Revised January 1, 2008
© CACI 2007

A Message from the President and Chief Executive Officer

Dear Colleagues:

U.S. laws, rules, and regulations place an emphasis on appropriate business ethics, integrity, and corporate-governance. At CACI this is nothing new. Our long-standing philosophy has been, and always will be, to sustain the highest possible business ethics in the pursuit and performance of the Company's business.

Fundamental to CACI's commitment to high ethical standards is a corporate policy statement, issued and administered at the executive level, clearly delineating the company's philosophy, responsibilities and authorities for assuring compliance with the policy. Our goal and policy remains one of high ethics, being ever vigilant, doing top-notch work, being responsive to clients, and "QCS, BV" ... quality client service, best value.

Being Ever Vigilant means something to us and to those we serve:

To our customers ... it means we are committed to their success.

To our employees ... it means we are never complacent.

To our stockholders ... it means we deliver performance and accountability.

To our culture ... it is who we are.

This document contains CACI's Standards of Ethics and Business Conduct and the basis of our ethical principles and practices for all of our business — government and commercial. It is consistent with all we have said and done in the past in terms of high ethical standards, and it applies to every CACI employee and consultant.

Since no one document can provide specific guidance for all situations encountered in daily business operations, CACI encourages employees to bring any questions regarding the interpretation of these Standards or concerns regarding compliance to the immediate attention of their supervisor or manager, or, if the employee prefers, to the Corporate Ombudsmen or to the Legal Division. The CACI Hotline also is available 24 hours a day at 1-800-928-3505 to report confidentially potentially illegal, unauthorized, or inappropriate conduct. In addition, CACI has established the CACI Accounting Hotline at 866-839-8686, for employees to report suspected violations of corporate accounting policies, practices, or controls, or auditing policies and practices)

It is the obligation of every CACI employee and consultant to uphold the ethical principles and business practices stated in these Standards. It is the duty of every CACI employee and consultant to take responsibility for their actions. Good corporate leadership similarly demands manager oversight of employee execution and adherence to these Standards.

CACI is a quality-oriented company, with high ethical standards and business practices we can all be proud of. Let's keep it this way through continued vigilance and pride in our reputation.

Paul M. Cofoni

President and Chief Executive Officer
January 2008

Table of Contents

Message from the Chief Executive Officer and President

CACI Operational Philosophy

CACI's Ten Business Values

CACI Standards of Ethics and Business Conduct

Application

Responsibility/Accountability

CACI Workplace Environment

Timekeeping Policy

Interference with an Audit

Use and Protection of Company Assets

Use of Software

Protection of Intellectual Property, Trade Secrets, Confidential Information

Electronic Communications Policy

Acceptable Use of Computer Resources

Insider Trading/Tipping

Reporting Material Developments and Complying with Internal Controls

False Information and Employment

Personal Conflicts of Interest

Acceptance of Gifts, Gratuities, and Entertainment

Providing Gifts, Gratuities, and Entertainment

Dealings with Suppliers, Vendors, Business Partners, and Competitors

Employee Dispute Resolution

Fiduciary Duty of Employees

Additional Policies Relating to U.S. Government Contracting

False Claims/False Statements

Gifts and Gratuities to U.S. Government Officials

Lobbying Activities

Classified Information

Prohibited Use of Source Selection Information

Hiring of Government and Former Government Employees

Prohibited Contractual Relationships

Avoidance of Restrictions on Trade

Consultant Compliance with Standards

Drug-Free Workplace Act Compliance

Government Furnished Property

Conducting International Business

Administration and Interpretation

Obligation of Employees to Report Violations

Investigation of Misconduct

Operational Philosophy

1. Our Commitment ... National Priorities

America's missions are our missions. Since 1962, we have been driven by a company-wide commitment to support our country's highest priorities and to serve as a trusted national asset. As national missions evolve, CACI evolves with them. Ever vigilant, our people are ready to respond rapidly and efficiently with solutions that meet the challenges ahead.

2. Our Clients ... Number One

At CACI, the client is Number One! We are a client service-oriented company. We are in business to provide quality services and solutions to our clients. Their needs are our opportunities. Our goal is complete client satisfaction. Once we have a client, our goal is to keep that client forever.

