PATHWAY TO SUCCESS CODE OF ETHICS AND BUSINESS CONDUCT UNISYS CODE OF ETHICS AND BUSINESS CONDUCT - PATHWAY TO SUCCESS A LETTER FROM OUR LEADERS PETER ALTABEF AND ERIC HUTTO We do not tolerate harassment or discrimination of any Integrity is at the heart of Unisys. kind. It informs everything we do: every Our Code applies to everyone at Unisys, and all of decision, every action and every us must familiarize ourselves with it. Speak up if you are unclear about a decision you need to make or a relationship. Our commitment to concern you have about suspected violations. Our support for a speak-up culture is unwavering. We have integrity is absolute. It cannot be zero tolerance for retribution against those who come forward. We build a creative, safe and committed sacrificed for short-term gains, community that values diversity, equity and inclusion. nor can it bow to pressure from In a way, our Code is an extension of our culture colleagues or business partners. of “let me help.” It helps us make consistently ethical decisions and hold ourselves and each other While we count on every associate to behave with accountable for doing so. integrity, we also understand that in some cases the Nothing is more important than our reputation for correct decision is not immediately apparent. That integrity. Our shared commitment to act ethically and is why we provide this Code of Ethics and Business Peter Altabef Eric Hutto maintain that reputation is our strength and one of our Conduct. It details the key principles that guide our greatest assets. Chairman and Chief Executive Officer President and Chief Operating Officer business activity and enable you to make the right ethical decisions. 2 UNISYS CODE OF ETHICS AND BUSINESS CONDUCT - PATHWAY TO SUCCESS A Letter From Our Leaders 2 Records Management 25 Accurate Financial, Costs and 26 Our Values and Heritage 4 Timekeeping Records How to Use This Code 5 Information Security 27 INTEGRITY IS IN OUR CODE 6 INTEGRITY WITH SOCIETY AND GOVERNMENTS 28 TABLE OF Every Associate’s Responsibility 7 Interactions with the Public Sector and 29 Every Leader’s Responsibility 8 Government Officials Making Ethical Decisions 9 Political Activities 30 CONTENTS Working with Third Parties 10 External Communications and Social Media 31 Charitable Contributions 32 INTEGRITY IN OUR WORKPLACE 11 Insider Trading 33 Diversity, Equity, Inclusion, and a Safe and 12 Respectful Workplace Conflict Minerals and Human Rights 34 Export Controls and Trade Sanctions 35 INTEGRITY IN OUR BUSINESS DEALINGS 14 Anti-money Laundering 36 Compete Fairly 15 Environment 37 Improper Payments and Benefits, Bribery and 16 Corruption COMPLIANCE WITH OUR CODE 38 Offering or Accepting Business Courtesies 17 Conducting our Business with Integrity 39 Navigating Business Courtesies 18 Speaking Up 40 Conflicts of Interest 19 Investigations 41 Oversight 42 INTEGRITY WITH ASSETS AND INFORMATION 20 How to Contact the Compliance & Ethics Office 43 Use of Unisys Property and Resources 21 Confidential Information and Intellectual Property 22 Personal Data 23 Data Privacy Principles 24 3 UNISYS CODE OF ETHICS AND BUSINESS CONDUCT - PATHWAY TO SUCCESS Our Our Our Our Assets and Society and Compliance and Code Workplace Business Dealings Information Governments Speaking Up Download PDF 1816 1873 1878 1886 1888 OUR VALUES AND HERITAGE Unisys has a rich history of game-changing innovation that enhances people’s lives. We were there at the beginning – the creation of the UNIVAC, one of the world’s first 1933 1946 1953 1976 1986 computers. We bring technological innovation to businesses and governments around the world, delivering better outcomes – securely – for our clients, their customers and the communities we all serve. What drives us to excel with such passion and purpose? It is simple: our Core Beliefs. 2001 2006 2017 2020 Next… Curiosity: We embrace the unknown and continuous learning You are part of writing Creativity: We look past routine ways of doing things the next chapter in Client-Centricity: Our clients’ success is our success the Unisys story. What will that be? Integrity: We act ethically and honestly 4 UNISYS CODE OF ETHICS AND BUSINESS CONDUCT - PATHWAY TO SUCCESS KAREN MOORE CHIEF COMPLIANCE AND PRIVACY OFFICER Our Code sets out our fundamental principles across The Compliance & Ethics Office is also at your When I am asked about the a wide range of risk areas, why they are important disposal, whether you contact us directly or via the size of my team, I respond that and what is expected from all of us to manage those Helpline. You will find contact details at the end of risks. Although we follow local laws or regulations this Code, or via the Helpline icon on the tool bar. compliance and ethics is owned when they set a higher standard than our Code, you should consider this document the first step on a by the thousands of associates pathway that begins with asking the right question and finding the right answer to guide your business at Unisys I am proud to call decisions and actions. Leaders, you will find additional expectations associated with your elevated responsibilities in the colleagues – we are all on the In each section, look for the pathways with links to organization. Ethical leadership is a key contributor to more guidance: related polices, frequently asked an ethical culture; we cannot do it without your active Compliance & Ethics team. questions and other resources. involvement. Look for the blue boxes and this symbol for more information: Policy 1 Policy 2 FAQ Resources Karen Moore Chief Compliance and Privacy Officer Speak up – ask questions – get answers – take the right course of action. 