Code of Ethics

CODE OF ETHICS

Living our values and purpose: CODE OF ETHICS the ServiceNow Code of Ethics Everything comes down to trust. Trust is the ultimate human currency. Bill McDermott ServiceNow Chief Executive O昀케cer At ServiceNow, we make the world of work, work better for people. Our purpose is core to how we think, act, partner, innovate, and execute each and every day. Living and breathing our purpose requires all of us working together in the same way, towards the same goals, with our customers always at the heart of everything we do. To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS Our Code re昀氀ects our values and purpose So, how do we do it? We show up every day with our purpose leading the way, aligned to our core values, and we always do the right thing by keeping integrity, teamwork, and trust top of mind. This not only applies to ServiceNow’s employees and leaders, but our entire community including contingent workers, executive o昀케cers, and Board of Directors. We recognize that decisions are not always clear-cut. © 2023 ServiceNow, Inc. All Rights Reserved. Confidential. 2 That’s why our Code provides an overview of some of our speci昀椀c policies, as well as the framework to help us navigate areas of uncertainty and apply our Because, to make the world of values to all situations. work, work better for people, Our values and behaviors come together as our Code of Ethics (our “Code”). we must make our world of And, the true function of our Code is to act as our cultural guide-rails and work the best that it can be. provide tools and resources to help you do the right thing, time after time, no matter the circumstances. To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS A letter from our Chief Ethics and Compliance O昀케cer ServiceNow is a value driven organization and is committed to fostering an Everyone in the ServiceNow community - from our ethical culture. This helps uplift our brand, increase stakeholder trust, and employees to our Board of Directors are expected to live attract and retain our customers and the best employees. Whether it is by our purpose and values and act with integrity and honesty. winning the right way, or upholding ServiceNow’s core values every day, we all Therefore, when you suspect or witness an ethical issue play a part in delivering world-class service to our customers in an ethical and or potential violation of our Code of Ethics, it is your duty forthright manner. to speak up. When you report a concern, you help make our company stronger by helping us identify areas of opportunity which bene昀椀t all of us. Integrity isn’t a choice —it’s a core value that You are protected from retaliation for reporting your is represented in every concerns and can report your concern anonymously. To thread of our company’s learn more about the multiple ways you can report ethical identity. concerns and the policies in place to protect you from retaliation, please review the Whistleblower and Complaint (Speak Up) policy. Thank you for all you do to make ServiceNow a world-class company, both in what we do and how we do it. We all win when we win the right way. John Castelly Chief Ethics and Compliance O昀케cer To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

INTEGRITY We live our values everyday We speak up and do not tolerate retaliation We avoid organizational or personal con昀氀icts of interest We do not engage in insider trading or tipping We comply with all applicable laws and regulations We do not make bribes or engage in corrupt activity We compete for business fairly We follow our code and uphold our commitments

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We live our values everyday Integrity isn’t a part-time principle. We always do the right thing — for our We have to win the right Company, our teams, our customers, way and we have to stick to our business partners, our shareholders, our Code of Ethics for our and the communities where we live, customers, our employees work, and play. and our partners. That’s why our core values are deeply embedded in our Code. Russ Elmer ServiceNow General Counsel Our reputation as a Company is a direct result of what each of us does individually. So, we’re all responsible for upholding our reputation by acting with integrity, aligned to our values, and following our Code each and every day. .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We speak up and do not tolerate retaliation Doing the right thing means speaking up whenever something doesn’t seem right. Not all of the details are needed to raise a concern – just a good faith belief that misconduct or violations of our Code may be occurring. All concerns are taken seriously and investigated promptly and thoroughly, as appropriate. THE WORLD We have several ways you can let us know when you see, S hear, or feel something is wrong. Please raise concerns WORKS WITH under the reporting methods you feel comfortable with SERVICENOW below. If you feel more comfortable raising concerns anonymously, you can do so to the extent permitted by © 2023 ServiceNow, Inc. All Rights Reserved. Confidential. 