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.
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