COMPANY CASES

WEBSITE DISCLOSURE

TATA CONSULTANCY SERVICES

Tata companies have consistently adhered to the values and ideals articulated by the Founder
for over 150 years. The Tata Code of Conduct was first formalized by Mr Ratan Tata. It
articulates the Group's values and ideals that guide and govern the conduct of our companies
as well as our colleagues in all matters relating to business. Today, the Code is a bedrock on
which we base our individual, as well as leadership commitments to core Tata values.
The Tata Code of Conduct outlines our commitment to each of our stakeholders, including the
communities in which we operate, and is our guiding light when we are sometimes faced with
business dilemmas that leave us at ethical crossroads. The Code is also dynamic in that it has
been periodically refreshed in order to remain contemporary and contextual to the changes in
law and regulations. However it remains unaltered at its core.
Our stellar reputation and success as a business entity has been defined by the powerful
commitment and adherence to the core values and principles expressed in this Code, by all our
employees, directors and partners. I trust every Tata colleague and Tata company will continue
to not only comply with the laws and regulations that govern our business interests around the
world, but will continue to set new standards of ethical conduct that will generate deep respect
and inspire emulation by others

The Culture of TCS is observed to be highly ethical as is the case with most TATA Group
Companies. The culture according to the various interviews was found to be highly networked
although the job responsibilities and positions of employees were clearly defined. This helped
the employees settle down in the organization quickly and effectively along with giving
providing them the autonomy to bring out the best in themselves due to highly networked
nature of the environment. This is well exemplified by the fact that even the CEO of the
company is addressed by his first name. The culture of TCS is also the one that supports growth
and learning by providing and facilitating platforms for individuals to innovate and experiment
even if that is not a direct requirement of their project. One of the most striking feature of this
company is that employees are referred to as associates and not ’employees’. This reflects the
pride the company wants to experience in being ‘associated’ with the concerned individuals
and holds them as important and superior as the company itself. However since TCS is huge
organization with approximately 170,000 employees, many-a-times underutilization of human
resources is observed before the project allocation. Hence periods of inactivity is observed in
such cases. The size of the company and it’s well defined hierarchy is centralized at higher
management level and localized at domain or vertical level. The company is also studied to be
too customer driven even when it’s not a part of the customer requirement or specification.

TCS overall is an employee driven company, The Company provides the best in the class
facilities to work and learn. TCS has a separate learning and development cell, which
encourages the associates (yes the employees are called associates) to learn and develop their
technical, managerial, interpersonal communication and other skills. The company provides a
good mix of talent and challenging work which appeals to the associates. In the interviews, we
didn’t find one thing that was low on culture practices at TCS. The employees are well paid,
well satisfied and love the culture. The company has the lowest attrition ration of 9% for the
last 4 quarters is a proof of the culture that prevails there.

A. VALUES

TATA has always been values-driven. The five core values that underpin the way we conduct
our business activities are:

INTEGRITY We will be fair, honest, transparent and ethical in our conduct; everything we do
must stand the test of public scrutiny.

EXCELLENCE We will be passionate about achieving the highest standards of quality, always
promoting meritocracy.

PIONEERING We will be bold and agile, courageously taking on challenges, using deep
customer insight to develop innovative solutions

UNITY. We will invest in our people and partners, enable continuous learning, and build caring
and collaborative relationships based on trust and mutual respect.

RESPONSIBILITY We will integrate environmental and social principles in our businesses,

ensuring that what comes from the people goes back to the people many times over.

B. SCOPE AND PURPOSE OF THIS CODE

1. This Code sets out how we behave with:

• our employees, or those who work with us;

• our customers;
• the communities and the environment in which we operate;
• our value-chain partners, including suppliers and service providers, distributors, sales
representatives, contractors, channel partners, consultants, intermediaries and agents;
• our joint-venture partners or other business associates;
• our financial stakeholders;
• the governments of the countries in which we operate; and
• our group companies.

2. In this Code, “we or us” means our company, our executive directors, officers, employees
and those who work with us, as the context may require.

3. The term “our group companies” in this Code typically means companies Tata Sons intends
for this Code to apply to, and / or to whom Tata Sons has issued this Code.

4. This Code sets out our expectations of all those who work with us. We also expect those
who deal with us to be aware that this Code underpins everything we do, and in order to work
with us they need to act in a manner consistent with it.

