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Integrity HP

at
Table of Contents TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED

Integrity at HP Our Company Our Impact


27 Protect our assets 53 Respect human rights
29 Keep accurate records 54 Reduce our
A Message from 31 Avoid conflicts of interest
environmental footprint
Dion Weisler 55 Make a difference
33 Do not trade on material
non-public information

Our Promise Closing Thoughts from


9 What we value Our Relationships Michelle VonderHaar
11 Using Integrity at HP 37 Engage responsible
business partners
13 How to raise a concern Our Resources
39 Never bribe or accept kickbacks
41 Know the rules about gifts
Our People and entertainment

17 Build trust 43 Compete fairly

19 Respect others 45 Putting customers first

21 Promote a safe HP 47 Know the rules about importing


and exporting
23 Protect personal data
49 Speaking on behalf of HP

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A Message from Dion Weisler TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED

A Message from
Dion Weisler
At HP, we imagine the future and
make it happen. Our conduct is
the core of our culture, founded
on shared values that are as
relevant today as when HP was
established back in 1939.
Integrity at HP guides us on how to win the
right way, how to protect and strengthen our
reputation, and how to sustain our success for
the long term.

Every decision we make matters in our effort


to deliver meaningful contributions. We are
all accountable for our actions, responsible
for their consequences. By living our values,
we are building a culture based on trust and
respect, and solving tough challenges with
integrity—all with a vision to make life better,
for everyone, everywhere.

Dion Weisler
CEO

5 A Message from Dion Weisler 6


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Our Promise
9 What we value
11 Using Integrity at HP
13 How to raise a concern

7 Our Promise 8
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What we value
The HP Way includes three components,
each equally important.
• W
 hat we value: Our values reflect the high standards to which
we hold ourselves.
• H
 ow we work: These fundamentals sum up what differentiates
how we work at HP.
• H
 ow we lead: Our leadership principles and practices describe
how everyone at HP has the opportunity, and the responsibility,
to be a leader.

The “what” and the “how” are familiar concepts to HP


employees. That is because how we do things here is
as important as what we do, a belief that is reinforced
throughout this document, just as it is in our day-to-
day lives at HP.
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Using Integrity Applying the Headline Test


The Headline Test is a simple but powerful tool designed to make sure we appropriately consider
the soundness and impact of our business decisions. It is named after one of the tools most

at HP
commonly used by executives.

Integrity at HP is a resource for If you are a manager,


all employees and members you must also:
of the Board of Directors.
Be an ethical leader—Use your good
Integrity at HP is the new judgment and the Headline Test to ensure
name for the Standards of that your actions demonstrate the highest
standards of ethical behavior.
Business Conduct. It
represents the highest level Be a resource—Know Integrity at HP values
of guidance for our conduct. and expectations so you can reinforce
Before you make a decision, consider how it would look in a news story. If needed,
them with your team and answer employee
check it with an internal resource.
questions.
As an employee,
you are expected to: Open your door—Encourage employees
to come to you if they want to talk or
have questions.
Act with uncompromising integrity—
Demonstrate your commitment to our Act with integrity
values, policies, and the law by always Build trust—Take employee concerns
putting integrity first. seriously, provide guidance and take Q: My manager suggested I do A: No, you should not. Nobody at any level
appropriate action to prevent, detect, something that seems to violate our of HP has the authority to direct you to do
and respond to misconduct and ask for policies. It feels wrong, but I am afraid something that violates our policies or the
Raise a concern—Every employee has
help if needed. I will be fired if I do not do what she law. Before you act, check Integrity at HP.
a responsibility to report any suspected
asks. Should I just go along with it? If the action seems wrong, let your manager
misconduct immediately, honestly, and in
know you cannot do it and why. If she insists,
good faith. Never Retaliate—Do not retaliate (or let
or if you are uncomfortable approaching her
others retaliate) against someone who directly, share your concerns with another
Cooperate—Comply with all internal comes forward in good faith with a concern. member of management or another internal
investigations and audits. resource right away.
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How to raise
Your manager is usually the best place • T
 he GuideLine. Available anywhere
to start. When it is not possible to raise in the world, 24 hours a day:
or resolve an issue with your immediate
From the U.S. and Canada:
manager, use the HP Global Open Door
800-424-2965

a concern
Policy to discuss it with:
Outside the U.S. and Canada:
• Another manager
1. Go to AT&T Access Codes
• Human Resources 2. Find your country in the
• Global Legal Affairs alphabetical listing

At HP, we believe everyone’s voice should be heard. • Your local Integrity at HP team 3. Dial the AT&T Direct Code
4. When prompted,
It is also important that you know there are resources available if you have a question • Your business group or region
dial 800-424-2965
or concern. If you believe someone may have violated Integrity at HP, our policies, or the
Integrity at HP Liaison
law, you are required to speak up immediately, and we offer a variety of ways to do so. • Internal Audit Translators are available and callers
can remain anonymous except where
• Ethics and Compliance Office anonymous reporting is prohibited by
• E
 thics and Compliance Office, local law.
via email: integrity@hp.com
• Via mail:
• Internal web form
HP Inc.
Ethics and Compliance Office
1501 Page Mill Road
Mailstop 1560
Palo Alto, CA 94304-1112
United States