At CACI our motto is "Quality Client Service and Best Value" (QCS/BV). Our "good name," our reputation, is paramount. We strive always to be "top-notch" ... quality is everything. We are the "best value" company. We perform valuable project services and provide quality products. In everything we do our goal is quality, distinction, and excellence.

At CACI, our motto is "Quality Client Service and Best Value" (QCS/BV). Our good name, our reputation, is paramount. We strive always to be top-notch ... quality is everything. We are the best-value company. We perform valuable project services and provide quality solutions. In everything we do, our goal is quality, excellence, and distinction.

At CACI, we take full responsibility for the conduct of our business. We are fully accountable for what we do. Our published Standards of Ethics and Business Conduct defines our uncompromising policies on compliance with the laws and regulations of the jurisdictions where we conduct business. We reward legitimate success and forgive understandable failure (no one is perfect!) … but always with a focus on the next achievement.

At CACI, high productivity is our constant goal. We are always competitive. We use time and resources efficiently and effectively to benefit our clients. We are creative, finding innovative solutions to meet client needs. We apply advanced technology to increase client capabilities. We develop cost-effective solutions to improve client services. We are problem solvers.

CACI remains dedicated to creating value for our clients, our shareholders, our employees, and our communities. We are committed to serving clients with quality, excellence, and distinction. Our shareholders are assured of long-term value. Our employees enjoy equal opportunity for growth, recognition, and reward. We are good corporate citizens who support and enhance the communities in which we do business. Value is the bottom line in everything we do.

CACI's Ten Business Values

1. Integrity - Place integrity and honesty above all else.

2. Customer Commitment - Put our clients first.

3. Customer Satisfaction - Create value for clients and deliver quality.

4. Employee Advancement - Provide career opportunities for our people.

5. Recognition - Recognize and reward our top performers.

6. Friendly Corporate Culture - Maintain a value-oriented culture where people enjoy working.

7. Growth - Grow our business profitably and create long-term shareholder value.

8. Accountability - Maintain accountability and responsibility for what we do…and if it's not right, fix it.

9. Respect - Treat each other fairly, with mutual respect and with equal regard for our clients, business partners, vendors, suppliers, and the public at large.

10. Reputation for Excellence - Work to sustain the highest-quality reputation for CACI and its people.

CACI's Standards of Ethics and Business Conduct

Application

These Standards of Ethics and Business Conduct (the "Standards") apply to all officers, employees, and consultants of every CACI company and business unit worldwide, and to all business activities of CACI.

Responsibility/Accountability

CACI people are fiercely proud of their work and reputation. As such, we are all responsible for upholding our own reputation and that of CACI. CACI people are responsible for ensuring that their own conduct, both at work and away from the office, as well as the conduct of those who report to them and whom they observe, is honest and ethical under all circumstances and fully complies not only with the law but also our policies and these Standards. Because our reputation for high ethical standards and quality work is so important, violations of these Standards or CACI policies will be the basis for disciplinary action, including among other things reprimand, loss of compensation or promotional opportunities, demotions, or discharge with cause.

It is the personal responsibility of each employee and consultant to read, understand, and comply with these Standards and to diligently comply with our other corporate policies and procedures. If you have any questions regarding specific policies, discuss them promptly with your immediate manager or higher-level manager. You may also contact Employee Services or the Legal Division for clarification. A listing of corporate contacts is included at the end of this document for your use. You will be required to certify to your understanding of these Standards on an annual basis.

All employees should be aware that if they are a party to any demonstrably illegal activity, the Company in its discretion might make a record of any involvement and disciplinary action taken available to the appropriate law enforcement officials. This could lead to individual criminal prosecution.

CACI is committed to identifying capable people to fill our workforce and providing them with opportunities to prosper without regard to their race, color, religion, gender, age, national origin, citizenship status, sexual orientation, physical or mental disability, marital, or veteran status, or any other protected status.

Our policy is to provide a work environment free from all forms of discrimination and harassment, including sexual harassment. It is against CACI policy for any employee or consultant, male or female, to sexually harass another employee by (a) making unwelcome sexual advances, requests for sexual favors, or engaging in other verbal or physical conduct of a sexual nature, or (b) making submission to or rejection of such conduct the basis for employment decisions, or (c) creating an intimidating, hostile, or offensive working environment by such conduct. It is also against CACI policy to engage in behavior that constitutes harassment of any kind, whether such activity would be considered to be sexual harassment or otherwise.