C. CORE PRINCIPLES

The Tata philosophy of management has always been, and is today more than ever, that
corporate enterprises must be managed not merely in the interests of their owners, but equally
in those of their employees, of the consumers of their products, of the local community and
finally of the country as a whole.

1. We are committed to operating our businesses conforming to the highest moral and ethical
standards. We do not tolerate bribery or corruption in any form. This commitment
underpins everything that we do.

2. We are committed to good corporate citizenship. We treat social development activities

which benefit the communities in which we operate as an integral part of our business plan.

3. We seek to contribute to the economic development of the communities of the countries and
regions we operate in, while respecting their culture, norms and heritage. We seek to avoid any
project or activity that is detrimental to the wider interests of the communities in which we
operate.
4. We shall not compromise safety in the pursuit of commercial advantage. We shall strive to
provide a safe, healthy and clean working environment for our employees and all those who
work with us.

5. When representing our company, we shall act with professionalism, honesty and integrity,
and conform to the highest moral and ethical standards. In the countries we operate in, we shall
exhibit culturally appropriate behaviour. Our conduct shall be fair and transparent and be
perceived as fair and transparent by third parties.

6. We shall respect the human rights and dignity of all our stakeholders.
7. We shall strive to balance the interests of our stakeholders, treating each of them fairly and
avoiding unfair discrimination of any kind.

8. The statements that we make to our stakeholders shall be truthful and made in good faith.

9. We shall not engage in any restrictive or unfair trade practices.

10. We shall provide avenues for our stakeholders to raise concerns or queries in good faith, or
report instances of actual or perceived violations of our Code.

11. We shall strive to create an environment free from fear of retribution to deal with concerns
that are raised or cases reported in good faith. No one shall be punished or made to suffer for
raising concerns or making disclosures in good faith or in the public interest.

12. We expect the leaders of our businesses to demonstrate their commitment to the ethical
standards set out in this Code through their own behaviour and by establishing appropriate
processes within their companies.

13. We shall comply with the laws of the countries in which we operate and any other laws
which apply to us. With regard to those provisions of the Code that are explicitly dealt with
under an applicable law or employment terms, the law and those terms shall take precedence.
In the event that the standards prescribed under any applicable law are lower than that of the
Code, we shall conduct ourselves as per the provisions of the Code

D. EMPLOYEES

Equal opportunity employer

1. We provide equal opportunities to all our employees and to all eligible applicants for
employment in our company. We do not unfairly discriminate on any ground, including
race, caste, religion, colour, ancestry, marital status, gender, sexual orientation, age,
nationality, ethnic origin, disability or any other category protected by applicable law.

2. When recruiting, developing and promoting our employees, our decisions will be based
solely on performance, merit, competence and potential.

3. We shall have fair, transparent and clear employee policies which promote diversity and
equality, in accordance with applicable law and other provisions of this Code. These policies
shall provide for clear terms of employment, training, development and performance
management.
Dignity and respect

4. Our leaders shall be responsible for creating a conducive work environment built on
tolerance, understanding, mutual cooperation and respect for individual privacy.

5. Everyone in our work environment must be treated with dignity and respect. We do not
tolerate any form of harassment, whether sexual, physical, verbal or psychological.

6. We have clear and fair disciplinary procedures, which necessarily include an employee’s
right to be heard.

7. We respect our employees’ right to privacy. We have no concern with their conduct outside
our work environment, unless such conduct impairs their work performance, creates conflicts
of interest or adversely affects our reputation or business interests.

Human rights

8. We do not employ children at our workplaces.

9. We do not use forced labour in any form. We do not confiscate personal documents of our
employees, or force them to make any payment to us or to anyone else in order to secure
employment with us, or to work with us.

Bribery and corruption

10. Our employees and those representing us, including agents and intermediaries, shall not,
directly or indirectly, offer or receive any illegal or improper payments or comparable benefits
that are intended or perceived to obtain undue favours for the conduct of our business.