Find Out More


Regardless of the resource
HP Global HR Policies
you contact, you can be
assured that your concern HP Global Open Door Policy
will be handled promptly
HP Litigation and Investigations Policy
and appropriately.
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Our People TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED

Our People
17 Build trust
19 Respect others
21 Promote a safe HP
23 Protect personal data

15 Our People 16
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Build trust
What We Do
Follow Integrity at HP,
our policies, and the law.

How We Do It
Maintain high standards. When someone Cooperate with investigations. Reports of
violates Integrity at HP, our other policies, misconduct are reviewed, investigated if
or the law, it can result in disciplinary appropriate, and treated confidentially, to
action, up to and including termination. the extent possible under the law. Everyone
Certain violations can have additional who works at HP has a responsibility to:
consequences under the law. All of us
have a responsibility to do our part to • P
 articipate fully and honestly with
protect our reputation and our company. investigations and audits
• C
 ooperate with Global Legal Affairs
Take action when aware of misconduct. to respond to litigation or requests
Every employee has a responsibility to from government and other
report any alleged misconduct immediately. external agencies
Use the HP Open Door Policy to raise concerns. • N
 ever act in any manner that would
Managers must encourage open and impede an investigation, including
honest communication. destroying or fabricating evidence,
intimidating witnesses, or improperly
discussing the investigation or
Never retaliate. HP does not tolerate
disclosing information in a manner
retaliation against anyone who raises a that impedes a fair review
concern or question honestly and in good
faith. ​Every HP employee must feel free to • R
 etain and do not alter or destroy
speak out about potential Integrity at HP records in response to litigation,
violations without fear of retaliation. investigations, or audits

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Respect others
What We Do
Treat all people—inside and
outside the company—with
fairness, dignity, and respect.

How We Do It
Embrace our diversity. HP values Promote trust and respect. Promote and
differences—whether race, ethnicity, encourage an inclusive work environment,
gender, nationality, ability, military status, free of harassment. Do not behave in a
religion, generation, or sexual orientation. disrespectful, hostile, violent, intimidating,
We engage top industry talent to drive our threatening, or harassing manner. HP has zero
company’s long-term success. HP benefits tolerance for any form of sexual harassment,
from the creativity and innovation that including unwanted sexual advances, requests Act with integrity Find Out More
results from employees with different for sexual favors, the display of sexually
experiences, perspectives, and cultures explicit materials, or any other verbal or Q: A woman on my team just confided in HP Global HR Policies
working together.  physical conduct of a sexual nature. me about her manager who, despite
prior refusals, continues asking her on HP Global Non-Discrimination Policy
Focus on fairness. Practice equal dates. She even asked me to walk out
opportunity in every action and embrace the Watch Out For … of the office with her at the end of the HP Global Harassment-Free Work
diversity of all HP employees. As set out in day. She is obviously uncomfortable Environment Policy
our policies, do not discriminate against any • C
 ritical or dismissive comments about but says she does not want to report it.
employee or applicant. our harassment policies Should I respect her wishes? HP Litigation and
Investigations Policy
• T
 he perception of harassers as A: Not in this case. Despite what your
victims or victims as complainers colleague says, she is experiencing
• Threats or name-calling harassment under HP’s policies. This
behavior is not tolerated at HP. Speak
• J okes or comments that are sexual up about this situation immediately
or offensive by calling the GuideLine or reaching
out to integrity@hp.com.

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Promote a Help to prevent viruses and


breaches of our IT systems.
Follow our policies as well as:

safe HP • Protect your password(s)


• S
 ecure your workstation when you
step away
• U
 se only hardware and software
What We Do provided by HP
Put the safety and security • N
 ever download or install
unauthorized applications
of people first. or storage devices

How We Do It • N
 ever access our network via
unauthorized applications
Prevent safety risks. Comply with safety, Prevent breaches of our IT systems. Keeping
health, and security policies and procedures. our IT systems safe from inappropriate access • B
 e alert to phishing scams, and do
Be proactive in preserving your safety and and disclosure is the responsibility of every not open suspicious links in emails,
the safety of those around you. Do not sell, employee. All employees must be familiar even if you know the source
possess, or use illegal drugs or create a safety with HP data security policies, standards, and
risk through drug use or intoxication while on specifications. Never provide information that
HP property or while conducting HP business. can be used to access our systems to anyone Report cybersecurity incidents
If you see a situation that could put others at unless you are sure that the recipient is who
risk, report it to your manager. they claim to be, is authorized to have access, • R
 eport an IT security event,
and has a valid need for the information. incident, or crisis
Keep HP violence-free. Threats, acts of • Immediately forward any suspicious
violence, and physical intimidation have no emails as an attachment to the
place at HP. Follow good security practices HP Security Operations Center at
and be alert to what is going on around you.
Immediately contact your manager about any
Find Out More phish@hp.com

situation that could jeopardize safety at HP.


