IMS HEALTH - Code of Ethics

IMS Health Incorporated Code of Ethics for Principal Executive Officer and Senior Financial Officers

Statement of Purpose
IMS’ reputation for honesty and ethical conduct is shaped by the decisions its employees make and the principles they practice everyday. IMS has set high ethical and professional standards for its employees, which it has codified in its Policy on Business Conduct. Compliance with that Policy is mandatory for all IMS employees. For its Chief Executive Officer (“CEO”) and senior financial officers, however, IMS demands more.

The CEO and senior financial officers hold an important and elevated role in corporate governance. As part of the IMS leadership and finance teams, theyare uniquely capable and empowered to protect, balance, and preserve the interests of IMS’ investors, customers, suppliers, employees and the citizens of the communities in which IMS’ business is conducted. This Code of Ethics for Principal Executive Officer and Senior Financial Officers (the “Code”) sets forth the enhanced standards to which IMS’ CEO and senior financial officers are expected to adhere and advocate.

This Code is designed to reinforce the understanding by IMS’ CEO and its senior financial officers of their responsibilities in ensuring that IMS’ financial management practices are sound, accurate and ethical and that its reporting practices are carried out with the highest standards of ethics and integrity. This Code is also intended to ensure that the CEO and senior financial officers are clearly aware of the consequences of violating these responsibilities.

Both the U.S. Congress and the U.S. Securities and Exchange Commission (“SEC”) have imposed stricter accounting controls on public corporations, requiring senior officers to personally verify the accuracy of their companies’ financial statements. Specifically, IMS’ CEO and CFO must certify, with respect to each periodic report that IMS files with the SEC, that among other things:

The report does not contain any untrue statement of a material fact or
omit to state a material fact necessary to make the statements made
in the report not misleading; and
The financial statements, and other financial information included in
the report, fairly present in all material respects the financial condition,
results of operation and cash flows of the Company.

Another goal of this Code is to help create this same sense of accountability in IMS’ other senior financial officers. Making all senior financial officers directly accountable for their teams’ financial practices not only helps IMS to comply with these stricter requirements, but also strengthens the trust IMS has established with its investors, customers, suppliers, communities and each other.

Application
This Code applies to IMS’ principal executive officer, or CEO, and all IMS professionals worldwide serving at the director level and above in a finance, accounting, treasury, tax or investor relations role. Your full compliance with this Code and with IMS' Policy on Business Conduct is mandatory.

Accurate Financial Records and Periodic Reports
As you are aware, full, fair, accurate, timely and understandable disclosures in IMS' periodic reports that are filed with the SEC are legally required and are essential to the success of IMS’ business. You should exercise the highest standard of care in preparing such reports in accordance with the following guidelines:

All IMS accounting records, as well as reports produced from those records, must be maintained and produced in
accordance with U.S. generally accepted accounting principles and the laws of each applicable jurisdiction.
All records must fairly and accurately reflect the transactions or occurrences to which they relate.
All records must fairly and accurately reflect, in reasonable detail, IMS' assets, liabilities, revenues and expenses.
IMS' accounting records must not contain any false or intentionally misleading entries.
No transactions should be intentionally misclassified as to accounts, departments or accounting periods.
All transactions must be supported by accurate documentation in reasonable detail and recorded in the proper account and in the proper accounting period.
No information should be concealed from the internal auditors or the independent auditors.
Compliance with IMS' system of internal accounting controls is required.

You are prohibited from directly or indirectly taking any action to fraudulently influence, coerce, manipulate or mislead the Company’s independent auditors for the purpose of rendering the financial statements of IMS misleading.

Conflicts of Interest
Engaging in any conduct that represents a conflict of interest is strictly prohibited. In addition, you should avoid even the
appearance of such a conflict. You must avoid any action, investment, interest or association that might interfere, or even
appear to interfere, with your independent exercise of judgment in the best interests of the Company. You may not exploit your position or relationship with IMS for personal gain.

A likely conflict of interest would exist if, for example, you:

cause IMS to engage in business transactions with individuals or companies with whom you have a relationship, including relatives or friends;
have more than a modest interest in any IMS' customer, supplier or other company if you will be making decisions in your job that affect such customer, supplier or other company;
use non-public IMS, employee, customer, supplier or alliance partner information for your personal gain or that of your relatives or friends (including securities transactions based on such information);
accept gifts or favors that exceed local social and/or business custom;
receive a loan, or guarantee of obligations, from IMS or a thirdparty as a result of your position at IMS; or
compete, or prepare to compete, with IMS while still employedby IMS.