Gifts and hospitality

11. Business gifts and hospitality are sometimes used in the normal course of business activity.
However, if offers of gifts or hospitality (including entertainment or travel) are frequent or of
substantial value, they may create the perception of, or an actual conflict of interest or an ‘illicit
payment’. Therefore, gifts and hospitality given or received should be modest in value and
appropriate, and in compliance with our company’s gifts and hospitality policy

Freedom of association

12. We recognise that employees may be interested in joining associations or involving

themselves in civic or public affairs in their personal capacities, provided such activities do not
create an actual or potential conflict with the interests of our company. Our employees must
notify and seek prior approval for any such activity as per the ‘Conflicts of Interest’ clause of
this Code and in accordance with applicable company policies and law.
Working outside employment with us

13. Taking employment, accepting a position of responsibility or running a business outside

employment with our company, in your own time, with or without remuneration, could
interfere with your ability to work effectively at our company or create conflicts of interest.
Any such activity must not be with any customer, supplier, distributor or competitor of our
company. Our employees must notify and seek prior approval for any such activity as per the
‘Conflicts of Interest’ clause of this Code and in accordance with applicable company policies
and law.

Integrity of information and assets

14. Our employees shall not make any wilful omissions or material misrepresentation that
would compromise the integrity of our records, internal or external communications and
reports, including the financial statements.

15. Our employees and directors shall seek proper authorisation prior to disclosing company
or business-related information, and such disclosures shall be made in accordance with our
company’s media and communication policy. This includes disclosures through any forum or
media, including through social media.

16. Our employees shall ensure the integrity of personal data or information provided by them
to our company. We shall safeguard the privacy of all such data or information given to us in
accordance with applicable company policies or law.

17. Our employees shall respect and protect all confidential information and intellectual
property of our company.

18. Our employees shall safeguard the confidentiality of all third party intellectual property
and data. Our employees shall not misuse such intellectual property and data that comes into
their possession and shall not share it with anyone, except in accordance with applicable
company policies or law.

19. Our employees shall promptly report the loss, theft or destruction of any confidential
information or intellectual property and data of our company or that of any third party

20. Our employees shall use all company assets, tangible and intangible, including computer
and communication equipment, for the purpose for which they are provided and in order to
conduct our business. Such assets shall not be misused. We shall establish processes to
minimise the risk of fraud, and misappropriation or misuse of our assets.

21. We shall comply with all applicable anti-money laundering, anti-fraud and anti-corruption
laws and we shall establish processes to check for and prevent any breaches of such laws.
Insider trading
22. Our employees must not indulge in any form of insider trading nor assist others, including
immediate family, friends or business associates, to derive any benefit from access to and
possession of price sensitive information that is not in the public domain. Such information
would include information about our company, our group companies, our clients and our
suppliers.

Prohibited drugs and substances

23. Use of prohibited drugs and substances creates genuine safety and other risks at our
workplaces. We do not tolerate prohibited drugs and substances from being possessed,
consumed or distributed at our workplaces, or in the course of company duties.

Conflicts of interest

24. Our employees and executive directors shall always act in the interest of our company and
ensure that any business or personal association including close personal relationships which
they may have, does not create a conflict of interest with their roles and duties in our company
or the operations of our company. Further, our employees and executive directors shall not
engage in any business, relationship or activity, which might conflict with the interest of our
company or our group companies.

25. Should any actual or potential conflicts of interest arise, the concerned person must
immediately report such conflicts and seek approvals as required by applicable law and
company policy. The competent authority shall revert to the employee within a reasonable time
as defined in our company’s policy, so as to enable the concerned employee to take necessary
action as advised to resolve or avoid the conflict in an expeditious manner.

26. In the case of all employees other than executive directors, the Chief Executive Officer /
Managing Director shall be the competent authority, who in turn shall report such cases to the
Board of Directors on a quarterly basis. In case of the Chief Executive Officer / Managing
Director and executive directors, the Board of Directors of our company shall be the competent
authority.
 E. CUSTOMERS

Products and services

1. We are committed to supplying products and services of world-class quality that meet all
applicable standards.

2. The products and services we offer shall comply with applicable laws, including product
packaging, labelling and after-sales service obligations.

3. We shall market our products and services on their own merits and not make unfair or
misleading statements about the products and services of our competitors.

Export controls and trade sanctions

4. We shall comply with all relevant export controls or trade sanctions in the course of our
business.

Fair competition

5. We support the development and operation of competitive open markets and the
liberalisation of trade and investment in each country and market in which we operate.

