Hewlett-Packard Company Contingent Worker Code of Conduct This

Hewlett-Packard Company Contingent Worker Code of Conduct This training can be used by members of Hewlett-Packard Company’s Extended Enterprise to provide training to their employees on the HP Contingent Worker Code of Conduct © 2007 Hewlett-Packard Development Company, L. P. The information contained herein is subject to change without notice

Contingent Worker Code of Conduct Hewlett-Packard Company is committed to the highest standards of business ethics. Members of the HP Extended Enterprise which provide Contingent Workers agree to deliver services in a manner consistent with this commitment. 2 2/14/2007 HP Confidenital Final Version

HP’s Commitment • HP is committed to the highest ethical standards in its extended enterprise. • HP needs our suppliers who act on our behalf and perform critical processes to act in accordance with ethical standards expected by HP shareholders and customers. • It is for these reasons we have prepared a Code of Conduct for our suppliers of Contingent Workers. This training will help contingent workers understand actions expectations of them while working on behalf of HP. 3 2/14/2007 HP Confidenital Final Version

Code of Conduct -- Application All suppliers of Contingent Workers shall ensure that any member of its workforce (including employees, suppliers and contingent workers) involved in the performance of services for or on behalf of HP is aware of, trained on, and adheres to HP’s Contingent Worker Code of Conduct. Definition: Contingent Worker (“CW”): A non-employee performing services at the direction of his or her respective employer for or on behalf of HP 4 2/14/2007 HP Confidenital Final Version

CW Code of Conduct Local Law Compliance 5 2/14/2007 • Comply with all applicable local law, rules, and government regulations HP Confidenital Final Version

CW Code of Conduct Equal Opportunity • Do Work Environment • Harassment 6 2/14/2007 not discriminate on the basis of race, creed, color, religion, • gender, sexual orientation, gender identity/expression • national origin, disability, age • any other protected status will not be tolerated, whether verbal, physical or visual • Actions directed at an individual based on their gender, color, race, ancestry, religion, national origin, age, disability, sexual orientation or gender identity/expression are prohibited • Sexual harassment in any form is not tolerated HP Confidenital Final Version

CW Code of Conduct Scenario – Harassment Marie is working for XQ under a contract to HP. Her job requires that she be present at the HP site in the late afternoon and evenings. For several nights in the past week, Dave, a colleague of Marie’s who also works for XQ has been hanging around Marie’s desk. One evening, Dave made some comments to Marie about her appearance. At first she was flattered, but when it happened the second time, Marie felt uncomfortable and told Dave she needed to get to work. Marie has tried to avoid Dave but Dave is hanging around more. What should Marie do? A. Marie should not be so sensitive. B. Marie should talk to her XQ supervisor. • 7 2/14/2007 HP Confidenital Final Version

CW Code of Conduct General Conflicts of Interest Agency Contractor Conflicts of Interest 8 2/14/2007 • Do not provide or receive business amenities, such as gifts, meals or entertainment, that may create the appearance of impropriety or undue influence • During HP assignment • Do not work for HP competitor, partner, non-employer supplier or OEM • Do not work for an end-user customer in the purchase or support of any HP products or services • Disclose to employer when may be conducting business with family, friends, others of close personal relationship HP Confidenital Final Version

Conflict of Interest • Do not engage in an activity that results in personal interests competing with those of your employer and /or HP • Business Gifts and Entertainment Do not accept gifts, meals, services entertainment or anything else of value if doing so would create the appearance of undue influence. • Special Rules for Agency Contractors during HP Assignment • May not work for an HP competitor • May not work for a HP channel, alliance, marketing partners; OEM; or other non-employer supplier. • May not work for an HP end-user customer in the purchase or support of any HP product or service. • Should disclose to employer situations where business may be conducted with family or friends. 9 2/14/2007 HP Confidenital Final Version

Scenarios -- Conflict of Interest 1. Johannes is consulting on marketing plans for a new HP printer. He has been contacted by an HP competitor to prepare marketing research. True or False. Johannes can work for an HP competitor at the same time he works for HP. 2. Kye is on a temporary contract as a buyer for the HP server manufacturing organization. One of the suppliers she buys from is owned by her brother. True or False. Kye should notify her employer or HP about this situation. 10 2/14/2007 HP Confidenital Final Version

CW Code of Conduct Use of HP Resources 11 2/14/2007 • Any use assets and resources only for HP business • Use must be consistent with HP policies and guidelines • Do not allow family and friends to use HP assets • Do not use assets for illegal or harassing purposes, solicitations, pornography HP Confidenital Final Version

Use of HP assets Specifics Use only by the HP Can’t violate law. No CW for business threats, pornographic, purpose harassing, demeaning HP CW should not HP owns emails, have expectation of voicemails stored or privacy transmitted on/by HP equipment 12 Friends and families can’t use HP may access or retrieve data at any time consistent with local law 2/14/2007 HP Confidenital Final Version No personal gain, solicitations, chain letters

Scenarios – Use of HP Assets/Resources 1. During his assignment in the HP Finance Department, Marcus has use of an HP notebook computer. He also owns a business repairing clocks. May he load the laptop with a billing software to use in his repair business? A. Clock repair is not an HP business. Marcus can load the software. B. Marcus can’t use HP equipment for personal use. Eric is working at HP on an assignment from his employer inputting contract information into a computer database. On his breaks, he surfs the web where he places orders and occasionally visits adult entertainment sites. Do any of his actions violate the HP Contingent Worker Code of Conduct? Yes or No 2. 13 2/14/2007 HP Confidenital Final Version

CW Code of Conduct Anti. Corruption 14 2/14/2007 • Do not bribe government officials • Do not pay ‘finders fees’ • Document all payments made on behalf of HP HP Confidenital Final Version

