Winning the Right Way Standards of Busin Ess Co Nduct

Standards of business conduct Winning the right way Standards of busin ess co nduct

Table o cont nts

4 HP Values 4 Core Principles 4 Leader Attributes 6 A message from Dian Weisler 6 A message from David Deitchman 7 Using the HP Standards of Business Conduct 9 The Headline Test 9 Unsure about a decision or action? 10 Building trust 10 We make ethical decisions 10 We take action when aware of misconduct and do not retaliate 10 We cooperate with investigations 11 Respect 11 We honor human rights 11 We treat others with respect 11 We maintain a safe and secure work environment 11 We promote and provide a harassment-free work environment 11 We respect privacy and protect personal information Standards of bus iness co nduct

12 Uncompromising integrity 12 We use assets wisely 12 We maintain accurate business records 12 We avoid conft.icts of interest 13 We provide and accept gifts and entertainment only when appropriate 13 We do not bribe or accept kickbacks 13 We protect sensitive information 14 We comply with laws governing international trade 14 We do not trade on or disclose nonpublic material information 15 Passion for customers 15 We provide quality products and services 15 We market responsibly 15 We compete vigorously and fairly 15 We obtain business intelligence appropriately 16 Responsible citizenship 16 We are stewards of the environment 16 We engage with responsible business partners and suppliers 17 We communicate honestly with investors and the media 17 We exercise our rights in the political process 17 We support giving and volunteering in our communities 18 Winning the right way, every day 19 Contacting the Ethics and Compliance Office Standards of business co nduct Since Bill Hewlett and Dave Packard started our company many years ago, HP has been known not just for the products and services we offer, but also for the values we share.

HP Values Core Principles Leader Attributes Trust & Respect We have a desire to make Always Accountable a difference Achievement & Contribution Will to Win Results through Teamwork We are driven to achieve Passion for Customers meaningful results Meaningful Innovation Highly Capable & Innovative We believe in the power Uncompromising Integrity of people People & Team Developer Standards of business con du ct We want to be a company known for its ethical leadership-a company where employees are proud to work; a company with which customers, business partners, and suppliers want to do business.

We gain trust by treating others with integrity, respect, and fairness. We must continue to demonstrate these values in all our interactions, every day.

..... -Fairness Sta nd ards of business conduct A message from Dion Weisler

At HP, how we do things is as important as what we do.

Our conduct is the core of our culture, founded on shared va lues that are as relevant today as when HP was established back in 1939. The HP Standards of Bu sine ss Conduct (SBC) sets the standards that guide our business practices and govern our behavior.

We are all responsible for protecting and enhancing HP's reputation for integrity. Every decision we make matters in our effort to deliver meaningful co ntributions to people, organizations, our communities, and the world. We're accountable for our actions, responsible for their consequences, and proud of our efforts. Together, let's build trust in everything we do by living our values.

Dian Weisler CEO

A message from David Deitch man

HP has built its reputation as an exceptional company by doing bu siness ethically and in compliance with the law. Doing otherwise can damage our reputation and business we've worked so hard to build. We take ou r ethical re sponsibilities ve ry seriously, and we must work together to address any issues that arise under the SBC, related polic ie s, and local la ws. This includes all of us speaking up and reporting what doesn't seem right.

We provide a variety of avenues for employees to ask questions or voice their concerns. And we don't tolerate retaliation against employees who spea k up honestly and in good faith . We take action when we find misconduct, and we hold people accountable.

The SBC is a key part of the company's unique culture and id entity, and we 're proud to stand behind it. Its standards and supporting policie s set expectations and are designed to give you the guidance and confidence to make ethical choice s even in tough situations, no matter where you are located in the world. If you don't know what to do, reach out and ask-your leaders, Legal, Human Resources, or my office can help you find the answer so yo u can make the right choice.

Our continued success depends on all of us working together and competing to win, while at all times acting with honesty, integrity, and respect. Let's win the right way.

David Deitchman Chief Ethics and Compliance Officer

6 Stand ard s of busin ess conduct Using the HP Standards of Busin ess Conduct HP does not tolerate retaliation against anyone who raises a concern or question honestly and in good fa ith .

The SBC is a resource for employees and at! those who repre se nt HP. All employees and members of the Board of Directors are required to act in ways that are consistent with the SBc.'

Th e SBC is based on HP's values, core principles, and leader attributes. It repres ents the highest level of guidance. In addition, there are other rules and specific policies that are to be followed and enforced within HP. As figure 1 ittustrates, information on the se rules and policies, including relevant corporate policies, may be found by following links throughout th e SBC . Ther e is also additional guidan ce in the form of key points &pract ices, questions and answers, and red flag s.

