CODE OF ETHICS AND BUSINESS CONDUCT - FTI Consulting

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CODE OF ETHICS ANDBUSINESS CONDUCTEXPERTS WITH IMPACT

A LETTER FROM OURPRESIDENT AND CEO,STEVEN H. GUNBYDear Colleagues,Over the last 30 years, FTI Consulting has grown tobecome a market-leading global consulting firm byserving as a trusted advisor to our clients in both goodand bad times. As trusted advisors, our clients lookto us to protect their interests with unquestionableintegrity.Our Code of Ethics and Business Conduct is designedto help us meet this expectation. This Code reflectsour corporate values, outlines our collective intentions with respect to how we conduct global businessactivities and addresses important laws and policiesthat apply to our day-to-day interactions with keyconstituents.Direct and honest communications and behaviorare critical to the success of our firm. By committingto those behaviors and following this Code, we willcontinue to protect and strengthen our reputation.I urge each of you to familiarize yourself with theelements of this document. It may not addressevery situation you encounter, but it will help youmake the right decisions. If you are not sure howiFTI Consulting, Inc.the Code applies to a particular circumstance, orif you see something that you believe violates thisCode, I encourage you to contact our Chief Risk& Compliance Officer, our General Counsel or ourHuman Resources Department, You will never bepunished or retaliated against for making an honest,accurate report of your suspicions or concerns.It is an honor to be a part of this terrific group ofindividuals, a group that aspires to enhance ourCompany’s reputation each and every day. I lookforward to working with each of you as we continueto strengthen our firm’s legacy as an unparalleledbusiness partner.Sincerely,Steven H. GunbyPresident and CEOFTI Consulting, Inc.CODE OF ETHICS AND BUSINESS CONDUCT February 18, 2020

FTI CONSULTING, INC. CORE VALUES

FTI CONSULTING, INC. CORE VALUESSince its founding, FTI Consulting has dedicated itselfto providing its clients with market leading management consulting advisory services, performed inaccordance with the highest ethical standards. Byconsistently delivering sophisticated and innovativesolutions to the challenging and complex issues thatimpact enterprise value, FTI Consulting has earned itsreputation as a premier consulting firm.iiiFTI Consulting’s institutional reputation relates directlyto our individual commitment to professional responsibility as well as professional excellence. Our continuedstatus as a trusted and respected advisor to the business community and the law firms that serve it, as wellas to institutions in the public sector, depends in largemeasure on our adherence to the highest standards ofprofessionalism, independent judgment, expert adviceand accountability. These bedrocks of our corporateculture are reflected in our Company values.I NTEGRITYI act with integrityC REATIVITYI am committed to continuousimprovementA CHIEVEMENTI am committed to quality andaccountable for resultsR ESPECTI welcome diversity anddifferences of opinionE MPATHYI support othersFTI Consulting, Inc.CODE OF ETHICS AND BUSINESS CONDUCT