Our policy is also to provide CACI people with a working environment free of the problems associated with the use and abuse of controlled substances or alcohol. The use of any controlled substance or alcohol is inconsistent with the behavior expected of our employees. Thus, CACI has implemented the "Drug-Free Workplace" policy. Under this policy, the use, distribution, sale or possession of illegal drugs or other controlled substances, except for approved medical purposes, is strictly prohibited. In no event should any employee be under the influence of alcohol, illegal drugs or controlled substances while present at a CACI "workplace". For purposes of these Standards, "workplace" includes any CACI office, client office or site, or any other office or site where CACI employees and/or consultants engage in work-related activities.

In addition, while a number of jurisdictions where CACI conducts business have passed legislation to allow individuals to bear arms or to carry concealed weapons, CACI's policy is that weapons are not allowed in our workplace. Thus, employees, consultants, and visitors are forbidden from bringing a weapon, concealed or otherwise, to the CACI workplace.

High ethical standards are demanded of every employee to ensure that CACI's timekeeping procedures are followed to the letter. Each employee has responsibility to accurately record his or her time on a daily basis, in accordance with CACI's official timekeeping policy and procedures. Upon being hired, employees are provided with a copy of CACI's timekeeping policy and procedures. Revisions and updates are provided as necessary. Employees must retain a copy of such policy and procedures at their workstation or place of employment. Each employee is expected to read, fully understand, and precisely follow the policies and procedures set forth. Any question or doubt should be discussed with your immediate manager, or CACI's Government Compliance Group (703-841-7985). Any suspected violation should be reported to a CACI Ombudsmen, or the Legal Division, or by contacting the 24 hour CACI hotline at 800-928-3505. A knowing failure to comply with CACI's Timekeeping Policy will be the basis for disciplinary action up to and including termination of employment and may be the basis for action by law enforcement authorities.

CACI's officers and employees, and persons acting under their supervision, must refrain from taking any action that misleads, impedes or otherwise disrupts the work of either the Company's Internal Audit Department or its independent outside auditors, including any action to fraudulently induce, coerce, manipulate, hinder, or mislead any auditor in any respect.

All employees and consultants are responsible for the protection and appropriate, efficient use of CACI assets. CACI assets include physical assets as well as intellectual property and confidential information. All company assets are to be used for legitimate business purposes only. Theft, careless, inappropriate or negligent use, or loss, of the company's physical assets, as well as unauthorized disclosure or transfer in the case of CACI's intellectual property and confidential information, may subject the offending person to disciplinary action up to and including termination of employment. Where appropriate, CACI may refer information regarding any such action to law enforcement authorities.

Except for software supplied by a client or teaming partner pursuant to the terms of a contract, Employees shall use only Company licensed software. Employees shall use all software only in accordance with the terms of CACI's license agreements or other contracts under which the software is supplied. CACI licensed software may not be copied or provided to any third party unless authorized under CACI's license agreement. Before taking any action to transfer CACI licensed software, employees should contact the CIS department to determine whether their proposed action is permitted. Unauthorized use, copying, transfer or disclosure of software may subject the offender to disciplinary action and as well as civil and criminal penalties under copyright laws.

It is essential for all employees and consultants to safeguard the Company's trade secrets and confidential information and to refuse any improper access to trade secrets and confidential information of any other company or entity, including our competitors. Our basic guidelines are: Company proprietary information must not be discussed with others within CACI, except on a strict need-to-know basis; if there is a need to disclose CACI trade secrets or confidential information to any person outside CACI, it must be done only in conjunction with a disclosure agreement provided by the Legal Division. Always be alert to avoid inadvertent disclosures which may arise in social conversations or in normal business relations; and do not receive any such information from other companies or people except pursuant to written agreement. Similarly, CACI's property rights in its technology and products must be protected by use of appropriate agreements whenever such technology and/or products are used, transferred or disclosed. Contact the Legal Division for an appropriate agreement.