Because HP is committed to getting things done the right way, violations of the SBC or HP policies or rules may result in disciplinary action, up to and including termination of employment.

Figure 1. HP Standards of Bu siness Conduc t

Keys to Red flags

Scenarios Q&A

Policy Policy

Policy

' HP also sets high standards for those who pe rfo rm service s for or on behal f of HP through ou r Partner Code of Condu ct, Suppl ier Code of Conduct, and Co ntin gent Wo rke r Code of Co ndu ct.

7 Standa rds of bus ine ss co ndu ct

Wh en con ce rn s or qu estions com e up, co mmunica ti on at th e loca l level. either peer-to-peer or with yo ur manager, is often the bes t pl ace to sta rt. When it is not possib le to raise or reso lve an issue with your immediate manager. use th e Op en Doo r Policy to con tact the ne xt leve l of management, or co ntact HP Human Resources. yo ur local SBC tea m, yo ur busin ess group or region SBC liaison, or th e HP Ethi cs and Co mpliance Offi ce:

• By email: co rporate.co mpliance@h p com • By phone: Call th e Guid eline from anywhere in the world , 24 hours a day Tr ansla tors are available and ca llers ca n remain ano ny mous except where anonymous repor tin g is proh ibited by lo ca l law. From the U.S. and Canada: 800-424-2965 Outside the U.S. and Canad a: 1. Go to AT&T Acce ss Cod es 2. Find your co untry in the alph ab eti ca l listin g 3. Dial the AT&T Direct ® Code 4. Wh en promp te d, dialS00 -424 -296 5

· By mai l: HP Inc. Ethics and Compli ance Offi ce Mailstop 1 560 1501 Page Mill Road Palo Alto , CA 94304-111 2 United Stat es

8 Standards of business condu ct The Headline Test

Unsure about a decision or action? Consider the following: The Headline Test is a simple but powerful tool designed to make sure we appropriately consider the soundness and impact of our business decisions. It is named after one of the tools most commonly used by executives.

Figure 2. Headline Test & & & Check it Check it Check it • Not<.:,IJ''-' tiot ,,,re t; Not SUfi? B :5r;; ;:.»£ Yec. ® '/f!':i v~~ ..... Is it consistent ..... Would others think ..... Is it legal? with HP values, it was OK if they read SBC. and policies7 it in a news story?

No ~j(j ) r ~ o 0 0 0 Don't do it Don't do it Don't do it

''Before I make a decision, I consider how it would look in a news story."

We should each ask ourselves what the impact would be if our conduct or actions became public or we re reviewed by colleagues we respect . If you are uncomfortable with the answer, don't do it!

Che ck it with: • Yo ur ma nager • Another manager • HP Office of the Genera l Co unsel • HP Human Resources · Your local SBC team • Your business group or region SBC liaison • Phone call to the Guideline • Email to: [email protected]

9 Standards of business conduct Building trust Key po ints & practices We gain trust by treating others with integrity, respect, • Engage in open and hone st co mmunicat ion in all yo ur business in teractions and fairness