TABLE OF CONTENTSA LETTER FROM OUR PRESIDENT AND CEO,STEVEN H. GUNBYFTI CONSULTING, INC. CORE VALUESiiiiINTRODUCTION TO OUR CODE OF ETHICS ANDBUSINESS CONDUCTGetting to Know Our CodeScope of Our CodeComplying with Our Code, Laws and Regulations2223OUR RESPONSIBILITIES UNDER THE CODEUnderstanding Our Shared ResponsibilitiesAccepting Additional Responsibilities as Managers555ADDRESSING OUR QUESTIONS AND CONCERNSSeeking Advice and Making ReportsInvestigations of ReportsNo Retaliation at FTI ConsultingNotice of Whistleblower Rights of EmployeesConsequences777888RESPECT FOR OUR COLLEAGUESDiversityEqual Opportunity and NondiscriminationHarassmentWorkplace RelationshipsUpholding Human RightsSubstance AbusePornographyProviding Consistent, Quality Services101010101111121214PROTECTING CONFIDENTIAL INFORMATIONAND OBSERVING CAREFUL COMMUNICATIONSPRACTICESComplying with Data Protection LawsProtecting Personal Employee InformationPreserving Third-Party InformationProtecting FTI Consulting’s Confidential InformationProhibition Against Trading on Inside Information161616171818Coordinating Our Corporate CommunicationsSocial MediaIDENTIFYING AND DISCLOSING PERSONALCONFLICTS OF INTERESTFinancial InterestsOffering and Accepting Gifts and EntertainmentOutside Business ActivitiesBusiness with Friends and Family MembersCorporate OpportunitiesPersonal Use of Corporate Property and CorporateInformationCOMPLYING WITH LAWSAnti-Corruption LawsAbiding by U.S. and International Competition LawsAbiding by Economic Sanctions andAnti-Boycott LawsPreventing Money Laundering andTerrorist FinancingAbiding by Export Control Laws191921212123242424262627272828RESPECT FOR OUR STOCKHOLDERSAND THE PUBLICProtecting Our Company Against Fraud and TheftTruthful and Accurate ReportingRecords Management and Document Retention30303131PROTECTING FTI CONSULTING ASSETS ANDPROPERTYProper ExpendituresProtecting Intellectual PropertyUsing FTI Consulting Technology Resources33333334OUR ROLE IN THE COMMUNITYCharitable ContributionsPolitical Contributions and CampaigningLobbyingEmploying Sustainable Practices3636363636WAIVERS AND AMENDMENTS OF OUR CODE38

INTRODUCTION TO OUR CODE OF ETHICSAND BUSINESS CONDUCT

INTRODUCTION TO OUR CODE OF ETHICSAND BUSINESS CONDUCTGETTING TO KNOW OUR CODEWhile working at FTI Consulting, Inc. and its subsidiary companies and affiliates (“FTI Consulting” orour “Company”), all of us are expected to performour work with integrity, honesty and purpose. Theseprinciples are reflected in this Code of Ethics andBusiness Conduct (our “Code”). Our Code, as well asother FTI Consulting policies and procedures, shouldbe followed at all times, wherever we do business orinteract with the public.Our Code is a guide for making sound decisions incomplex situations. It provides information, supportand resources to help us act ethically and comply withthe laws and regulations that affect our business. Ourconduct is the foundation of our reputation, and ourindividual business decisions help us to maintain thetrust we have built with our clients and other stakeholders. For this reason, we have a continuing responsibility to understand and comply with our Code andother Company polices, and seek guidance whereappropriate. Our Company also encourages us toreport violations that we observe. This is an importantdimension of accountability.If you are ever unsure whether an action or decision isethical and acceptable under our Code, ask yourself:If the answer to any of the above questions is nota resounding “Yes,” you should reconsider yourproposed course of action and seek guidance.Similarly, if the answer to any of the below questions is other than a resounding “No,” you shouldstop immediately. Would I be embarrassed if my actions were reportedpublicly? Would FTI Consulting suffer any potentially negativeconsequences due to my actions?SCOPE OF OUR CODEFTI Consulting’s reputation and continued successdepend on our integrity and accountability, as individuals and as an institution. For this reason, ourCode applies to all of us, including all FTI Consultingworldwide employees, officers and outside directors(collectively known as “personnel”). Our Companyalso expects all agents, vendors, contractors, consultants, business partners and all third-party representatives to uphold similar standards when working withour clients and representing our Company aroundthe world. In short, we must all live up to the ethicalstandards outlined in our Code. Am I adhering to the spirit and meaning of all applicable laws, regulations and our Code and Companypolicies? Do my actions reflect the highest standards ofhonesty, integrity and accountability? Is my decision responsible and in furtherance oflong- and short-term Company goals? Are my actions explainable and justifiable to mycolleagues, managers, senior management, clientsand other stakeholders?2FTI Consulting, Inc.CODE OF ETHICS AND BUSINESS CONDUCT