30 applicable law. Q: What if I only suspect a violation but don’t have all the details? To access additional scenarios and A: If you have a good faith belief that there has been a potential violation of our Code, policies or the law by resources, visit our Ethics Employee anyone a昀케liated with ServiceNow, including partners, all employees have a duty to report the matter. Resources Site. .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We speak up and do not tolerate retaliation When faced with a situation that If you If you could be unethical, ask these answered answered questions... YES to NO to all the any of the • Does it align with our values? questions questions • Does it comply with our Code of Ethics? • Is it ethical and right? Is it legal? • Would it withstand public scrutiny? The situation The situation • Is it in our best interest? is likely is likely ethical unethical Need guidance in determining Need to report a concern? whether a situation is unethical? .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We Speak Up and Do Not Tolerate Retaliation No tolerance for retaliation: ServiceNow does not tolerate retaliation against anyone who How can you speak up? (i) raises a concern in good faith or escalates a report or Red Flag, • Contact your manager, Global People, or Legal, Ethics & Compliance (ii) participates in an internal investigation, or • Email [email protected] (iii) refuses to engage in conduct that violates applicable laws or Company policies. • Submit a concern online at www.servicenow. ethicspoint.com Retaliation against someone for engaging in these activities will result in • Call the Speak Up Line at (855) 869-7272 or the disciplinary action, up to and including termination of employment. number listed for your country at www.servicenow. If you are a person who has received a report of an actual or potential ethicspoint.com violation of Corporate Policies or a Red Flag, it is your responsibility to ensure that the Legal, Ethics & Compliance Team (legal_compliance@ • Contact a member of our executive team (“P4 servicenow.com) is made aware so that it may be investigated and member”) appropriately resolved. • Contact the ServiceNow Board of Directors by sending a letter to our Santa Clara, CA, Need to know more? headquarters labeled: “Attention: Board Audit • Whistleblower and Complaint Policy (the Speak Up Policy) (internal) Committee Chair” .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We Speak Up and Do Not Tolerate Retaliation Our investigation process for when a concern is reported: Intake Assignment Investigation First, a cross-functional team We’ll assign a lead investigator to the concern. The team conducts an investigation, reviews the report to determine if an Investigations are handled by di昀昀erent groups which can include collecting investigation is appropriate. If it is, based on the nature of the concern and documents, interviewing witnesses, and then we’ll assign the right parties to the reporting channel. Global People may assessing facts. investigate. investigate some situations, while others may involve Security, Legal, Compliance, or even outside third parties. Determination Outcome The team makes a factual determination of the If there is a 昀椀nding of misconduct, ServiceNow will concerns. Relevant decision-makers review and take appropriate action and remediation will occur, in approve the response. accordance with ServiceNow’s policies. .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We avoid organizational or personal con昀氀icts of interest Those within the ServiceNow community are expected to act with integrity and in the best interest of ServiceNow. That means avoiding situations where our personal interests con昀氀ict, or appear to con昀氀ict, with ServiceNow’s interests. And if a potential issue arises, your 昀椀rst instinct should be transparency. Q: I’ve been approached to sit on the board of a non-pro昀椀t organization. Do I need approval before accepting this position? A: Yes. You should complete a COI disclosure to ensure no con昀氀icts of interest exist, prior to accepting a board position. You should also complete a disclosure before accepting part time employment or a position as a consultant. To access additional scenarios and resources, visit our Ethics Employee Resources Site. .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We avoid organizational or personal con昀氀icts of interest Examples of potential con昀氀icts of interest: • Using ServiceNow business opportunities, con昀椀dential information, assets, or services to bene昀椀t another entity, individual, or yourself. • Participating in outside employment or consulting activity without prior approval. • Serving on a Board of Directors for a non-pro昀椀t or for-pro昀椀t organization or company, without prior approval. • Hiring or supervising a family member or household member. • Engaging in a romantic relationship with a subordinate employee. • Accepting gifts, entertainment, or favors from a customer, potential customer, sales partner, competitor, vendor, or Need to know more? supplier in violation of our Con昀氀ict of Interest Policy and ServiceNow Gift Policy. • Con昀氀ict of Interest Policy (Internal) • Related Party Transactions Policy (Internal) For more speci昀椀c information regarding the giving and receiving of gifts, • ServiceNow Corporate Gift Policy (Internal) please review the ServiceNow Corporate Gift Policy. • Ethics Employee Resource Center (Internal) .