Anti-Corruption Specifics Bribery • May not directly or indirectly give gifts, payments, entertainment Finder Fees • May not pay a commission or fee Records • Must document any payments on behalf of HP 15 2/14/2007 HP Confidenital Final Version • Applies in all countries • If the payment is to win or keep business Unless in approved written document Must be bona fide distributors, sales reps agents, consultants

Scenarios – Corruption HP has contracted with Horatio’s employer to provide sales representatives to sell HP printers. Horatio is about to close a large sale when Ana Lucia, the customer’s buyer, asks for a special fee to be paid in cash. She says that if the fee is not paid the order will go to an HP competitor who is willing to pay. Should Horatio pay the special fee to ensure HP gets the order? Yes or No? 2. Song is a contingent worker who wants to sell an HP IT solution to the Education Ministry but is having difficulty setting up a meeting with the Ministry. Harry tells Song that he can introduce him to the Ministry purchasing officer for $1000. The sale will be for $30 million. Should Song pay Harry? Yes or No? 1. 16 2/14/2007 HP Confidenital Final Version

CW Code of Conduct Gray Marketing 17 2/14/2007 • Ensure that HP products are not diverted into unauthorized channels • Follow processes for discounting and special promotions HP Confidenital Final Version

Gray Marketing • 18 “Gray” products are those that enter into the marketplace without HP’s authorization. This typically happens when a channel partner orders more product than it can use at a substantially discounted price. It then sells the product to unauthorized customers. − HP has to compete against these suppliers. − Channel partners who follow rules are at a disadvantage. − HP pays contra revenue (discount), decreasing profit. 2/14/2007 HP Confidenital Final Version

Scenario -- Grey Marketing Michelle is a contingent worker helping HP process orders for servers. BIG, a global partner, qualifies for a large volume discount. A person claiming to be the employee of a company affiliated with BIG has placed a product order under BIG’s discount schedule. Michelle should: a) b) c) d) 19 Investigate to see if the affiliate company is eligible for the discount Find out if the affiliate is a real company Trust the caller and grant the discount because the order will help the country meet quota. Both a) and b). 2/14/2007 HP Confidenital Final Version

CW Code of Conduct Insider Trading 20 2/14/2007 • Do not use material, non-public information about HP to make personal investment decisions HP Confidenital Final Version

Scenario --- Insider Trading • 21 Jake works for Axis Co. , which is providing consulting services to HP with respect to an acquisition of a software company, Radar. Can Jake buy stock in Radar? HP? 2/14/2007 HP Confidenital Final Version

CW Code of Conduct Confidential Information Dealing with the Press or Media 22 2/14/2007 • Adhere to specific confidentiality obligations agreed to between employer and HP • Presume that information from HP is confidential, including that received from other HP suppliers, customers or partners • Contingent Workers are not authorized to speak to the media on behalf of HP HP Confidenital Final Version

Scenario – Confidentiality • Anna is working for as an agency contractor as a Procurement Specialist for HP. She regularly receives parts from suppliers to build notebook computers. Anna’s friend Peter is a purchasing agent for an HP competitor in the notebook computer space. Peter tells Anna about his excellent negotiations with DISPLAY TECH and that he has been able to get a great price of 132 Euros for a 17 inch LCD. Anna knows that HP is currently paying DISPLAY TECH 120 Euros for a similar LCD. Which of the following are correct? 1. Anna can disclose the price to Peter because there is a chance the LCDs are not the same model. 2. Anna can’t disclose HP’s price to Peter because the price is confidential information and Anna would violate the HP Contingent Worker Code of Conduct by sharing this information with Peter. 3. Anna can disclose the price to Peter because HP’s lower price is probably because HP buys in higher volumes than Peter’s company. • 23 2/14/2007 HP Confidenital Final Version

CW Code of Conduct Privacy 24 2/14/2007 • Protect data that is personally identifiable, whether obtained from HP employees, customers, or partners HP Confidenital Final Version

Scenario – Privacy Under a contract to provide IT support to HP, Roberta is working on a new employee information database containing the government identification numbers for all HP employees. An HP manager has called Roberta and asked for a file that contains the names, salaries and social security numbers of all his employees in the US. • Roberta should give the manager this information. True or False? • 25 2/14/2007 HP Confidenital Final Version

CW Code of Conduct Non. Solicitation 26 2/14/2007 • Contingent Workers may not solicit any HP employee during his or her work time • Do not distribute literature or other materials in HP’s working areas • Do not hand out materials for non-business reasons including charitable organizations HP Confidenital Final Version

Scenario --- Solicitation • 27 Ravi’s father-in-law asked him to post discount coupons for his local sandwich shop in the employee lounge areas at the HP Roseville site. Ravi is an employee of TEAMWORK, the outsourced contractor managing the food service needs at the site. Should he post the coupons? 2/14/2007 HP Confidenital Final Version

Report Misconduct Talk: To your employer Telephone: Email: Mail: corporate. compliance@hp. com Hewlett-Packard Ethics and Compliance Office PO Box 692015, Houston, TX 772692015 28 2/14/2007 HP Confidenital Final Version Guide. Line 1 -800 -424 -2965 (Outside U. S. , first dial AT&T Access Number)

Code of Conduct for Contingent Workers HP expects all suppliers of Contingent Workers to take the required steps to ensure that members of their workforce comply with the HP Contingent Worker Code of Conduct. . • HP expects that all Contingent Workers will perform services on behalf of their employees in a manner that is consistent with this Code of Conduct. • Contingent Workers must report potential violations of this Code to their employers, their HP engagement manager, or to the HP Ethics and Compliance Office. • 29 2/14/2007 HP Confidenital Final Version