• Keep your prom ises-show others th at they can We make ethical decisions re ly on you r word · Obe y the la w and HP policies • Be willing to make the right decision fo r HP, even if it is no t th e best decision for you r orga ni zation · Do not engage in any fraudulent conduct or behavior or you pe rsonally • Seek guidance from the SBC and the resources and policies linked to it Question and an swer · Talk to colleagues, yo ur manager, or other members of management to get help to make the Q: I have a co nce rn. but it is not cove red in th e SBC. right decision Does that mean there is no prob lem' • Use your good judgment, the Headline Te st, and the supporting decision-mak ing model to A: No. The SBC can not possibly ad dress eve ry work through situations when the right course of action may not be clea r situation or ethi ca l dilemma . However, the principles, values. an d other guidance discussed in · Alwa ys act honestly, in good fa ith, an d in a re spec tful manner when ra ising co ncerns or the SBC. including the Headl in e Test, ca n help you otherwise using th e SBC ma ke the ri ght decision. We are all expec ted to ac t · Managers must be ethical leade rs and cultiva te a work environment that promotes integrity, eth ically even in the absence of a company policy. trust, and respect If you ne ed more help, talk to yo ur manag er. ano ther member of management. HP Human · Managers must provide proper gu idance to employees and take appropriate ac tion to prevent, Resources, your loca l SBC te am , or you r business detec t, and respond to misconduct group or regio n SBC liaison . You can also contac t the HP Ethi cs and Compliance Office. »Global HR Policies » Fraud Mitigation Policy ::!) Red flags: We take action when aware of misconduct and We take action when aware of misconduct and do not retaliate do not retaliate • Every employee has a res ponsibility to report any alleged misco nduct immediately, including • Awareness of an issue with out willingness to misco nduct by employees, clients, visitors, contractors, pa rtners. and suppliers raise it with anyone • Diffe ren t trea tment of any employee who ra ised · Use the Open Door Policy to ra ise co nce rn s with your manager. If thi s does not work or seem an issue or concern appropriate, go to another member of management, HP Human Resources, your local SBC team, or your business group or region SBC liaison. Also co ntact the HP Ethics and Compliance We cooperate with inve stigations Office if you ha ve a qu estion or concern that you are not comfortable discussing with your • Withholding of relevant documents or management team information from inves tig ators or au ditors • Lies to , or less than complete honesty with, ·Speak up for HP values, knowing that our company does not tolerate retaliation against invest igators or aud itors anyone who raises a co ncern hones tly and in good faith • De letion of docum en ts or in forma tion in · Managers must encourage open and honest comm unication , and ensure that employees ca n response to an investigation or audit ask questions or raise concerns without fear of retalia tion • Dis cuss ion of an internal invest ig ation with )) Global Open Doo r Policy oth ers without permission from the inves tigation team. except communi ca ti on with governmental We cooperate with investigations agencies in comp liance with local law · Cooperate fully with all internal investigations and audits · Work with the HP Office of the General Counsel to res pond to li tigation or requ es ts from government and other external agencies • Tell the whole truth when re sponding to an investigation or audit • Never alter or destroy re cords in response to litiga tion. an in vestiga tion, or an audit, wheth er ongoing or anticipated • Do not discu ss an internal inves tigation with anyone, in side or outside HP, unless yo u are permitted to do so by the internal investigators or are communicating wi th governmen t agencies in compliance with local la w )) HP Global Master Records and Information Ma nagement Policy

)) Litigation and Inve stigation s Policy

10 Standards of bus iness co ndu ct Respect .s-.... Key points & practices L We treat all people-inside and ou tside the company-with • Treat others the way you an d they would like to be treated fairness, dignity, and respect • Let others know if they make you uncomfortable We honor human rights • Re po rt concerns to your manager. another ·Support and respe ct the protection of human rights and ensure that our bu siness partners membe r of management, HP Human Re sources, and suppli ers do the same your local sse team, your business group or region SBC liaison. or the HP Ethics and ·Avoid complicity in human rights violations that could arise through our businesses ac ti ons Compliance Office ·Take all allegations seriously through prompt in vestigation and pursue action to mitigate an y • Behave profess ionall y, and do not threaten or ad ve rse human rights impacts intimidate anyone ·Ensu re that child labor, prison or forced labor, and physical punishment are never permitted in any operation of HP, or our business partners or suppliers Question and answer Q: Different co untries have different cultures and • Res pect the ri ght of employees to organi ze in labor unions and collectively bargain in laws. Does the SBC apply worldwid e7 accordance with local laws and established practices A: Ye s. The SSe es tab li shes prin cip les for business » HP Sustainability Policy conduct applicab le throughout HP, regardless of the location or the particular HP organization or business. Where differences exist on any particular question , as a result of local customs, cultures We treat others with respect or laws, employees must apply either the sse or • Be open and hones t with one another local req uirements- whi chever se ts the highes t standard of behavior with respect to the situation. • Do not discriminate against any employee or applicant for employment because of any characteristic protected by law, including gender, color, race, ethnicity, national origin, relig ion, Red Hags: age, marital status, sex ual orientation, gender identity and expre ssion, disability, pregnancy, We promote and provide a harassment-free covered veteran status. protec ted genetic information, and political affiliatio n work environment • Embrace the diversity of all members of th e HP team • Dismissive at titude or co mments about anti-ha rassment policies »Global HR Policies

• Depiction of hara ssers as victims or vict ims as >> Global Non-Discrimination Poli cy complainers We maintain a safe and secure work environment • Unwelcome remarks . gestures. advances, or physical co ntact • Comply wi th safety, health, and security policies and procedures

• The disp lay of sexually explicit or offensive ·Correct or report any health, sa fety, or security threats pictures or other materials ·Do not sell, possess, or use illegal drugs or create a safety risk through drug use or intox ica tion • Sex ual or offensive jokes or comments (explicit while on HP property or while conducting HP business or by innuendo) "Environmental Health and Safety Policy • Verbal ab use » Global Security Standards • Threa ts or taunting We promote and provide a harassment-free work environment • Do not behave in a disrespectful, hostile, viole nt, intimidating, threatening, or harassing manner ·Encourage a harassment-free work environment • Refuse to accept or tolerate sexual harassment. including unwelcome sexual advances, reques ts for sexual favors, or the physical or computer image displa y of sex ually-explicit posters, pictures, cartoons, or drawings, and other ve rbal or physical cond uc t of a sexual nature » Global HR Policies » Harassment- Free Work Environment Polic y