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We do not engage in insider trading or tipping We don’t trade in ServiceNow’s securities while in possession of material non-public information, disclose material non-public To access information, or give trading advice about the Company. additional scenarios and Our Code for avoiding insider trading: resources, visit our Ethics We’re honest and respectful in every trade we make, Employee and that starts with making sure we follow all applicable Resources Site. 昀椀nancial laws. We don’t trade ServiceNow’s securities if we’re in possession of material non-public information about ServiceNow. It’s not only against our Code – it’s illegal, too. Similarly, it’s illegal to “tip” or share material non-public Q: I may have inadvertently displayed an email to my barber which information with others so they can trade based on such stated that ServiceNow will soon acquire a major competitor. I’ve just information. learned this may be considered material non-public information. • Information is “material” if • Information is “non-public” there is a substantial likelihood until ServiceNow broadly If the barber buys or sells ServiceNow stock based on this information, that a reasonable investor communicates it, and it is this insider trading? If so, should I report what happened? would consider it important has been absorbed by the when making an investment investing public. A: Yes. This information is material non-public information, and if your decision. barber trades based on this information, it would be considered insider trading. You should report this violation and any potential violation of Need to know more? • Insider Trading Policy (Internal) the Insider Trading Policy to [email protected]. .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We comply with all applicable laws and regulations We do the right thing for ServiceNow, our customers, our partners, and the Our Code for compliance: communities in which we operate – without exception. We demonstrate our commitment to this by complying with all applicable laws and regulations. • We comply with all applicable anti-corruption, anti- money laundering, sanctions, anti-boycott, import and export laws, and regulations that govern who we can do business with, how we can do business, where we can do business, and the transfer of sensitive technologies. • We are truthful and transparent when interacting with government o昀케cials and representatives, and we comply with all applicable lobbying laws. • We are committed to respecting human rights, and upholding all applicable human rights laws, rules, and regulations, including those pertaining to child labor, modern slavery, and human tra昀케cking. • We are committed to adhering to all applicable labor Need to know more? • Global Procurement Policy (Internal) laws, rules, and regulations, including those pertaining • U.S. Export and Trade Controls Policy • U.S. Public Sector Code of Ethics to minimum wages and working hours. (Internal) Addendum (Internal) • We are committed to engaging in responsible and • Anti-Corruption Policy (Internal) • U.S. Public Sector Gifts & Gratuities sustainable business practices. • Anti-Human Tra昀케cking Policy (Internal) Policy (Internal) .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We do not make bribes or engage in corrupt activity Ethics and integrity come 昀椀rst at ServiceNow. If it comes down to losing business or gaining it unethically, the choice is clear – we would rather lose business and maintain our integrity. Anti-corruption laws and Company policy prohibit us (and third-parties acting on our behalf) from o昀昀ering, authorizing, or providing anything of value in order to obtain an improper business advantage or in昀氀uence a government o昀케cial. ServiceNow can be held accountable for the actions of third-parties acting on our behalf, including our channel partners, vendors, and consultants. That’s why we make it clear to our third-parties that ServiceNow requires full compliance with all applicable anti-corruption laws. We Speak Up if we have concerns Need to know more? about a third-party’s conduct or our own conduct. • Anti-Corruption Policy (Internal) • ServiceNow Corporate Gift Policy (Internal) • Global Travel, Expense, and Credit Card Policy (Internal) .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We do not make bribes or engage in corrupt activity Our Code for avoiding bribes and corrupt activity: • We do not make charitable contributions, sponsorships or political contributions in exchange for an improper business • We never o昀昀er or pay bribes or kickbacks to anyone. We don’t advantage or in connection with any o昀케cial governmental allow our partners to do it either. decision. • Gifts or hospitality we o昀昀er to a government o昀케cial or customer • We do not make hiring decisions to improperly bene昀椀t a must be modest, appropriate, directly tied to a legitimate customer or government o昀케cial. business purpose, and in compliance with applicable laws (and • We hold ourselves to the same standards – we do not request pre-approved by Legal, Ethics & Compliance Team in certain or accept kickbacks or bribes. circumstances). • We never o昀昀er or provide cash, gift cards, or travel stipends to a government o昀케cial or employee of a state-owned enterprise (such as a public hospital or university) or public international organizations. For more speci昀椀c information regarding the giving and receiving of gifts, please review the ServiceNow Corporate Gift Policy. .