Exhibit 14.2

TABLE OF CONTENTS



|                           |  |                                                                               |  |                                             |  |   
|-------------------------- |  | ----------------------------------------------------------------------------- |  | ------------------------------------------- |  | --
|Message from the CEO       |  | 2                                                                            
|                           |  |                                                                              
|                           |  | 1.      The Code                                                              |  | 3                                          
|                           |  |                                                                              
|                           |  | 2.      Raising Questions and Concerns                                        |  | 5                                          
|                           |  |                                                                              
|                           |  | 3.      Who Do I Contact?                                                     |  | 6                                          
|                           |  |                                                                              
|                           |  | 4.      Maintaining a Safe, Healthy and Affirmative Workplace and Environment |  | 7                                          
|                           |  |                                                                               |  | 4.1      Alcohol and Substance Abuse        |  | 8 
|                           |  |                                                                               |  | 4.2      Fostering a Safe Workplace         |  | 9 
|                           |  |                                                                               |  | 4.3      Protecting the Environment         |  | 9 
|                           |  |                                                                              
|                           |  | 5.      Conflicts of Interest                                                 |  | 9                                          
|                           |  |                                                                              
|                           |  | 6.      Protection and Proper Use of Company Assets                           |  | 11                                         
|                           |  |                                                                              
|                           |  | 7.      Confidential Information/Privacy                                      |  | 12                                         
|                           |  |                                                                              
|                           |  | 8.      Insider Trading and Fair Disclosure                                   |  | 13                                         
|                           |  |                                                                              
|                           |  | 9.      Network Use, Integrity & Security                                     |  | 13                                         
|                           |  |                                                                              
|                           |  | 10.    Trade Practices                                                        |  | 14                                         
|                           |  |                                                                               |  | 10.1    Fair Dealing                        |  | 14
|                           |  |                                                                               |  | 10.2    Fair and Accurate Advertising       |  | 15
|                           |  |                                                                               |  | 10.3    Antitrust Compliance                |  | 16
|                           |  |                                                                              
|                           |  | 11.    International Business Dealings                                        |  | 17                                         
|                           |  |                                                                               |  | 11.1    Bribery and Other Corrupt Practices |  | 17
|                           |  |                                                                               |  | 11.2    Export and Other Considerations     |  | 18
|                           |  |                                                                              
|                           |  | 12.    Political Contributions and Activities                                 |  | 20                                         
|                           |  |                                                                              
|                           |  | 13.    Accounting Practices, Books, & Records                                 |  | 20                                         
|                           |  |                                                                              
|                           |  | 14.    Records Retention                                                      |  | 22                                         
|                           |  |                                                                              
|                           |  | 15.    Violations of This Code                                                |  | 22                                         
|                           | 
|Frequently Asked Questions |  | 23                                                                           
|                           | 
|Certificate of Compliance  |  | 26                                                                           



1



---

MESSAGE FROM THE CEO

Dear Colleagues,

Today, more than ever,
honesty and integrity are requisite parts of successful relationships, both business and personal. At Comverse, honesty, integrity and accountability are crucial to our business success, and they are the foundation for our continued growth.

The integrity of all of our employees, officers and directors provides the basis for our strong core values, and we must all uphold these
values every day. We strive to provide our customers with the highest quality products, services and solutions, and in doing so, we must also maintain the highest ethical standards. Nothing must compromise customer trust and confidence in our
Company.

This Code of Business Conduct and Ethics sets forth our legal and ethical standards. It should help guide your decisions and help
you understand the conduct that is expected of every one of us. As custodians of the Companys reputation and integrity, we must all ensure that we abide by the letter of the Code and protect and promote its spirit.

Please read the Code carefully and become familiar with its terms. If you have any questions, suggestions or concerns about the Code, please contact your
supervisor or the Legal Department. Once you have read the Code and understand it, please sign the enclosed certification and return it to the Legal Department. You may also be asked periodically in succeeding years to certify that you have complied
with the Code.

Thank you for your hard work in enhancing our Companys reputation and your continued commitment to ethical conduct.

Andre Dahan

Chief Executive
Officer and President



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



2



---

|1. | THE CODE
|-- | --------

This Code of Business Conduct
and Ethics (this Code) is designed to promote:



| |  |  | Honesty
| | - |  | -------



| |  |  | Ethical behavior
| | - |  | ----------------



| |  |  | Lawful conduct
| | - |  | --------------

It
applies to all:



| |  |  | Employees
| | - |  | ---------



| |  |  | Officers
| | - |  | --------



| |  |  | Directors
| | - |  | ---------

of Comverse
Technology, Inc. and all wholly-owned subsidiaries, including Comverse, Inc. (and its subsidiaries) and other controlled entities (collectively, the
Company),*whether in the United States or abroad.
The Company will also take reasonable steps to ensure that those who represent the Company and conduct Company business such as:



| |  |  | Independent contractors
| | - |  | -----------------------



| |  |  | Agents
| | - |  | ------



| |  |  | Consultants
| | - |  | -----------



| |  |  | Sales representatives
| | - |  | ---------------------

comply with relevant portions of the Code.

