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.