HP Environmental, Health and
Safety Policy

HP Security Policy

HP Global Cybersecurity Policies

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Protect
personal data
What We Do
Recognize and honor
our obligations.
Act with Integrity
How We Do It What are some examples
Respect the privacy of personal data. We Q: One of our team members recently
demonstrate through words and actions Watch Out For … of personal data? had a baby and I wanted to send her
that we respect the privacy of personal data a card to congratulate her on the new
that is shared with us by our employees • S
 haring more personal data than is addition. My manager said she could
and customers. Follow our policies and all needed for business purposes not provide my colleague’s home
applicable laws in collecting, accessing, • C
 ontact details (name, email address, address. It is just a greeting card—is
• “ Free” or individually purchased phone number, postal address)
using, storing, sharing, and disposing of this taking privacy too far?
internet hosting, collaboration,
personal data. Be transparent about our or cloud services—we cannot • Government ID number
practices and provide choice to individuals A: No. Even though this is a kind gesture,
guarantee data privacy • Location data (GPS, IP address)
regarding their privacy preferences. Use your manager has an obligation to
personal information only for legitimate HP • S
 ocial engineering—when you • Serial number protect this information. You could
business purposes. are asked to share personal contact your colleague via work email
information, first authenticate to ask for her address directly, or you
Know what types of data are personal. the request could wait until she has returned to
Personal data is anything that could be work to offer your best wishes.
• U
 sing customer lists with unclear
used to identify someone, either directly or
contact preferences
indirectly, such as a name, email address,
phone number, or credit card number.
Sensitive personal data includes racial or
ethnic origin, political opinions, religious or
Find Out More
philosophical beliefs, sexual orientation,
genetic data, or biometric data.
HP Global Master Privacy Policy

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Our Company TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED

Our Company
27 Protect our assets
29 Keep accurate records
31 Avoid conflicts of interest
33 Do not trade on material
non-public information

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Protect
Safeguard sensitive information.
Information about our company, products, Act with Integrity
customers, business partners, suppliers, and
our processes is our most valuable asset. Q: I have noticed a colleague visiting

our assets
To protect our sensitive information, always websites with explicit content. Maybe
label it properly, use only for business I am just too sensitive. Is it OK to visit
purposes, share only with those who have a inappropriate websites as long as you
legitimate business need, are an authorized do not share them with others?
party, and/or have a signed confidential
agreement, and properly store or dispose A: No, it is not OK. HP systems are meant
What We Do of it. for business use and should never be
used to access inappropriate websites
Preserve our competitive Safeguard intellectual property (IP). Be or information. Share your concerns
advantage in the marketplace. proactive in protecting intellectual property with your manager or another
from loss, theft, or accidental disclosure. internal resource.
How We Do It Never discuss HP intellectual property on
social media, share it without an appropriate
Safeguard our physical assets. It is non-disclosure agreement in place, or take it
important to do your part to protect HP with you if you leave HP.
assets, including phones and computers, Watch Out For …
from theft, loss, damage, and waste. What is Safeguard the HP brand. The HP brand is • B
 orrowing or using HP assets
Never use them to promote your personal
interests or allow other people, including “intellectual property?” our corporate identity and an integral part without approval
of our intellectual property. Each of us has
friends or family, to use HP resources. • S
 ending work emails containing
a duty to protect the brand by following
Additionally, you should follow HP sensitive information to your
the brand standards.
procedures for reuse, redeployment, personal email account
It includes:
and return of all work equipment upon
leaving HP. • Trade secrets and trademarks • D
 iscussions about sensitive
information in public places,
• Patents
Safeguard our electronic assets. Be • Copyrights Find Out More such as planes, elevators,
and restaurants
responsible in your use of HP hardware,
software, voicemail, and email. Keep • Business plans HP Conflicts of Interest Policy • U
 sing HP assets to conduct
personal use to a minimum and never use • Engineering ideas non-HP business
our systems to violate the law or to create, HP IT Policies
store, or send content that others might • Customer lists
find offensive. HP Brand Guidelines and Tools