There are other situations in which a conflict of interest may arise, including those described in the IMS Policy on Business Conduct. If you have concerns about any situation, follow the steps outlined in the Section on "Reporting Violations."

As an IMS CEO or senior financial officer, it is imperative that you avoid any investment, interest or association that interferes, might interfere, or might appear to interfere, with your independent exercise of judgment in IMS' best interests.

Confidentiality
You should take all reasonable steps to protect the confidentiality of information you receive or create in the course of your work, including Company information, employee information as well as information you receive from or relating to customers, suppliers, alliance partners and others. You must not disclose, use or copy any such information for other than Company purposes, unless specifically authorized or legally obligated to do so.

You should take all reasonable steps to ensure that no employee, contractor or customer accidentally or intentionally misuses or improperly discloses confidential information.

If you have concerns about any particular set of facts, follow the steps outlined in the Section on "Reporting Violations."

Compliance
You should comply with both the letter and spirit of all applicable governmental laws, rules and regulations.
If you fail to comply with this Code, with IMS' Policy on Business Conduct, and/or with any applicable laws, you will be subject to disciplinary measures, including loss of compensation, stock, benefitsand, in certain cases, termination of employment. You should contact the Corporate Legal Department if you desire additional information regarding the consequences of non-compliance.

As required by the rules of the SEC, any change to, or waiver of, this Code must be immediately publicly disclosed.

Reporting Violations
Your conduct can reinforce an ethical atmosphere and positively influence the conduct of fellow employees. IMS expects you to proactively promote and be an example of ethical behavior among your fellow employees and in your community.

If you are powerless to stop suspected misconduct or discover it after it has occurred, you must report it directly to the IMS’ EthicsPoint Website, EthicsPoint Hotline or Corporate General Counsel. For your convenience, both the EthicsPoint Website and EthicsPoint Hotline are available 24 hours a day, 7 days a week, 365 days a year. Each is operated by the same independent external third-party vendor.

You may contact the EthicsPoint Website or Hotline using the following contact information:

EthicsPoint Website: www.ethicspoint.com

EthicsPoint Hotline: 1-866-294-IMS4 (U.S and Canada)
Toll-free numbers for specific countries are posted on the IMS Intranet
1-971-250-4116 (collect calls)

You may contact the Corporate General Counsel by regular mail, telephone, overnight delivery or e-mail, using the following contact information:

Corporate General Counsel:
Robert H. Steinfeld
IMS Health Incorporated
901 Main Avenue, Suite 612
Norwalk, Connecticut 06851
U.S.A.
Phone: 1-877-530-8879
Fax: 1-203-845-5302
Email: buscon@imshealth.com

Employees may make reports to the EthicsPoint Website or Hotline and to the Corporate General Counsel anonymously and confidentially. You have the commitment of IMS and of the Audit Committee of IMS' Board of Directors that you will be protected from retaliation.

Conclusion
Any employee who ignores or violates any of IMS' ethical standards, and any manager who penalizes a subordinate for trying to adhere tothese ethical standards or for trying to report a violation thereof, will be subject to disciplinary action, up to and including termination of employment.

Great companies adhere to strong ethical principles, and employees of great companies understand and live by those principles every day. At IMS, our commitment to integrity, honesty and ethical conduct in everything we do isn’t an option – it’s a business imperative as fundamental as the services we provide.

IMS Health Incorporated
901 Main Avenue, Suite 612
Norwalk, CT 06851
(203) 845-5200

Your Personal Commitment to the IMS Code of Ethics for Principal Executive Officer and Senior Financial Officers

I acknowledge that I have received and read the IMS Code of Ethics for Principal Executive Officer and Senior Financial Officers, dated May 19, 2006, and understand my obligations as an employee to comply with the Code of Ethics.

I understand that my agreement to comply with the Code of Ethics does not constitute a contract of employment.

Signature: ____________________________________

Name (please print):___________________________

Title:_________________________________________

Country and Department:________________________

Date:__________________________________________

This signed and completed form must be returned to Sean Ascher, IMS Health Incorporated, 901 Main Avenue, Suite 612, Norwalk, CT 06851 (Fax: (203) 845-5302).