Foundation of Integrity

Throughout its proud history, Sprint has continually been an innovator in the telecommunications industry, driven by a legacy of integrity, accountability and service. Today, Sprint delivers amazing technology, service and experiences to our customers, communities, employees and shareholders (stakeholders). And, along the way, we take great pride in our high-caliber workforce, our outstanding corporate citizenship and our industry-leading environmental sustainability accomplishments and commitments.

As we look to the future, we recognize that our capacity to continuously incorporate better experiences for our stakeholders hinges entirely on our collective ability to perform at the highest level – from the retail store to the customer service center to the office of the CEO. A high-performance culture is the path to a bright future. At Sprint, our high-performance culture focuses on accountability, first and foremost, along with open communication and innovation. Within these traits, integrity and ethics are critical success factors. Amidst unprecedented change and technological advancement, acting with integrity is not just the right thing to do, it is the unwavering foundation for Sprint.

Sprint Code of Conduct

The Sprint Code of Conduct (the Code) is applicable to employees of Sprint and its controlled subsidiaries, the Sprint Board of Directors (Board Members), and anyone we authorize to act on Sprint’s behalf. The Code establishes the basic foundation of Sprint’s ethics by communicating our philosophy and commitment to all of our employees, customers, other stakeholders and the communities in which we do business. The Code should be used as a resource when questions of legal or ethical appropriateness arise on the job. It is not a comprehensive rulebook, but rather a statement of how Sprint commits to do business. We are bound by the Code and the specific operational policies of Sprint.

Leading with Integrity

Our reputation as an ethical company is a valuable asset. The Code is intended to help us understand our responsibilities and to guide us in making the right choices. We take great pride in the Sprint Imperatives that define our cultural values:

Act with Integrity

We are responsible for:

Conflicts of Interest

We will conduct ourselves with high standards of integrity, honesty and fair dealing and should avoid any conflicts of interest with Sprint. A conflict of interest occurs when an individual’s personal interests either interfere or could reasonably appear to interfere with the interests of Sprint. We will always work solely in the best interests of Sprint when conducting company business. We will not compete with Sprint, take advantage of our position or misuse confidential or proprietary information for personal gain or any other reason. Relationships with prospective or existing suppliers, contractors, consultants, customers, competitors or regulators should be structured so that they could not reasonably appear to affect your independent and sound judgment on behalf of Sprint.

Disclosure

To avoid conflict of interest situations, we will disclose any relationships that have the potential to be misinterpreted by others. Should you need guidance and help to identify these situations, you should complete a “Conflict of Interest Questionnaire” and ask your supervisor or another member of your management team, your Human Resources representative or the Ethics Helpline for guidance to determine if any additional action is warranted. Please note that you have a duty to update the form any time your circumstances change.

It is not possible to list all cases in which a conflict of interest may exist. We rely on your integrity and good judgment to avoid situations that may create a conflict of interest. If you are unsure about a particular situation, you should discuss it with your supervisor or another member of your management team, your Human Resources representative or contact the Ethics Helpline.

Gifts, Entertainment and Travel

Gifts, entertainment and travel have the potential to create a conflict of interest with your obligation to Sprint. While each is often an integral part of building and maintaining business relationships and advancing the interests of Sprint, it is essential that we conduct each in such a manner as to avoid even the reasonable appearance of a conflict. The Code incorporates by reference the Sprint Gift, Entertainment and Travel Policy, which explains the policy in detail.

If you are ever in doubt as to how accepting or giving a gift, favor, travel or entertainment might appear, you are encouraged to speak with your supervisor or another member of your management chain, your Human Resources representative or contact the Ethics Helpline.

Notwithstanding anything in this Code of Conduct to the contrary, conflicts of interest, including corporate opportunities, and similar provisions of this Code of Conduct involving any member of the Board of Directors or their affiliates shall be addressed (i) by the Board of Directors or applicable committee thereof in accordance with Sprint’s certificate of incorporation and bylaws, as in effect from time to time, and the other policies and procedures followed by the Board of Directors from time to time, and (ii) in a manner that is consistent with the discharge by the members of the Board of Directors of their fiduciary duties.