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We do not make bribes or engage in corrupt activity U.S. Public Sector There are speci昀椀c laws and regulations that apply to interactions with U.S. Government employees and U.S. Government contractor employees. For more information speci昀椀c to those interactions, please refer to the U.S. Public Sector Gifts & Gratuities Policy. If the contemplated gift or payment relates to a U.S. Government o昀케cial, employee, or contractor, reach out to U.S. Public Sector Compliance at [email protected] for guidance. Need to know more? • U.S. Public Sector Gifts & Gratuities Policy (Internal) • U.S. Public Sector Code of Ethics Addendum (Internal) Q: I would like to take a government employee out an expensive lunch as a thank you. Is this ok? A: Probably not. The rules governing the types of gifts and entertainment we can o昀昀er government employees are much stricter than those governing our interactions with commercial contacts. Taking a government employee (foreign or domestic) to lunch could violate anti- corruption laws, including the U.S. FCPA and U.K. Bribery Act, and may also violate local laws. Please contact the Anti-Bribery/Anti-Corruption team if you have questions or need more information. To access additional scenarios and resources, visit our Ethics Employee Resources Site. .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We compete for business fairly As market leaders, we want to be known for always leading Customer success as a the right way–with products, services, and solutions that leading digital transformation deliver value to our customers—not through unethical company can’t exist without practices. When we compete, we do it fairly, in ways that trust and fair competition. build trust with our customers and each other. We compete in compliance with our policies and procedures. We comply Kevin Haverty with the antitrust and competition laws of all countries in Vice Chairman which we do business. Global Public Sector Our Code for competing fairly: • We do not enter into formal or informal agreements to limit competition, including agreements to 昀椀x prices, allocate customers or geographic territories, or reduce the quality of our products. • We do not discuss prices, discounts, incentives, • We do not discuss our bidding plans with our competitors, or otherwise demographic divisions, customers, research, and compromise competitive bidding processes, or assist others in doing so. development plans, strategic initiatives, or other non- • We do not set or discuss the price that our sales partners o昀昀er to customers. public competitively sensitive information with our • We do not use any illegal or unethical means to seek or acquire information competitors. about other companies, competitors, or customers. .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We compete for business fairly Q: I’m an account executive at ServiceNow and we are in the process of submitting a bid for two companies- “Company 1’ and Company 2”. An account executive from ABC Software reached out promising not to compete for the business of Company 1 if we respect their existing relationship with Customer 2 and do not compete for their business. Should I agree to this proposal? A: You must not agree to this proposal. We do not enter into formal or informal agreements to limit competition, including agreements to allocate customers – it is unethical and likely illegal to do so. You should communicate clearly to ABC Software that ServiceNow does not agree to ABC Software’s proposal. Instead, we will compete and win the right way. Need to know more? • U.S. Public Sector Code of Ethics Addendum To access additional scenarios and resources, visit our Ethics Employee Resources Site. • U.S. Public Sector Gifts and Gratuities Policy .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We follow our Code and uphold our commitments Applicability Our Code applies to everyone in the ServiceNow community, from executive o昀케cers to contingent workers, and members of our Board of Directors. All are responsible for upholding the standards set forth in our Code, ServiceNow policies, and applicable laws. Oversight Our Board of Directors established the standards in our Code and, directly or through its committees, oversees its compliance. Our General Counsel is responsible for ensuring adherence to our Code and, while serving in this capacity, reports directly to the Board of Directors and its committees. Violations Violations of our Code, other ServiceNow policies, or applicable laws can result in disciplinary action, up to and including termination of employment. Waivers and Amendments Waivers of provisions of our Code may be made only by our General Counsel, or, with respect to directors, executive o昀케cers, and senior 昀椀nancial o昀케cers, by the Board of Directors or the appropriate Board Committee. In addition, any amendments to our Code must be approved by the Board of Directors. When required, any waiver or amendment will be reported as required by federal securities laws and applicable stock exchange rules. .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We follow our Code and uphold our commitments Our Code for upholding our commitments: • Review and understand our Code. • If you don’t understand something about our Code, our policies, or certain laws, ask. • Speak Up if you see or hear about potential violations of our Code, ServiceNow policies, or applicable laws. • Be truthful and cooperate fully in internal investigations. • Complete all required training to show you understand the principles set forth in our Code, ServiceNow policies, and applicable laws. .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