We respect privacy and protect personal information · Provide transparency in HP practices, provide choice to customers regarding their privacy preferences, and honor those choices • Protect the personal information of current and former employees, members of the Board of Directors, customers. job applicants, online users, business partners. and suppliers • Obtain and use personal information solely for legitimate business purposes, and only if you ha ve a legitimate need to know » Global Master Privacy Policy

11 Standards of business co nduct Uncompromising integrity ~ Key points & practices We are open, ho nest, and ethical in all of our dealings L- · Do the right thing, regardless of the pressure

• Make the right dec is io n fo r HP, not yourse lf We use assets wisely or others · Keep personal use of HP assets to a minimum • Protect all HP asse ts , rememberin g that our • Do not allow other people, including friends or family, to use HP re so urces reputation is the most important asset to keep - an d the easiest to lose • Theft. damage, or unauthori zed possession or use of property or systems is prohibited · Do not use HP equipment or systems to violate the law or to create, store, or send co ntent that :1) Red ftags : others might find offensive We use assets wisely · Avo id any usage that might lead to loss or da mage, including the in troduction of viruses or a • Cowo rkers who are excessively protective of their co mputers (because they may be breach of our IT secu ri ty concerned that their misuse of their computers ·Uphold your responsib ili ty to protect HP financial assets or other HP assets may be discovered by others) »Conflicts of In terest Policy • HP property th at is not secured when not in use » IT Policy Set • Those who allow others to borrow or use HP equipment wi thout approval We maintain accurate business records • Unknown in dividuals without proper credentials · Create business records that accurately re fl ect th e truth of the underlying transac tion or event on HP premises · Ensure the financi al policies and rep or tin g guidelines in th e Accounting and Fina nce Manual • Excessive use of HP resources for personal are followed purposes · Sign only documents, including contracts, that you are au thorized to sign and tha t yo u believe • Use of HP resources to access or store inappropriate materials are accurate and truthful

• Lax en force ment of electronic access control • Remember that email and other electronic communications may be business records; avoid ca rds and other tools that provide acce ss to exaggeration, derogatory language, an d other expressions that co uld be ta ke n ou t of co ntex t HP facilities ·Do not establi sh any undisclosed or unrecor ded HP fund or asset for any purpose • Sha ri ng of passwords • Do not enter into any sid e lette rs or side agreements

We maintain accurate business records ·Retain, protect, and dispose of re cords accordin g to policy • Establishm ent of any off-the-books funds or >> Accounting and Finance Man ual undisclosed or unrecorded assets or li ab ilities »Gl obal Master Records and In formation Management Policy • Undocumented ag reements wi th customers. business partners, or suppliers We avoid conflicts of interest • Backdating of con tracts or other documents ·Make decisions in the bes t interest of HP • Creation of side letters or side agreements • Discuss with your manager any situation that could be perceived as a po ten tia l co nfl ict outside of the HP contracting processes of in te rest • The act of creating or entering into fa lse con trac ts or other docu ments · Proactively address situations that may put your in te res ts or those of a family member or friend in potential con flict with HP We avoid conftlcts of interest »Co nflicts of Interes t Policy • Outside employment wi th, or rece iving compensation from, a cus tomer, business par tner, supplier, or competitor

• Sign ificant financial interest in a cus tomer, bu siness partner. supplier. or co mpe titor held by you or a fam ily member

• Conduc ting business with a business partner, supp lier, chan nel partner or customer when someone in yo ur fa mily, or anyone else with whom yo u have a close pe rsonal relationship, has a substantial role in that company

• Service in a govern ment or pu blic body that has re gulatory au thority over HP or that purchases from HP

• Family members or individ uals with close perso nal relationships shou ld not report to each other, either directly or in direc tly