Electronic communications, including electronic mail, voice mail, and electronic commerce are integral components of our work place. Each employee must realize, however, that there are risks associated with electronic communications as more fully described in CACI's Electronic Communications Policy and its Computing Resources Acceptable Use Policy. Each employee is expected to read, fully understand, and comply with these policies, including the rules on content, distribution, receipt and retention of electronic communications. The hardware and software on which our company electronic communications take place are assets of the company provided for business use only. Accordingly, CACI reserves the right to access, review, delete, disclose or use employee's electronic communications for any business purpose. As a result, you should not have any expectation of privacy for the data, e-mails, and other material stored in any company telephone or computer system. Any question or doubt regarding electronic communications should be discussed with your immediate manager, the CIS organization, or the Legal Division.

CACI "Computing Resources" include any computer, server or network provided or supported by the CACI Corporate Information Systems (CIS) Division as well as all communications equipment, systems, and services provided to CACI employees in the course of their employment. This includes, for example, telephone, e-mail, voice mail, fax, local and wide area networks, paging, and Internet access. Also covered by this definition are any data and programs stored on or utilized in connection with such CACI Computing Resources, whether in the form of magnetic tape, floppy disk, CD ROM, DVD, or other medium.

CACI Computing Resources are provided to Users to support their work on behalf of the company. Users are expected to utilize these resources in a professional and appropriate manner, in accordance with published CACI policy, including CACI's Electronic Communications Policy and its Computing Resources Acceptable Use Policy. Unauthorized or improper use of Company Computing Resources may subject a CACI employee to disciplinary action up to and including termination of employment.

Since CACI is a publicly-owned company, we have legal obligations to be especially vigilant in safeguarding material, non-public Company information from disclosure both inside and outside the Company. It is a violation of Federal law for anyone with knowledge of such information to buy or sell CACI stock, or to make any unauthorized disclosure of such information (known as "tipping"). Our policy is that CACI employees with knowledge of material information about the company that has not been disclosed to the general public must refrain from disclosing such information to anyone else and from engaging in any transaction in CACI stock until the third business day following public disclosure of such information. Always contact the Legal Division when in doubt before conducting a transaction in CACI stock. As an aid to compliance, CACI has established periodic trading blackouts each quarter. Employees who receive e-mail notification of such blackouts are required to precisely comply with the requirements of the blackout.

Those insiders considered as "reporting persons" under the securities laws of the U.S. are also required to comply with the CACI policy regarding notice and reporting of all transactions in CACI stock. It is vitally important that such persons provide notice of any such trade to the Company's Legal Division and the Chief Financial Officer in time to allow timely filing of the required reports to the SEC (currently within 48 hours of the action).

It is the duty of every employee to fully, fairly, accurately, timely and understandably report financial and non-financial information and developments that could possibly have a material affect on the operations or financial condition of CACI up-line through his/her chain of command and to the Company's Chief Financial Officer, the Corporate Controller, or the Legal Division as soon as it is discovered. In addition, it is every employee's obligation to comply with our internal control policies and procedures and our disclosure controls and procedures. Employees are expected to report any failure to comply with such controls and procedures as described above, to a Company Ombudsman, the Internal Audit Department, or the CACI Accounting Hotline at 1-866-839-8686, which has been established specifically for employees to report suspected violations of corporate accounting policies, practices, or controls, or auditing policies and practices.

Those employees engaged in preparation and filing of documents with the Securities and Exchange Commission and/or with public news releases or other public communications made by CACI are expected to fully, fairly, accurately, timely, and understandably disclose all information that is required in connection with such communications.

If CACI learns that an employee intentionally provided false or misleading information, or intentionally omitted pertinent information regarding essential background, employment history, educational credentials, or other qualifications for employment, CACI reserves the right to discipline the employee as appropriate up to and including termination of employment. In this regard, CACI considers degrees obtained from institutions that are not properly accredited to be fraudulent. Such bogus academic credentials should not be reflected on any employee's resume or used as the basis to qualify for any position. The use of any such credential will expose the employee to discipline up to and including termination of employment.

A "conflict of interest" occurs when a person's private interest (financial gain, career development, reputation advantage, etc.) interferes in any way - or even appears to interfere - with the legitimate business interests of CACI. It is not practical to attempt to list all possible kinds of conflicts. Nonetheless, employees should be very conscious of the potential for their own interests, or those of their immediate family, to be in conflict with CACI's interests, and should take care not to act in a way that prefers those personal interests over CACI's interests when they do conflict.

