Delivering Excellence

DXC’s Code of Conduct

Committing to our
values and our Code to
make a positive impact
across the globe

DXC Public
Delivering Excellence | DXC’s Code of Conduct

Table of contents
Our values 3 Use artificial intelligence responsibly 24
for Colleagues
Message from our president and CEO 4 Take a stand against corruption 25
No excellence without integrity 5
Delivering excellence for our investors 26
Everyone. Everywhere. Every day. 6
Avoid conflicts of interest 27
Leading with integrity 7
Choose integrity 8
Use company systems and resources responsibly 28
The Code is our guide to
Protect our confidential information and 29
Speak up, DXC! 9 intellectual property delivering excellence with
Delivering excellence for our colleagues 10 Respect others’ intellectual property rights 30 integrity for those who
Respect and encourage each other 11
Create and maintain accurate records 31 depend on us.
Record time and charge costs honestly 32
Value our diverse contributions 12
Safeguard inside information 33
Nurture talent 13
Create shared value through sustainable 34
Promote wellness at work 14
operations
Safeguard personal data 15
Delivering excellence with our partners 35
Delivering excellence for our customers 16
Source responsibly 36
Deal honestly and keep commitments 17
Select trusted partners 37
Safeguard customer data 18
Outperform competitors fairly and honestly 19 Delivering excellence for our communities 38
Gain an ethical edge 20 Communicate with one voice 39
Understand special requirements of government 21 Engage responsibly in the political process 40
customers Respect and protect human rights 41
Cross borders with care 22 Invest in our communities 42
Give and receive appropriate gifts and 23 Closing message from our chief ethics and compliance 43
hospitality officer
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OUR VALUES GUIDE CHOICES AND INSPIRE BEHAVIORS Be smart.

Don’t assume.
THAT DELIVER EXCELLENCE Don’t guess.
Check the Code.
DXC Technology is an IT services company that uses the power of technology to build better futures for our customers,
colleagues, communities and the environment. To achieve our purpose, we foster a positive, inclusive and supportive
culture defined by our values.

We believe the following five values best express who we are, what we stand for and how we show up for our
customers, colleagues and communities.

Deliver Care
We do what we say We take care of each
we are going to do. other and foster a culture
of inclusion and belonging.

Do the right Collaborate

thing We work as a team —
globally and locally.
We act with integrity.

Community
We believe in stewardship
and building a sustainable company
that supports our communities.

Our values are integrated throughout Delivering Excellence: DXC’s Code of Conduct. Together with our purpose,
the values inform our goals and point us to our destination. The Code helps us get there, navigating complexity,
uncertainty or potential risk along the way.
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Message from our

president and CEO

Dear colleagues,
We can feel inspired and proud to work for a company that uses the power of technology to build better futures
for our customers, colleagues, communities and the environment.

By focusing on how we pursue our purpose as well as what we do, we strengthen our culture, relationships and
reputation. By growing trust, we will grow DXC in ways that make our business sustainable, resilient and admired.

Our Code of Conduct helps us connect our values with the decision making and behaviors that will grow trust
“Our Code of Conduct helps and reduce risk. We must all be familiar with and follow the Code and speak up whenever we have a question

us connect our values with or concern. Please commit to doing this, connect the Code with what you do every day, and put it into practice
to deliver excellence for our customers and colleagues.
the decision making and Sincerely,
behaviors that will grow Raul Fernandez

trust and reduce risk.” President and Chief Executive Officer

DXC Technology
— Raul Fernandez
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for our colleagues for our customers for our investors with our partners for our communities

No excellence without integrity

Why the Code matters
At DXC, we deliver excellence for our customers and colleagues. Excellence means being truly the best — not only at what we do, but also at how
we do it. The way in which we accomplish our goals is as important as whether we accomplish them; understanding this helps us do the right thing.