INTRODUCTION TO OUR CODE OF ETHICS AND BUSINESS CONDUCTCOMPLYING WITH OUR CODE,LAWS AND REGULATIONSFTI Consulting conducts business in many countriesthroughout the world. As a global organization, wemust know and follow the laws and regulations thatapply to our work in all locations where we operate.Because we are a public company based in the UnitedStates, United States laws govern our business operations and conduct. However, the global reach of ourbusiness means we are subject to the laws of othercountries as well. If you ever have a question aboutwhich legal standard to follow, seek guidance from FTIConsulting’s Legal department before taking action.FTI Consulting will use all reasonable means toprevent and immediately halt the occurrence ofconduct that violates our Code. Anyone who directlyor indirectly performs, facilitates, condones orapproves of any illegal or unethical conduct will besubject to disciplinary measures, consistent withapplicable laws and regulations.3FTI Consulting, Inc.CODE OF ETHICS AND BUSINESS CONDUCT

OUR RESPONSIBILITIES UNDER THE CODE

OUR RESPONSIBILITIES UNDER THE CODEUNDERSTANDING OURSHARED RESPONSIBILITIESWe are all expected to read, understand, stay apprisedof and comply with our Code, all other Companypolicies, and all applicable laws and regulations. Keepin mind that this Code reflects general principles toguide us in making ethical decisions. It is not intendedto address every situation that may arise. In situationswhere customary conduct is at odds with our Code,other Company policies or applicable local laws orregulations, we must comply with the more stringentstandard. Any violation of law or regulations will alsobe considered a violation of our Code. If you havequestions, or if you are unsure of which rule to follow,you may seek guidance from your manager, segmentor region leader, the Chief Risk & Compliance Officer,or the Legal department.For your convenience, the Code contains referencesto many, but not all, policies that are available on ourCompany’s website or FTI Atlas. In addition to askingquestions, we should all refer to these resources foradditional guidance.ACCEPTING ADDITIONALRESPONSIBILITIES ASMANAGERSHolding a management position at FTI Consultingmeans accepting an additional set of responsibilities.Our managers, at all levels, are expected to demonstrate a strong commitment to professionalism andto lead by example. If you are a manager, you must: Act as a role model to inspire ethical conduct andcompliance by others. Ensure that all of your direct reports understandtheir responsibilities under this Code. Create an “open-door” environment where yourdirect reports and other FTI Consulting colleaguesfeel comfortable asking questions or making reports. Encourage your colleagues to voice their opinionsand concerns about Company policies and internalpractices. When your direct reports or other colleagues raise aconcern, escalate it appropriately. Consider professionalism and accountability to bean integral part of the performance evaluations ofyour direct reports. Supervise your direct reports to ensure compliancewith this Code, other Company policies and procedures, and applicable laws and regulations.As a manager, you must also ensure that FTIConsulting individuals who voice their opinion ormake reports are informed of FTI Consulting’snon-retaliation policy. Further, take appropriate actionif you witness an act of retaliation or suspect onehas occurred, and report such conduct immediatelyto your manager, segment or region leader or FTIConsulting’s Chief Risk & Compliance Officer.5FTI Consulting, Inc.CODE OF ETHICS AND BUSINESS CONDUCT

