter wrongdoing and to promote:



| |  |  | Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;
| | - |  | -------------------------------------------------------------------------------------------------------------------------------------------------------



| |  |  | Full, fair, accurate, timely, and understandable disclosure in reports and documents that TriZetto files with the Securities Exchange Commission and in all other
public communications;
| | - |  | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| |  |  | Compliance with applicable governmental laws, rules and regulations;
| | - |  | --------------------------------------------------------------------



| |  |  | The prompt internal reporting of violations of the Code; and
| | - |  | ------------------------------------------------------------



| |  |  | Accountability for adherence to the Code.
| | - |  | -----------------------------------------



The Code covers a wide range of business practices and procedures, but is not intended to summarize all applicable laws and regulations or
to respond to every question or concern that may arise. If you have a question regarding any of the goals, principles, or standards discussed or policies or procedures referred to in this Code or are in doubt about the best course of action to take
in a particular situation, please contact TriZettos General Counsel or follow the procedures set forth in Section XVI of this Code.



Every director, officer and employee of TriZetto has a duty to adhere to this Code. Any individual who violates the standards in this Code
is subject to disciplinary action, up to and including termination, and civil and criminal prosecution, if appropriate. If you are in a situation that you believe may violate or lead to a violation of this Code, follow the guidelines described in
Section XVI of this Code.



|II. |  | COMPLIANCE WITH LAWS, RULES AND REGULATIONS
|--- |  | -------------------------------------------



Obeying the law, both in letter and in spirit, is the foundation on which TriZettos ethical standards are built. All directors,
officers and employees must respect and obey the laws of the cities, states and countries in which we operate. Although not all employees are expected to know the details of these laws, it is important to know enough to determine when to seek advice
from supervisors, managers or other appropriate personnel. Compliance with the law does not obviate the need to act with the highest ethical standards.



TriZetto provides a wide range of training, both mandatory and voluntary, for employees to promote understanding and compliance with
various laws, rules and regulations.



|III. |  | CONFLICTS OF INTEREST
|---- |  | ---------------------



A conflict of interest exists when a persons private interest interferes in any way with the interests of TriZetto. A
conflict situation can arise when a director, officer or employee takes actions or has interests that may make it difficult to perform his or her TriZetto work objectively and effectively. Conflicts of interest may also arise when a director,
officer or employee, or members of his or her family, receives improper personal benefits as a result of his or her position with TriZetto. Loans to, or guarantees of obligations of, officers and employees, and their family members, may create
conflicts of interest. Loans to directors and executive officers of TriZetto are prohibited by law and may not be made.



---



A conflict of
interest may arise if a TriZetto director, officer or employee works simultaneously for a competitor, customer or major supplier. You are not allowed to work for a competitor as a consultant or board member. The best policy is to avoid any direct or
indirect business connection with our customers, suppliers or competitors, except on our behalf.



Conflicts of interest are prohibited as a matter of TriZetto policy, except under guidelines approved by the Board of Directors. Conflicts of interest may not always be clear-cut. Therefore, you should
avoid any situation that could give rise to the appearance of a conflict of interest. If questions arise, you should consult TriZettos General Counsel. The Chief Executive Officer and directors must report any such circumstance to and obtain
approval from the Audit Committee.



Any director,
officer or employee who becomes aware of a conflict or a potential conflict should bring it to the attention of a supervisor, manager or other appropriate personnel or follow the procedures described in Section XVI of this Code.



|IV. |  | INSIDER TRADING
|--- |  | ---------------



Directors, officers and employees of TriZetto who have access to confidential information are not permitted to use or share that
information for stock trading purposes or for any other purpose except the conduct of our business. All non-public information about TriZetto should be considered confidential information. To use non-public information for personal financial benefit
or to tip others who might make an investment decision on the basis of this information is not only unethical but also illegal. Please refer to TriZettos Insider Trading Policy for more information regarding TriZettos
policies and procedures with respect to trading in TriZettos securities. If you have any questions, please consult TriZettos General Counsel.