In
order to maintain the integrity and value of this Company, all employees, officers and directors are expected to comply with all applicable laws, rules and regulations in countries where the Company does business. Violation of domestic or foreign
laws and



|* | This Code also constitutes the code of ethics applicable to senior financial officers and the principal executive officer required by Section 406 of the
Sarbanes-Oxley Act of 2002.
|- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



3



---

regulations may subject you, as well as the Company, to civil and/or criminal penalties. To assist with the compliance of applicable laws and regulations, and to stimulate awareness of ethical
issues you may encounter in carrying out your responsibilities, the Company has established this Code along with various policies and compliance procedures. While the Code cannot possibly cover every situation you may encounter, it does provide
guidance with respect to some of your responsibilities to the Company. This Code should be looked at as a guide or a roadmap as to what is expected of all of us.

Look inside your employee manual or ask your supervisor about which Company policies specifically apply to you. You have an obligation to comply with
these policies and procedures and to promptly alert the Legal Department of any deviation from them.

At all times, you are expected
to:



| |  |  | Avoid conflicts between personal and professional interests where possible
| | - |  | --------------------------------------------------------------------------



| |  |  | Disclose any conflict to a supervisor or the Companys Legal Department and pursue the ethical handling of unavoidable actual or apparent
conflicts
| | - |  | ---------------------------------------------------------------------------------------------------------------------------------------------------



| |  |  | Provide accurate and complete informationand in a timely manner
| | - |  | ---------------------------------------------------------------



| |  |  | Provide full, fair, accurate, timely, and understandable disclosure in the periodic reports required to be filed by the Company
| | - |  | -------------------------------------------------------------------------------------------------------------------------------



| |  |  | Comply with all applicable laws, regulations and Company policies
| | - |  | -----------------------------------------------------------------



| |  |  | Seek guidance where necessary from a responsible supervisor
| | - |  | -----------------------------------------------------------



| |  |  | Value and respect others
| | - |  | ------------------------



| |  |  | Promptly report any violations of this Code to the Legal Department
| | - |  | -------------------------------------------------------------------



| |  |  | Be personally accountablefor adherence to this Code
| | - |  | ---------------------------------------------------



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



4



---

The actions of every employee, officer and director affect the reputation and integrity of the
Company. Therefore, you must take the time to review this Code and develop a working knowledge of its provisions. (You should also review Company policies and compliance procedures pertaining to your particular position within the Company. These
policies and procedures should be included with your employee manual. If they are not, you should contact your supervisor or Human Resources.) You are required to complete a certificate attesting to compliance with the Code upon becoming an
employee, officer or director and periodically thereafter.



|2. | RAISING QUESTIONS AND CONCERNS
|-- | ------------------------------

Each
employee, officer and director is responsible for promptly reporting to the Company any circumstances that such person believes in good faith may constitute a violation of this Code, or any other Company policy, or applicable law, regulations and
rules. If you are in a situation that you believe may involve or lead to a violation of this Code, you have an affirmative duty to disclose to, and seek guidance from a responsible supervisor, the Companys General Counsel, the
Companys Legal Department or other appropriate internal authority. See Who Do I Contact for Guidance or to Report Concerns? below.

If you are uncomfortable reporting any violation of the Code, including with respect to accounting, internal accounting controls or auditing matters,
to your Supervisor, HR Manager or the Legal Department, you may do so anonymously by calling the Companys Ethics Helpline at 866-398-0010 (toll-free within the United States) or +1-314-628-6276 (collect call outside the United States) see Who Do I Contact? below. The Company will do everything it can to ensure the confidentiality of any report.

The Ethics Helpline is a special, toll-free line available 24 hours a day, 365 days a year. It is intended to operate in addition to other resources
available to you to voice complaints or concerns, such as supervisors, managers and Human Resources staff. The Ethics Helpline is monitored by a third party for reporting to the Companys Audit Committee.

It is the Companys policy to encourage the communication of bona fide concerns relating to the lawful and ethical conduct of business as well as
audit and accounting procedures or related matters. It is also the policy of the Company to protect those who communicate bona fide concerns from any retaliation for such reporting.No retaliation against any individual who reports violations of
this Code in good faith will be permitted.



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



5



---

Confidential and anonymous mechanisms for reporting concerns are available and are described in this section
of the Code as well as under the Who Do I Contact? section below. However, anonymous reporting does not serve to satisfy your duty to disclose your potential involvement in a conflict of interest or in unethical or illegal conduct. While
self-reporting a violation will not excuse the violation itself, the extent and promptness of such reporting will be considered in determining any appropriate sanction, including dismissal. Every effort will be made to investigate confidential and
anonymous reports, and the Company will investigate any matter which is reported and will take any appropriate corrective action.



|3. | WHO DO I CONTACT?
|-- | -----------------

WHO
DO I CONTACT

FOR GUIDANCE OR TO REPORT CONCERNS?

Each employee, officer and director is responsible for promptly reporting to the Company any circumstances that such person believes in good faith may
constitute a violation of this Code, or any other Company policy, or applicable law, regulations and rules.If you believe a situation may involve or lead to a violation of this Code, you have an affirmative duty to seek guidance and report such
concerns.



| |  |  | Seek guidance from, or disclose concerns or violations of the Code to, a responsible supervisor (for example, your immediate supervisor, a
department head or location manager) or other appropriate internal authority (for example, your local Human Resources representative, Internal Audit or the Legal Department)
| | - |  | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| |  |  | Report audit and accounting concerns to the Finance Department, Internal Audit, the Ethics Helpline, the Audit Committee, or the Legal
Department.
| | - |  | --------------------------------------------------------------------------------------------------------------------------------------------------



| |  |  | Report suspected violations of the Code of Conductto the Ethics Helpline anonymously if you are uncomfortable making a report to one of the
other resources described here.
| | - |  | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------

ETHICS HELPLINE:

866-398-0010(Toll-Free within the United States)

+1-314-628-6276(Collect Call Outside the United States)



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



6



---

Legal Department:

Legal Department

Comverse Technology, Inc.

