Code of Business Conduct and Ethics

Code of Business Conduct and Ethics

Introduction

The TSYS Code of Business Conduct and Ethics (the "Code") covers a wide range of business practices and procedures. While it does not cover every issue that may arise, this Code outlines basic principles to guide all employees and officers of the Company and its majority-owned subsidiaries ("team members"). In addition, all members of the Company's Board of Directors and members of the boards of directors of the Company's majority-owned subsidiaries, in regard to their Company duties, are responsible for conducting themselves in connection with the applicable provisions of this Code. Team members and directors must conduct themselves accordingly and seek to avoid even the appearance of improper conduct. The Code will be provided to all team members and directors and should also be provided to the Company's agents and representatives, including business partners, vendors and consultants.

If a local, state or national law conflicts with any policy in this Code, team members and directors must comply with the law; however, if a local custom or policy conflicts with this Code, team members and directors must comply with the Code. A team member who has questions about these conflicts should ask his or her supervisor how to handle the situation or call the Helpline.

Team members who violate the standards in this Code will be subject to disciplinary action.

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 12.

1. Compliance with Laws, Rules and Regulations

Obeying the law, both in letter and in spirit, is the foundation on which this Company's ethical standards are built. All team members and directors must respect and obey the laws and all applicable rules and regulations of the cities, states and countries in which the Company operates. Although team members are not expected to know the details of each law, it is important to know enough to determine when to seek advice from supervisors, managers or other appropriate personnel.

This Code of Business Conduct and Ethics and additional information is available to every team member online through the enterprise portal ( insite ) as well as made available to new team members during their orientation.

2. Conflicts of Interest

All team members and directors should avo...

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...ocedures. The section deals with how to comply with the procedures in the code of Ethics. They have included steps that should be taken if there has been any violation of the code of ethics witnessed by an employee.

I feel, after reviewing the sections of the ethics statement, that the purpose of the ethics statement is to have a written procedure for employee behavior and compliance of the policies and procedures of the company. After reading the ethics statement, I honestly feel that the company succeeds in the purpose of their mission statement. They have laid out all of the procedures that need to be followed and have included steps to take if you observe a violation in the code. If I were an employee at TSYS, I believe that the Code of Ethics, as it has been written, would contribute favorably to my work environment. If no one observed the ethical guidelines, there probably would be a lot of people going to serve prison sentences in federal penitentiaries due to Insider trading laws, and national and foreign policies that are already in place.

I do not think that there is anything that I would change or anything that needs to be improved on.