Material Nonpublic Information and Insider Trading

Federal and state securities laws and regulations govern transactions in securities (e.g., stocks and bonds) of Sprint and other companies, including our customers, suppliers and other companies with which we do business. You violate the insider trading provisions of securities laws and regulations if, while aware of material nonpublic information about a public company, whether Sprint or another company, you trade on that information, disclose or “tip” it to others before the information is public.

“Material nonpublic information” is information that has not been publicly disclosed and that could affect an investor’s decision to buy or sell securities. Examples include, but are not limited to, sales and earnings figures, plans for stock splits or dividends, proposed acquisitions or mergers, or new product and service offerings. Securities laws and Sprint policy require that you do not trade in Sprint stock and other securities based on material not public information. Sprint’s policy against insider trading and disclosure of material nonpublic information is explained in detail in the Sprint Securities Law Compliance Policy.

Focus on Customers

Customer Privacy

Sprint takes the protection of its customers’ privacy very seriously. Customer information should only be used for legitimate business purposes by employees with a business “need to know.” Customers are more focused than ever on privacy and the protection of their personal information. Additionally, privacy laws and regulations at the federal and state level are becoming increasingly complex, and enforcement of these requirements is becoming more aggressive.

You are obligated to protect customers’ information, including:

If you learn of any unauthorized access to, or use of, customer information, immediately report this to your supervisor and the Office of Privacy.

For more information, please review the Sprint Privacy Policy.

Although privacy is important and protected by law, if you suspect a customer is using Sprint’s products or services for an unlawful purpose, contact Corporate Security immediately.

Government Customers

Governmental Business Practices

Special rules and regulations apply when doing business with federal, state or local governments, so you should take extra steps to know and comply with these requirements if your assignment directly involves the government or if you are responsible for someone working with the government on behalf of Sprint. In addition, when dealing with government officials and employees, avoid any conduct which could appear improper. Any attempts, even if well intended, to influence a government official or employee by means of payments, gifts or other favors are strictly prohibited. Failure to avoid these activities may expose the government agency, the government employee, Sprint and the Sprint employee to substantial fines and penalties. For these reasons, any sale of our products or services to any government entity - federal, state or local - must be in accordance with the Sprint Financial Policy. For information on relationships with government representatives, please refer to the “Political Activity and Lobbying” section of this Code.

Compete Like Winners

Competition Law and Business Conduct

It is in Sprint’s best interest to compete on a level playing field. Our differentiated products and services speak for themselves when competition is free and open. The antitrust and fair competition laws of the U.S. and of many other countries where we engage in business were developed to encourage healthy competition among businesses and to protect consumers against anti-competitive activities. While it is beyond the scope of the Code to explain each of these laws in detail, compliance with them is critical as the penalties for violations may be substantial – up to and including imprisonment. If you have questions or are unsure how to handle competitive information, contact the Legal Department or the Ethics Helpline.

Sales initiatives with direct and indirect dealers should have contracts in place; offers, terms, restrictions, product handlings and dealer negotiations should be communicated through and approved by the Legal Department.

Statements about Sprint products and services, and competitors’ products and services should be approved by Sprint Marketing, Corporate Communications and the Legal departments before release to external channels.

Competitive Information

Sprint’s policy is to respect the trade secrets of others. Employees should not reveal or encourage others to reveal or use any trade secrets of a former employer or competitor in connection with their employment with Sprint. Trade secrets may include, for example, customer lists, technical developments, operational data, sales strategies or pricing information. If information that might constitute a trade secret or proprietary information of another company is obtained by mistake, do not use it and consult the Legal Department.

Sprint prohibits making false or misleading statements or material misstatements that could impact Sprint, its suppliers or its competitors. For example, posting a false statement online regarding a Sprint or competitor’s major product launch is prohibited.

