Code of Ethics COGNIZANT CODE OF ETHICS | 2 Table of Contents

A Message from Brian 3 Principle 4: We Live Up to Our Responsibilities 15 The Right Way at Cognizant 4 Respect Privacy, Confidentiality How to Follow Our Code of Ethics 5 and Keep Our Data Secure 15 Principle 1: Safeguard Company and Client Assets 15 We Earn Trust 6 Communicate Professionally and Accurately 16 Prevent Corrupt Activities 6 Never Engage In Insider Trading 16 Avoid and Manage Conflicts of Interest 8 Practice Good Financial Stewardship 16 Participation In Political and Lobbying Activities 8 Manage Records Responsibly 17

Principle 2: Additional Considerations 18 We Do the Right Thing, the Right Way 11 Good Judgment 18 Compete Fairly and Honestly 11 Government Investigations 18 Comply with Competition Laws 11 Waivers of this Code 18 Conduct Ethical Sales, Marketing & Delivery 11 Getting Help or Reporting a Concern 19 Respect International Trade 12 Prohibit Money Laundering 12 Accessing the Cognizant Ethics & Compliance Helpline 20 Principle 3: We Respect People and the Environment 13

Respect Human Rights 13 Commit to Environmental Responsibility 13 Protect the Health and Safety of Ourselves and Others 13 Treat People Fairly and Prohibit Discrimination and Harassment 14 COGNIZANT CODE OF ETHICS | 3

A Message from Brian

Team,

Each day provides opportunities to show that we are truthful, ethical, and principled. Every time we interact with clients, prospects, partners, and one another, we are making a statement about our company’s character. Simply put, Cognizant’s global reputation is in our hands. Staying true to our values of integrity, ethical behavior, and lawfulness is critically important.

As ingrained and powerful as our culture of integrity is, our reputation can be damaged with just one small lapse. So we must stay ever vigilant to maintaining our culture of ethics and compliance. Our Code of Ethics is designed to help us do so.

This Code, together with our company’s vision, purpose, and values, serves as our guide to conducting business the right way. We follow all applicable laws in the countries in which we do business. We never cut corners or bend the rules. We treat one another with respect. We always report suspected misconduct with the knowledge that our company will protect us from retaliation for doing so in good faith. In short, we fuse high performance with high integrity.

Living by a clear set of values, ethics, and standards is what earns and sustains the trust of clients, which in turn creates a competitive advantage, contributes to our growth, and strengthens our brand.

Let’s all work together to ensure that acting with integrity remains core to our culture. Cognizant’s Ethics & Compliance Be.Cognizant page

Cognizant’s Global Brian Humphries Corporate Policies Chief Executive Officer COGNIZANT CODE OF ETHICS | 4

The Right Way The Four Principles: How we do our work defines us. at Cognizant 1. We earn trust. We continually strive to be a We engineer modern businesses to improve everyday life. trusted business partner and This is our purpose, and how we do it matters more now corporate citizen. In pursuing this goal, we must consistently than ever. incorporate ethical standards into our day-to-day business activities At the heart of our purpose is a desire to improve 2. We do the right thing, not just our clients’ businesses, but how we Everyone is responsible operate as a leader in our industry. One way the right way. for maintaining a culture of we distinguish ourselves in the market is by Our clients, shareholders, and maintaining the highest standards of integrity. integrity at Cognizant. communities depend on our Our reputation and our success depend on commitment to perform with the it— but it’s more than that. Whether at work, in highest level of integrity. a development center, on-site with our clients, in our corporate office, or in our everyday lives, 3. We respect people integrity is core to who we are. and the environment. We created our Code of Ethics (“Code”) to help Our Code applies to all Cognizant We are committed to a safe and you ensure that everything you do at Cognizant directors, officers, and employees healthy work environment. is in accordance with our standards of integrity. The principles of this Code, and the related worldwide as well as all Cognizant Ethics and Compliance Program are approved business units, subsidiaries, 4. We live up to our by and have the full support of Cognizant’s and joint ventures over which responsibilities. Board of Directors. The Board of Directors and Cognizant has operational control Our commitment to doing business management is responsible for overseeing the ethically includes respecting Ethics and Compliance Program and compliance (collectively “associates”). privacy, protecting information, with this Code. and safeguarding assets. COGNIZANT CODE OF ETHICS | 5 How to Follow Our Code of Ethics