ADDRESSING OUR QUESTIONSAND CONCERNS

ADDRESSING OUR QUESTIONSAND CONCERNSSEEKING ADVICE ANDMAKING REPORTSIf you become aware of an actual or potential violationof this Code, another corporate policy or any applicable law or regulation, you are strongly encouragedto report it promptly (managers are required to doso), where allowed by applicable law. Making sucha report may allow FTI Consulting to manage theconsequences of any illegal or unethical act before itbecomes a bigger issue. It can also stop a situationfrom escalating. In addition, timely reporting helps FTIConsulting to assess the operation of its risk management programs and procedures and to prevent futuremisconduct.You can ask questions or raise concerns inseveral ways: Your Manager Our Human Resources Department Our Chief Risk & Compliance Officer The Legal department The FTI Consulting Integrity Helpline:See also FTI Consulting’s Policy on ReportingConcerns and Non-Retaliation.INVESTIGATIONS OFREPORTSWe are each expected to cooperate fully in any internal or external investigation. Our Company will treatreported information in a confidential manner to theextent permitted by local laws and consistent withgood business practices, and will always uphold ourcommitment to our non-retaliation policy.When making an internal report, you can alsoexpect the following:— In the U.S. by calling 1-866-294-3576 Your report will be handled promptly.— In the United Kingdom, by calling applicable toll Your report will be verified for accuracy andfree number:completeness.– 0-500-89-0011 United Kingdom (C&W) or– 0-800-89-0011 United Kingdom (BritishTelecom)– At the prompt dial 866-294-3576— From a country other than the U.S. or UK, byfollowing the instructions for filing a report on theInternet (described below) until you reach the FTIConsulting landing page. On that page, click thelink for the list of international access codes tofind the telephone number for your location. Via the web: www.fticonsulting.ethicspoint.com7The Helpline is staffed by an outside company and isavailable 24 hours a day, 7 days a week. Reports to theHelpline may be made on a confidential or anonymousbasis where local law allows, and the information willbe relayed to FTI Consulting for further investigation.Please note, however, that it may be more difficult forour Company to thoroughly investigate reports that aremade anonymously. For this reason, you are encouraged to share your identity when making a report.FTI Consulting, Inc. You may receive follow-up communications requesting additional information.Please refrain from conducting your own investigation. Such actions could compromise the integrityof our Company’s investigation. Any unauthorizedinvestigation is strongly discouraged and may resultin disciplinary action. If you are asked to participatein any investigation other than by Human Resourcesor the Legal Department of FTI Consulting, whetherinternal or external, you must contact FTI Consulting’sGeneral Counsel immediately.CODE OF ETHICS AND BUSINESS CONDUCT

ADDRESSING OUR QUESTIONS AND CONCERNSNO RETALIATION ATFTI CONSULTINGFTI Consulting strictly prohibits acts of retaliationagainst any person for providing information in goodfaith regarding any conduct that you believe constitutes a violation of law or this Code, or assisting in aninvestigation. Acting in “good faith” means that youcome forward with all of the information you have andbelieve you are giving a sincere and complete report.In other words, it does not matter whether your reportturns out to be true, as long as you deliver it honestly.An individual who makes a report in bad faith, orwho retaliates against a person for making a reportor participating in an investigation in good faith, maybe subject to disciplinary action, up to and includingtermination, as local law permits. Anyone making areport in bad faith may also be subject to disciplinaryaction, as local law permits.See also FTI Consulting’s Policy on ReportingConcerns and Non-Retaliationproceedings, (3) prohibits an employee from collecting any financial incentives in connection with any ofthe foregoing activities, or (4) requires notification to,or prior approval by, FTI Consulting or its affiliates inconnection with any of the foregoing activities.See also FTI Consulting’s Policy on ReportingConcerns and Non-RetaliationCONSEQUENCESViolations of our Code, policies or the law may carryserious consequences for the individuals involvedand our Company. Those engaging in unethical orillegal behavior, or who otherwise violate our Code andpolicies, and those who direct, condone, approve orfacilitate such behavior, may be subject to disciplinaryaction, up to and including termination, subject tolocal laws. Furthermore, such behavior places all ofus at risk of damaged reputation, hinders our professional prospects, and may subject us—as individualsand as an institution—to fines and civil or criminalliability.NOTICE OF WHISTLEBLOWERRIGHTS OF EMPLOYEESNothing in this Code of Conduct or other FTIConsulting policy or employee handbook, or in anyapplicable employment, restrictive covenants, severance, release or other written agreement betweenan employee and FTI Consulting or its affiliates, (1)prohibits an employee from making reports, chargesor complaints of possible violations of law or regulations to a government agency in accordance withany applicable legal whistleblower protection law,even if doing so would require an employee to shareconfidential or other proprietary information of theCompany, (2) prevents an employee from makingtruthful statements to any such government agencyin response to legal process, required governmental testimony or filings, or administrative or arbitral8FTI Consulting, Inc.CODE OF ETHICS AND BUSINESS CONDUCT