810 Seventh Avenue,
35thfloor

New York, NY 10019, USA

P: +1 212/739-1000

Email: legal@cmvt.com

Audit
Committee:

Audit Committee Chair

Comverse Technology, Inc.

810 Seventh Avenue,
35thfloor

New York, NY 10019, USA



|4. | MAINTAINING A SAFE, HEALTHY AND AFFIRMATIVE WORKPLACE
|-- | -----------------------------------------------------

The Company is committed to a workplace where people are treated with dignity, fairness and respect. You have the right to work in an environment that
provides equal employment opportunities and one that is free of discrimination and illegal harassment. The Company bases its recruitment, employment, development and promotion decisions solely on a persons ability and potential in relation to
the needs of the job, and the Company complies with local, state and federal employment laws. The Company does not discriminate on the basis of:



| |  |  | Sex
| | - |  | ---



| |  |  | Race
| | - |  | ----



| |  |  | Color
| | - |  | -----



| |  |  | Religion
| | - |  | --------



| |  |  | Sexual orientation
| | - |  | ------------------



| |  |  | Age
| | - |  | ---



| |  |  | National origin
| | - |  | ---------------



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



7



---

| |  |  | Citizenship status
| | - |  | ------------------



| |  |  | Disability
| | - |  | ----------

The Company
makes reasonable, job-related accommodations for any qualified employee or officer with a disability when notified by the employee that he/she needs an accommodation.

The Company will not tolerate any:



| |  |  | Sexual, racial or other unlawful harassment
| | - |  | -------------------------------------------



| |  |  | Threats or acts of violence or physical intimidation
| | - |  | ----------------------------------------------------



| |  |  | Abusive, harassing or other offensive conduct, whether verbal, physical or visual
| | - |  | ---------------------------------------------------------------------------------

If you believe that you have been harassed, or threatened with or subjected to physical violence in or related to the workplace, you should report the
incident to an appropriate supervisor or Human Resources or contact one of the others resources described above under Who do I Contact?, who will arrange for it to be investigated. It is the policy of the Company to protect those who
communicate bona fide concerns from any retaliation for such reporting.No retaliation against any individual who reports violations of this Code in good faith will be permitted. All efforts will be made to handle the investigation
confidentially.

In addition, the Company will not tolerate on Company property:



| |  |  | Possession, use or distribution of pornographic, racist, sexist or otherwise offensive materials
| | - |  | ------------------------------------------------------------------------------------------------



| |  |  | Use of Company personal computers or other equipment to obtain or view such materials
| | - |  | -------------------------------------------------------------------------------------

All employees and officers must promptly contact an appropriate supervisor or Human Resources about the existence of offensive materials on the
Companys systems or premises or contact one of the other resources described above under Who do I Contact?



| | 4.1 | Alcohol and Substance Abuse
| | --- | ---------------------------

The
Company is committed to providing a drug-free work environment. The illegal possession, distribution or use of any controlled substances on Company premises or at



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



8



---

Company functions is strictly prohibited. Similarly, reporting to work under the influence of any illegal drug or alcohol, and the abuse of alcohol or medication in the workplace is not in the
Companys best interest and violates this Code.



| | 4.2 | Fostering a Safe Workplace
| | --- | --------------------------

The
Company places the safety of its employees at the top of its priority list. If you come across or are concerned about unsafe equipment, practices, conditions or other potential hazards, you should immediately report it to an appropriate supervisor.
If you witness or are involved in any accidents while at work, or you are injured in any way, you should immediately contact your supervisor.



| | 4.3 | Protecting the Environment
| | --- | --------------------------

The
Company is committed to protecting the environment in which we all live. Each employee of the Company is responsible for supporting the Companys commitment to protecting the environment. The Companys commitment is embodied in our
compliance with U.S. federal, state and overseas environmental laws and regulations. All Company operations are to be conducted in a manner that protects the health and safety of all people in the communities where we operate. If you become aware of
an incident which threatens the health and safety of people in or around the places where we operate, notify your supervisor immediately.



|5. | CONFLICTS OF INTEREST
|-- | ---------------------

You are expected
to avoid situations where your interests may conflict or appear to conflict with the interests of the Company. In particular, you have an obligation to avoid any conflicts of interest, such as:



| |  |  | An activity
| | - |  | -----------



| |  |  | An agreement
| | - |  | ------------



| |  |  | A business investment
| | - |  | ---------------------



| |  |  | An interest
| | - |  | -----------



| |  |  | Other situation
| | - |  | ---------------

that
might in fact or in appearance cause you to place your own interests, or those of another, above your obligation to the Company. Conflicts or even the appearance of a conflict might impair confidence in, or the reputation of, the Company even if
there is no actual conflict and no wrongdoing.



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



9



---

The Company expects its employees and officers to devote their full time and attention to the Companys
business during regular working hours and for whatever additional time that may be required. Employees and officers should avoid outside business activities that divert their time and talents from the Companys business. The Company expects you
to exercise good judgment and the highest ethical standards in your activities on behalf of the Company as well as in your private activities outside the Company.