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Keep accurate
Stay alert. If accessing records is a
regular part of your job, watch for any Act with integrity
irregularities that might signal fraud,
bribery, or other illegal activity, such as: Q: In compiling some end-of-quarter

records
false entries, discrepancies, omissions, data, my manager directed me to
misleading entries, or unrecorded funds. change information on an invoice that
Raise a Concern about any unusual I don’t think is accurate. She did not
activity immediately. Employees who have provide me with any documentation to
questions about records should contact support this change. What should I do?
either the Records Information Management
What We Do team or their department’s Records
Coordinator or Records Officer.
A: You have a responsibility to be
honest and accurate and to record
Make business decisions information in a way that fully and
based on complete and Preserve materials subject to legal hold. accurately reflects every transaction.
Ask your manager for the supporting
accurate information. Do not delete or destroy any records or
documentation. If she does not
materials that are subject to a legal hold,
or relate to the subject matter of an ongoing provide it, report the issue to another
How We Do It litigation, investigation, or audit. Be sure member of management or
Insist on accurate business records. You must not: to suspend any manual or automated internal resource.
Accurate records are essential to how we practices that might lead to the deletion
manage our business, maintain compliance • E
 stablish any off-the-books funds or destruction of any such records or
with financial reporting regulations, and or undisclosed or unrecorded assets materials. Employees departing HP whose
uphold credibility with both our customers
and our stakeholders. Create business
or liabilities records are on legal hold, or the managers
of such employees, must contact the
Find Out More
• Backdate contracts or other documents
records that accurately reflect the truth Litigation Department prior to deleting or
• Create side letters or side agreements HP Accounting and Finance Manual
of the underlying transaction or event. destroying any information.
Ensure the financial policies and reporting • S
 ign documents that you are HP Global Master Records and
guidelines in the Accounting and Finance not authorized to sign Information Management Policy
Manual are followed. Where required,
• A
 lter records or make false or
obtain approvals and be prepared to
misleading entries
provide supporting documentation.
Business records are valuable HP information
assets that are created, received, and
maintained as evidence of HP’s business
What are transactions or compliance with legal
obligations. They can include time sheets,
business records? purchase orders, invoices, expense reports,
invoices, emails, or regulatory filings.

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Avoid conflicts Act with integrity


Q: I am planning to start a side business,

of interest
marketing a product that I developed on
my own time. Are there any conflicts of
interest concerns with this?

A: It depends on the nature of the


product. As long as it does not
What We Do compete with what HP sells and you
do not use HP’s time, resources, or
Make decisions in the business relationships in support of
best interest of HP. your business, it is likely OK. The best
strategy is to review the HP Conflicts
How We Do It of Interest Policy, disclose your
plans to your manager, and obtain
Proactively address potential conflicts of Some situations involving potential conflicts approval in writing, if needed. And
interest. We all have activities, interests, of interest include: remember, any outside pursuit should
and relationships outside of HP, but not interfere with the time, talent, or
they should never influence or appear • O
 utside employment—or conducting passion you bring to your work at HP.
to influence the decisions we make as non-HP business—with an HP
employees on behalf of HP. It is your business partner, supplier, channel
responsibility to recognize situations that partner, or customer
could be perceived as a conflict of interest
and avoid or address them. If you are
• I nvesting or having a financial interest
in an HP business partner, supplier, Find Out More
unsure, discuss the situation with your channel partner, or customer
manager, and consult HP’s Conflicts of HP Conflicts of Interest Policy
• F amily or close personal relationships
Interest Policy. within HP
• P
 ursuing a business opportunity
for yourself that you learned about
through your work at HP
• S
 ervice on a board of directors or as
advisor of an organization whose
interests conflict with HP

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Do not trade on What could be considered


“inside information?”
Find Out More
HP Confidential Information Policy

material non- Information like:


HP Insider Trading Policy

public information • Financial earnings


• Forecasts
• New product offerings
• Business strategies
What We Do • P
 otential mergers, sales,
Protect confidential or acquisitions

information and never use • Changes in management

it to make trades or tip others.

How We Do It Act with Integrity


Know what to protect. Material, non-public Do not trade or tip on it. If you come across
information is any information about HP or inside information through your work or
Q: My work involves mergers and
our customers or business partners that is through another person, even if it is just
acquisitions. I mentioned a possible
not publicly available, but might be useful something you overheard, do not trade
new acquisition to my husband over
to an investor. You might have access to on it. Do not share this information with
dinner, but cautioned him not to share
this information through your role, and it is anyone, including family or friends. This
the information with anyone else. Did
your responsibility to keep it confidential. activity is called “tipping,” which is another
I do anything wrong?
Using this kind of information to trade is form of illegal insider trading.
called insider trading, which is illegal and
unfair to other investors. Insider trading
A: Yes, it is important to keep inside
Understand the rules. Familiarize yourself information private, even from family
has serious consequences, including with the HP Insider Trading Policy. Even and friends. If your husband trades
potential civil and criminal prosecution of exercising employee stock options may be based on this information or shares
you and the company. considered a “trade,” so follow the rules the information with someone else
about quarterly trading restrictions and (“tipping”), he—and you—could
windows, and contact Global Legal Affairs violate our policies and the law.
if you have questions.
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Our Relationships TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED

Our
Relationships
37 Engage responsible
business partners
39 Never bribe or
accept kickbacks
41 Know the rules about gifts
and entertainment
43 Compete fairly
45 Putting customers first
47 Know the rules about
importing and exporting
49 Speaking on behalf of HP

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Engage responsible
business partners
What We Do
Hold our business partners to Act with integrity Find Out More
the same high standards we
Q: I just learned that one of our suppliers HP Global Procurement Policy
set for ourselves. was arrested for bribing one of their
customers. The allegation has not HP Sustainability Policy
How We Do It been proven, and it does not involve
Source responsibly. We must ensure that Communicate our expectations. We must HP. Should I do anything? HP Partner Code of Conduct
our partners share our commitment to comply with HP’s Global Procurement
A: Yes. Any potential violation of the law HP Supplier Code of Conduct
conducting business with integrity. HP’s Policy when engaging business partners.
business partners should uphold our high All contracts with business partners must by a third party is cause for concern.
You should share this information HP Contingent Worker Code of Conduct
standards in ethics, human rights, diversity, be in writing and must clearly describe
management, health, safety, and the their obligations and ours. We have a with your manager or Global Legal
environment. Our partners and suppliers responsibility to monitor contractual Affairs as soon as possible.
must meet our quality, delivery, service, and arrangements and promote compliance
pricing standards. with the law and our policies. Report any
concerns about violations of our policies It could be:
by business partners or suppliers, and
terminate contracts with partners who fail • A vendor
to address violations of our standards.
• A supplier

Who is considered a • A consultant


• A contractor
“business partner?” • A contingent worker
• A
 n agent or any third party doing
business on behalf of HP

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Never bribe or A bribe can take many forms including:

• A payment

accept kickbacks
• A gift
• A favor
Can You Recognize • A job offer
a Bribe? • An offer of entertainment or travel

What We Do Even a charitable or political contribution


could be considered a bribe if offered
Never give, request, or accept to influence a decision.
bribes, kickbacks, or improper
payments of any sort.

How We Do It
Do not put yourself or HP at risk. Report Do not make facilitation payments.
any request for—or offer of—a bribe or
kickback to your manager, Global Legal
A facilitation payment is a small payment
of cash or something of value made to a Act with Integrity Find Out More
Affairs, or the Ethics and Compliance Office. government official to secure or speed up the
performance of a routine government action. Q: A long-time, trusted supplier offered HP Global Business Amenities Policies
Any requests for a facilitation payment, or me a commission in exchange for
Maintain a zero-tolerance position.
any facilitation payments made under duress, securing an annual contract with HP HP Anti-Corruption Policy
Regardless of local practice or the practices
must be reported immediately. for his company. Is there any problem
of other companies, make sure you avoid
with this?
even the appearance of impropriety.
Never provide, offer, pay, ask for, or accept Monitor third parties. We are responsible for
anything of value in order to win business the acts of third parties conducting business A: Yes, a “commission” for doing
or improperly influence a decision—even on behalf of HP. When hiring third parties,
business is another word for a
if it means losing business. ensure that you follow approved onboarding
kickback or bribe, both of which
processes, set clear expectations, and
are unethical and potentially illegal.
Let the supplier know that this kind
actively manage their work. Guarantee our
of request violates HP policy and
commissions or arrangement fees will not
report the incident to your manager.
be used as bribes on our behalf. Report any
requests for or offers of bribes, kickbacks,
or payments of any sort to your manager,
Global Legal Affairs, or the Ethics and
Compliance Office.
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Know the rules How do I know if a


gift is acceptable?
Act with integrity
Q: An HP business partner who is bidding

about gifts and


on work in my department has
offered me his two tickets to a local
sporting event because he cannot
make the game. The tickets are not
Reasonable gifts offered in the normal course expensive. May I go?

entertainment
of business can be perfectly acceptable, but
any offer that creates a sense of obligation
A: No. Even if the tickets are
or compromises your professional judgment
inexpensive, accepting them
is always inappropriate. Do not take a risk—
would be inappropriate. Since the
always ask your manager or Global Legal
business partner is not attending
Affairs if you are unsure.
What We Do with you, this offer is considered a
gift. Because this gift was extended
Provide and accept gifts during a competitive bidding process,
and entertainment only accepting the tickets could suggest
Watch Out For … to others that the business partner is
when appropriate. trying to win your favor and therefore
• L avish or excessive gifts, meals, HP’s business. You must ensure
How We Do It travel, or entertainment that all business decisions are made
objectively and that there is not
Comply with our policies. Give and receive • A
 ppear reasonable and legitimate to • F requent giving or receiving of gifts, even the appearance of something
gifts, meals, travel, and entertainment only an outside observer meals, travel, or entertainment improper. Refuse the offer and report
if they comply with the HP Global Business • N
 ever be given in exchange for • G
 ifts of cash, gold, precious the incident to your manager.
Amenities Policy. Never give the impression something in return
that a business decision was made because
metals, gemstones, or any item
• Never be solicited or entertainment that is sexually
of something we gave or received. All gifts
explicit, involves gambling, or would
or entertainment must:
• B
 e consistent with the policies of
Meet our obligations. Make sure you obtain
any approvals required by our policies in
otherwise create embarrassment
for HP Find Out More
the giver or recipient, as well as advance of giving or receiving, and, where
HP policies • G
 iving or receiving gifts during a bid, HP Conflicts of Interest Policy
required by the policy, report to your
deal, or contract negotiation
• B
 e intended only to improve HP’s manager gifts, meals, or entertainment you
image, better represent products receive. Be aware that the rules for what you HP Anti-Corruption Policy
and services, or foster goodwill may give to government representatives are
in business even stricter than those in the commercial HP Global Business Amenities Policy
sector, and that rules for government
representatives vary by country. HP U.S. Business Amenities Policy
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Compete
Bid fairly. Bid rigging happens when
competitors manipulate bidding to limit Act with Integrity
competition. It can include comparing bids,
agreeing not to bid, or agreeing on who will Q: I was at an industry conference and,