TEAMWORK We lead by example Our communications are always accurate and truthful We choose our business partners and suppliers carefully We embrace diversity, equity, and inclusion

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We lead by example Everyone at ServiceNow is responsible for upholding the culture and values that are outlined in our Code. When each of us accepts that responsibility and commits to leading by example, our team is as strong as it can be. With that in mind, you should pay attention to how decisions are made, wins are celebrated, losses are handled, consensus is reached, and debate is fostered. Our success largely depends on all of us embracing that accountability and leading by example in every action. Our Code for leading by example: • Listen to your team, take their concerns seriously, and escalate concerns when you feel you need additional support. Need to know more? • Talk with teams about acting with integrity and doing the right thing. Make it known that at • Ethical Leadership: Managers Toolkit ServiceNow, we all must align to our policies and all applicable laws. (Internal) • Emphasize that while reaching our goals and executing on our priorities matter, how we • People Leaders Resources Site (Internal) achieve them is equally important. • Ethics Employee Resources Center (Internal) • Listen. Good leadership allows for two-way dialogue. Ask questions and check in regularly, • ServiceNow People Pact (Internal) particularly about the challenges your team is facing. .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST Our communications are always accurate and truthful Our commitment to building and maintaining a strong reputation and brand relies on each of us aiming for the same target and projecting the same information. We must ensure that internal and external audiences all receive consistent – and accurate – information about our Company. When it comes to addressing the public, we must be truthful and provide accurate information. Our statements can’t be misleading, and we must speak with one uni昀椀ed voice to ensure we are upholding our commitments to investors and the public. This includes any commentary about, or from, the Company on social media. Our Code for communicating accurately: • All 昀椀nancial disclosures about the Company must be fulsome, accurate, and timely. Need to know more? • All communications about our products, including advertising and promotional • Corporate Communications Policy (Internal) statements, must be accurate. • We never disclose con昀椀dential or non-public information about ServiceNow without • Social Media Policy (Internal) authorization. • When contacted by the press, or when unsure about external speaking opportunities, direct inquiries to our Global Communications Team at [email protected]. .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We choose our business partners and suppliers carefully We collaborate and win as a team through strong partnerships with a broad range of global channel partners, vendors, suppliers, and consultants. We are mindful when selecting these partners. It is our responsibility to ensure third-parties acting on our behalf uphold the strict standards we’ve set for ourselves, and align to our values – by following all applicable laws and ServiceNow requirements. It’s your responsibility to act as a guardian of our Code, to communicate our expectations, and report any concerns when working with third-parties. Q: What is needed prior to onboarding a vendor? A: A signed contract, a purchase order, and the vendor risk assessment process must be complete. To access additional scenarios and resources, visit our Ethics Employee Resources Site. .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We choose our business partners and suppliers carefully Our Code for partnerships and collaborations: • We follow proper protocols for vetting and entering into business with any third-party. • We work with third-parties only when there is a valid business reason for doing so. • We never encourage or allow third-parties to engage in illegal conduct or conduct that violates our policies. • We ensure our vendors abide by our Supplier Code of Conduct and that our channel partners abide by our Partner Code of Conduct. Need to know more? • Global Procurement Policy (Internal) • Supplier Code of Conduct • Partner Code of Conduct (Partner Portal) • ServiceNow Corporate Gift Policy .