In order to avoid potential conflicts of interest, employees should avoid any activity outside their Company work that is reasonably likely to put them in a conflict situation. For example, it is important to avoid engaging in a personal business in which you provide products or services that may be competitive with the products or services provided by CACI. If in doubt whether a situation or certain activity constitutes a conflict of interest, contact the Legal Division for guidance. Similarly, it is important to obtain advance approval from the Chief Executive Officer of CACI International Inc to serve on the board of directors or any advisory board of any commercial business, or of any federal, state or local government agency. Requests for such approval should be submitted to the General Counsel.

CACI cautions employees that acceptance of gifts and gratuities from actual or would-be clients, suppliers, vendors, competitors or business partners can result in possible conflicts between the employee's duty of loyalty to the Company and the personal interests of the employee. In order to ensure that such situations are considered thoughtfully, any employee who is offered a gift or gratuity with a value exceeding $100 must report such offer and seek approval to accept it through his/her up-line chain of command to the General Counsel and transmit a copy of such report to each of the Operations Executive Officer, the President of U.S. Operations, and the Chief Executive Officer of CACI International Inc.

In no event should an employee accept a gift where it would be prohibited by law or is known by employee to be contrary to law or the corporate business practices of the company employing the person offering the gift.

Due to the nature of CACI's business, the giving of gifts, gratuities or entertainment (considered "Business Courtesies") requires the use of good business judgment by employees and careful monitoring by managers. For commercial, non-government clients, Business Courtesies, including meals, entertainment, gifts, promotional items, services, and favors, may be extended, provided they are reasonable, not extravagant in value or number, infrequent enough not to become expected, and not offered in exchange for favorable consideration or treatment. A business courtesy is simply that - a courtesy - and should not be given if doing so would create even the appearance of an impropriety on CACI's part.

Federal government employees, as well as those of most state and local governments and many private companies, are subject to strict rules regarding the acceptance of gifts. CACI must respect these rules. In the government environment, the failure to do so may result in severe legal and financial consequences for both CACI and the offending employee. In addition, there are significant legal prohibitions associated with providing gratuities in the context of international activities. When in doubt regarding the appropriateness of a gift or extension of business courtesy, consult your immediate manager or the Legal Division, and always err on the side of caution.

Integrity and fair dealing are core components of our business practices. All vendors, suppliers, other business partners, and competitors should be treated fairly and uniformly in accordance with the Company's established purchasing policies and procedures. Employees must not engage in any activity prohibited under anti-trust laws, including boycotting, price-fixing, refusal to deal, price discrimination, or disparate treatment of suppliers. Paying bribes, accepting kickbacks, and obtaining and using third party insider information in dealings with suppliers, vendors and business partners are completely inappropriate and will not be tolerated.

We are committed to maintaining a workplace in which all feel valued and fairly treated, and where all actions are in accordance with law and CACI policy. We provide many avenues through which employees can make complaints and/or bring attention to problems in the workplace. If you feel you have not been treated appropriately in any way; or if you feel that you have been the subject of harassment, discrimination or other wrongful behavior, please make a report of the incident to: (i) your manager or anyone in your chain of command; (ii) a Company Ombudsman; (iii) the Employee Relations Department; (iv) the Legal Division; or (v) the Internal Audit Department. Any complaint or report received will be handled as confidentially as possible consistent with investigating and resolving the matter, taken seriously, and investigated. Please help us maintain a workplace we all can be proud of by reporting such incidents. There will be no retaliation against anyone for making any such complaint or report in good faith.

To the extent we cannot resolve matters informally, our policy is to handle all employment-related disputes in accordance with a two-step dispute resolution process designed to be less costly and more efficient than litigation. In accordance with that process, employees are required to submit their employment-related disputes first to a Company Ombudsman, for mediation, and then, if still not satisfied, to arbitration in accordance with the Rules for the Resolution of Employment Disputes of the American Arbitration Association ("AAA"). The arbitrator's decision will be final and binding upon both the employee and CACI. Employees may obtain a copy of the AAA's rules from Employee Services.

As a growing company, CACI's greatest assets are the knowledge, ingenuity, and productivity of its employees. The Company benefits most from such assets when employees perform their work with the highest degree of loyalty. In recognition of this fact, the law places upon each employee certain fiduciary responsibilities to the Company, including, for example, the duty to place the interest of the Company and its shareholders above the employee's personal interest in any situation where they might conflict.