fairly
submit the winning bid. If you are involved in during a lunch break, a group of
the bid preparation process, comply with the competitors started sharing pricing
law and our policies. information in an effort to level the
playing field for everyone participating
Market fairly. In talking with customers— in an upcoming bid for ABC Corporation.
whether in person or through our advertising, I did not participate in the conversation,
What We Do marketing, or sales materials—we provide since I knew it was wrong. Did I handle
only truthful information about our products. the situation correctly?
Win the right way, by marketing Do not make false or illegal claims about
responsibly and by competing our competitors and never use deception or A: You did not participate, and that is
vigorously and lawfully. misrepresentation to gain an unfair advantage good, but if you do not speak up about
over them. what happened, others may think
you were complicit in the discussion.
How We Do It Obtain business intelligence appropriately. The best action would be to stop the
Honor our legacy. At HP, we work fairly and We have a responsibility to protect confidential conversation, remove yourself from
passionately, competing based on the merits information of former employers and to the situation, and report the incident to
of our products and services and avoiding any honor any disclosure limitation to which you Global Legal Affairs. In addition, if you
conduct that could restrict fair trade. may be subject. Do not use or share with HP heard competitors’ pricing information,
any confidential information from a former you should not participate in HP’s bid
Follow the law and HP policies. Countries employer. Do not hide your true identity or ties for business with ABC Corporation.
around the world have antitrust and to HP when gathering information.
competition laws, and violations can result
in significant legal consequences for HP
Watch Out For …
and for you. Be sure you know and follow
the antitrust and competition laws in the
Find Out More
countries where we operate.
What’s an “improper” agreement?
HP Marketing and Sales Policies
Avoid agreements that discuss:
Avoid improper agreements. We conduct
• Fixing prices HP Confidential Information Policy
business ethically, never entering into any
agreement with a competitor, customer, • P
 reventing a company from
supplier, or other business partner, either entering the market
formally or informally, about pricing, costs • R
 efusing to deal with a
or terms or conditions of sale, wages, or the customer or supplier
division of customers, suppliers, or markets.
• L imiting production, sales,
or output
43 Our Relationships 44
Our Relationships TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED

Putting Act with integrity


Q: I received a large order from an

customers first
HP partner, and the partner has
requested a large discount. Since I
have done business with this partner
many times, do I have to market
responsibly and verify the end user?

What We Do A: Yes. To ensure that HP products do


not end up on the gray market, HP
Insist on quality. policies require verification that
there is a legitimate end-user for
How We Do It discounted deals and that the end-
user has a need for the quantity of
Meet or exceed industry standards … Market responsibly. We must represent our
the product listed on the order.
and customer expectations. We all have products and services fairly, accurately, and
a responsibility to deliver an exceptional truthfully. We must not create misleading
customer experience by embedding quality impressions in any advertising, marketing, or
in everything we do. We only promise sales materials, or in any presentations and
what we can deliver, and we deliver what
we promise. We use due diligence when
must not make false or illegal claims about
competitors or their products and services.
Find Out More
choosing a business partner or supplier to We protect the HP brand and marks and use
HP End-User Customer
ensure that they meet HP standards. And them only with the proper authorization.
Verification Policy
always remember that HP products stand
for quality. Do not gray market. We must use due HP Confidential
diligence in preventing situations that may Information Policy
lead to the gray marketing of HP products.
This includes complying with HP policies on HP Quality Policy
end-user customer verification.
HP Standard 014-0: Safe
and Legal Products