6. We shall not enter into any activity constituting anti-competitive behaviour such as abuse
of market dominance, collusion, participation in cartels or inappropriate exchange of
information with competitors.

7. We collect competitive information only in the normal course of business and obtain the
same through legally permitted sources and means.

Dealings with customers

8. Our dealings with our customers shall be professional, fair and transparent.

9. We respect our customers’ right to privacy in relation to their personal data. We shall
safeguard our customers’ personal data, in accordance with applicable law.
 WIPRO

Wipro Ltd (NYSE:WIT) is a global information technology, consulting and outsourcing

company with services spanning financial services, retail, transportation, manufacturing,
healthcare services, energy and utilities, technology, telecom and media.

Serving clients in 175+ cities across 6 continents, we help customers do business better by
leveraging our industry-wide experience, deep technology expertise, comprehensive portfolio
of services and vertically aligned business model. Our 55+ dedicated emerging technologies
‘Centers of Excellence’ enable us to harness the latest technology for delivering business
capability to our clients. Wipro also champions optimised utilization of natural resources,
capital and talent.

A. CULTURE

WIPRO believe that excellence is not a destination but a journey of continuous improvement
and we keenly promote an open culture, encouraging feedback, and actively transforming it
into action.

SPIRIT OF WIPRO
The Spirit of Wipro is the core of Wipro. These are our Values. It is about who we are. It is our
character. It is reflected consistently in all our behavior. The Spirit is deeply rooted in the
unchanging essence of Wipro. But it also embraces what we must aspire to be. It is the
indivisible synthesis of the four values. The Spirit is a beacon. It is what gives us direction and
a clear sense of purpose. It energizes us and is the touchstone for all that we do.
Be passionate about clients’ success
We succeed when we make our clients successful. We collaborate to sharpen our insights and
amplify this success. We execute with excellence. Always.
Be global and responsible
We will be global in our thinking and our actions. We are responsible citizens of the world.
We are energized by the deep connectedness between people, ideas, communities and the
environment.
Treat each person with respect
We treat every human being with respect. We nurture an open environment where people are
encouraged to learn, share and grow. We embrace diversity of thought, of cultures and of
people.

Unyielding integrity in everything we do

Integrity is our core and is the basis of everything. It is about following the law, but it’s more.
It is about delivering on our commitments. It is about honesty and fairness in action. It is about
being ethical beyond any doubt, in the toughest of circumstances.

1. EMPLOYEE RESPONSIBILITIES

Wipro is made up of thousands of individuals, each with unique perspectives and aspirations.
Though we are all different, we all share an understanding of the importance of “Unyielding
Integrity.” Without a reputation for integrity we would fail with customers, with investors and
in our own eyes. We must strive to maintain the highest ethical standards.

In particular:

• Always act in a professional, honest, and ethical manner when acting on behalf of the
Company.

• Be familiar with the information contained in the COBC and policies, and pay particular
attention to the policies that pertain to your job responsibilities.

• Complete all required employee trainings in a timely manner and keep up-to-date on current
standards and expectations.

• Promptly report concerns about possible violations of laws, regulations or the COBC to your
manager, manager’s manager, HR manager, head of the business, any member of Senior
Management, any member of the Legal & Compliance Department or the Ombudsperson.

• Cooperate and tell the whole truth when responding to an investigation or audit and never
alter or destroy records in response to an investigation, or when an investigation is anticipated.

2. COOPERATING WITH SURVEYS, INVESTIGATIONS AND INQUIRIES

The Company will promptly investigate all credible reports of misconduct. Also, using both
internal and external resources, Wipro conducts surveys and audits to assess risks and
enhance compliance. All employees are required to cooperate fully and truthfully with
designated audit and investigations professionals. Regular purging of documents is in order
except if an investigation is in progress and a document preservation or hold notice is issued.
Never mislead any investigator and never alter or destroy documents or records in response
to an investigation.
 3. ETHICAL LEADERSHIP

If you are in a leadership position at Wipro, you are also expected to meet the following
additional responsibilities:

• Lead by example. Managers are expected to exemplify the highest standards of ethical
business conduct and to model the “Spirit of Wipro.”

• Support implementation of ethics and business conduct programmes and monitor compliance
of Wipro’s values and ethical business conduct guidelines through such programmes.

• Help create a work environment that focuses on building relationships. Recognize effort and
value mutual respect and open communication.