What Associates Must Do What Managers Must Do As an employee at Cognizant, All associates are responsible for upholding our Managers are accountable for fostering an you are expected to: culture of integrity. It is not only the right thing to atmosphere of compliance in which associates do, but also an integral part of our commitment clearly understand their obligations and feel at • Uphold our culture of integrity to excellence and our dedication to being a ease to raise a concern without fear of retaliation. in all you do. responsible corporate citizen. EDUCATE • Understand and follow our LEARN • Remind associates that business results are Code, policies, and procedures. • Be familiar with, understand, and uphold never more important than ethical conduct our Code. and compliance with our Code. • Follow applicable laws, rules, and • Know the details of any part of our Code, • Ensure that associates know that they can regulations in every country in policies, and procedures that are relevant to always report suspected violations of the which we operate. your specific daily responsibilities. law, or of our Code, policies or procedures, BE AWARE without fear of retaliation. • Report all suspected violations LEAD of our Code without fear of • Look for and address developments in retaliation. your business or functional area that might • Foster a spirit of ethics, integrity, and impact Cognizant’s compliance with laws and lawfulness by personally leading compliance regulations, or our reputation. efforts. BE VIGILANT • Communicate the importance of compliance • Report any suspected violations of our Code, at every appropriate opportunity. policies, and procedures or law. • Never retaliate or tolerate retaliation against • Cooperate fully in Cognizant investigations any individual for making a good-faith report. related to our Code, policies, and procedures. COMMUNICATE COMMIT • Immediately inform our Chief Ethics & • Complete Cognizant’s required compliance Compliance Officer upon receiving a report training courses on a timely basis. of suspected violation of our Code, policies, procedures or law. • Execute an annual certification acknowledging your commitment to the principles in our Code. Principle 1: We Earn Trust COGNIZANT CODE OF ETHICS | 6 We Earn Trust At Cognizant, we continually strive to be a trusted business IMPORTANT DEFINITIONS partner and corporate citizen. In pursuing this goal, we A bribe is any payment or “Anything of Value” offered or provided to improperly influence a must consistently incorporate ethical standards into our decision-maker or to obtain an unfair business day-to-day business activities. advantage. Anything of Value includes items such as cash, Prevent Corrupt Activities bonuses, gifts, favors, charitable donations, political contributions, offers of employment, We do not give or receive bribes. Never hospitality/entertainment, kickbacks, or any authorize, offer, promise, or provide “anything other type of preferential benefit. of value” – including a bribe – to get business or secure any advantage in connection with A facilitation payment is generally a Cognizant’s business. Do not request or accept small, unofficial payment made to a low- any bribes, kickbacks or other improper benefits. level Government Official for the purpose of expediting the performance of a routine, Do not We do not make facilitation payments. nondiscretionary government action. make facilitation payments to expedite routine government administrative actions, unless A Government Official is any individual acting approved in writing by the General Counsel. in an official capacity for or on behalf of a We keep accurate business records. Submit Government Entity, including an employee or accurate and complete timesheets, travel and official of any Government Entity. expense reports, financial statements, customer A Government Entity refers to any: billing, and other records. Never misconstrue or mislabel a transaction in our books and records • Government or government division; or circumvent stated polices or controls. The • Department, agency, or instrumentality of company’s books and records must correctly such a government or organization; reflect the true nature of all business transactions, no matter how small. • Political party; or We do not use third parties to “work around” • Company or entity owned or controlled our policies. Do not retain a third party to make an (partially or wholly) by or acting on behalf improper payment on our behalf or to do anything of any of the above. that we cannot do under our company policies. Principle 1: We Earn Trust COGNIZANT CODE OF ETHICS | 7

