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.