A goal achieved the wrong way — by disregarding our values, legal obligations or ethical principles — is not really achieved at all. In fact, it undermines
The Code is a practical guide that everything we stand for. We can claim to be excellent only if our decisions and actions — as well as the product of our work — are beyond reproach.
helps us identify and understand That’s why knowing and following our Code is so important.
ethical and legal compliance
How the Code is organized to help us
considerations that may
The Code is a practical guide that helps us identify and understand ethical and legal compliance considerations that may arise in our work. The Code
arise in the course of cannot anticipate or explain every situation, but it highlights key commitments and expectations, as well as areas of potential risk that require special care.
our work.
For consistency and ease of use, each topic in this guide is structured as follows:

COMMIT A brief, memorable statement of principle indicating the standard to which we hold ourselves in the relevant area

CONNECT  hree short paragraphs that connect the Code’s expectations and requirements to DXC’s values and culture, our customers and business,
T
and building trust and reputation — establishing the everyday relevance and importance of the Code

DELIVER A list of key actions that help us put our values into practice and deliver excellence with integrity

Who the Code applies to

The Code applies globally to all directors, officers, executives, employees and representatives of DXC, its wholly owned subsidiaries and their affiliates, subject
to applicable laws and regulations. It also applies in certain respects to business partners, such as suppliers, contractors, consultants, representatives and
agents. We are all expected to be familiar with and follow the Code. A violation of the Code is a serious matter that may result in disciplinary action.

Waivers and amendments

In rare circumstances, to avoid unintended consequences or hardship, we may consider a waiver of a requirement of the Code. DXC’s vice president
and chief ethics and compliance officer may grant a waiver to a DXC employee, other than an executive officer. Any waiver or modification of this
Code for an executive officer or member of the Board of Directors (Board) must be approved by DXC’s Board and promptly disclosed, as may be
required by laws and regulations, including the rules of the New York Stock Exchange (NYSE) and U.S. Securities and Exchange Commission. Any
material amendment of this Code must be approved by the Board.
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for our colleagues for our customers for our investors with our partners for our communities

Everyone. Everywhere. Every day. We all have an obligation

to maintain the knowledge
At DXC, we strive for growth: growing ourselves, our teams, our customers and our company. We know that growth is sustainable only if we achieve it the
right way, consistent with our values, the Code and the law. Making sure we do this is a shared responsibility, regardless of our role, seniority or location. and skills necessary to
We fulfill this shared responsibility when we:
perform with excellence.
• Embrace and exemplify DXC’s values. Our values guide our decisions and actions; they may not give us all the answers we need, but they help us
ask the right questions to identify ethical issues and seek help.

• Know and use the Code. The Code is much more than an introduction for new hires and an annual refresher for everyone else. It provides essential
information and resources relevant to our everyday work. We should consult it as needed.

• Are open and inclusive. We discover opportunities for collaboration and growth when we are receptive to others’ ideas and perspectives. An open
and inclusive mindset injects fresh energy and rigor into our thinking, which benefits us all.

• Resist pressure to do anything that feels wrong. No one has the authority to make any of us do something that violates this Code.

• Invest in learning and skills development. We all have an obligation to maintain the knowledge and skills necessary to perform with excellence.
This includes timely completion of required training.

• Speak up with ideas, questions and concerns. Any of us can have a great idea that can make things better for our company or customers.
Asking questions promotes alignment and collaboration. When we see or suspect anything that raises a concern, speaking up is the right thing to do.

The Code is designed to be

a practical guide; it helps
us identify and understand
ethical and legal compliance
considerations that may arise
in the course of our work.
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for our colleagues for our customers for our investors with our partners for our communities

Our success and growth

depend on the trust we Leading with integrity
build together.
Leaders have a special responsibility to care for DXC’s culture and values. Leaders should promote an inclusive and collaborative work environment
for our teams.

As a leader or manager, the way you make decisions and handle concerns, differences of opinion and even bad news sets the foundation for trust
with your teams, customers and stakeholders. Our success and growth depend on the trust we build together.

We have an impact that matters when we:

• Communicate integrity. Regularly communicate that how we do things matters as much as what we do. Be clear that DXC’s values are important and
that you expect work to be done ethically.

• Model ethical leadership. Anyone, at any level, can demonstrate ethical leadership through their decision making and actions. When you have a formal
leadership role, remember that your teams will constantly look to you for ethical cues and guidance.

• Ask questions. Remind your teams regularly of the importance of doing the right thing; tell them that for results to matter, they must be achieved the
right way. Asking questions will help to satisfy you that everyone is operating with integrity.

• Look and listen. As a leader, it is critical that you coach and care for your teams. Make sure they know you will listen, even if they have something difficult
to say. Look for and respond to signs that team members need support.
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for our colleagues for our customers for our investors with our partners for our communities

Choose integrity
Doing the right thing is a choice — and we always have a choice.
Striving for excellence isn’t always easy. Situations can be complex, risks may not be obvious, and we may be balancing competing interests.
One thing is always clear, however: If we are concerned about a situation or unsure about the right course of action, we must set ourselves up to make the right choice.
It can help if we take three simple steps: Pause. Think. Ask.