Q&A Expecting Too Much? Manager Approval Allowed? I am considering a new vendor for an A client has asked if Cognizant initiative our team is launching later would like to be a sponsor for this year. As part of the evaluation their annual golf tournament at process, I asked the vendor if they the silver level for USD $4K. The would agree to comply with the sponsorship includes our logo in detailed anti-corruption provisions the event ad/program, company in our agreement, which include signage throughout the event, two compliance with anti-corruption foursomes, and promotional item laws, completing anti-corruption giveaways. If we have the funding A Simple Thank You? training, and conducting anti- available, can the decision to corruption diligence on sub-vendors participate be made by my manager? I am planning to give a gift to my that may interact with government No. In addition to your manager’s client to thank them for their loyalty officials on Cognizant’s behalf. The approval, other reviews are to Cognizant. I know he has children vendor was noncommittal. Am I required depending on the nature so I am planning to purchase an expecting too much? of the activity. If the golf tournament Xbox for each child. They are so If Legal or Ethics & Compliance deem your is a charitable event in which the proceeds popular right now! Since this client vendor to be high risk for one reason or are given to a charitable organization, you is a platinum account, this seems another, then you are obligated to need to follow the process outlined in the appropriate, right? ensure that appropriate controls Procedure for Charitable Contributions No, that would not be appropriate. are in place to manage that risk. & Sponsorships. If the golf tournament is Cognizant has specific principles that In this instance, if the vendor has been not a charitable event, you must follow the govern the provision of gifts, entertainment, deemed high risk for anti-corruption Global Events Requisition Policy. For more and hospitality. This proposed gift would purposes, then the requirements set information on the requirements and review be inconsistent with those principles. forth by Legal or Ethics & Compliance – process, see the Global Events page. including contractual provisions with related Always review and follow our Procedure Also, if the sponsorship is approved to move consequence management, including for Gifts & Entertainment before giving or forward, be mindful of the requirements of termination rights – must be complied with. receiving a gift. Providing expensive gifts the Procedure for Gifts & Entertainment

or entertainment to clients or their relatives You are not expecting too much if others outside of Cognizant are invited and you should not move forward with the could create the appearance of improper to play golf (as part of the two foursomes) vendor unless they agree to comply. influence, even if it is legally permitted. or receive anything else of value that only a paying attendee would receive. Principle 1: We Earn Trust COGNIZANT CODE OF ETHICS | 8

Avoid and Manage Cognizant requires that associates disclose any We give and receive gifts and business situation that would reasonably be expected to hospitality only as appropriate and under Conflicts of Interest give rise to a conflict of interest. If you suspect certain circumstances. It is the obligation of We conduct business only in Cognizant’s best that you have a situation that could give rise to a all associates to ensure that any gift or business interests. Putting our personal interests over conflict of interest, or something that others could hospitality is only offered or accepted in strict the interests of Cognizant creates a conflict of reasonably perceive as a conflict of interest, you accordance with applicable company policies. interest and is not allowed. We never conduct must report it to your manager or Cognizant’s As a general rule, giving or receiving gifts or business based on our personal relationships or Chief Ethics & Compliance Officer as set forth in entertainment that improperly influence business any personal or financial stake we may have in the our Conflicts of Interest Policy. decisions, or create the appearance of doing so, is prohibited. While the provision of reasonable outcome of a decision. Similarly, we never use our If you are an executive officer or Board Member, (non-lavish) gifts and entertainment in support connection to Cognizant for personal gain of any you must report any such situation in writing of relationship building with a client given in an kind. Potential conflicts could arise through: to Cognizant’s General Counsel who will then open and transparent fashion can be permissible, discuss with the Chair of the Committee of care must be taken to comply with applicable law • Outside Employment & the Board of Directors, as needed. Cognizant’s and avoid any appearance of impropriety. The Board Memberships Chief Ethics & Compliance Officer or the General Company’s Procedure on Gifts and Entertainment • Financial Investments Counsel, as applicable, will work with you to provides guidance on acceptable gifts and and Arrangements determine whether you have a conflict of interest entertainment and also sets forth specific approval and, if so, how best to address it. All transactions • Close Personal Relationships requirements for certain gifts and entertainment. that could potentially give rise to a conflict of • Government Roles interest involving an executive officer or Board Participation In Political and • Corporate Opportunities Member must then be referred to and approved by the Audit Committee. Lobbying Activities • Gifts & Entertainment Associates may participate in the political process when it is clear that such activity is conducted on an individual basis — not on PLEASE NOTE behalf of our company or during working hours. A conflict of interest is not automatically a Disclosing and seeking approval for any activity Use of company facilities or resources for political violation of Cognizant’s Code. However, a that may give rise to a potential conflict allows activity may be permissible, but only with advance failure to promptly disclose a conflict is always a the company to document its approval and any approval by our Government Affairs Department. violation. In fact, many conflicts can be cleared agreed upon controls to mitigate the impact of Similarly, we do not make political contributions to or easily resolved once reported. that conflict on the company. candidates or lobby the government on behalf of Cognizant unless it is explicitly approved in writing by Cognizant’s Government Affairs Department. Principle 1: We Earn Trust COGNIZANT CODE OF ETHICS | 9