RESPECT FOR OUR COLLEAGUES

RESPECT FOR OUR COLLEAGUESDIVERSITYHARASSMENTFor our Company to succeed as a global professionalservices firm, we must strive to reflect the diversity ofthe communities in which we operate. That means wemust maintain a workplace atmosphere that attracts,develops and retains people from various backgrounds. If we do not treat one another with respect,we will not maintain a comfortable and professionalatmosphere. Our professionalism is vital to buildingour Company’s reputation and retaining our diversetalent base. Together, we must strive to create a workplace that is free from discrimination and harassment.In addition, our Company does not tolerate harassment. Harassment can take many forms, includingverbal remarks, physical advances or visual displays,and may come from colleagues, managers, vendors,contractors or clients. The legal definition of harassment may vary depending on where we are doingbusiness, but such behavior always has the purposeor effect of creating an intimidating, offensive ordemeaning environment for another person. It is aform of discrimination and, as such, has no place atFTI Consulting.See also your applicable Employee HandbookIt is important to note that harassment can besexual or non-sexual in nature. Sexual harassmentmay include:EQUAL OPPORTUNITY ANDNONDISCRIMINATIONDiscriminating against someone for his or her traitsis a violation of our Code, Company policies and,in some cases, the law. Such actions have no placewithin FTI Consulting. FTI Consulting does notdiscriminate against others on the basis of race, color,gender, age, sexual orientation or identity, nationalorigin, ethnicity, religion, marital status, pregnancy,physical or mental disability or veteran status. OurCompany makes employment-related decisionsbased on merit. To be clear, “employment-relateddecisions” include those involving the hiring, placement, promotion, demotion, transfer, training,compensation, benefits and termination of personnel.See also your applicable Employee Handbook Unwanted advances Inappropriate touching Sexually suggestive comments or jokes Requests for sexual favors Inappropriate comments about another’sappearanceNon-sexual harassment may include: Offensive comments Jokes or pictures related to race, religion, ethnicity,gender or ageIn order to keep harassment out of our workplace,we must be sure that our comments and actionsare appropriate and respectful. If you feel that youhave experienced or observed any discriminatory orharassing behavior, you are encouraged to disclosethe situation to the Chief Human Resources Officer,your manager, segment or region leader, or FTIConsulting’s General Counsel, immediately.See also FTI Consulting’s Global Employee Handbook10FTI Consulting, Inc.CODE OF ETHICS AND BUSINESS CONDUCT