5 UNISYS CODE OF ETHICS AND BUSINESS CONDUCT - PATHWAY TO SUCCESS INTEGRITY IS IN OUR CODE WE ARE HONEST IN ALL OUR DEALINGS AND STAND FOR WHAT IS RIGHT. 6 UNISYS CODE OF ETHICS AND BUSINESS CONDUCT - PATHWAY TO SUCCESS Our Our Our Our Assets and Society and Compliance and Code Workplace Business Dealings Information Governments Speaking Up Download PDF EVERY ASSOCIATE’S RESPONSIBILITY Compliance. Ethics. Integrity. These are all just words unless every associate at Unisys owns and accepts accountability for them. As a Unisys associate, you are expected to comply with our Code, with Unisys policies and procedures and with the law. Associates must: • Read, understand and pledge to act in compliance with our Code and the policies, laws and regulations that apply to your job. • Speak up when you observe, learn about or suspect violations of our Code or related policies. • Cooperate in any internal investigations. • Complete all assigned mandatory training on compliance and ethics issues. Policy FAQ Resources 7 UNISYS CODE OF ETHICS AND BUSINESS CONDUCT - PATHWAY TO SUCCESS Our Our Our Our Assets and Society and Compliance and Code Workplace Business Dealings Information Governments Speaking Up Download PDF EVERY LEADER’S RESPONSIBILITY As a Unisys leader, you are held to an even higher standard, and you have a special responsibility to lead with integrity. You must model ethical behavior and take active measures to make certain your team does, too. If you communicate and listen to your team and handle concerns and different opinions with ethical compassion and understanding, you will build trust, promote productivity and protect the company. Leaders are expected to understand the risks associated with their organization’s business activities and actively seek to mitigate them. These risks arise from the global nature of our business and include areas covered in our Code. Your comprehensive understanding will enable you and your team to take actions that minimize those risks and contribute to overall success. Leaders must: • Identify the risks relevant to your work, regularly discuss them with your team and implement mitigation measures. • Clearly communicate and demonstrate that efforts to win business must never be compromised by unethical or illegal actions, even if it means losing a business opportunity. • Complete your compliance training on time, and make sure your team does, too. • Be approachable – make sure your team knows that you will listen and that they can ask questions and raise concerns without fear of retaliation. • Know how to identify and manage suspected misconduct – refer the matter to the Compliance & Ethics Office for investigation, and do not attempt to investigate or resolve the issue yourself. Resources 8 UNISYS CODE OF ETHICS AND BUSINESS CONDUCT - PATHWAY TO SUCCESS Our Our Our Our Assets and Society and Compliance and Code Workplace Business Dealings Information Governments Speaking Up Download PDF MAKING If NO to ANY, it’s ETHICAL DECISIONS If YES to ALL, it’s probably OK to proceed. NOT OK to proceed. Creating a culture of integrity starts with making good decisions. Ask yourself these questions before taking actions that might compromise our Code and our Are my actions consistent with our Code, our policies and the law? NO STOP commitment to conducting our business with integrity: Making ethical decisions and good choices builds a culture of integrity and YES a place we all want to work. When we act with integrity, we build trust with each other, our clients and our business partners. When faced with an ethical dilemma or difficult decision, ask yourself the following questions. When in Would I be comfortable if my actions were public and my NO STOP doubt, seek guidance. leader, co-workers, family and friends knew about them? YES Leaders must also seek guidance from the Compliance & Ethics Office or the Law Department Are my actions in the best interests of Unisys, when confronted with an ethical issue on their team. NO STOP our reputation and advancing our business interests? YES GO FAQ Resources 9 UNISYS CODE OF ETHICS AND BUSINESS CONDUCT - PATHWAY TO SUCCESS Our Our Our Our Assets and Society and Compliance and Code Workplace Business Dealings Information Governments Speaking Up Download PDF WORKING WITH THIRD PARTIES If you regularly supervise, manage or interact with third parties, whether they are consultants, sub-contractors, suppliers, contracted and contingent workforce, or anyone working on our behalf, you should be familiar with our Business Partner Code of Conduct.