• Communicate to employees and business partners (such as dealers, distributors, agents) about
how the COBC and policies apply to their daily work.

• Be proactive. Look for opportunities to discuss and address ethics and ethically challenging
situations with team members.

• Create an environment where everyone feels comfortable asking questions and reporting
potential violations of the COBC and policies.

• Never ask another or pressure anyone to do something that is in violation of the COBC.

• Be aware of the limits of your authority and do not take any action that exceeds those limits.
Delegate authority only where permissible and never delegate authority to any individual who
you believe may engage in unlawful conduct or unethical activities.

• If you supervise third parties, ensure that they understand their ethics and compliance.

4. MAKING THE RIGHT CHOICE

Making the right decision is not always easy. There will be times when you will be under
pressure or unsure of what to do. Always remember when you have a tough choice to make,
you are not alone. Your fellow Wiproites are available to help and you have other resources to
turn to including the COBC. When faced with a tough ethical decision it may help to pause and
ask these questions. If you give a negative answer to even one question, consider a different
action or seek help.

Managers must listen openly to concerns about misconduct, respond appropriately, and never
retaliate against those who raise issues in good faith. Lack of content/ expert knowledge could
cause anxiety on an employee’s part to believe it to be wrong— that’s fine. It is a violation of
our policy and contrary to our values to engage in retaliatory acts against any employee who
reports wrongdoing of any type, or any employee who testifies, assists or participates in a
proceeding, investigation or hearing relating to allegations of misconduct.

5. ASKING QUESTIONS AND RAISING CONCERNS

In today’s complex business environment, it is inevitable that questions and ethics and
compliance concerns will arise. The sooner Wipro leadership knows about possible problems,
the sooner they can be addressed. Each one of us is responsible to promptly raise issues or
concerns about misconduct. If you become aware of conduct that you believe violates
Wipro’s policies, regulations, or the law, talk to your manager. If this seems inappropriate, or
if you don’t believe the person to whom you’ve reported your concern has taken appropriate
action, you have several additional options:

• Speak with your manager’s manager or any member of Senior Management

• Contact the Legal & Compliance Department or your HR manager.

• Use the Company’s Ombudsprocess, which is a whistle-blower process, by contacting

ombuds.person@wipro.com

6. PREVENTING RETALIATION

Managers must listen openly to concerns about misconduct, respond appropriately,

and never retaliate against those who raise issues in good faith. Lack of content/
expert knowledge could cause anxiety on an employee’s part to believe it to be
wrong— that’s fine. It is a violation of our policy and contrary to our values to engage
in retaliatory acts against any employee who reports wrongdoing of any type, or any
employee who testifies, assists or participates in a proceeding, investigation or
hearing relating to allegations of misconduct. Wipro takes claims of retaliation
seriously. All such claims will be thoroughly investigated and if substantiated,
retaliators will be disciplined up to and including termination. If you believe you have
been retaliated against, you should report such action to the Ombudsperson or use any
of the reporting methods described in the COBC.
 7. ACCOUNTABILITY AND DISCIPLINE

Violating relevant laws, regulations, or the COBC, or expecting or encouraging others to do

so, exposes the Company to liability and puts the Company’s reputation at risk. If an ethics or
compliance problem does occur, you have an obligation to contact one of the resources listed
in the COBC so that an effective solution can be developed. Wipro will take appropriate
disciplinary action including up to termination against any employee, agent, contractor or
consultant, whose actions are found to violate these policies or any other policies of Wipro.
The Compliance process at Wipro has the oversight of the Board of Directors, Audit
Committee and Corporate Compliance Committees comprising of Board Members.

CUSTOMER RELATIONS

Our standard

Customers purchase our services and products because they trust them. They trust the quality
of our services and products, they trust their value, and they trust that we will stand behind
what we sell and deliver. We must preserve that trust. Wipro has a fundamental responsibility
to ensure that customers have faith in the quality of our services and products. It is the primary
responsibility of every employee to make sure that our services and products are consistently
of the highest quality

Our responsibilities

• Each of us must ensure that we follow our rigorous product safety and quality standards.

• Any concerns about product safety or quality must be immediately reported. It is the job of
every employee to make sure that consumers get what they expect—and pay for.