12 Standards of business conduct

We provide and accept gifts and entertainment only when appropriate • Provide gifts, mea ls, travel, and entertainm ent only if they comp ly with the Globa l Business • Family members or individuals with close Amen ities Policy; gifts, meals, travel, and ente rtainment must be reasonable for the busines s per so na l re lati onships shoul d not direc tly relationship and intended only to im prove HP's image, be tter represe nt prod ucts and services. or ind irec tly be involved in each other's or establish co rdia l re lationships employ ment -re lated decisions such as hiring. work assignments, co mpen sation, · Accept gifts, meals, travel, and entertainment only if they co mply with the Global Business pe rfor mance revi ews, discipl inar y ac tio ns, Amen ities Policy or reco mm enda ti ons fo r promo tions • Excha nge gifts, mea ls. travel, and entertainment that foster goo dwi ll in business relat ionship s, but never provide or accept gifts. mea ls, travel, or entertainment that may Question and answer crea te undu e influence , or eve n the appea rance of undue influence, and never provide or Q: Are there an y limit s on what type s of gifts or accept gifts, meals, travel, or entertain ment in exchange or return fo r a reciproca l ac tion entertainment can be provided to a representative of a customer. partner, or other person on behalf • Provide gifts, mea ls, and ente rtainment only if cons istent with the policies of the rec ipient 's of HP7 employer, as we ll as HP po licies A: Yes. HP has restrictions on the types of • Do not provide gifts, meals. or entertainment to a govern men t officia l unless doing so is lega l amenities that may be provided to our customers, and co nsis tent with HP policies pa rtn ers, or other th ird partie s, be cau se ce rtain ty pes of ameni tie s create unnece ssa ry risk to HP. · Do not so licit gifts, meals, or entertai nment Refe r to the Global Business Amenit ies Po licy. · Report to yo ur manager any gifts, mea ls, or entertainment yo u receive. as req uired by the The foll owing bu siness ameni ties ar e Global Business Amenities Policy never perm itted: • Cash , loans , stock , or stock opt ions · Consu lt the Globa l Business Amenities Po licy before offering or accepting gifts, mea ls, travel or entertain ment, and act accord in g to the po licy, including any approval process • Cash gift cards suc h as, but no t limited to, American Express, Visa, Ma ster Card '' Conflicts of Interest Policy • Any gift or entertainment provided in direct "Globa l Business Amenities Po licy exchange for a reciproca l act ion " Anti- Co rruption Policy • Any item tha t is illegal or sexually explicit, " U.S. Business Amen ities Po licy involves gambling, or wo uld otherwise violate ou r va lues or the SBC We do not bribe or accept kickbacks • Any it em tha t might present an appearance of • Do not offer or provide bribes or other improper payments or ind ucements to win business or impropr iety or conflict of interest to influence a business decis ion-anywhere on anything, even if it means losing business in • Any item exc hang ed during a co mpet itive bi d the sho rt te rm proces s or co ntra ct nego tia tion • Do not request or accept a bribe or kickback of any sort • Excess ive. lavish. or frequent gifts or entertainment · Report to yo ur manager any requests for, or offers of, bribes or kickbacks • Any item that might violate the rec ipient 's policies • Do not make fac ilitation payments, and report any requests for facilitation payments • Amenities given to, or received from , immediate • Use agents and distributors only after they have passed our du e di ligence process to ensure family members (parent s, children, spouse, and that our commiss ions or fee arra ngements wi ll not be used as bribes on our behalf in-laws). significant others. close friends, and business assoc iates (e.g., agents, consu ltants , " Global Business Amenities Po licy etc.) of th ird parties. Exception is infrequent "Anti-Corruption Policy at tend ance of immed ia te family member or significant oth er at co mm erc ial eve nts of "Global Anti - Co rruption websi te nomi nal va lue where the fami ly members or significant others of HP employees are also We protect sensitive information attending or where custo mary fo r a family • Use and disclose HP, customer, business par tner, and supp li er sensitive information only for member or signifi can t ot her to attend . va lid business purposes and only if the appropria te protections are in place • Properly label sens itive information to indica te how it should be ha ndled, distributed , J) We provide and accept gifts and entertainment only when appropriate and destroyed • Fre quent giv ing or rec eipt of gifts. meals, trave l, · Share se nsitive information outside HP only with authorized pa rties who have signed a or entertainmen t to or from customers, business confiden tia l disclosure agreement pa rtners, or suppli ers • Share sensitive information insi de of HP only with employees who have a need to know • Giving or recei pt of gifts, meals. travel, or entertainme nt to or from custome rs. bu siness · Fo llow HP procedures fo r reuse, redeployment, and re turn of all yo ur HP work equipment pa rtne rs, or suppliers during a bid , deal, or • Understand and follow HP policies fo r the use of social media, inc luding but not limited to user co ntract negotiat ion forums, blogs, social platforms (for example, Facebook, Twitter, and others), chat rooms, and • Lavish or excessive gifts, meal s, trave l, or bu lletin boards enterta inment