Some examples of conflicts include situations where you, an immediate family member, or an entity with which you are closely affiliated
(see also Frequently Asked Questions below):



| |  |  | Solicit or accept from customers, suppliers or others dealing with the Company any kind of gift or other personal, unearned benefits as a result of
your position or relationship with respect to the Company, including payment or reimbursement of travel and meal expenses (other than non-monetary items of nominal value)
| | - |  | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| |  |  | Have a financial interest in the Companys competitors, customers, suppliers or others dealing with the Company (excluding interests that are less
than 1% of the outstanding securities of a publicly-traded corporation or equivalent percentage of ownership interests in an unincorporated business)
| | - |  | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| |  |  | Have a consulting, managerial or employment relationship with a competitor, customer, supplier or others dealing with the Company
| | - |  | ---------------------------------------------------------------------------------------------------------------------------------



| |  |  | Acquire real estate, leaseholds, patents or other property or rights in which the Company has, or is likely to have, an interest
| | - |  | --------------------------------------------------------------------------------------------------------------------------------



| |  |  | Accept loans or guarantees of obligations (except from banks or other entities that provide such services at arms length and in the normal course
of business) from any individual, organization or entity doing or seeking to do business with the Company
| | - |  | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

In all instances
where the appearance of a conflict exists, you must disclose the nature of the conflict to the Legal Department. You should also immediately refer to the Legal Department any conflict you know of, or suspect, involving a director of the Company.



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



10



---

|6. | PROTECTION AND PROPER USE OF COMPANY ASSETS
|-- | -------------------------------------------

All directors, officers and employees have a personal responsibility to protect the assets of the Company from misuse or misappropriation. The assets of
the Company include



| |  |  | Products
| | - |  | --------



| |  |  | Equipment
| | - |  | ---------



| |  |  | Facilities
| | - |  | ----------



| |  |  | Corporate opportunities
| | - |  | -----------------------



| |  |  | Intellectual property
| | - |  | ---------------------



| |  |  | Trade secrets
| | - |  | -------------



| |  |  | Business information (including any non-public information learned as an employee, officer or director of the Company)
| | - |  | ----------------------------------------------------------------------------------------------------------------------

You must not:



| |  |  | Take, use or misappropriate the assets of the Company, for personal use, for use by another, or for an improper or illegal purpose
| | - |  | ----------------------------------------------------------------------------------------------------------------------------------



| |  |  | Remove, dispose of, or destroy anything of value belonging to the Company without the Companys express prior written consent, including both
physical items and electronic information
| | - |  | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| |  |  | Deprive the Company of any business opportunity you may become aware of which could be construed as related to any existing or reasonably anticipated
future activity of the Company. If you learn of any such opportunity through your association with the Company, you may not disclose it to a third party or invest in the opportunity without first offering it to the Company.
| | - |  | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| |  |  | Use any Company property, information or position for personal gain
| | - |  | -------------------------------------------------------------------



| |  |  | Participate in an initial public offering or otherwise accept special investment opportunities from a supplier, vendor (including banks or financial
advisers), or customer with whom the Company is doing business or that is seeking to sell products or services to the Company without first disclosing the opportunity to the Companys Legal Department
| | - |  | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



11



---

|7. | CONFIDENTIAL INFORMATION/PRIVACY
|-- | --------------------------------

You may
be entrusted with information of a confidential or proprietary nature (about the Company, its suppliers, customers or other constituents). Confidential information includes all non-public information of the Company. It includes, but is not limited
to;



| |  |  | Non-public information that, if disclosed, might be (i) of use to competitors, suppliers, vendors, joint venture partners or others, (ii) of
interest to the press, or (iii) harmful to the Company or its customers
| | - |  | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| |  |  | Non-public information about the Companys financial condition, prospects or plans, its marketing and sales programs and research and development
information, as well as information relating to mergers and acquisitions, stock splits and divestitures
| | - |  | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| |  |  | Non-public information concerning possible transactions with other companies or information about the Companys customers, suppliers or joint
venture partners, which the Company is under an obligation to maintain as confidential
| | - |  | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| |  |  | Non-public information about discussions and deliberations, relating to business issues and decisions, between and among employees, officers and
directors
| | - |  | ----------------------------------------------------------------------------------------------------------------------------------------------------------



| |  |  | Non-public information about fellow employees or any other individuals, such as customers, about whom the Company may hold information
| | - |  | --------------------------------------------------------------------------------------------------------------------------------------

Maintaining the confidentiality of important information earns us the trust of our customers and the public in general. If
you come across or work with confidential information, you cannot:



| |  |  | Disclose that information outside the Company, either during or after service with the Company, unless the Company authorizes the disclosure in
writing, or the disclosure is otherwise required by law
| | - |  | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| |  |  | Use confidential information for your own personal benefit or the benefit of persons or entities outside the Company
| | - |  | --------------------------------------------------------------------------------------------------------------------

We respect the confidentiality and privacy of our suppliers and customers. You must respect and protect any confidential or proprietary information
shared with the Company unless disclosure is necessary to comply with statutory requirements, subpoenas, court orders or other lawful process or properly authorized government investigations.



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



12



---

Employees and officers should not divulge any confidential or proprietary information about their former
employers, nor shall any employee, officer or director ever ask them to.

In addition, most countries have data privacy laws regulating the
collection and use of personal data, which is any information that directly or indirectly identifies a natural person. Examples of personal data include employment, medical, financial, education and training information. All employees are
responsible for ensuring compliance with the data privacy requirements under the laws, rules and regulations of the applicable countries.



|8. | INSIDER TRADING AND FAIR DISCLOSURE
|-- | -----------------------------------

You
may become privy to news or information not yet disclosed to the public, also known as material inside information. Material inside information is any information that has not been disclosed broadly to the marketplace and, if
made public, would be likely to be considered important by investors deciding whether to trade in the Companys shares or other listed securities.