Business Records and Communications

Sprint’s records are its corporate memory, providing evidence of actions and decisions, and represent a vital asset that supports daily functions and operations. Records consist of all forms of information created or received by Sprint, whether originals or copies, regardless of media. A record may be as obvious as a memorandum, e-mail, contract or presentation, or something not as obvious, such as a digital desk calendar, appointment book or voice mail. Other examples of business records include but are not limited to the following: quality, safety or personnel records or operational metrics. All records are the property of Sprint and should be retained in accordance with the Sprint Records Retention Policy.

Accounting, Internal Controls, Auditing and Tax Matters

Any complaints or concerns regarding accounting, internal controls, auditing or tax matters must be reported by using the Ethics Helpline or by writing to (1) both the Chief Financial Officer and the General Counsel, (2) the Chief Ethics Officer, or (3) the Chairman of the Audit Committee of the Board of Directors. Any such reports will be treated confidentially and investigated according to the Sprint Ethics Helpline and Whistleblower Procedural Process. Federal law protects “whistleblowers” that report these types of complaints in good faith and prohibits retaliation against such individuals.

Company Assets

You have a responsibility to protect Sprint assets, including both tangible and intangible property, from loss, damage, misuse and theft. Failure to protect company assets may subject you to disciplinary action up to and including termination of employment. In some cases, e.g. fraud or theft, the matter may be referred to law enforcement agencies for prosecution. Information is one of our key corporate assets and the future success of Sprint depends in part on our ability to develop and deploy technical information and know-how ahead of our competitors. All company assets should be used for legitimate business or authorized purposes, including customer proprietary information, Customer Proprietary Network Information (CPNI) and account details.

Confidential and Proprietary Information

All information related to Sprint’s business should be considered proprietary and confidential unless it has been released in authorized public documents. You must take steps to protect confidential and proprietary information. You should not discuss confidential or competitive information with family, acquaintences or at social gatherings, when in public areas such as elevators, restaurants and airplanes, as well as online bulletin boards, chat rooms, personal Web pages, blogs, or any other form of social media (e.g., Facebook, Twitter, etc.) For additional guidance, review the Sprint Social Media Policy. In addition, your obligation to keep proprietary or competitive information confidential continues after your employment with Sprint ends. It is never appropriate to photograph, copy or otherwise disseminate Sprint documents for personal gain. All documents should be managed according to a business “need to know.”

Intellectual Property

Sprint values and encourages the protection of its intellectual property (such as patents, trade secrets, copyrights and trademarks) and proprietary information while simultaneously respecting the valid intellectual property rights of third parties. Intellectual property laws protect many materials

Demonstrate Teamwork

Community Support

Sprint has contributed to the economic and social development of the communities it serves for many years. In addition to the jobs created and the services provided, Sprint encourages employees and business units to become actively involved in their communities. The Sprint Foundation and many Sprint employees provide support to thousands of worthwhile community organizations. The community leadership offered by thousands of Sprint employees around the world is another example of Sprint’s long-standing civic commitment.

Personal Community Activities

Employees are encouraged to participate in the community activities of their choice. However, you should make it clear that your views, actions and support are your own, and not those of Sprint. In addition, employees should ensure that outside activities do not interfere with their job performance. All employees should be aware of, and abide by, the Sprint Solicitation Policy which generally prohibits solicitation for non-Sprint charitable organizations. Employees should not pressure other employees to contribute to any charitable organization. Sprint reserves the right to solicit employees to contribute to Sprint-sponsored charitable organizations.

Political Activity and Lobbying

Employees should not make any contribution on behalf of Sprint or use its name, funds, personnel, property or services for the support of political parties or candidates unless the contribution is permitted by law and authorized in advance by the Sprint Government Affairs group within the Legal department.

Employees should not pressure other employees to express a political view or to contribute to a political action committee, political party or candidate. U.S. law and the laws of many state and local governments restrict companies from making contributions of money, goods or services to political candidates, except for administrative support of organizations such as the Sprint PAC, which is funded solely through Sprint employee donations.