In light of the special trust and confidence that CACI places in its employees, these Standards require that employees act with undivided loyalty to the Company and fairness in dealings with the Company, its employees, its suppliers, its business partners, and its existing and potential clients. The restrictions placed upon employees by this portion of the Code are not intended to prevent employees from competing lawfully and fairly with the Company following termination of employment (subject to the non-competition restrictions of the CACI Employee Agreement), or from engaging in subsequent employment in any field of their choice. Instead, they are intended solely to proscribe certain acts (including those listed below by way of example) that would be inconsistent with employees' legal obligations arising out of their employment relationship with the Company, such as:

Each employee is expected to fulfill his/her fiduciary responsibilities to the Company as required by law. Any failure to comply with the law or these policies constitutes grounds for discipline up to and including termination of employment for cause.

As a government contractor, we have a special obligation to the U.S. Government, and to the general public, to ensure that we administer our contracts and deliver our products and services in a manner that fully satisfies both our legal obligations and our own high standards of integrity and quality.

Contracting with the U.S. Government imposes requirements not traditionally associated with purely commercial business transactions. We are committed to compliance with the letter and spirit of the laws and regulations governing U.S. Government contracting. Below are summarized a number of key requirements affecting U.S. Government contracts. Please contact your immediate manager or Legal Division with any questions or concerns you may have regarding the following U.S. Government contracting policies and procedures.

False Claims/False Statements

It is a felony to knowingly make a false claim or false statement to the government. Violations of these and other statutes can subject the Company to damaging publicity, expensive and time-consuming investigations and litigation, reduction of negotiated contract rates, and the revocation of contracts. Both CACI and individual employees may also be subject to civil and criminal sanctions including fines, debarment or suspension, and prison sentences. Such violations also can expose an employee to discipline up to and including termination of employment.

Although it is not possible to specify here all contract-related dealings with the Government that present the risk of false statements, false claims, or other violations, particular attention is called to the following:

Gifts and Gratuities to U.S. Government Officials

CACI employees must not offer, give, or promise to offer or give any money, gratuity or other thing of value to any government employees that such employee is prohibited from receiving by applicable law, including transportation, meals at business meetings, tickets to sporting or other events, or the like.

Even if applicable government regulations permit their acceptance, CACI employees must refrain from offering or giving or reimbursing expenses for any entertainment or offering any gratuity to any government employee who is personally and substantially involved in a procurement or administrative function relating to any contract for the direct or indirect purchase of products or services from the Company.

Lobbying Activities

CACI is prohibited from using federal funds to pay persons such as lobbyists or consultants to influence or attempt to influence executive or legislative decision-making in connection with the award of any contract. We are also required to furnish a certification that no federal funds have been paid or will be paid in violation of this prohibition. In addition, CACI is required to report to the government any payments to any lobbyist or consultant paid with non-federal funds for such purposes. Our specific policies and procedures regarding the use of lobbyists and other outside professional consultants are set forth in Chapter 6 of CACI's Policy and Guidelines.

Classified Information

Government information that is national security classified, procurement sensitive, or proprietary shall not be solicited or accepted from (or provided to) any source, either directly or indirectly, in circumstances where there is reason to believe that the release is not authorized.

All classified information in CACI possession shall be treated in strict compliance with U.S. Government mandated procedures for such classified information.

Prohibited Use of Source Selection Information

CACI must be particularly concerned with obtaining sensitive procurement information from federal government agencies. During the conduct of any procurement action, CACI will not solicit or accept from any officer or employee of the agency, or any other source, any proprietary or source selection information regarding that procurement. This prohibition begins with the development, preparation, and issuance of a solicitation and concludes with award of a contract, a contract modification or extension. As used herein, proprietary data includes information contained in a bid or proposal, cost or pricing data, and any information submitted to the Government by a contractor and properly designated as proprietary. Source selection information includes such information as listings of offerors and prices, listings of bidders prior to bid opening, source selection plans, technical evaluations of proposals, competitive range determinations, rankings (except for sealed bidding), source selection board reports and evaluations, source selection advisory board recommendations, and other information determined by the head of the agency or contracting officer to be information which would jeopardize the integrity or successful completion of the procurement if disclosed.