You (or any of your immediate family members, grandparents, grandchildren, business associates or controlled investment vehicles) must not:



| |  |  | Trade in securities in the Company or any other company while aware of material inside information
| | - |  | --------------------------------------------------------------------------------------------------



| |  |  | Disclose material inside information of any company to third parties (tipping)
| | - |  | --------------------------------------------------------------------------------



| |  |  | Communicate to anyone outside the Company material inside information of any company
| | - |  | ------------------------------------------------------------------------------------

Trading in Company securities while aware of material inside information, or tipping others to trade, is both unethical and illegal.

In addition, you are not authorized to answer questions from the media, analysts, investors or any other members of the public. If you should receive
such an inquiry, you must record the name of the person and immediately notify Investor Relations.



|9. | NETWORK USE, INTEGRITY & SECURITY
|-- | ---------------------------------

You will have access to and use the Companys computer networks and systems and are expected to use our computer networks and systems with the
highest standards of care.



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



13



---

You cannot use our networks and systems to:



| |  |  | Commit illegal acts
| | - |  | -------------------



| |  |  | Violate any provision of this Code
| | - |  | ----------------------------------

The Company reserves the right to monitor or review any and all data and information contained on any employees or officers computer or other
electronic device issued by the Company. In addition, the Company reserves the right to monitor or review an employees or officers use of the Internet, Company Intranet and Company e-mail or any other electronic communications without
prior notice.

You must:



| |  |  | Keep secret any passwords used to access any Company computer or database
| | - |  | -------------------------------------------------------------------------



| |  |  | Create strong passwords that cannot be easily discovered by others
| | - |  | ------------------------------------------------------------------



| |  |  | Refrain from using or distributing software that may damage or disrupt the Companys work environment by transmitting a virus
| | - |  | -----------------------------------------------------------------------------------------------------------------------------



| |  |  | Not engage in the unauthorized use, copying, distribution or alteration of computer software
| | - |  | --------------------------------------------------------------------------------------------



| |  |  | Access the Internet at work for business purposes and for limited personal use
| | - |  | ------------------------------------------------------------------------------

Any suspected breach of the Companys network security systems should be reported to a responsible supervisor or appropriate internal authority
immediately.



|10. | TRADE PRACTICES
|--- | ---------------



| | 10.1 | Fair Dealing
| | ---- | ------------

In dealing with
Company suppliers, customers, competitors and employees, we expect you to utilize high standards and values and the highest level of fairness. This means that you must not take unfair advantage of anyone we conduct business with through:



| |  |  | Manipulation
| | - |  | ------------



| |  |  | Concealment
| | - |  | -----------



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



14



---

| |  |  | Abuse of privileged information
| | - |  | -------------------------------



| |  |  | Misrepresentation of material facts
| | - |  | -----------------------------------



| |  |  | Any other unfair-dealing practice
| | - |  | ---------------------------------

Information about the Companys suppliers, customers, competitors and employees must be used in an ethical manner and in compliance with the law.
Under no circumstance should you obtain information through:



| |  |  | Theft
| | - |  | -----



| |  |  | Illegal entry
| | - |  | -------------



| |  |  | Blackmail
| | - |  | ---------



| |  |  | Electronic eavesdropping
| | - |  | ------------------------



| |  |  | Misrepresenting your affiliation with the Company or your identity
| | - |  | ------------------------------------------------------------------

You should not release information about the Companys suppliers, customers, competitors or other employees without proper authorization and should
use that information for legitimate business purposes only.



| | 10.2 | Fair and Accurate Advertising
| | ---- | -----------------------------

Customers and potential customers are entitled to receive accurate information regarding prices, capabilities, terms and scheduling. The Company strives
to produce advertisements that are:



| |  |  | Fair
| | - |  | ----



| |  |  | Accurate
| | - |  | --------



| |  |  | Lawful
| | - |  | ------

We all must avoid
false or misleading statements to sell or market Company products or services, and we should make immediate efforts to correct any misunderstanding that may exist with a customer or potential customer.



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



15



---

| | 10.3 | Antitrust Compliance
| | ---- | --------------------

Vigorous
competition  free from collusion and unreasonable restraints  is the best mechanism for ensuring the production of high quality, well-priced and innovative products and services. The Companys policy is to compete solely on the
basis of its superior and innovative products and services, through your collective efforts and contributions, and to avoid improper actions that unreasonably restrain trade.

Antitrust and trade regulation issues are very complex. Determining if our actions unreasonably restrain trade or are otherwise improper will depend on
the structure of the market and a number of other factors. If you are unsure as to whether or not any communication, action, arrangement or transaction is legal, please contact the Legal Department immediately to report any concerns.