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We embrace diversity, equity, and inclusion We embrace diversity, inclusion, and belonging as a business Transparency, trust imperative. It’s a cultural value and a shared commitment and belonging are across our global leadership team. the new business currency. Diverse, inclusive teams where everyone belongs are more creative, more innovative, and more successful. Research proves it. And we believe it. Karen Pavlin We’re committed to racial justice and equity for all, and want Chief Diversity O昀케cer to always be learning, growing, and understanding how to be allies. We extend that to our customers and partners and do our part to lead the charge for sustainable, positive change. Need to know more? • Equal Employment Opportunity (EEO) Policy • Anti-Harassment Policy (Internal) • 2023 Diversity, Equity, and Inclusion Report • Diversity, Equity, and Inclusion Site .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We embrace diversity, equity, and inclusion Our Code for embracing diversity and creating belonging: • We’re committed to providing equal employment opportunities and pay equity to all quali昀椀ed candidates. • We strictly prohibit any form of harassment (including, but not limited to, sexual harassment), discrimination or retaliation within the work relationship, including during the recruitment process. • Reports of harassment (including but not limited to, sexual harassment), discrimination and retaliation will be promptly, e昀昀ectively, thoroughly and objectively investigated. • Disciplinary action up to and including separation of employment will be taken on a case by case basis, as appropriate and based on the outcome of any investigation. Q: At several team meetings, my co-worker made comments about another colleague’s nationality though he says he is “just kidding”. Should I say something to my manager or report this? A: Yes. Please tell your manager or utilize the Speak-Up hotline. It is every employee’s duty to promote an inclusive and respective workplace and culture. All ServiceNow employees deserve to work in an environment where they can be comfortable and successful. To access additional scenarios and resources, visit our Ethics Employee Resources Site. .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

TRUST We maintain a safe and respectful workplace We maintain accurate books and records We abide by policies on gifts and business courtesies We protect customer and employee data We safeguard ServiceNow’s data and innovation We protect and use corporate assets responsibly © 2023 ServiceNow, Inc. All Rights Reserved. Confidential. 19

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We maintain a safe and respectful workplace A safe, secure work environment is essential for focusing and Need to know more? collaborating to execute on our priorities, whether in a ServiceNow • Global Occupational Health and Safety Policy (Internal) o昀케ce or working remotely. This means creating trust by: • U.S. Workers’ Compensation Policy (Internal) • Treating each other respectfully and not tolerating harassment, • Workplace Safety Incident Reporting Guidelines discrimination, bullying, intimidation, or threats of violence. • Not allowing 昀椀rearms, other dangerous devices, and drugs or other illegal substances, at work or at work events. • Never working under the in昀氀uence of drugs or alcohol. Our Code for creating a safe workplace: • Treat others with respect. • Be thoughtful — act responsibly and with others in mind. • Resolve problems and disagreements with conversation, not threats. .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We maintain accurate books and records Our business relies on the trust of our investors and the public, so we must maintain complete and accurate books and records We need to at all times. We must ensure our 昀椀nancial reports, public 昀椀lings, have unrelenting and public statements meet legal requirements and accounting commitment standards. And that our business records fairly and accurately to integrity in re昀氀ect our activities. everything we do. Our Code for maintaining accurate books and records: Gina Mastantuono • We accurately record and report 昀椀nancial transactions in compliance with all applicable laws, regulations, accounting Chief Financial O昀케cer practices, and ServiceNow policies. • Our written contracts fully and accurately re昀氀ect all deal terms. • We don’t enter into side agreements or o昀昀-the-books transactions. • We retain and dispose of all documents and materials in compliance with our legal obligations and our Record Retention Policy. .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We maintain accurate books and records Q: My team held an o昀昀-site dinner where some team members could not attend. If all team members had attended, the dinner would have ended up being on budget. Without them, the total amount exceeded the total allowed expense. When submitting the expense report, can I include all team members on the expense so it will be approved under the Travel and Expense Policy? A: No. Our books and records form the basis on which we make important strategic decisions. They help us ful昀椀ll our commitments and hold us accountable to those who rely on our 昀椀nancial information. You have a responsibility to make sure all records you create (such as time sheets, expense reports, and other corporate information) are prepared as accurately as possible. You should never make Need to know more? a false or misleading entry in any of ServiceNow’s records, • Record Retention Policy (Internal) whether 昀椀nancial or non-昀椀nancial. • Global Disbursement Policy (Internal) To access additional scenarios and resources, visit our • Internal Audit Policy (Internal) Ethics Employee Resources Site. .