Q&A Asking For A Friend Work On The Side I am part of a team selecting a new I am considering working part-time vendor and my brother-in-law works for a start-up company that does for one of the companies we are not compete with or have offerings considering. Looking at the facts similar to Cognizant. Since the work and data, his company does great I would be doing for them is different work and I think it is the right choice. from my job at Cognizant, it should Is it okay for me to recommend his not be a problem, right? company since I think that is what is best for Cognizant? Disclose, disclose, disclose! With limited exceptions, all outside roles You can recommend the company, but and interests must be disclosed on the you need to inform your manager Cognizant Ethics & Compliance Portal. about your relationship and excuse Refer to Cognizant’s Conflicts of Interest yourself from the decision-making Policy for more information about conflict process. This is the best way to ensure of interest principles. If you have questions, there is no appearance of something unfair ask the Ethics & Compliance Helpline – or improper. click Ask A Question. Principle 1: We Earn Trust COGNIZANT CODE OF ETHICS | 10

KEY TAKEAWAYS

• Prevent corrupt activity.

• Always report any sign of corruption or unethical behavior, even if you’re not absolutely sure.

• Putting our personal interests before Cognizant’s creates a conflict of interest and is not allowed.

• You have a duty to report any possible conflicts of interest right away.

• Associate involvement in the political process should be done only in a personal capacity and not on behalf of the company.

LEARN MORE

• Anti-Corruption Policy • Procedure for the Selection & Retention of Third Parties • Conflicts of Interest Policy • United States Political Activities and Gifts to • Procedure for Gifts & Entertainment Government Officials Compliance Policy

• Procedure for Charitable Contributions • Doing Business with the U.S. Public & Sponsorships Sector Policy Principle 2: We Do the Right Thing, the Right Way COGNIZANT CODE OF ETHICS | 11

We Do the Right Thing, A Competitive Edge I have access to a client’s intranet as part of my job. I know we are trying the Right Way to win more business with the client and I found some information on their Our clients, shareholders, and communities depend on our intranet that I think could be helpful commitment to perform with the highest level of integrity. to the bid team. It is not marked confidential and I have access to it, so it is okay to share it, right? Compete Fairly Comply with and Honestly Competition Laws No, it is not okay to share. It is also not okay to view this information unless doing so We respect our competitors’ confidential We comply with antitrust and competition laws is part of your role. We cannot use our access information. To compete fairly in the of every country where we do business. Never to client systems to search for competitive marketplace, we must show the same respect engage in agreements, understandings, or plans information or other such information that for the confidential information of our with competitors that limit or restrict competition, may be viewable without proper authorization. competitors that we show for our own. Always including price-fixing and allocation of markets. When our clients give us access to their gather competitive information in a lawful and Do not discuss the prices we charge for services or ethical manner, never through deception or our business strategies with competitors. systems and internal information, we need misrepresentation. For example, we do not to respect that trust and always act ethically use our access to customer systems to search Conduct Ethical Sales, with integrity. Even if the information available for competitor presentations or other such Marketing & Delivery is not restricted, otherwise protected, or information that may be viewable without proper marked confidential, we have to consider the authorization. Similarly, we may not retain or use a We use ethical sales and marketing techniques. commercial sensitivity of the information and third party to do what we ourselves cannot. Never seek an unfair advantage over potential not use it for our benefit without approval. We or current clients, vendors or competitors by should never compromise our integrity, our abusing confidential information, manipulating, reputation, or our standards. No shortcuts, no concealing or misrepresenting facts, or any other cutting corners, no unethical or questionable unfair-dealing practice. Our communications practices. That is not how we ever want to win about our services, whether oral or in written promotional materials, presentations, or slide business. We only want Cognizant winning decks should always be accurate. business the right way – with integrity and on the strength of our talent and work ethic. Principle 2: We Do the Right Thing, the Right Way COGNIZANT CODE OF ETHICS | 12