To avoid even the perception of unlawful conduct, employees must not:



| |  |  | Discuss with a competitor prices, costs, production, products and services, bidding practices, other non-public business matters, territories,
distribution channels or customers
| | - |  | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| |  |  | Restrict the right of a customer to sell or lease a product or service at or above any price
| | - |  | --------------------------------------------------------------------------------------------

In addition, you should also strive to avoid:



| |  |  | Conditioning the sale or lease of a product or service on the sale or lease of another product or service, sometimes referred to as tying
| | - |  | -------------------------------------------------------------------------------------------------------------------------------------------



| |  |  | Conditioning the purchase, sale or lease of a product or service on a reciprocal agreement with a customer or supplier
| | - |  | ----------------------------------------------------------------------------------------------------------------------



| |  |  | Entering into an exclusive dealing arrangement with a customer (including a lessee) or supplier
| | - |  | -----------------------------------------------------------------------------------------------



| |  |  | Limiting a customer (including a lessee) as to the territories and customers a product or service can be resold or leased
| | - |  | -------------------------------------------------------------------------------------------------------------------------



| |  |  | Discriminating in the prices or allowances offered to competing customers (including lessees)
| | - |  | ---------------------------------------------------------------------------------------------



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



16



---

In certain, limited circumstances, the above practices may be permissible, but you should not engage in any
of them without first obtaining the written approval of the Legal Department.



|11. | INTERNATIONAL BUSINESS DEALINGS
|--- | -------------------------------



| | 11.1 | Bribery and Other Corrupt Practices
| | ---- | -----------------------------------

The Company strictly prohibits giving or promising, directly or indirectly, anything of value to any person, including any employee or official of a
government (including state-owned companies) or a political party, candidate for office, or to any other person performing public duties or state functions, in order to obtain or retain business or to secure an improper advantage with respect to any
aspect of the Companys business.

Moreover, as a U.S. entity, the Company is subject to the U.S. Foreign Corrupt Practices Act, which
makes it illegal for the Company, its subsidiaries and persons working for or on behalf of the Company to offer, pay, give, promise or authorize the payment of any money or of anything of value, directly or indirectly, to any government official or
employee, or a political party, candidate for office or to any person performing public duties for the purpose of obtaining or retaining business or to secure an improper advantage, as well as comparable laws in other countries in which we operate.
Under the Foreign Corrupt Practices Act, improper payments are defined expansively to include:



| |  |  | Payments, both direct and indirect (for example through agents or contactors)
| | - |  | -----------------------------------------------------------------------------



| |  |  | Gifts
| | - |  | -----



| |  |  | Entertainment
| | - |  | -------------



| |  |  | Certain travel expenses
| | - |  | -----------------------

Although local law may permit gift-giving or the payment of entertainment expenses under certain circumstances, the Companys Legal Department must
approve in advance any such payments. In addition, the anti-bribery laws permit in narrow circumstances small facilitating payments, which are legal payments made to public officials in order to expedite the routine performance of
legitimate duties.You must discuss any proposed facilitating payment with the Companys Legal Department prior to taking any action. The Company prohibits facilitating payments without the prior approval of the Companys Legal
Department.



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



17



---

Any question as to whether a gift or payment would be considered improper under the Companys
guidelines or national or foreign laws must be discussed with the Companys Legal Department.

Under no circumstance is it
acceptable for you to offer, give, solicit or receive any form of bribe, kickback, payoff, or inducement.

In many instances, you may find
yourself working with agents, independent contractors, consultants or other representatives of the Company. You must become very familiar with the background of any agent or third party that will be working with you because you may ultimately be
responsible for their actions. When you retain agents, consultants, independent contractors or other representatives, you must complete adequate background checks and verify their business credentials in accordance with Company policy. Some
red flags to look out for include:



| |  |  | Third parties with family or other relationships that could influence the decision
| | - |  | ----------------------------------------------------------------------------------



| |  |  | Independent contractors or consultants with a reputation for bribes
| | - |  | -------------------------------------------------------------------



| |  |  | A history of corruption in the country where the third party is being hired
| | - |  | ---------------------------------------------------------------------------



| |  |  | Unusually high commission requests
| | - |  | ----------------------------------



| |  |  | A sales representative or agent who approaches you near the award of a contract and indicates a special arrangement with an official is
warranted
| | - |  | ---------------------------------------------------------------------------------------------------------------------------------------------------



| |  |  | A customer who suggests that a Company bid be made through a specific agent or representative
| | - |  | ---------------------------------------------------------------------------------------------



| | 11.2 | Export and Other Considerations
| | ---- | -------------------------------

Specific laws and regulations apply to international business, in addition to those of the United States. These laws include:



| |  |  | Export control and licensing laws
| | - |  | ---------------------------------



| |  |  | Economic sanctions
| | - |  | ------------------



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



18



---

| |  |  | Anti-boycott laws
| | - |  | -----------------



| |  |  | Various laws regulating the transnational movement of technology, goods and services
| | - |  | ------------------------------------------------------------------------------------

For U.S. foreign policy purposes, formal government approval and/or a license is required for the export and re-export of certain software, services, and
technology. In addition, certain countries and persons are subject to U.S. embargoes or trade sanctions, and you may be prohibited from dealing with them. You should also be aware that you cannot do business with any person or entity that is on the
Office of Foreign Assets Control list, which typically includes those who are a threat to national security, support terrorism or violate U.S. or international law. You should be careful not to:



| |  |  | Do business with a restricted country, company, or individual
| | - |  | -------------------------------------------------------------



| |  |  | Export controlled products or technologies without a license
| | - |  | ------------------------------------------------------------



| |  |  | Sell or give a controlled product to an unauthorized foreign national
| | - |  | ---------------------------------------------------------------------



| |  |  | Sell or give a controlled product to a foreign national if it might be later transferred to a prohibited person, entity, or country
| | - |  | -----------------------------------------------------------------------------------------------------------------------------------



| |  |  | Distribute a controlled technology to prohibited individuals or countries by e-mail
| | - |  | -----------------------------------------------------------------------------------



| |  |  | Export a controlled product or technology if you have reason to believe it will be re-exported to a prohibited individual or country
| | - |  | ------------------------------------------------------------------------------------------------------------------------------------



| |  |  | Ship anything through a prohibited country
| | - |  | ------------------------------------------



| |  |  | Take controlled software, products, or information out of the country without explicit legal authorization
| | - |  | ----------------------------------------------------------------------------------------------------------



| |  |  | Participate in a boycott against a U.S. company or a country friendly to the U.S.
| | - |  | ---------------------------------------------------------------------------------