Relationships with a government representative should be conducted in a manner that would not embarrass Sprint or the official if publicly disclosed. Activities with the potential to influence government officials are strictly regulated. Persons representing Sprint should be extremely careful to avoid even the reasonable appearance of impropriety. Reasonable entertainment and courtesies should be extended only if not prohibited by law and then only to the extent that is customary and appropriate. Any questions on this matter should be directed to the Sprint Government Affairs group within the Legal Department.

Be Accountable

Employee Relations and Discrimination

At Sprint, we thrive on creativity and innovation. We believe that new ideas from diverse perspectives lead to better business results. Diversity is just good business. We embrace diversity of ethnicity, gender, generation, geography and thought. Different perspectives enable us to better understand the complexity of our customers’ needs and to deliver high-value solutions in innovative ways. It is critical that every Sprint employee feel valued and be provided with opportunities to contribute value to the business. If you believe your rights have been violated or if you have any other workplace concerns, you should consult the Employee Guide, your supervisor or another member of your management chain, or call your Human Resources representative directly. If you do not receive a clear explanation or believe you may not receive an objective or adequate review of the issue from your supervisor or Human Resources, call the Ethics Helpline.

Sprint does not tolerate discrimination. We recognize that highly productive and diverse employees are essential to our success and should be given opportunities to flourish in a barrier-free, non-discriminatory environment. We will conduct all employment practices including activities relating to recruiting, hiring, benefits, leaves of absence, training, transfer, promotion, job assignments, compensation, corrective action and termination in a non-discriminatory manner.

We conduct business without regard to, and do not discriminate because of, an employee’s race, color, religion, creed, sex, gender identity, sexual orientation, age, disability, pregnancy, national origin, genetic information or ancestry, as well as citizenship, marital, veteran, and family and medical leave status or any other status protected by law. Consult the Employee Guide for more information

Employee Privacy

Employees should have no expectation of privacy in information they send, receive, access or store on any of Sprint’s computer systems or network. Electronic message traffic that interferes with the network or its interconnected systems is prohibited. Sprint reserves the right to review workplace communications (including but not limited to Internet activity, e-mail, instant messages, social media or other electronic messages, computer storage and voice mail) as well as employees’ company-provided workspace at any time.

Sprint is committed to protecting employees’ privacy in regards to medical, family and personal information by refraining from discussing private matters when there is not a valid business “need to know.”

Lead with Integrity

Tone at the Top

Sprint leaders have a responsibility to understand and uphold the Code to their organizations, and to create a tone at the top that encompasses Sprint’s imperative of “Acting with Integrity.”

Sprint leaders uphold the Code as individuals and demonstrate a visible commitment by:

Leaders must be particularly careful with their words and conduct with respect to placing, or seeming to place, pressure on subordinates that could cause them to perform in a way that is contrary to the ethical standards set forth in this Code or our company policies. Additionally, they must be cognizant of their actions and dealings with customers, suppliers and employees to create an atmosphere of ethical leadership and integrity.

As a Sprint leader, if someone approaches you with a question or concern relating to the Code, listen carefully and ask for clarification and additional information to ensure that you fully understand the question or concern. Answer any question that you can, but do not feel that you must provide an immediate response. If necessary, seek help or guidance from others, including your Human Resources representative and the Ethics Helpline.

You are expected to perform all of your duties on behalf of Sprint in compliance with all laws, regulations and company policies. The Legal Department is always available to help you understand the laws and regulations that apply to your job; however, it should be understood that upholding our Code may require more than mere compliance with the laws and regulations.

Supervisor Responsibility

Supervisors should exemplify the highest standards of ethical business conduct by integrating the ethics and compliance program into all aspects of their operations, and by encouraging open and frank discussion of the ethical and legal implications of business decisions. Supervisors should also ensure that everyone in their organization receives proper training, completes annual i-Comply certification and clearly understands the legal and ethical expectations of working for Sprint. This includes any aspect of the Code, policies, training or law with particular applicability to their business operations. It is incumbent upon supervisors to take every opportunity to model behaviors consistent with our values and the Code.