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We abide by policies on gifts and business courtesies We’re trusted with the responsibility of giving modest gifts, meals, Our Code for giving and receiving gifts: and entertainment in accordance with all applicable laws, our policies, and the recipient’s own internal policies. • When we give or receive a gift or hospitality, it must be reasonable, appropriate, and tied to a legitimate business purpose. • Gifts or hospitality to government personnel must also comply with applicable anti-corruption laws, ServiceNow’s Anti-Corruption Policy and the recipient’s rules and policies. • Gifts to non-U.S. Government o昀케cials may be provided in very limited circumstances and must be ServiceNow branded and of nominal value. • We can’t use personal funds to do something that can’t be done with ServiceNow funds. • We can’t use a third-party, including our channel partners and consultants, to do something that can’t be done with ServiceNow funds. • We can accept modest gifts and hospitality from third-parties, but never ask for them. Refer to the U.S. Public Sector Gifts & Gratuities Policy for speci昀椀c restrictions applicable to interactions with U.S. Government For more speci昀椀c information regarding the giving and receiving of employees and U.S. Government contractor employees. gifts, please review the ServiceNow Corporate Gift Policy. .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We abide by policies on gifts and business courtesies Q: A vendor I’ve work with often just sent me a few branded stickers. What should I do with them? A: Keep them if you want. Accepting a token(s) of appreciation that is of nominal value is OK. Q: I would like to take some business partners out to dinner, but I’m not sure if the company they work for is owned or partially owned or controlled by a foreign government. What should I do? A: Contact [email protected] for guidance before you schedule any outings. It is important Need to know more? to know if an entity is owned or partially government owned. • Anti-Corruption Policy (Internal) • ServiceNow Corporate Gift Policy (Internal) To access additional scenarios and resources, visit our • U.S. Public Sector Gifts & Gratuities Policy (Internal) Ethics Employee Resources Site. • U.S. Public Sector Code of Ethics Addendum (internal) • Global Travel, Expense, and Credit Card Policy (Internal) .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We protect customer and employee data Keeping our customers’, employees’, partners’, Handling and and service providers’ information safe and protecting all data secure is a priority for ServiceNow. with care serves We are committed to privacy in our own our two most products, our data practices, and in the third- important assets – party products we use. our customers and our employees. We maintain a comprehensive data privacy program and follow all applicable privacy and data protection laws and regulations. Chris Bedi We process personal data in compliance with Chief Digital Information O昀케cer our privacy and security documentation. We all must follow the obligations outlined in these documents without exception. .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We protect customer and employee data Our Code for protecting customer and employee data: • Handle all personal data in accordance with our privacy and security Q: I was at a cafe 昀椀nalizing a presentation for a policies, procedures, and standards. customer and left my table to order a cup of co昀昀ee. I left my laptop open and unlocked on my table so I • Treat all personal data we have access to as con昀椀dential information. wouldn’t lose any time getting back to work. • Access only the personal data necessary to ful昀椀ll the business Are there steps that I should have taken to protect purpose. customer and employee data? • Ensure that appropriate data protection terms are in place with any third-party before disclosing personal data of our stakeholders. A: Yes. You must always be diligent when working with con昀椀dential data. When working in a public place, ensure you use a privacy screen to prevent Need to know more? the disclosure or theft of con昀椀dential data, such as • Acceptable Use Policy (Internal) ServiceNow bid details, business plans, and customer • Employee Privacy Statement Policy (Internal) data. When not in use, lock your laptop’s screen and ensure it is kept it in a secure location. • Information Security Policy (Internal) • Data Protection Statement Policy (Internal) To access additional scenarios and resources, visit our Ethics Employee Resources Site. .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We safeguard ServiceNow’s data and innovation Innovation isn’t just a buzzword at ServiceNow. It’s one of the core values that drives everything we do, and it’s essential to our commitment to continued growth and customer focus. So, it’s crucial that we protect and respect our innovation every day. It’s equally crucial that when we’re handling the ideas, information, or intellectual property of others, that we protect and respect it as well. This is critical for maintaining trust with our customers, our partners, and the communities in which we operate. Need to know more? • Corporate Business Continuity Management Policy (Internal) • Trademark and Copyright Guidelines .