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.