13 Stan da rds of bu siness co nduct

·Never discuss HP intellectual property, trade secrets, and other comp any confidential information in social media J) We do not bribe or accept kickbacks · Contact HP Legal if you are unsure how information should be ha nd led, whe ther something • Req ue st by an agent for payment s in a different is confidential or for any other questions co unt ry, to a third party, or in cas h »Confidential In forma tion Policy • Req ues ts for. or offers of, cas h or favor s »So cial Media and Blogging Go vernan ce Polic y • Direct ions from a government offi cial that a par ticu lar agen t is to fac ilitate a transaction We comply with laws governing International trade • An agen t wh o ha s a reputat io n for making • Remember that every product and service marketed by HP, as well as te chnical information pro hibited payment s related to products and services, must be cl assified by Global Trade to en sure compliance • An agent who requ es ts fees higher than the with app licable regulations in all countries where HP authorizes delive ry ma rket ra te without reaso nabl e ex planation ·Seek guidance from HP Global Trade to ensure that al l trans fer s of pr odu cts, ser vices, an d • A close personal relationship between an ag ent technology comply with applicable laws an d a gove rnm ent official · Screen all customers and business partners against the list of embarg oed coun trie s and • Reque st by an agent for a cha rit abl e or poli tical government sanctioned parties, and obtain appropriate government export authorizations co ntri bution where required • An age nt who object s to HP 's eff orts to perform • Maintain appropriate im port. export, and customs record s an d controls due diligence · Re spond to req uests relating to bo yc otts only as permitted by th e HP Global Tr ade Poli ci es or We protect sensitive information the HP Offi ce of the Gen eral Coun sel • Failure to mark sensi ti ve in fo rma tion as "sensi tive" or "confidential" · Ensure compliance wi th immigration laws and obtain proper authori zation s (including work permits and visas) in each country when wo rking on behalf of HP • Send ing of sensi ti ve inf ormat ion to unattended fax ma chin es or pri nte rs »Global Trade Policies • Loud or open disc ussi on of sen si tive information »Global Employee Mobility Policy when others mi ght be ab le to hear » HP Standard 014 -0: Safe and Legal Products • Dist ributi on of co pyrigh ted materials without the appropriate copyri ght noti ce We do not trade on or disclose nonpublic material information • Disc ussions about HP proprie tary informa tion • Do not trade in HP securities while you are aware of material nonpublic information about wit h custo mer s or suppli ers without proper HP, or pas s material nonpublic information about HP to others or make rec ommendat ion s approval an d knowledg e of the st atus of th e to others about the purchase or sale of HP se curities while you are aw are of th e material relationsh ip as confi de nti al or nonconfidential nonpublic information • Confide nti al dra ft s and notes that are improperly ·Do not trade in the securities of any other company whi le you are aware of material nonpublic disca rded or not shre dd ed when no lon ger needed information about that company or pass material nonpublic information about that com pa ny • Use of "free " or indivi du ally purchas ed interne t to others or make recommendations to others about the purchas e or sa le of that company's hosting , collabo rati on or cloud ser vices, "just to securities while you are aware of the material nonpublic information ge t the job done" · Remember that material nonpublic information is information that has not been relea sed to We do not trade on or disclose material the public that a reasonable investor would consider important in deciding whether to bu y, nonpublic information sell, or hold securities If invited to join an ex pert network, adv isor y • Recognize that exercising employee stock options may be consid ered a "trade " boar d, pee r exch ange, or other information sharin g group, be alert to the following red flag s: • Become familiar with the HP Insider Trading Poli cy, including any quarterly tra ding re strictions • Exper t ne tworks spon sored by firms managing that may be applicable to you stock market investme nts »Confidenti al In formation Policy • Invitations made without apparent involvement of a firm 's lega l depa rtment , Insider Trading Policy • Re ques ts tha t you not inform HP about you r » Insider Trading Compliance web page partici pation • Re qu ests for de tails of possible future event s at HP • Re qu ests for any ma terial nonpublic information

14 Standa rds of business conduc t Passion for customers £'-.. . . L Key pomts & practices We put our customers first • Focus on trea ting the cus tomer right

• Compe te fairly We provide quality products and services • Promise only what you can deliver • Choose business pa rtners. suppliers, and others who rep resen t HP with car e • Delive r on what you promise

Question and answer · Remember that products and services delivered by HP stand for quality

Q: To help me do a better job at HP, I kept several >> HP Quality Policy doc uments from my previo us employer describi ng various pr ocesses they used . Ca n I use those » HP Standard 014-0: Safe and Legal Pro ducts documents at HP J » HP Standard 014-2: Supplier Safe and Legal Products A: It depends. If the docu ments co ntain yo ur fo rmer employer's confiden tia l or proprietary We market responsibly information, yo u ca nnot use or share this • Represe nt our products and se rvices fai rly, accurately, and truthfully in forma ti on. HP expects all employees to • Do not create misleading impres sions in an y advertising, marketing, or sal es material s or honor any disclosu re or use restricti ons on th e con fi dential information they have obtain ed from pre sentations former employers or oth er th ird parties. In fac t, · Protect the HP brand and marks, and use th em on ly with proper authori za tion new employees are ins truc ted not to bring such information onto HP prem ises. If you are unsure, ·Use due diligence in preventing situations that may lead to the gray marketing of HP products yo u should not use or sha re th is infor mation • Do not make false or illegal claims about competitors or their prod ucts and services until you have co nsulted with the HP Offi ce of the Gene ral Co un sel. ·Use due diligence when choosing a business partner or supplier to en sure that they meet HP standard s Red flags: :I) » Br and Guidelines and Tools We compete vigorously and fairly • Formal or informal understand ings with »Marketing and Sales Policies co mpetitors that stab ilize prices or alloca te sal es » End -Use r Cu stomer Verification Policy territori es, product lines, or groups of customers