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We safeguard ServiceNow’s data and innovation Our Code for protecting our innovation: • We use best practices to safeguard con昀椀dential ServiceNow information or intellectual property – and we do not disclose it to others – even after leaving ServiceNow. • We also protect ServiceNow’s innovation in our copyrights, trademarks, and patents – and ensure they are being used appropriately. • We don’t use con昀椀dential information or intellectual property of other companies without proper authorization. • We don’t use copyrighted materials – including graphics, videos, and music – without a license. .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

CODE OF ETHICS INTEGRITY TEAMWORK TRUST We protect and use corporate assets responsibly Our corporate resources are the tools that allow us to innovate and conduct business in the ServiceNow way. From the laptops we work on to the tools we use for our business needs and the workspaces we collaborate in, the way we provide value to our investors and our customers is by putting our corporate resources to their best use – for business purposes. Each of us is responsible for ensuring our corporate resources are used appropriately. That means guarding against waste, fraud, and abuse – and keeping an eye out for any misuse or misconduct. It also includes keeping a close watch on how we use corporate assets and spend our corporate funds on things like travel or work-related expenses. • Global Travel, Expense, and Credit Card Policy Need to know more? • Acceptable Use Policy • Global Disbursement Policy .To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

Appendix: contacts CODE OF ETHICS Speak Up Workplace Safety and Security Concerns • You should report all workplace safety and security • Report any concerns to a manager, Global People, Legal, Ethics & concerns to ServiceNow’s 24/7 Global Security Compliance, or [email protected] Team or by calling any of the numbers listed below. • Contact your manager, Global People, or Legal, Ethics & For any life-threatening emergencies, you should Compliance contact your local emergency authority. • Email [email protected] • +1-855-760-8477 (U.S.) • Submit a concern online at www.servicenow.ethicspoint.com • +31202414277 (EMEA) • +6568090905 (APJ) • Call the Speak Up Line at (855) 869-7272 or the number listed for your country at www.servicenow.ethicspoint.com • +914066294902 (India) • Contact a member of our executive team (“P4 member”) Innovation and Data Queries • Contact the ServiceNow Board of Directors by sending a letter to our Santa Clara, CA, headquarters labeled: “Attention: Board Audit Committee Chair” • [email protected] Trade Related Questions U.S. Public Sector • [email protected] • [email protected] To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

Appendix: resources CODE OF ETHICS • To learn more about the topics in our Code of Ethics, please • 2023 Diversity, Equity, and Inclusion Report access the Code of Ethics Scenarios Supplement in the Ethics Employee Resource Center (Internal). • Diversity, Equity, and Inclusion Site • Employee Privacy Statement Policy (Internal) Policies and Resources • Equal Employment Opportunity (EEO) Policy • Acceptable Use Policy (Internal) • Ethics Employee Resource Center (Internal) • Anti-Corruption Policy (Internal) • Ethical Leadership: Managers Toolkit (Internal) • Anti-Harassment Policy (Internal) • Global Impact Site • Anti-Human Tra昀케cking Policy (Internal) • Global Travel, Expense, and Credit Card Policy • Human Rights Statement • Global Disbursement Policy (Internal) • Corporate Communications Policy (Internal) • Global Travel, Expense, and Credit Card Policy (Internal) • Con昀氀ict of Interest Policy (Internal) • Global Procurement Policy (Internal) • Corporate Business Continuity Management Policy (Internal) • Global Occupational Health and Safety Policy (Internal) • Data Protection Statement Policy (Internal) To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

Appendix: resources CODE OF ETHICS Policies and Resources • Information Security Policy (Internal) • Supplier Code of Conduct • Internal Audit Policy (Internal) • Trademark and Copyright Guidelines • Insider Trading Policy (Internal) • U.S. Export and Trade Controls Policy (Internal) • Partner Code of Conduct (Partner Portal) • U.S. Public Sector Code of Ethics Addendum (Internal) • People Leaders Resources Site (Internal) • U.S. Public Sector Gifts & Gratuities Policy (Internal) • Related Party Transactions Policy (Internal) • U.S. Workers’ Compensation Policy (Internal) • ServiceNow Corporate Gift Policy (Internal) • Whistleblower and Complaint Policy (the Speak Up Policy) (internal) • ServiceNow People Pact (Internal) • Workplace Safety Incident Reporting Guidelines • Record Retention Policy (Internal) • Social Media Policy (Internal) To report concerns or seek guidance about any of the issues raised here, contact the Ethics Hotline online at www.servicenow.ethicspoint.com or call +1 (855) 869-7272 or the number listed for your country as listed on the Ethics Hotline.

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