Respect International Trade KEY TAKEAWAYS RFP Dilemma

We follow all international trade regulations. • Compete ethically. I am working on an RFP for a customer Wherever you work, you must obey laws and that is looking for Cognizant to provide regulations concerning embargoes, economic • Obey all laws and regulations onsite support for its worldwide sanctions, export controls, import requirements, governing competition and trade. locations, which include some countries and antiboycott regulations. Cognizant prohibits I believe are embargoed. The project doing business with or supporting – directly • Know your client and only do will also require Cognizant to license or indirectly – certain countries and parties. In business with reputable clients and send copies of software to the addition, these laws and regulations apply to a involved in legitimate business customer’s different locations around number of aspects of our business; including activities with funds derived from the world and contains an export lawful sources. technology transfers, accessing software, travel compliance provision that requires across borders with technical data documents, Cognizant to obtain export licenses the sharing of controlled information with foreign from the relevant authorities. Can I nationals during visits to the or proceed with responding to the RFP? even to foreign nationals who may have access to export-controlled software, data, or technology LEARN MORE while working in the United States. Before proceeding, you must involve • Financial Stewardship Policy Cognizant’s Global Trade Controls Prohibit • Procedure for Anti-Money (“GTC”) team and Legal. First, Cognizant Money Laundering Laundering Compliance prohibits doing business with embargoed countries and sanctioned parties. You We do not engage in money laundering. We • Global Trade Compliance Policy think you may have identified some of are committed to conducting business only with those countries in the RFP. GTC will need • Intellectual Property Policy reputable clients involved in legitimate business to determine whether Cognizant can activities, with funds derived from legitimate, provide onsite support in the countries lawful sources. Never participate in acquiring, involved. Second, the RFP appears to using, converting, concealing or possessing the require Cognizant to take on export and proceeds of crime, nor assist any other party in import obligations for sending the software. doing so. Such activity requires GTC assistance to ensure we proceed in compliance with the applicable laws. Principle 3: We Respect People and the Environment COGNIZANT CODE OF ETHICS | 13 We Respect People and the Environment We are committed to a safe and healthy work environment.

Respect Human Rights Protect the Health and

We uphold human rights in all of our global Safety of Ourselves and Others Everyone who works for Cognizant is operations. We maintain a safe working environment. entitled to fair wages and hours, consistent with All business activities should be conducted with local laws, and is entitled to an environment free the necessary permits, approvals, and controls. from discrimination, harassment and retaliation. Report any potential health or safety issues to We do not condone human trafficking in any your manager. We do not make use of child labor or forced form. We do not tolerate violence, threats of violence, labor and we will not work with third parties that intimidation, bullying, abuse, or physical engage in such practices. In the event we were to retaliation in the workplace. If you are a victim learn of human trafficking, we immediately report or witness these activities, report it to a manager such incidents to law enforcement. immediately. Commit to Environmental We do not work under the influence of drugs Responsibility or alcohol. We forbid the use, sale, purchase or possession of illegal drugs, the abuse of doctor- We are committed to operating in an prescribed drugs, and the abuse of alcohol on PLEASE NOTE environmentally responsible manner. We our property or while on company business. If you witness or are the victim of an act utilize sustainable practices to help reduce our Tell a manager if an associate’s performance environmental footprint and ensure our impact seems impaired, or if someone is using a banned of violence, intimidation, the threat of on the world is a positive one. Always follow the substance at work. violence, abuse, physical retaliation, or other environmental laws, regulations, and standards threatening behavior, you should report the that apply in your location. matter immediately to a manager. Principle 3: We Respect People and the Environment COGNIZANT CODE OF ETHICS | 14