PAUSE THINK ASK

A short pause can save a lot of trouble. It allows you to: You are not expected to resolve the issue by yourself, but you can Asking questions and seeking help from colleagues with
help avoid unnecessary harm. Ask yourself whether the situation or the necessary expertise is the best way to ensure we make
• Check your instincts. Does someone or something make you
proposed course of action is consistent with: the safe, ethical choice. For a list of channels and resources
feel uncomfortable?
for getting help, see the next page.
• Take a breath. Do you sense potential risk? Are you feeling • DXC’s values. Our values remind us of who we are, what we
pressure to do something that you think may be wrong? Slow stand for and how we do things at DXC. If something seems
down; give yourself time to think. inconsistent with our values, it is probably something we
should not do.

• The Code and DXC’s policies. These important documents

reflect not only our values, but also our legal and ethical
obligations. Violating the Code or our policies is never acceptable.

• Our desired culture and reputation. If this is not something we

would want everyone doing, don’t do it. If it could undermine trust
or damage DXC’s reputation, don’t do it.
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for our colleagues for our customers for our investors with our partners for our communities

Speaking up is how Speak up, DXC!

we keep ourselves
At DXC, we are all empowered to speak up — with ideas, questions and concerns. Doing so benefits our business and work environment in several ways.
accountable for living our
As a company committed to innovation and continuous improvement, we encourage everyone to share ideas on how we can do things better or deliver
values and maintaining a excellence for our customers and colleagues in new and improved ways.
strong ethical culture.
When we ask questions, we promote the clarity and alignment needed to collaborate effectively. Questions can also reveal perspectives and opportunities
that we might otherwise have missed.

When colleagues raise concerns, it allows us to proactively identify and manage risks, avoid or address problems, and prevent situations from escalating.
Most importantly, speaking up is how we keep ourselves accountable for living our values and maintaining a strong ethical culture.

Speaking up is …

Easy
Anytime you have a question or concern or face a situation where the course of action is not clear, speaking with your direct supervisor is usually the
best first step. If you are uncomfortable doing so or if the issue involves your supervisor, other reporting options include:

• Your supervisor’s manager

• SpeakUp Line

• SpeakUp mailbox

• Human Resources

• DXC Response Operations Center (DROC)

• DXC Legal

Speaking up is …

Safe
Resources:
Anonymous reporting is available via the SpeakUp Line, where allowed by local law.
Case Management &
DXC has zero tolerance for retaliation in any form. It is prohibited by the Abusive Conduct & Harassment Policy. Investigations Policy

DXC will take disciplinary action, up to and including dismissal, against anyone found to have engaged in or Global Whistleblowing
tolerated retaliation. Policy

Speak up. It’s the right thing to do.

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for our colleagues for our customers for our investors with our partners for our communities

Delivering excellence
for our colleagues
builds a caring culture of collaboration and trust
in which we can succeed together.

Respect and encourage each other

We treat others as we wish to be treated, so that we can be ourselves and give our best effort.

Value our diverse contributions

Our different talents, backgrounds and perspectives make us stronger, smarter and more creative
together.

Nurture talent
We give everyone a fair chance to succeed and grow, based on their merits, performance and
potential.

Promote wellness at work

We prioritize our physical and mental well-being so we can all perform at our best.

Safeguard personal data

We protect the privacy of our personal data by sharing it only with those who have a business
need or legal right to receive it.
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for our colleagues for our customers for our investors with our partners for our communities