• Excha nge of information with competitors on these su bjects We compete vigorously and fairly • Agreemen ts with customers, business pa rtne rs • Do not use a substantial market position to establish restrictive practic es that diminish or suppliers that establi sh the resale price of a co mpetition without valid business justification or consumer benefits produc t or se rvice. limit a customer's right to se ll a produc t, or make the sa le of a product • Do not agree with competitors or partners to any type of bid rigging or improper collusion; or se rvice co nditional on the purchase of other this includes. but is not limited to, setting prices, limiting production , or dividing up customers , produ cts or se rvices suppliers, or markets

• Pricing tha t is below cos t, especially when we »Antitrust/Competition Law Legal Resources Website have a substantial share of the marke t • Unfair discri mination between similarly si tuated We obtain business intelligence appropriately customers or chan nel pa rtners • Respect people's obligations to protect the confidential information of thei r cu rren t and former employers; never induce anyone to violate any obligation of co nfidentiality We obtain business intelligence appropriately ·Do not request, accept , use, or share confidential competitor information • Use of anyone else's confidential information without appropriate approvals · En sure that third parties ac ting on our beh alf live up to our stand ard s • Req ues ts fo r or gaining of compe titor pricing • Do not dis close customer, busin ess partner, or supplier non public pricing informatio n information from customers, busin ess partners, or suppliers · Accept information in confidence only when HP management agrees that we nee d it. and only under a written agreement that defines and limits our obligations in dealing with it • Pressure on or encouragemen t of an HP em ployee to discuss a prev ious employer's » Confidential Information Policy confidential in formation

• Suggestions from third par ties for new product s, product fea tures, or se rvices when the source of the origina l idea is not ful ly known • Ac quisition of information th rough any behavior tha t you would no t be willing to fu lly disclose

• Reliance, without verification, on third parties' cla ims tha t business intelli gence was properly obtained

15 Standards of business conduct Responsible citizenship

~ Key points & practices We are an economic, intellectual, and social asset in every • Take community interests into account whe n making decis io ns country and community where we do business • IV1a ke decisions with a long-term view We are stewards of the environment • Remember that people outside HP judge us · Reduce use of ene rgy, wate r, an d other re sources whe re fea sibl e solely on ou r ac tions because they do not know ou r decision-making processes · De sign and manufacture our products to in crease efficiency, reuse, and recycling · Support waste reduction and recycl ing effor ts at HP and in our com mun ities Que stion and answer Q: I've seen activities at HP tha t may be crea ting » HP Sustainability Po licy an envir onmenta l hazard , but I don't wan t to get » HP Standard 011 : General Specincation for the Environment involved. Isn't thi s the safes t cou rse? " Environm ental Hea lth and Safety Policy A: No. Al l HP emp loyees are respo nsible for tak ing act ion when aware of potential violation s We engage with responsible business partners and suppliers of the SBC. This responsibility in clud es reporting environmental hazards or other un safe wo rk ing ·Business partners and suppliers mu st meet our qua lity, delivery, service , and pricing co nd itions of wh ich you are aware. Retaliation standards and be respon sible co rporate cit iz ens agai nst anyone mak in g a good faith re por t will not · Communicate our standards for high bu siness partn er and supplier performance in ethics, be to lerated. human rights, managemen t, hea lth, safety, and th e environ men t