Hiring of Government and Former Government Employees

Special concerns apply to hiring or retaining a government or former government employee as an employee or consultant of CACI. In addition, there are special constraints regarding any communication concerning possible employment of government employees who are designated as "procurement officials" during the conduct of any procurement action and otherwise. CACI employees shall not conduct any discussions regarding, or make any offer or promise of, future employment or business opportunity to any procurement official during the conduct of any procurement. In order to be sure that you do not run afoul of restrictions in this area, before discussing potential CACI employment with any government employee, contact a representative of the Legal Division for advice.

CACI's specific hiring policy affecting clients and government or former government employees is contained in the CACI Policy and Guidelines, Chapter 3. There are no exceptions to this policy. Authorization from the General Counsel must be obtained before even mentioning proposed employment to current government employees, and then only after they have publicly announced that they are leaving government service. In addition, any plans to employ retired military officers of general or flag rank, or civilian officials having the rank of Deputy Assistant Secretary or above, must be approved by the Chief Executive Officer of CACI International Inc, prior to an offer of CACI employment.

Prohibited Contractual Relationships

CACI shall not knowingly employ an individual nor contract with a company, by any means, if the individual or company is on the General Services Administration's (GSA) Consolidated List of Debarred, Suspended and Ineligible Contractors, nor knowingly employ an individual who has been convicted of an offense related to government contracting.

Nor will CACI knowingly contract with an individual or entity identified on the Office of Foreign Asset Control's (OFAC) "Specifically Designated" list of nationals or persons who are subject to trade restrictions.

CACI employees will immediately sever all business connection with any former employee or consultant of CACI whose conduct violates applicable laws, regulations, or basic tenets of business integrity and honesty, and such other individuals specifically identified by the Company. Appropriate notices specifically identifying such individuals will be provided to employees or posted on Company bulletin boards.

Avoidance of Restrictions on Trade

CACI will not enter into a subcontract or teaming agreement that unreasonably restricts sales by the other company directly to the U.S. Government of items made or supplied by the other company and will not otherwise act to restrict unreasonably the ability of any other company to sell directly to the U.S. Government. Conversely, CACI will not enter into agreements where, as a subcontractor or teaming partner, we are subject to any unreasonable restriction to sell our products or services directly to the U.S. Government.

Consultant Compliance with Standards

Consultants shall be required by contract to comply with all laws and regulations relating to U.S. government contracting. These Standards shall be incorporated in all consultant contracts, and each such contract shall expressly provide for termination in the event the consultant violates the laws or regulations relating to government contracting, CACI Policies, or these Standards.

Drug-Free Workplace Act Compliance

CACI fully complies with the The Drug-Free Workplace Act of 1988, which was enacted with objectives of achieving a drug-free America and combating illegal drugs in the workplace. Among the Act's requirements is a provision that any contractor seeking a single federal government contract of $25,000 or more, will certify that the Company has a drug-free workplace policy, and, as a minimum, has instituted programs prescribed by law. In addition, DoD has a Drug-Free Work Force Regulation that specifies, along with other requirements, that all defense contractors institute and maintain certain programs to achieve a drug-free work force. The policies and procedures adopted by CACI are found in the Policy and Guidelines, at Chapter 3, paragraph 3030.

Government Furnished Property

Employees and consultants are responsible for appropriate use, maintenance, accounting for, and, when necessary, disposal of government property in compliance with government mandated policies and procedures. Failure to properly handle government property may result in disciplinary action, including termination, and may expose a wrongdoer to criminal penalties.

As CACI expands its international business, it is critical that CACI employees be mindful of complying with both U.S. laws and the foreign laws governing the place where CACI is conducting its international business activities, as well as import and export regulations relating to shipment of items and/or information. The broad principles expressed in these Standards apply to CACI's international business as well as domestic business that require performance abroad. In addition to other areas of potential concern, the following U.S. laws apply and must be strictly observed:

The Foreign Corrupt Practices Act prohibits directly, or through an agent or intermediary giving, offering, or promising of anything of value to foreign government officials to influence them to misuse their authority or exert an unfair business advantage. The Act also imposes civil liability on a company which does not keep accurate accounting records or knowingly fails to implement adequate accounting controls.

The Anti-Boycott Act prohibits companies from participating in non-U.S. boycotts of countries friendly to the U.S. The Act has particular application to dealing with Arab countries who may participate in a boycott of Israel.