This guidance also applies to trading in securities of other companies for which you receive information in the course of your employment
with TriZetto.



|V. |  | CORPORATE OPPORTUNITIES
|-- |  | -----------------------



Directors, officers and employees are prohibited from personally benefiting from opportunities that are discovered through the use of
corporate property, information or position without the consent of TriZettos Board of Directors. No director, officer or employee may use corporate property, information, or position for improper personal gain. Directors, officers and
employees owe a duty to TriZetto to advance its legitimate interests when the opportunity to do so arises.



|VI. |  | COMPETITION AND FAIR DEALING
|--- |  | ----------------------------



We seek to outperform our competition fairly and honestly. We seek competitive advantages through superior performance, never through
unethical or illegal business practices. Stealing proprietary information, possessing trade secret information that was obtained without the owners consent, or inducing such disclosures by past or present employees of other companies is
prohibited. No director, officer or employee of TriZetto should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other intentional unfair-dealing
practice.



The purpose of business entertainment
and gifts in a commercial setting is to create good will and sound working relationships, not to gain unfair advantage with customers. No gift or entertainment should ever be offered, given, provided or accepted by any TriZetto director, officer,
employee, family member of any of the foregoing or agent unless it:



| |  |  | is not a cash gift;
| | - |  | -------------------



| |  |  | is consistent with customary business practices;
| | - |  | ------------------------------------------------



| |  |  | is not excessive in value;
| | - |  | --------------------------



| |  |  | cannot be construed as a bribe or payoff; and
| | - |  | ---------------------------------------------



| |  |  | does not violate any laws or regulations.
| | - |  | -----------------------------------------



Please discuss with your supervisor any gifts or proposed gifts that you are not certain are appropriate.



|VII. |  | DISCRIMINATION AND HARASSMENT
|---- |  | -----------------------------



The diversity of TriZettos employees is a tremendous asset. As evidenced by our equal employment opportunity and anti-harassment
policies, TriZetto is firmly committed to providing equal employment opportunity to qualified individuals regardless of race, color, religion, gender, age, national origin, sexual orientation, disability, veteran status, marital status, or other
protected status. TriZetto will not tolerate illegal discrimination or harassment of any kind. Our anti-harassment policy explains in detail the types of conduct that are prohibited. Examples include



2



---

derogatory comments based on racial or ethnic characteristics and unwelcome conduct of a sexual nature.
Violations of our anti-harassment and equal employment opportunity policies should be reported immediately as provided in those policies and in Section XVI, below.



All of our employees deserve a work environment where they will be respected and TriZetto is committed to
providing an environment that supports honesty, integrity, respect, trust and responsibility. All of our employees should contribute to the creation and maintenance of such an environment and our executive officers and management and supervisory
personnel should take a leadership role in achieving a work environment that meets our diversity standards and is free from discrimination and harassment.



|VIII. |  | HEALTH AND SAFETY
|----- |  | -----------------



TriZetto strives to provide each employee with a safe and healthy work environment. Each employee has a responsibility for maintaining a
safe and healthy workplace for all employees by following safety and health rules and practices and reporting accidents, injuries and unsafe equipment, practices or conditions and complying with visitor hosting procedures and other facility security
related policies and procedures.



Violence and
threatening behavior are not permitted. Employees should report to work in condition to perform their duties, free from the influence of alcohol, illegal drugs or controlled substances. Employees who report to work under the influence of or in
possession of illegal drugs or alcohol are subject to disciplinary action up to and including termination.



|IX. |  | RECORD-KEEPING
|--- |  | --------------



TriZetto requires honest and accurate recording and reporting of information in order to make responsible business decisions.



Many directors, officers and employees regularly
use business expense accounts, which must be documented and recorded accurately. No one should rationalize or consider misrepresenting facts or falsifying records. If you are not sure whether a certain expense is legitimate, ask your supervisor or
the Corporate Accounting Department. Rules and guidelines are available from the Corporate Accounting Department.



All of TriZettos books, records, accounts and financial statements must be maintained in reasonable detail, must appropriately
reflect TriZettos transactions, and must conform both to applicable legal requirements and to TriZettos system of internal controls and generally accepted accounting principles. Unrecorded or off the books funds or assets
should not be maintained unless permitted by applicable law or regulation.