Leading by example Respect and encourage each other Zero tolerance

DXC has zero tolerance
for harassment and
I have noticed that our project team leader regularly
compliments my colleague’s hair, clothing or jewelry. My COMMIT We treat others as we wish to be treated, so that we can be ourselves and give abusive conduct or
our best effort. bullying.
colleague confirmed to me in private that the attention
was unwelcome and embarrassing, but she had decided We can prevent harassment
to ignore it. The team leader then pinged her, noting that CONNECT Values and culture
by treating others with dignity
they lived only 20 miles apart and should get together in Our Care value reminds us to be caring and inclusive. This helps create a positive and supportive and respect. We use care in
person for the first time. Being new and relatively junior, culture that empowers excellence. our interactions and avoid
my colleague is reluctant to complain about the leader; behavior that creates an
Customers and business
she thinks he will eventually lose interest. I don’t think she intimidating, offensive or
should have to tolerate this. I don’t want to do anything Positive interactions with colleagues translate into great customer service and experiences. hostile work environment.
against her will. What should I do? Trust and reputation Harassing behavior and
Treating colleagues and customers well builds trust and promotes collaboration; it also enhances language can include:
DXC’s reputation as an employer of choice.
• Offensive images or
If the attention from the project team leader is
comments, such as
unwelcome and embarrassing, it can be harassment DELIVER We deliver excellence when we:
suggestive pictures, racial
and is unacceptable. We do not tolerate harassment
• Listen well and assume positive intent slurs or religious jokes
or abusive conduct. If your colleague is comfortable
doing so, she should tell the project team leader that • Consider how others might perceive our words and actions • Aggressive pressure and
she is uncomfortable with his conduct. Alternatively, intimidation, whether verbal,
• Never mock or belittle others based on race, color, age, sex or any physical or visual
she can report the matter to her manager, HR, Legal or
other characteristic protected by law
DXC Integrity. If she is reluctant to act, then you have a • Sexual harassment, such as
responsibility to address the conduct — either with the • Don’t tolerate degrading or intimidating behavior unwanted sexual advances,
project team leader directly (based on what you have unwanted touching, crude
• Watch for signs that others are being harassed or bullied
noticed) or by reporting the matter yourself. remarks or offering of
Resources:
employment-related favors
Abusive Conduct & in exchange for sexual
Harassment Policy contact
Global Diversity and
Non-Discrimination
Policy
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for our colleagues for our customers for our investors with our partners for our communities

Value our diverse contributions Why diversity, equity and

inclusion matter to us
COMMIT Our different talents, backgrounds and perspectives make us stronger, smarter and Doing the right thing
more creative together. By valuing what makes each of us unique and giving
everyone a fair chance to contribute and thrive, we align
CONNECT Values and culture with our Care value.
Our Care value is about inclusion and belonging. It empowers us all to bring our true selves to work
Growing our business
and contribute value every day.
Our ability to understand and meet diverse customer needs
Customers and business depends on DXC’s own diversity.

With a global team as diverse as our customers’ needs, we can deliver the right solution every time. Fueling innovation
Trust and reputation The ideas we bring to market are the result of a diverse,
inclusive team examining challenges and opportunities
Striving for a diverse and inclusive work environment is essential to becoming an employer of choice.
from every angle.

DELIVER We deliver excellence when we: Building trust

• Celebrate our differences as a source of collective strength and opportunity When we demonstrate that we share our customers’ and
business partners’ commitment to diversity, equity and
• Promote an equitable work environment in which we recognize and respond to colleagues’
inclusion, we build mutual respect and trust.
diverse needs
Attracting and retaining top talent
• Allow everyone to feel included, valued and empowered to contribute
A work environment that makes our colleagues feel
• Examine our unconscious bias so we can make considered decisions and treat others fairly welcome, respected and valued inspires loyalty and effort
and grows DXC’s reputation as an employer of choice.
• Welcome ideas, opinions and approaches that may be different from our own to broaden our
perspective and deepen our insight Improving our communities
Resources: A diverse global workforce provides the community insights
• Speak up when we think a point of view is being missed
Global Diversity and and connections that enable DXC to drive positive social
Non-Discrimination change around the world.
Policy
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for our colleagues for our customers for our investors with our partners for our communities

Leading by example Nurture talent

I was hired out of college last year, and I love working at
DXC. My first role enabled me to shine in areas that really
interest me, and I got a quick promotion. My new manager
COMMIT We give everyone a fair chance to succeed and grow, based on their merits,
performance and potential.
often seems uncomfortable or irritated if I ask questions
or offer opinions in meetings. I try to do so respectfully, but
CONNECT Values and culture
I’m afraid my manager thinks I’m overconfident. Lately, I’ve
We attract and nurture talent. This aligns with our Care and Collaborate values and our belief that
been excluded from some meetings that I participated in
every individual and team should reach their potential.
previously. It seems unlikely, but my friend suggested that
the manager might feel threatened by me. How should I Customers and business
address this?
We serve our customers and investors well by hiring and promoting our people on their merits and
empowering them to give their best efforts.

