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.