Hostile Work Environment

My boss is verbally demeaning to me and several other women on the team about our appearance and intellect, and offers us very few opportunities. While, on the other hand, she always praises and rewards other male members of the team. I want to speak up, but I’m afraid that if I do, my boss will find out. Should I just keep quiet? Treat People Fairly and remarks about a person’s legally protected characteristics as applicable in a specific country, Absolutely not! This type of Prohibit Discrimination or those of a sexual nature. At no time should we behavior is inappropriate and could and Harassment allow, encourage or create an offensive, violent, be considered harassment. Under discriminatory, abusive, or hostile environment, no circumstances is it appropriate for any We make employment decisions based on whether in a location where we conduct our Cognizant associate to make comments merit. We treat others with fairness and respect, business (such as a Cognizant office or a client that are derogatory, abusive, or sexual and value each other’s individual contributions. site) or at other locations where we congregate in nature. We have a strict prohibition We never discriminate against a person’s legally for a work-related activity or event (such as a on retaliation for reporting suspected protected characteristics, such as race, color, restaurant, hotel or conference center). religion, gender identity, age, national origin, or actual ethical violations, including sexual orientation, marital status, disability status, workplace harassment and Cognizant will or veteran status when we make employment LEARN MORE protect you if any manager were to act decisions including recruiting, hiring, training, against you because you raised a concern. • Statement on Modern Slavery promotion, termination, or providing other terms and conditions of employment. We also comply • Human Rights Policy with all applicable equal employment opportunity laws, including those related to discrimination • Environmental, Health and Safety Policy and harassment. • Sustainability and Social Responsibility site We do not tolerate discriminatory conduct, abuse of authority, or harassment of any • See the Human Resources Policies site for kind, including that of a sexual nature. We country specific policies and information. also refrain from making jokes, slurs, or other Principle 4: We Live Up to Our Responsibilities COGNIZANT CODE OF ETHICS | 15

We Live Up to London Calling I just received an email from someone claiming to be Kristina Our Responsibilities from our London office, but her email address is from the @gmail. Our commitment to doing business ethically includes com domain. Kristina requested respecting privacy, protecting information, and that I share personal information such as date of birth for some of our safeguarding assets. associates. We work in a really big company so I don’t know everyone Respect Privacy, We safeguard company and client assets from but since the request is coming from misuse, abuse, unauthorized disclosure and another associate, should I respond? Confidentiality and Keep theft. We safeguard company and client assets – including physical property, intellectual property, Our Data Secure You should verify the individual’s and confidential information (e.g. strategic We respect and protect the confidential and and business plans; financial, sales, or pricing identity, purpose of the request personal information we hold on behalf of our information; customer lists and data; vendor terms and their “need to know”. We should clients, our associates, and third parties. We with suppliers; and promotional plans) – from not be providing personal information collect and handle confidential and personal misuse, abuse, and theft. Misuse includes sharing to anyone (inside or outside Cognizant) information in accordance with applicable laws confidential information with associates who do unless you can verify their identity, and take measures to maintain it securely in not need to know it for their job responsibilities authorization to access the information and accordance with our corporate policies. and disclosing confidential information outside the that it be sent only to a Cognizant email Safeguard Company company without authorization. account. If you need help responding or We respect the intellectual property rights of making those verifications, reach out to and Client Assets others and do not misuse their confidential your manager. If you become aware of We use company and client technology information. We obtain appropriate approvals or suspect a loss or misuse of personal properly. When using client systems and before accessing or using third-party software, information, report it immediately! It is technology, know and follow all contractual data, information, graphics or systems. Our very important to notify CSIRT of any data obligations. Be familiar with Cognizant’s associates do not use confidential information incident as soon as you become aware it. Acceptable Use Policy. from their prior employers or our competitors. Principle 4: We Live Up to Our Responsibilities COGNIZANT CODE OF ETHICS | 16