HP Standard 014-2:
Supplier Safe and
Legal Products

45 Our Relationships 46
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Know the rules


• U
 nderstand that all customers,
partners, and business transactions Rely on HP Global Trade
must be screened to confirm that
we do not engage in unauthorized This team is chartered with helping

about importing
transactions with sanctioned parties our businesses and functions
or countries subject to successfully learn, implement, update,
trade embargoes and comply with the necessary global
trade programs for each organization
within our company and in each

and exporting
country where HP does business.
Beware of requests to participate in Ask our Global Trade experts about
boycotts. Obtain and maintain the any issues related to the international
appropriate import, export, and customs trade of goods, services, and
documentation and records. Respond to technology. This ensures that the
requests related to trade-related boycotts appropriate internal controls are
What We Do only as permitted by HP Global Trade implemented in the organization
Policies. and documented in our business
Comply with applicable processes and procedures. All
laws as they relate to Comply with immigration laws. You
questions or instances of non-
international trade. have a responsibility to obtain proper
compliance should be immediately
authorizations (including work permits
escalated to the Global Trade team.

How We Do It and visas) for any countries in which you


work on behalf of HP.
Stay informed. As a global company, we Follow our processes. Operating a
must comply with all international trade multinational corporation requires us all to
laws and regulations to protect our ability be aware of, and abide by HP’s Global Trade
to buy, sell, and trade goods and services Policies. Across the company, we must: Find Out More
in countries around the world. Abiding by
global trade laws and regulations enables • C
 onduct the necessary due diligence HP Global Trade Policies
us to obtain and retain the government to ensure that our products are not
authorizations required to develop our used for sanctioned activities such HP Global Employee Mobility Policy
products and expedite deliveries to our as nuclear proliferation or prohibited
customers while avoiding significant weapons development
financial and criminal penalties for • R
 emember that every product and
non-compliance. service marketed by HP, along with
the related technical information,
must be reviewed and assigned
the appropriate import and export
classifications by the Global Trade
team prior to any transaction
47 Our Relationships 48
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Speaking on Act with Integrity


Q: I recently read a blog by an industry

behalf of HP
insider. He mentioned some features
about an upcoming HP product
release that was incorrect. I was
part of the team that developed the
product, and I am knowledgeable
about the product. Is it OK for me to
What We Do post a comment on his blog since I
have firsthand knowledge to share?
Allow only authorized
individuals to speak for A: No. You should refer information
about the blog to HP Corporate
our company. Media Relations at mediarelations@
hp.com and allow them to speak on
How We Do It HP’s behalf.
Rely on the experts. HP has designated In communications concerning HP,
individuals to speak on behalf of the you should never give the impression
company to ensure that all information that you are speaking on behalf of HP
disclosed about HP is accurate, consistent,
and complete. Unless you are authorized
unless you have been authorized to do
so. You should not disclose sensitive or
Find Out More
to do so, you should not make any public proprietary business information about
HP Confidential Information Policy
statements on HP’s behalf and should HP, our customers, suppliers, or other
refer all communications from investors, business partners, and never use slurs,
HP Global Social Media
analysts, and the media regarding HP insults, obscenities, or other wording that
Governance Policy
business to HP Investor Relations or HP might constitute a threat, intimidation,
Corporate Media Relations. harassment, or bullying.

Use social media wisely. In any online


communications (including user forums,
blogs, chat rooms, bulletin boards, and
other social media), you should understand
and follow HP’s policies regarding the use
of social media, and must make it clear that
your views are your own.

49 Our Relationships 50
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Our Impact
53 Respect human rights
54 Reduce our
environmental footprint
55 Make a difference

51 Our Impact 52
Our Impact TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED

Respect Reduce our


human rights environmental
What We Do
Conduct business in a way
that supports and respects
footprint
human rights. What We Do
Work to minimize our environmental
How We Do It
Respect fundamental rights and freedoms. Raise a concern. Any employee that believes
footprint and conserve resources.
Our commitment to upholding human rights he or she has been impacted adversely
is a core value at HP, shaping how we do or has observed an adverse human How We Do It
business worldwide. We believe all people rights impact is encouraged to report the Promote sustainability. We conduct business in Do your part. Understand how you can
are entitled to internationally recognized suspected violation to his or her manager a way that is environmentally responsible and contribute to sustainability at HP. This could
basic rights and freedoms. We promise or an internal resource. HP will conduct due complies with environmental laws, regulations, be through product design and development,
to respect the rights expressed in the HP diligence, promptly investigate allegations, and standards. We are constantly reinventing efficient use of resources, or participation
Sustainability Policy. and pursue action to mitigate any adverse how our products are designed, manufactured, in HP site or community environmental
human rights impact. and delivered to increase energy and materials initiatives or volunteer activities.
Live up to our values. We take steps to efficiency, promote reuse and recycling, and
advance the respect of human rights and do avoid materials of concern. We also support
not permit child, prison, forced, or trafficked
labor. We expect our suppliers to make the
Find Out More waste reduction, materials recycling, and
safe disposal of hazardous materials in the
Find Out More
same commitment and provide employees communities where we live and work.
HP Sustainability Policy HP Sustainability Policy
and suppliers with ways to report concerns.
Hold our supply chain accountable. Our suppliers HP Standard 011: General
are essential partners in improving HP’s carbon, Specification for the Environment
energy, water, and waste footprint. We comply HP Environmental Health and
with the terms of environmental permits and Safety Policy
authorizations and are proactive in ensuring that
our suppliers do the same. HP Sustainability Website
53 Our Impact 54
Our Impact TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED

Make a
difference
What We Do
Work in ways that are good
for us and the world.