Employees and officers involved in business transactions must be fully familiar with, and strictly adhere to, all applicable foreign and domestic laws
and regulations. If you have any questions regarding whether particular international transactions are permissible or about compliance with applicable laws and this policy, please contact the Companys Legal Department.



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



19



---

|12. | POLITICAL CONTRIBUTIONS AND ACTIVITIES
|--- | --------------------------------------

In the United States, federal and many state laws prohibit corporations from making political contributions. Any direct or indirect political contribution
of any kind (including the use of Company property, equipment, funds or other assets) in the name of the Company, or with Company funds, requires a prior written certification from the Companys Legal Department that the political contribution
complies with applicable law.



|13. | ACCOUNTING PRACTICES, BOOKS & RECORDS
|--- | -------------------------------------

Honest and accurate recording and reporting of information is critical to our ability to make responsible business decisions and foster investor trust.
You are expected to support the Companys efforts to fully and fairly disclose the financial condition of the Company in compliance with applicable accounting principles, laws, rules and regulations.

This responsibility includes, among other things, reporting hours worked (including overtime), reimbursable expenses (including travel and meals), and
sales activity. You should also ensure that you assist the Company in making:



| |  |  | Full
| | - |  | ----



| |  |  | Fair
| | - |  | ----



| |  |  | Accurate
| | - |  | --------



| |  |  | Timely
| | - |  | ------



| |  |  | Understandable
| | - |  | --------------

disclosures in our periodic reports filed with the Securities and Exchange Commission and in other communications to securities analysts, rating agencies
and investors. The Companys accounting records are relied upon to produce reports for the Companys management, rating agencies, investors, creditors, governmental agencies and others. Our financial statements and the books and records on
which they are based must accurately reflect all corporate transactions and conform to all legal and accounting requirements and our system of internal controls.



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



20



---

All employees, officers and directors  and, in particular, the chief executive officer, the chief
financial officer, the comptroller and the principal accounting officer  have a responsibility to ensure that the Companys accounting records do not contain any false or misleading entries.

We do not tolerate any misclassification of transactions as to accounts, departments or accounting periods. Please remember:



| |  |  | All accounting records, and reports produced from those records, must be kept and presented in accordance with the laws of each applicable jurisdiction
| | - |  | -------------------------------------------------------------------------------------------------------------------------------------------------------



| |  |  | All records must fairly and accurately reflect transactions, as well as Company assets, liabilities, revenues and expenses
| | - |  | --------------------------------------------------------------------------------------------------------------------------



| |  |  | Accounting records must not contain any false or misleading entries
| | - |  | -------------------------------------------------------------------



| |  |  | Transactions must not be misclassified as to accounts, departments or accounting periods
| | - |  | ----------------------------------------------------------------------------------------



| |  |  | All transactions must be supported by accurate documentation, in reasonable detail and recorded in the proper account and in the proper accounting
period
| | - |  | ---------------------------------------------------------------------------------------------------------------------------------------------------------



| |  |  | All accounting records must comply with generally accepted accounting principles
| | - |  | --------------------------------------------------------------------------------



| |  |  | You must follow the Companys system of internal accounting controls, including compensation controls, at all times
| | - |  | -------------------------------------------------------------------------------------------------------------------

Any effort to mislead or coerce the independent auditors or a member of internal audit staff concerning issues related to audit, accounting or
financial disclosure would lead to serious legal consequences, including criminal sanctions, and is strictly prohibited.

If you are
authorized to make expenditures or enter into transactions on behalf of the Company, you must ensure that the applicable records comply with the Companys accounting and purchasing policies and that all transactions are recorded properly. Laws
and regulations require the Companys records, including its



| |  |  | Financial
| | - |  | ---------



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



21



---

| |  |  | Environmental
| | - |  | -------------



| |  |  | Health and safety
| | - |  | -----------------



| |  |  | Human resources
| | - |  | ---------------



| |  |  | Research and development
| | - |  | ------------------------



| |  |  | Analytical
| | - |  | ----------



| |  |  | Engineering
| | - |  | -----------



| |  |  | Intellectual property
| | - |  | ---------------------

records, to accurately reflect the events they represent. Falsifying business records is a serious offense, which may result in criminal prosecution,
civil action and/or disciplinary action up to and including termination of employment.



|14. | RECORDS RETENTION
|--- | -----------------

You must comply with
the Companys records retention policy and procedures. Destroying or altering a document with the intent to impair the documents integrity or availability for use in any potential official proceeding is a crime. Destruction of corporate
records may only take place in compliance with the Companys records retention policy and procedures. You must not destroy any documents relevant to any pending, threatened, or anticipated litigation, investigation, or audit for any reason. If
you believe that Company records are being improperly altered or destroyed, you should report it to a responsible supervisor, the appropriate internal authority or the Legal Department. You should also speak to your supervisor or the Legal
Department if you have questions about destroying a particular document.



|15. | VIOLATIONS OF THIS CODE
|--- | -----------------------

Allegations of
Code violations will be reviewed and investigated by the Companys Legal Department or, in appropriate circumstances by the Companys Audit Committee. Violations of this Code may result in, among other actions, suspension of work duties,
diminution of responsibilities or demotion, and termination of employment.