Business records and communications often become public, and we should avoid exaggeration, derogatory remarks, guesswork, or inappropriate characterizations of people and companies that can be
misunderstood. This applies equally to e-mail, internal memos, and formal reports. Records should always be retained or destroyed according to TriZettos record retention policies. In accordance with those policies, in the event of litigation
or governmental investigation please consult TriZettos General Counsel.



|X. |  | FINANCIAL REPORTING AND DISCLOSURE
|-- |  | ----------------------------------



All transactions involving TriZetto and its subsidiaries must be documented, in reasonable detail, and accounted for on the books and
records of TriZetto in accordance with generally accepted accounting principles and applicable laws and regulations. TriZettos Chief Financial Officer (CFO) is the chief accounting officer of TriZetto and is responsible for
establishing and maintaining accounting policies and procedures, disclosure controls and internal control standards and the requirements for financial reporting to TriZettos Management and others.



|XI. |  | CONFIDENTIALITY
|--- |  | ---------------



Directors, officers and employees must safeguard the confidentiality of confidential information entrusted to them by TriZetto or its
customers, except when disclosure is authorized by the Legal Department or required by laws or regulations. Confidential information includes all non-public information that might be of use to competitors, or harmful to TriZetto or its customers, if
disclosed. It also includes information that suppliers and customers have entrusted to us, including Protected Health Information (PHI) as required under the Health Insurance Portability and Accountability Act (HIPAA). The
obligation to preserve confidential information continues even after employment ends. All officers and employees must complete training on TriZetto Privacy and Security policies and procedures and comply with applicable federal and state privacy
requirements. Any violation of HIPAA privacy requirements should be reported to your supervisor and to the HIPAA Privacy Officer.



3



---



|XII. |  | PROTECTION AND PROPER USE OF TRIZETTO ASSETS
|---- |  | --------------------------------------------



All directors, officers and employees should endeavor to protect TriZettos assets, including funds, property, electronic
communications systems, information resources, data, facilities, equipment and supplies to ensure their efficient use. Protection of TriZettos assets is vital since theft, carelessness and waste have a direct impact on TriZettos
profitability. Any suspected incident of fraud or theft should be immediately reported for investigation pursuant to Section XVI of this Code. TriZetto assets should not be used for non-TriZetto business, although we recognize that incidental
personal use may be permitted without adversely affecting the interests of TriZetto. Personal use of TriZetto assets must always be in accordance with TriZetto policy. You should consult your supervisor for appropriate guidance and permission.



The obligation of directors, officers and
employees to protect TriZettos assets includes its proprietary information. Proprietary information includes intellectual property such as trade secrets, software programs, patents, trademarks and copyrights, as well as business, marketing and
service plans, designs, databases, records, salary information and any unpublished financial data and reports. Unauthorized use or distribution of this information is a violation of TriZetto policy. It could also be illegal and result in civil or
criminal penalties. Each employee of TriZetto is required to comply with the provisions of the Intellectual Property and Technical Information Agreement, whether or not such agreement has been executed by the employee.



|XIII. |  | PAYMENTS TO GOVERNMENT PERSONNEL
|----- |  | --------------------------------



The U.S. Foreign Corrupt Practices Act prohibits giving anything of value, directly or indirectly, to officials of foreign governments or
foreign political candidates in order to obtain or retain business. It is strictly prohibited to make illegal payments to government officials of any country.