Communicate Professionally Practice Good and Accurately Financial Stewardship In The News

We communicate professionally and We are good stewards of the company’s I was contacted by a reporter who appropriately. Never threaten, libel or defame resources — time, money, people, and property is asking about some rumors I’ve any person or company. Be thoughtful in your — and make decisions that best serve the been hearing in the office. Everyone communications, including on social media. interest of the company. Always use company is talking about it so I can help them resources wisely, and ensure expenditures out and share what I know, right? We do not communicate to the press or via comply with all relevant Cognizant policies and social media on behalf of the company unless procedures. authorized. Unless you are authorized in writing Only authorized spokespeople by the Head of Investor Relations or the Head of We accurately record and support all can communicate with the media External Communications, do not communicate transactions in our books, records, accounts, on behalf of the company. If you are with any member of the media or investment and financial statements. Associates must approached by any media representative community on behalf of Cognizant, clients, ensure that we maintain complete, accurate (e.g. reporter, blogger, editor), direct those competitors or our industry. and timely books and records and that our queries to the Corporate Communications accounts accurately reflect transactions. This team. Never disclose company information, Never Engage In is a prerequisite to preparing accurate financial including emails, and always be mindful of Insider Trading statements for external stakeholders. Cognizant also has zero tolerance for submitting false or the potential to accidentally share internal We are responsible for not engaging in and inaccurate claims to its clients or third parties confidential information that you have been helping prevent insider trading. Through our with whom it interacts, including any government exposed to. Consider this, you could be in work at Cognizant, we may from time to time entities. Always ensure you record and categorize a WhatsApp group right now that includes learn of material nonpublic information about all costs — including timesheets, travel & expense third parties such as press or competitors. Cognizant or another company (such as a current reports and other billable expenses — to the If you were to discuss imminent personnel or potential customer, partner or M&A target). appropriate accounts and clients and carefully changes that have yet to be announced, you We have an obligation to ensure that we and our review all documentation to ensure its accuracy. would have just shared internal, confidential affiliated persons, such as family members, do We protect sensitive financial data from information. Be mindful of the information not trade on such material nonpublic information disclosure to third parties. Only share sensitive you have access to and be careful not to or provide (“tip”) or allow access to such financial data with those who need to know. Prior share confidential information externally. information to others who might trade. Cognizant to transmitting Cognizant sensitive financial data Thank you for doing your part in keeping all associates must fully understand and comply with to a third party, take all necessary precautions to Cognizant’s Insider Trading Policy and related confidential information inside the company! ensure that information is kept confidential and policies and procedures. secured. Principle 4: We Live Up to Our Responsibilities COGNIZANT CODE OF ETHICS | 17

Manage Records Responsibly

We retain and dispose of business records lawfully and responsibly. Always follow the Record Retention Policy and associated record retention schedules that apply to our locations and projects and never destroy records unless doing so is compliant with any applicable record retention schedule requirements and/or any legal hold notices.

KEY TAKEAWAYS

• Be sure to protect our company and client information and assets. • Communicate professionally and appropriately. • Do you suspect misuse of Cognizant or client assets? Report it to [email protected].