RESPECT FOR OUR COLLEAGUESWORKPLACE RELATIONSHIPSQUESTIONDanica was recently awarded a senior positionwithin her department after years of exemplaryservice. In her previous role, Danica showedstrong leadership and ingenuity, helping facilitate necessary developments and offeringkey recommendations for improvement. Sheis proud of the work she’s done, and feels herpromotion is deserved. Kate, one of Danica’scolleagues, was also considered for the position,and feels angry that Danica was chosen overher. She proceeds to make comments—both toother FTI Consulting personnel and to Danicaherself—that suggest Danica shared an inappropriate personal relationship with the hiringmanager. The rumors become more aggressive,and many mischaracterizations of Danica’scharacter are made. Danica is mortified, andKate’s insinuations are making it difficult for herto focus on her work. What should she do?ANSWERDanica should report the situation to hermanager or the Chief Human Resources Officerimmediately. Kate is engaging in harassingbehavior, succeeding in creating a hostileenvironment and making Danica uncomfortable. All FTI Consulting personnel deserve tocontribute to a positive, respectful workplace.It is difficult for us to meet our commitments toour Company and other stakeholders if we donot first meet our commitments to each other.False and harassing statements detract from theintegrity of our Company’s business and undermine our effectiveness as a team. Danica doesnot need to endure this harassment.11FTI Consulting, Inc.A consenting romantic or sexual relationship betweena supervisor/manager and an employee, between twocolleagues or between a client and employee may leadto complications and difficulties for all concerned:the individuals involved, the Company and any clientaffected by this relationship.Any such relationship, therefore, may be contrary tothe best interests of the Company. Accordingly, theCompany strongly discourages such relationships andany conduct (such as dating between a supervisor/manager and employee or a client and an employee)that may reasonably be expected to lead to a romanticor sexual relationship. Should such a relationship arise,you may be required to report or disclose it. Pleaseconsult your Employee Handbook for instructions.See also FTI Consulting’s Global Employee HandbookUPHOLDING HUMAN RIGHTSAs part of our commitment to our global community,we uphold individual human rights in all of our operations and we oppose the use of modern slavery in allforms. This means, in part, that we provide reasonableworking hours and fair wages for those who workon our behalf. FTI Consulting has a zero-tolerancepolicy for the use of child or forced labor, or humantrafficking practices. Further, we will not knowingly dobusiness with subcontractors, business partners orvendors who violate these practices. FTI Consultingcould be held accountable for the conduct of theseindividuals and entities. Therefore, if you have reasonto believe any third party is engaging in any of theabove practices, report the misconduct immediately.For more information, contact FTI Consulting’s ChiefRisk and Compliance Officer.With respect to labor and employment matters, weadopt and adhere to the following principles set forthin the UN Global Compact:CODE OF ETHICS AND BUSINESS CONDUCT

RESPECT FOR OUR COLLEAGUESPRINCIPLE 1: Businesses should support and respectthe protection of internationally proclaimed humanrights.PRINCIPLE 2: Businesses should make sure that theyare not complicit in human rights abuses.PRINCIPLE 3: Businesses should uphold the freedomof association and the effective recognition of the rightto collective bargaining.PRINCIPLE 4: Businesses should uphold the elimination of all forms of forced and compulsory labor.PRINCIPLE 5: Businesses should uphold the effectiveabolition of child labor.PRINCIPLE 6: Businesses should uphold the elimination ofdiscrimination in respect of employment and occupation.See also FTI Consulting’s Human Rights Policy.SUBSTANCE ABUSEThe work we perform for FTI Consulting requires usto have sharp, clear minds. Therefore, we must neverreport to work under the influence of drugs, alcoholor any other substance that may impair our ability towork safely and productively. Our Company prohibitsthe possession, use, sale, purchase or distributionof any illegal drugs or controlled substances by anyemployee, consultant or contractor on Companypremises, during working hours or when conductingCompany business. Lawfully prescribed medicationsare allowed to be used while at work, provided thattheir use does not adversely affect job performanceor our safety. While FTI Consulting may permit limitedalcohol use at approved Company events, you mustalways use good judgment and exercise moderation inthese situations.VIOLENCEActs of threats or violence interfere with our commitment to health and safety and will never be tolerated.Any threatening behavior, even if made in a seeminglyjoking manner, must be reported immediately. Also,weapons are never permitted on any FTI Consultingpremises. If you or someone you know is in immediatedanger, call local law enforcement authorities immediately. Then, report the matter internally throughnormal channels.PORNOGRAPHYIt is not permissible to possess, distribute, or viewpornographic material on FTI Consulting property, oruse FTI Consulting equipment (including computers)to obtain or view such materials. You are stronglyencouraged to report the existence of pornographyon the Company’s systems or premises to HumanResources so that appropriate action may be taken,including notification of the proper authorities.See also FTI Consulting’s Policy on Acceptable Use ofTechnology ResourcesSee also FTI Consulting’s Global Employee Handbook12FTI Consulting, Inc.CODE OF ETHICS AND BUSINESS CONDUCT