In addition, the U.S. government has a number of laws and regulations regarding business gratuities that may be accepted by U.S.
government personnel. The promise, offer or delivery to an official or employee of the U.S. government of a gift, favor or other gratuity in violation of these rules would not only violate TriZetto policy but could also be a criminal offense. State
and local governments, as well as foreign governments, may have similar rules. TriZettos General Counsel can provide guidance to you in this area.



|XIV. |  | IMPROPER INFLUENCE ON CONDUCT OF AUDITS
|---- |  | ---------------------------------------



No director, officer or employee of TriZetto shall take any action (e.g., offering or paying bribes or other financial incentives,
providing inaccurate or misleading legal analysis, blackmailing, and making physical threats) or make any false, misleading or inaccurate oral or written statement to fraudulently influence, coerce, manipulate or mislead an independent auditor
engaged in the performance of an audit of TriZettos financial statements for the purpose of rendering the financial statements materially misleading.



|XV. |  | COMPLIANCE PROCEDURES
|--- |  | ---------------------



Each director, officer and employee of TriZetto must work to ensure prompt and consistent action against violations of this Code. However,
in some situations it may be difficult to know if a violation has occurred. Since we cannot anticipate every situation that will arise, it is important that we have a way to approach a new question or problem. These are the steps to keep in mind:



| | · |  | Make sure you have all the facts. In order to reach the right solutions, we must be as fully informed as possible.
| | - |  | ------------------------------------------------------------------------------------------------------------------



| | · |  | Ask yourself: What specifically am I being asked to do? Does it seem unethical or improper? This will enable you to focus on the specific question you are faced
with, and the alternatives you have. Use your judgment and common sense; if something seems unethical or improper, it probably is.
| | - |  | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | · |  | Clarify your responsibility and role. In most situations, there is shared responsibility. Are your colleagues informed? It may help to get others involved and
discuss the problem.
| | - |  | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | · |  | Discuss the problem with your supervisor. This is the basic guidance for all situations. In many cases, your supervisor will be more knowledgeable about the
question, and will appreciate being brought into the decision-making process. Remember that it is your supervisors responsibility to help solve problems.
| | - |  | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | · |  | Seek help from TriZetto resources. In the case where it may not be appropriate to discuss an issue with your supervisor, or where you do not feel comfortable
approaching your supervisor with your
| | - |  | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



4



---

question, discuss it with your office manager or Human Resources manager. If that also is
not appropriate, call TriZettos Senior Vice President, Organizational Effectiveness or General Counsel.



| |  |  | You may report ethical violations in confidence and without fear of retaliation. If your situation requires that your identity be kept secret, every effort will be
made to protect your anonymity. TriZetto does not permit retaliation of any kind against employees for good faith reports of ethical violations or misconduct.
| | - |  | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| |  |  | Always ask first, act later. If you are unsure of what to do in any situation, seek guidance before you act.
| | - |  | ------------------------------------------------------------------------------------------------------------



XVI.    REPORTING ANY ILLEGAL OR UNETHICAL BEHAVIOR



Directors, officers and employees are
encouraged to promptly discuss with, or otherwise disclose to, their supervisors, managers or other appropriate personnel any observed or suspected illegal or unethical behavior. In the case where it may not be appropriate to discuss an issue with
your supervisor, or where you do not feel comfortable approaching your supervisor with your question, discuss it with your office manager or your Human Resources manager. If that also is not appropriate, call TriZettos Senior Vice President,
Organizational Effectiveness or General Counsel.



Reporting of violations will remain confidential to the degree possible. No employee of TriZetto may be discharged, demoted, suspended, threatened, harassed or in any other manner be discriminated against in the terms and conditions
of their employment because of reporting or aiding in the investigation of illegal or unethical behavior. Directors, officers and employees are expected to cooperate in internal investigations of misconduct.



|XVII. |  | VIOLATIONS OF THE CODE AND DISCIPLINARY ACTION
|----- |  | ----------------------------------------------



Every director, officer and employee of TriZetto has a duty to adhere to this Code. Any individual who violates the standards in this Code
is subject to disciplinary action, up to and including termination, and civil and criminal prosecution, if appropriate. TriZetto will promptly and properly document all reasons for disciplinary actions taken against its directors, officers and
employees for violations of the Code.



XVIII. WAIVERS OF THE
CODE OF BUSINESS CONDUCT AND ETHICS



Any
waiver of this Code for directors or executive officers of TriZetto may be made only by TriZettos Board of Directors or a committee thereof and will be promptly disclosed as required by law or by stock exchange or market rule or regulation.



5