How We Do It
Volunteer responsibly. You are encouraged There are processes and controls in place to
to take an active role in making a positive ensure company giving reflects HP’s core values
difference in your community, but make sure and business interests as well as to ensure that
your political or charitable activities remain these investments are properly classified. When
personal. Do not use HP’s resources without approaching HP for financial support, nonprofit
approval from HP to do so. organizations often use the terms “donation”
and “sponsorship” interchangeably. However,
Contribute responsibly. We encourageHP you there are legal and financial differences that
impact the ways in which we can engage with
Act with Integrity Find Out More
to make personal contributions to causes
and organizations you support. Do not nonprofits, and they are guided by distinct
Q: I have been asked to host a local HP Global Volunteerism Policy
pressure or solicit employees, business policies and processes. Please consult our
town hall event where candidates will
partners, or customers to contribute to or policies for more information.
answer questions about community HP Conflicts of Interest Policy
join your preferred charities, groups, or issues. Is it OK in my introduction to
political activities. Respect differing political views. If you engage share with the audience where I work HP Global Charitable Contributions Policy
in civic activities or share political views, do not and what I do?
Know our policies surrounding donations use HP’s time to do so and make it clear that HP Political Participation Policy
and sponsorships. HP supports strategic your perspective is your own. HP Government A: This might be OK. Reach out to
investments designed to address social Relations is solely responsible for managing the Government Relations team HP Sponsorship Policy
needs in the communities where we political contributions (including donations of in advance, and if approved, make
operate and advance HP business and products, services, transportation, and facilities) sure your participation in the event
market interests. on behalf of HP. You must also obtain approval complies with our policies.
from this team before lobbying a government
55 Our Impact official or engaging a lobbyist. 56
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Closing
Thoughts from
Michelle VonderHaar
We want HP to be a company known for
its ethical leadership—a company where
employees are proud to work; a company
with which customers, partners, and
suppliers want to do business.
The global business environment in which HP operates
presents many challenges and can put employees in difficult
situations that may push the boundaries of ethical practices.
Integrity at HP helps address those situations. With its
embedded tools, links, and avenues for raising questions, it
is designed to provide you with the guidance and confidence
you need to make the right choice, no matter where you are
located in the world. It is up to you to choose the right action.
The next time you face a difficult situation ask yourself, “Am
I acting ethically?” before you make that decision. We are all
accountable to make winning the right way a reality.

Michelle VonderHaar
Deputy General Counsel and
Chief Ethics and Compliance Officer
58
57 Closing Thoughts from Michelle VonderHaar
Our Resources TABLE OF CONTENTS RESOURCES LAST PAGE VIEWED

Our
Resources
HP Human Resources HP Ethics and Global Legal Affairs Waivers and updates to
Contact Human Resources
Compliance Office Contact Global Legal Affairs
Integrity at HP
Integrity at HP is the new name for the HP
Email: integrity@hp.com Standards of Business Conduct (the “SBC”). For
all purposes, Integrity at HP serves as our HP
Mail: HP Inc. Standard of Business Conduct.
Ethics and Compliance Office Corporate
1501 Page Mill Road
Local Integrity Mailstop 1560 Affairs HP understands and respects your rights as an
employee. Keep in mind that nothing in Integrity
Palo Alto, CA 94304-1112 Media inquiries can be sent to at HP is intended to interfere with your right to
at HP Team United States mediarelations@hp.com speak publicly about matters
of public concern or to engage in activities that
Contact Local Team
are protected under Section 7 of the U.S.
National Labor Relations Act. This includes
communicating about wages, hours, and other
terms and conditions of your employment.
HP GuideLine,
a 24/7 resource Integrity at HP will be disclosed to shareholders
and made available on the HP website. HP is
From the U.S. and Canada: 800-424-2965
Business Group Outside the U.S. and Canada:
committed to keep Integrity at HP up to date
and may periodically make updates as needed.
or Region Integrity The provisions of Integrity at HP are in addition
to, and do not modify, replace, or supersede
1. Go to AT&T Access Codes.
at HP Liaison HP’s other policies or procedures.

Contact Liaison 2. Find your country in the alphabetical listing.


Only our General Counsel may grant exceptions
3. Dial the AT&T Direct Code. or waivers to this document for employees and
non-executive officers. The Board of Directors
4. When prompted, dial 800-424-2965. must approve any waivers for directors or
executive officers and must properly disclose
59 Our Resources such waivers to the public. 60

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