SERVING OUR CLIENTS AND BUSINESSPARTNERS

SERVING OUR CLIENTS AND BUSINESSPARTNERSPROVIDING CONSISTENT,QUALITY SERVICESAt FTI Consulting, we compete effectively and withenthusiasm. There is no room for unfair or unethicalbusiness practices in what we do. We must remainhonest in all of our sales, marketing, advertising andbusiness pursuits. We must not take unfair advantageof anyone through manipulation, concealment, abuseof privileged information or any other intentionalunfair practices. We must make only factual and truthful statements about FTI Consulting and the exceptional services we offer. We should each be familiarwith the marketing and advertising review proceduresthat apply to our work.QUESTIONJulian is making a sales pitch to a major healthcare organization and feels confident about hisrepresentation of FTI Consulting’s restructuringservices. After his presentation, the floor is opento discussion, and Julian is engaged in a lively,optimistic debate. However, as Julian is adding inhis final comments, he misspeaks, prompting anadditional question from the potential client, towhich he does not know the answer. Not wantingto lose momentum or come across as incompetent, Julian fabricates a response he does notknow to be true. Is this truly detrimental?ANSWERYes. Inevitably, we face situations where wemay not feel certain about the answers we areexpected to provide. The appropriate responseto these situations is honesty. Julian shouldavoid the potential spread of misinformation byamending his previous statement, or agreeing tofollow up with the potential client when he hasall of the facts. False statements and promises not only affect future business with ourclients—they affect FTI Consulting’s reputationfor integrity.14FTI Consulting, Inc.CODE OF ETHICS AND BUSINESS CONDUCT

PROTECTING CONFIDENTIALINFORMATION AND OBSERVING CAREFULCOMMUNICATIONS PRACTICES

PROTECTING CONFIDENTIALINFORMATION AND OBSERVING CAREFULCOMMUNICATIONS PRACTICESCOMPLYING WITH DATAPROTECTION LAWSMany countries have unique legal requirementsgoverning the use, disclosure and/or privacy of dataand information (for example, the EU General DataProtection Regulation (“GDPR”), the U.S. HealthInsurance Portability and Accountability Act (“HIPAA”),etc.). We are committed to the consistent application of data privacy and data protection laws whenprocessing personal data. We are required to ensurethat personal information is processed with due careto prevent any misuse or unauthorized access.All processing of personal data, such as, data onemployees, business partners, clients and suppliers,must be in compliance with applicable data protectionlaws. In addition, we are obliged to ensure that we: Keep confidential information safe from loss, theft,or accidental disclosure. Comply with all applicable data protection laws andregulations, as well as all applicable FTI Consultingpolicies regarding data processing and data transfer. Implement information security safeguardsdesigned to protect personal information. Collaborate with our business partner’s on ensuringdata security and in investigating and responding todata protection breaches, if they occur.More specific information about the use of dataand information appear in the sections below andin other FTI Consulting policies. If you are unsure oflocal requirements, or have other privacy-relatedquestions, you should contact your manager, FTIConsulting’s Chief Risk & Compliance Officer, theLegal department, or, in countries where applicable, aData Protection Officer.16FTI Consulting, Inc.See also FTI Consulting’s Data Privacy Policy;FTI Consulting’s Information Security Policy; FTIConsulting’s Policy on Acceptable Use of TechnologyResources; FTI Consulting’s Incident Response and

iii FTI Consulting, Inc. CODE OF ETHICS AND BUSINESS CONDUCT FTI CONSULTING, INC. CORE VALUES Since its founding, FTI Consulting has dedicated itself to providing its clients with market leading manage-ment consulting advisory services, performed in accordance with the highest ethical standards. By consistently delivering sophisticated and .