Numerous Export Control laws and regulations apply to the export of materials, equipment, weapons, technology, data, software, information, and services ("items") to foreign governments, businesses, and individuals. Export controls may also restrict the sale of items to U.S. companies abroad and foreign corporations in the U.S. A sampling of relevant laws include: Foreign Asset Control legislation, the U.S. Department of Defense's International Traffic in Arms Regulations, and the U.S. Department of Commerce's Export Administration Regulations. Prior to the transfer of any item outside of the United States or to a foreign company within the United States, consult the Legal Division for a full review of applicable export laws and requirements.

The restrictions on exports can also apply to what is called a "deemed export." A deemed export occurs where export controlled data or items are disclosed to foreign national employees who may work for CACI or a CACI teammate. If you have foreign nationals working on your project, please take care to ensure that they are not exposed to restricted data or items.

CACI's Director of Business Operations will administer the Standards of Ethics and Business Conduct.

Given the complexities of today's business environment, including government contracting and international business concerns, and the determination of CACI's Executive Officers and Board of Directors to comply with both the letter and spirit of all relevant laws and regulations, it is recognized that questions of interpretation will arise.

All questions relating to the charging of material and labor and to the allowability and reasonableness of overhead expenses should be directed to the CACI Chief Financial Officer or the Internal Audit Department.

All questions relating to CACI's Drug-Free Workplace Policy should be directed to Senior VP of Employee Services.

All other questions relating to these Standards and CACI's ethics and business practices in general should be directed to a Corporate Ombudsmen, or the Legal Division.

Although questions of interpretation of these Standards may arise, the Company does not contemplate that it will grant any waiver of any of the terms of these Standards. Should extraordinary circumstances arise in which a waiver may be appropriate, however, such waiver may only be granted by the Board of Directors or the Audit Committee of the Board.

It is the responsibility of any employee or consultant having knowledge of any activity that is or may be in violation of these Standards, any law, rule, or regulation applicable to CACI's business, or any Affirmative Action Policy to promptly disclose such activity.

For this purpose, CACI has established the following contacts for reporting violations:

1. Immediate Manager

2. Corporate Ombudsmen

3. Legal Division

4. CACI Hotline 1-800-928-3505 (available 24 hours)

This hotline is intended for reports of any kind of inappropriate conduct.

5. CACI Accounting Hotline 1-866-839-8686

It is CACI's policy that there will be no retaliation against any person who reports what they believe in good faith to be a violation of these Standards or any law, rule, or regulation applicable to CACI's business.

It is the responsibility of an employee or consultant to have a reasonable basis on which to conclude that inappropriate activity may be occurring. This requires that a disclosing employee or consultant have some evidence that has led to a good-faith conclusion that conduct may be inappropriate. If, after investigation, it appears that an employee or consultant made a frivolous or bad faith allegation of improper conduct, such employee or consultant may be subject to discipline up to and including termination of employment.

Persons reporting potential violations should be aware that, while a CACI representative receiving a report of a suspected violation will take steps to keep such report confidential, the need to investigate and correct any impropriety may require disclosure of the matter reported to a restricted group.

CACI reserves the right to use any lawful method of investigation which it deems necessary to determine whether any person has engaged in conduct which in its view interferes with or adversely affects its business. Every employee and consultant is expected to cooperate fully with any investigation of any violation of law, CACI's policies, or these Standards of Ethics and Business Conduct.

By way of example, CACI or any investigator retained by CACI may investigate all information contained in an employee's resume to ensure that it is complete and accurate by contacting sources such as educational institutions, professional organizations, and former employers.

Company documents you also should be familiar with for ethics compliance

• CACI's Timekeeping Procedures (copy to be retained in your possession)
• CACI's Online Policy and Guidelines (P&G) (will open a new window)
• CACI's Drug-Free Workplace Policy, Policy and Guidelines, Chapter 3, paragraph 3030 (will open a new window)
• CACI's Equal Employment Opportunity and Affirmative Action Policy Statement
• CACI's Online Hot Line Procedures
• CACI's Computing Resources Acceptable Use Policy (will open a new window)
• CACI's Electronic Communications Policy (will open a new window)

Your manager can provide you with copies of any of these documents or you may access these documents online. Additionally, copies are also available by contacting the Corporate Employee Services Office or Employee Relations Office at 703-841-7800.

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