LEARN MORE

• Global Privacy Policy • External Communications & Social Media Policy • Associate Privacy Notice • Insider Trading Policy • Intellectual Property Policy • Financial Stewardship Policy • Acceptable Use Policy

• Record Retention Policy COGNIZANT CODE OF ETHICS | 18 Additional Considerations

Good Judgment Waivers of this Code requests and dispositions to the company’s Audit Committee. Our Code does not take the place of the good While the policies contained in this Code must Any executive officer or Board Member who judgment that all Cognizant associates must be strictly adhered to, an exception could seeks an exception to any of the Code provisions exercise every day. If you ever feel that you or be appropriate under special and limited should contact the company’s General Counsel. another associate is dealing with an ethical issue, circumstances. If you believe an exception is Any waiver of the Code for executive officers or consider the following before you decide how to appropriate, you should contact your immediate Board Members or any change to this Code that proceed: manager, and if he/ she agrees, you must obtain applies to them may be made only by the Board of approval from our Chief Ethics & Compliance • Could it be against the law? Directors of the company, and may be disclosed as Officer. required by law or stock market regulation. • Could it cause harm to Cognizant’s brand, Our Chief Ethics & Compliance Officer maintains reputation, financial performance or a record of all requests for exceptions and the business relationships? disposition of such requests, and reports such • How would the decision look to other Cognizant associates or to someone outside of Cognizant?

• Am I willing to be held accountable for this decision?

• Is this in line with Cognizant’s Code? Government Investigations Nothing in our Code should be misunderstood to prevent you from reporting a violation of law to a government agency, or from cooperating in a government investigation. If you have any questions about government investigations, please direct them to the Legal Department. COGNIZANT CODE OF ETHICS | 19 Getting Help or Reporting a Concern

Cognizant associates have a responsibility Retaliation for Reporting to report suspected violations of this Code. is Prohibited To report a real or suspected Cognizant is committed to ensuring that an violation of our Code, the individual does not face retaliation for reporting Cognizant is committed to ensuring that an such concerns. following individuals and individual does not face retaliation for reporting resources are available: ethics and compliance concerns in good faith. Prohibited acts of retaliation include discharge, • Any member of the Cognizant PLEASE NOTE demotion, suspension, harassment, threats, or any other action that discriminates against an Legal Department • If you suspect a violation of our individual who submits a report of suspected • Our Chief Ethics & Compliance Officer Code, report it. non-compliance. Those engaging in acts of email: chiefcomplianceofficer@ retaliation are subject to disciplinary action, up to cognizant.com • There will be no retaliation for and including termination, as permitted by local making a report, even if no violation laws. If you know or suspect that you or someone mail: Cognizant Technology Solutions is found. you know has been retaliated against, you should Attn: Chief Ethics & contact our Chief Ethics & Compliance Officer or Compliance Officer • Associates must fully cooperate the Ethics & Compliance Helpline immediately. Glenpointe Centre West with investigations of ethics or 300 Frank W. Burr Boulevard For more information about our prohibition compliance issues. Suite 36, 6th Floor on retaliation for reporting, please see our Whistleblower and Non-Retaliation Policy. Teaneck, 07666 USA • Our Cognizant Ethics & Compliance Helpline (See page 20 of this document.) To access the Ethics & Compliance Helpline via the internet, Accessing the please go to www.cognizant.com/compliance-helpline Cognizant Ethics & and follow the instructions for submitting a report. To make a report by telephone, please dial the number Compliance Helpline specific to your country and follow the prompts:

United Kingdom Netherlands 0800-89-0011 0800-022-9111 followed by followed by 866-824-4897 866-824-4897 United States & Canada 1-866-824-4897 Germany 0-800-225-5288 Philippines followed by 105-11 866-824-4897 India followed by 866-824-4897 000 117 followed by 866-824-4897 800-011-1111 followed by 866-824-4897 Brazil landline: mobile: 0-800-890-0288 0-800-888-8288 All other locations: followed by followed by Country access code + 866 824 4897 866-824-4897 866-824-4897 Additional AT&T Direct Access Codes are available at https://www.business.att.com/collateral/access.html

The Cognizant Ethics & Compliance Helpline is serviced by a third-party provider that is available by phone or online 24 hours a day, 7 days a week. Reports of suspected violations or concerns may be made anonymously, where local laws allow. However, you are encouraged to identify yourself when making a report, so that additional information can be obtained if needed. Whenever possible and permitted by law, your identity will be kept strictly confidential. The Ethics & Compliance Helpline also features a Question © 2021 Cognizant. All rights reserved. Manager, where an associate may seek advice.