• Do not create misleading impressions in any advertising, marketing, sales materials or

presentations.
 HEWLETT-PACKARD COMPANY

Hewlett-Packard Company is committed to the highest standards of business ethics. All

suppliers, consultants and contractors doing business with HP agree to deliver their services in
a manner consistent with this commitment. Accordingly, each such supplier, consultant and
contractor shall ensure that any member of its workforce (including employees, suppliers,
agents, etc.) involved in the performance of services for or on behalf of HP is aware of, trained
on and complies with this Code of Conduct.

All non-employees performing services for HP (hereinafter “contingent workers”) must under
the direction and control of their respective employers, comply with the following provisions
and adhere to the highest standards of business ethics.

Integrity at HP is a resource for all employees and members of the Board of Directors. Integrity
at HP is the new name forthe Standards of Business Conduct. It represents the highest level of
guidance for our conduct.

AS AN EMPLOYEE, YOU ARE EXPECTED TO:

Act with uncompromising integrity— Demonstrate your commitment to our values, policies,
and the law by always putting integrity first.

Raise a concern—Every employee has a responsibility to report any suspected misconduct

immediately, honestly, and in good faith.

Cooperate—Comply with all internal investigations and audits.

IF YOU ARE A MANAGER, YOU MUST ALSO:

Be an ethical leader—Use your good judgment and the Headline Test to ensure that your
actions demonstrate the highest standards of ethical behavior.

Be a resource—Know Integrity at HP values and expectations so you can reinforce them with
your team and answer employee questions.

Open your door—Encourage employees to come to you if they want to talk or have questions.

Build trust—Take employee concerns seriously, provide guidance and take appropriate action
to prevent, detect, and respond to misconduct and ask for help if needed.

Never Retaliate—Do not retaliate (or let others retaliate) against someone who comes forward
in good faith with a concern.
Compliance with Laws, Rules and Regulations

Contingent workers must comply with all laws, rules and government regulations applicable
to HP wherever it does business.

Equal Opportunity

Unlawful discrimination in the workplace is prohibited. Contingent workers must not in the
conduct of business discriminate on the basis of race, creed, color, religion, gender, sexual
orientation, gender identity/expression, national origin, disability, age or any other protected
status.

Work Environment

Harassment in the workplace is prohibited. Such harassment includes offensive verbal,

physical, or visual behavior and actions directed toward an individual, based upon the
individual’s gender, color, race, ancestry, religion, national origin, age, physical or mental
disability, sexual orientation, gender identity/expression or other protected status. All forms of
sexual harassment are unacceptable. This includes unwelcome sexual advances, requests for
sexual favors or the physical or computer image display of sexually-explicit posters, pictures,
cartoons or drawings and other verbal or physical conduct of a sexual nature.

Conflicts of Interest

General.
Contingent workers must not engage in any activities that would present a conflict of interest
related to their employer and/or HP.

Business Gifts and Entertainment.

Contingent workers may not provide or receive business amenities (gifts, meals, services,
entertainment, or anything else of value) when doing so may create the appearance of
impropriety or undue influence. This restriction applies to amenities given to or received from
representatives of HP, or its current or potential customers, channel partners, suppliers, other
business partners and competitors.

Agency contractors under the direction and control of their employer are expected to adhere
to the additional provisions set forth below.

Work with Competitors. Agency contractors may not work for an HP competitor during their
HP assignment.
Work with Channel Partners, suppliers and others. Agency contractors may not work for
a HP channel partner, supplier, OEM, alliance partner, marketing partner or other business
partner during their HP assignment.

Work with Customers. Agency contractors may not work for an HP enduser customer in the
purchase or support of any HP products or services.

Business with Family or Friends. During their HP assignment, agency contractors must
disclose to their employer all situations where they may be conducting business with members
of their family, friends or others with whom they have a close personal relationship.