When co ncerns or questions come up, · Report any conce rn s of a bu sin ess pa rtner or supplier violating our standards co mmunication at the local level, ei th er · Shift HP business away from busin ess partners and suppliers who fail to address violations peer-to-peer or with you r manager, is of ten the of our stan dard s best place to sta rt. When it is not possible to raise or reso lve an is sue wi th you r immediate manager, use · Docum ent all business partner and supplier rel at ionsh ips in appropriate wri tten contracts the Open Ooor Policy to contac t another member of management, or contact HP Human Resources, your »Global Procuremen t Policy local SBC team , your business group or region SBC "HP Sustainability Policy liaison, or the HP Eth ics and Compliance Office. >> Partner Code of Cond uct Red flags : >> Supplier Code of Conduct We are responsible citizens >> Contingen t Worker Code of Conduct • Use of materials that endanger the environmen t • Careless trea tment of a su pplier's co nfidential informatio n such that it is access ible to ot he rs • Crea tion of undo cumented agreements with customers. bu siness pa rtne rs, or suppliers • Discussion with a reporter of HP bu sin ess witho ut involving Co rp orate Communicatio ns • Support of a political ca ndidate or charity through unapproved use of HP resou rces • Use of business partners or agents who ha ve a reputation for une thi ca l conduct/behavior

16 Sta ndards of bu siness co nduct

We communicate honestly with investors and the media ·All communications with investors, analysts, and the media regarding HP bu siness must first be approve d by HP Investor Relations, Corporate Communications, or the appropriate HP communications specialists ·Never give the impression that you are speaking on behalf of HP in any personal communication or social media, including user forum s, blogs, chat rooms, and bulletin boards >>Confidential Information Pol icy >>Soc ial Media and Blogging Governance Policy

We exercise our rights in the political process ·Ensure that yo ur individual po litica l views and activities are not viewed as those of HP ·Obtain advance approval from HP Corporate Affairs before lobbying a government official or engaging a lobbyist · Remember that HP Corporate Affairs is solely responsible for managing political contributions on behalf of HP, including donations of products, services , transportation, and facilities >> Political Participation Policy

We support giving and volunteering in our communities • Get involved with efforts of your choice to improve your community • Do not pressure others to contribute to or join your preferred charities, groups, or political activities · Do not participate in HP decisions regarding a charity or other organization where you volunteer · Do not use HP resources for the benefit of your preferred charities. groups, or political activities, unless approve d officially by HP >>G loba l Contributions Policy >>Employee Volunteerism Polic y >>Con flicts of Interest Policy

17 Standards of busin ess conduc t Winning the right way, every day

We are all occasionally faced with situations where the right decision is not necessarily a clear one. Our SBC. together with its erniJeddecl tools, links, ancl avenues fo1 raising questiorls, is provided to help you make the nght choice.

It is up to you to thoose the right attion to make winning the right way a reality. HP depends on eath of us to: · Understand the SBC and underlying rules and po licies, and co mply with their provisio ns ·Inte rn al ize the HP Way Now values, co re principles and lea der attribu tes that drive our eve ryday behaviors · Use the Head line Test to guide decision making when challenged with ethical issues · Become famili ar with the key po ints and practices in order to model ethical behavior

· Recog ni ze red fl ag beha viors or actions · Know where to go and whom to contact if a question or co ncern arises

For HP to enhance its reputation as a company with a culture of integrity and ethical leadership, we must all work together, in line with our values, to win the right way, every day. We need to inspire the tru st of customers, business pa rtners, suppliers, and our col leagues. At all levels, we should fulfill ou r co mmitments to others as outlined in the SBC.

18 Sta nda rds of bu si ness conduct

Contacting the Eth ics and Compliance Office If you ha ve a qu es ti on or wish to di scu ss a po ss ible concern or violation of the SB C, yo u should first use the Op en Door Poli cy to di sc uss it with tho se in your management chai n. If yo u are un co mfortable with that appro ac h fo r any reason, or if no ac tion is ta ke n after your discussion, you may co nt ac t HP Hum an Reso urces, yo ur loc al SBC team, yo ur bu sin ess group or reg ion SBC li aison, or the HP Et hics an d Complian ce Offi ce : · By email: corporate.co mpliance@ hp .com · By ph one: Call th e Guid eline from any where in the world , 24 hours a day. Translators are ava ilable and ca llers ca n remain anon ymou s except where anonymous reporting is prohi bited by loc al law. From th e U.S. and Canada : 800-424 -296S Out sid e th e U.S. and Canada: 1. Go to AT&T Access Codes 2. Find you r co untry in the alphabeti cal listi ng 3. Di al th e AT&T Di rec t® Code 4. When pr ompte d, dialS00-424 -2965 • By mail: HP Inc . Ethi cs and Compliance Office Mailstop 1560 1501 Page Mill Roa d Palo Alto, CA 94304- 111 2 United States

19 Standards of business con du ct

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© Co pyright 20 14 He wlett-Packard Deve lopment Company, L.P. The information contained herein is subject to change w ithout notice. Th e only wa rr anties for HP products and services are set forth in the express warranty statements accompanying such products and services. Nothing herein should be co nstrued as constituting an additional warranty. HP shall not be liable for technical or editorial errors or omissions contained herein.

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March 2014, rev. Nov. 2015