Those who violate the standards in this Code will be subject to
disciplinary action. Failure to follow this Code or to comply with federal, state, local and any applicable foreign laws, and the Companys corporate policies and procedures may result in termination of employment or termination of board
service.



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



22



---

FREQUENTLY ASKED QUESTIONS

Q: What if I witness a Code violation but am afraid of coming forward in fear of retaliation?

A:The Company encourages the communication of bona fide concerns relating to the lawful and ethical conduct of business, audit and accounting
procedures and related matters. The Company will protect those who communicate bona fide concerns from any retaliation for such reporting. Confidential and anonymous mechanisms for reporting concerns, including the Ethics Helpline, are available and
are described in this Code.

Q: What if I am unsure of whether or not what I saw is in fact a Code violation?

A:No Company policy can provide definitive answers to all questions. It is difficult to anticipate every decision or action that you may face or
consider. Whenever you have doubt about the correct ethical or legal choice to make, or questions regarding any of the standards discussed or policies referenced in this Code, you should fully disclose the circumstances, seek guidance about the
right thing to do, and keep asking until guidance is obtained. The earlier a potential problem is detected and corrected, the better off the Company will be in protecting against harm to the Companys business and reputation.

Q: What will happen to me if I am found in violation of this Code?

A: Those who violate the standards in this Code will be subject to disciplinary action. Failure to follow this Code or failure to comply with federal,
state, local or applicable foreign laws or the Companys corporate policies and procedures may result in termination of employment or termination of board service.

Q: Am I expected to know all the laws and regulations that apply to me?

A:Legal compliance is not always intuitive. To comply with the law, you must try to learn enough about the laws that affect your work at the
Company so you can spot potential issues and obtain proper guidance on the right way to proceed. The Company also provides you with specific policies applicable to your job to assist you with spotting any potential issues. When you have anydoubt as to the lawfulness of any proposed activity, you should seek advice from the Legal Department.



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



23



---

Q: When does a conflict of interest arise?

A: While it is not possible to describe or anticipate all the circumstances that might involve a conflict of interest, a conflict of interest may arise
whenever you take action or have interests that may make it difficult to perform your work objectively or effectively or when you or an immediate family member, receive improper personal benefits as a result of your position or
relationship with respect to the Company.

Q: Who is considered to be an immediate family member?

A: An immediate family member includes your spouse, parents, stepparents, children, stepchildren, siblings, mothers- and fathers-in-law,
sons- and daughters-in-law, brothers- and sisters-in-law, and any person (other than a tenant or employee) sharing your household.

Q: As
an employee, may I engage in any activities outside of work?

A:Though the Company encourages professional activities and
community involvement, you must take special care not to compromise the duties you owe to the Company. Employees and officers are expected to disclose the nature of any non-Company activity for which compensation is received.

Q: Can I serve on any Boards of Directors?

A:You must obtain approval from the Companys Legal Department or the Board before agreeing to serve on the board of directors or similar
body of a for-profit enterprise or government agency. Serving on boards of not-for-profit or community organizations does not require prior approval unless such service with a not-for-profit or community organization creates a situation that may
pose a conflict of interest with the Company. If such a situation arises, you should contact the Companys Legal Department for approval to continue such service.

Q: Can I participate in political activities?

A:You are free to engage in outside activities that do not interfere with the performance of your responsibilities or otherwise conflict with the
Companys interests. If you wish to engage in activities that may be controversial or that involve sensitive matters, you should seek the guidance of the Legal Department. You must not use your Company position or title or any Company
equipment, supplies or facilities in connection with outside activities, nor may you do anything that might infer sponsorship or support by the Company of such activity, unless the use has been approved in writing by the Legal Department. In
addition, you should not solicit contributions or other support from



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



24



---

fellow employees, or distribute non-work-related material to fellow employees during working hours or in areas where work is being performed.

Q: Do the antitrust laws apply only in the U.S.?

A: Antitrust laws apply to every jurisdiction in which the Company does business. Failure to comply with antitrust and other trade regulation laws could
result in civil and criminal penalties for both the offender and the Company.



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



25



---

CERTIFICATE OF COMPLIANCE

I
                                         
                                         
                   hereby certify that I have read,

(Print name)

understand and am in compliance
with the terms of the foregoing Code of Business Conduct and Ethics.



|           |  | 
|---------- |  | 
|Date:      |  | 
|           | 
|Signature: |  | 
|           | 
|Title:     |  | 

If you have any questions, please contact the Legal Department:

Legal Department

Comverse Technology, Inc.

810 Seventh Avenue,
35thfloor

New York, NY 10019, USA

P: +1 212/739-1000

Email: legal@cmvt.com



QUESTIONS? CONCERNS?

CALL THE ETHICS HELPLINE @ 866/398-0010 (TOLL-FREE WITHIN THE U.S.)

OR +1 314/628-6276 (COLLECT CALL OUTSIDE THE U.S.)

OR

CONTACT THE
LEGAL DEPARTMENT AT +1 212/739-1000

OR

YOUR SUPERVISOR OR HR REPRESENTATIVE



26