Use of HP Resources
Any use of HP assets, resources, or equipment, including the company’s computers and
information systems, must be solely for HP business purposes and must be consistent with all
HP policies and guidelines. Contingent workers may not use any HP resource in violation of
the law and must not allow others, including friends and family, to use HP resources for any
purpose. HP resources may not be used to create, transmit, store, copy or display messages,
images or materials that are: for personal gain; solicitations; chain letters; or messages, images
or materials that HP deems to be threatening, pornographic, sexually explicit, harassing or
demeaning to any person or group. HP may, as allowed by applicable local laws, access and
inspect all HP resources that contingent workers may use for personal activity, including HP
computers, servers and systems, telephones, voicemail systems, desks, lockers, cabinets,
vehicles and other equipment belonging to HP. For reasons related to safety, supervision,
security and other concerns, HP may inspect persons and property on HP premises at any time
and without notice, subject to applicable local laws. Contingent workers should not have any
expectation of personal privacy in any messages or records created, transmitted or stored via
HP systems. HP owns all business emails, voicemails and any other non-personal data of any
kind stored on or transmitted by HP equipment. HP has the right to access or retrieve such data
at any time.

Anti-Corruption
Contingent workers must not use bribes, kickbacks or other corrupt practices and must comply
with all ethical standards and applicable law in every country in which HP does business.

Anti-bribery.
Contingent workers may not directly or indirectly bribe or improperly influence any federal,
provincial, state or local governmental employee in any country. The U.S. Foreign Corrupt
Practices Act ("FCPA") prohibits any payment or gift to government officials, political parties,
or candidates for office outside of the U.S. for the purpose of winning or keeping business. The
FCPA covers the actions of HP, HP subsidiaries, joint ventures, agents and representatives.
Finder Fees.
Contingent workers may not enter any commission or fee arrangements except under written
agreements with bona fide commercial distributors, sales representatives, agents or consultants.

Records.
All payments made on behalf of HP must be properly documented.

Grey Marketing

Contingent workers must avoid and report any situation that could lead to the unauthorized
diversion of HP products, such as noncompliance with permitted territorial assignments, abuse
of pricing and promotional programs, etc. Contingent workers should promptly report any
suspected gray marketing activity to their employer as well as the HP Ethics and Compliance
Office.

Insider Trading
Contingent workers may at times have access to “material insider” information, which is
undisclosed information concerning HP’s business that, if disclosed to the public, could
influence an ordinary investor’s decision to buy or sell HP’s stock or other securities. Trading
stock, or causing stock to be traded, on the basis of material inside information, regardless of
the size of the trade or where the trader is located, is a violation of U.S. securities laws and,
depending on the circumstances, the laws of other countries as well. Anyone who violates
insider trading laws may be subject to severe civil and criminal sanctions.

Confidentiality

Contingent workers are expected to be familiar with and adhere to any specific confidentiality
terms agreed to between their employer and HP. If a separate confidentiality agreement does
not exist, contingent workers must presume that all information available from HP is
confidential. This includes information that HP may have received from its suppliers,
customers or business partners. Confidential information may only be used or disclosed as
necessary and appropriate to perform assigned duties on behalf of HP.

Third-Party Confidential Information

Contingent workers are expected to honor any valid disclosure or use restrictions on
confidential information received from any current or former employers or any other third-
parties. Such information in any tangible or readable form must not be brought onto HP
premises without the prior written consent of such former employers or other third-parties.

Discussions with Press or Media

Contingent workers are not authorized to speak to the media on behalf of HP unless authorized
in writing by HP’s communications group.
Privacy

Contingent workers must follow HP privacy policies and data protection practices in using
online and offline systems, processes, products and services that involve the use, storage or
transmission of any personally identifiable data from HP customers, business partners,
employees and other individuals. Personal information includes data related to a person who
can be identified or located by that data.

Non-Solicitation

Contingent workers may not solicit any HP employee during the HP employee's working time.
Further, contingent workers may not distribute literature or other materials in HP working
areas. This policy prohibits soliciting or handing out materials for any non-business reason,
including for charitable purposes.

Additional Principles

This Code of Conduct must be read in conjunction with the standards of conduct, if any, of
the respective contingent worker’s employer. In addition, the principles described above are
not all-inclusive. Any conduct that could call into question HP’s commitment to the highest
standards of business ethics is prohibited. Contingent workers with questions concerning this
Code of Conduct must contact their employer, a member of HP management or HP’s Ethics
and Compliance Office.

Reporting Violations
Contingent workers are expected to report any conduct that they believe in good faith to be
inconsistent with this Code of Conduct or with the law. Reports should be made to their
employer, and a member of HP management or HP’s Ethics and Compliance Office. HP will
not retaliate, nor tolerate retaliation committed by others, against those who report in good faith
suspected violations of this Code or other wrongdoing.