Trust and reputation

At DXC, we develop our people and help them reach
their full potential. Whether younger or older, age We are committed to developing and advancing our people based on merit, free from favoritism,
is no barrier; on the contrary, we look to accelerate nepotism and unfair discrimination.
careers wherever we see talent. Discriminating against
a colleague based on age is illegal in many countries DELIVER We deliver excellence when we:
and is inconsistent with our values and culture. Tell your • Base hiring and promotion decisions on qualifications, performance and potential — never on
manager that you appreciate the opportunity to join the favoritism or bias
team and want to contribute whenever and however you
• Avoid discrimination based on any characteristics protected by law
can. You should ask if there is anything your manager
would like you to do differently since you are still learning • Provide reasonable accommodations for colleagues with disabilities or specific requirements
how to collaborate effectively. This should help build
• Maintain an agile workforce by emphasizing collaboration, communication and capability
trust, but if the situation does not improve, you should
development
raise your concerns with Human Resources or DXC Resources:
Integrity. Conflicts of Interest
Policy
Global Diversity and
Non-Discrimination
Policy
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for our colleagues for our customers for our investors with our partners for our communities

Promote wellness at work Take care of yourself

Balancing our work and personal lives can occasionally be
a challenge. At DXC, being conscientious should not mean
COMMIT We prioritize our physical and mental well-being so we can all perform at our best.
compromising our health and well-being. We can deliver
excellence only when we are at our best, physically and
CONNECT Values and culture
mentally. When we are tired or stressed, our judgment
We want a work environment in which everyone feels safe, energized and engaged. We look out for may be compromised and we can make mistakes, exposing
each other and try to maintain a healthy work–life balance. ourselves and DXC to risk. Taking care of ourselves is
Customers and business essential. If we are feeling stressed or burned out, it is okay
to take a pause. Here are several ways we can reenergize
Cultivating a work environment in which we can all thrive helps us deliver excellence for our customers
and refocus:
and colleagues.
Trust and reputation • Checking in regularly with teammates

Fostering a positive and supportive work environment promotes a sense of belonging and • Joining one of DXC’s Employee Resource Groups
engagement. This strengthens DXC’s reputation as an employer of choice. • Participating in DXC’s monthly well-being programming

DELIVER We deliver excellence when we: • Reaching out to our manager for support

• Follow all health and safety policies and guidelines at DXC facilities and customer sites • Blocking off time for personal and professional
development (DXC Learning offers many opportunities
• Maintain a work environment in which we can be safe and productive, no matter where we are for this)
working
• Incorporating mindfulness exercises into our day, such as
• Create space for colleagues to feel comfortable in requesting help or advice short meditation sessions or breathing exercises

• Practice active listening and try to be empathetic with colleagues • Taking short breaks to integrate movement and exercise
into the workday
• Recognize that we can all make mistakes and treat them as an opportunity to learn and grow

• Support colleagues as we wish to be supported so that we can feel fulfilled at and away from work Resources:
Health and Safety Policy
• Speak up about accidents or near-misses, suspected hazards, and unsafe or unhealthy conditions
or behaviors Human Rights Statement
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for our colleagues for our customers for our investors with our partners for our communities

What is personal
Leading by example Safeguard personal data data?
My role frequently involves handling the personal Personal data is any information
that relates to a specific person.
information of DXC colleagues and business partners. I
routinely receive and work on spreadsheets containing
COMMIT We protect the privacy of our personal data by sharing it only with those who have
It can include:
a business need or legal right to receive it.
personal data: first and last names, phone numbers, home • Contact information, such
addresses, and government-issued identification numbers.
CONNECT Values and culture as full name, home address,
telephone number or email
May I email one of these spreadsheets to an approved DXC
At DXC, our Care and Do the Right Thing values compel us to protect personal data. Preventing its address
vendor, provided I password-protect or encrypt the file?
unauthorized disclosure helps our colleagues feel respected and safe.
• Employment data, such
Customers and business as performance ratings,
salary, benefits, time entries,
The privacy laws of various countries in which DXC The same strong security controls we maintain for internal data equip us to protect our customers
skill profile and utilization/
operates have strict requirements on the sharing and/or and business partners. billability (unless aggregated)
transfer of personal information. In some cases, we may
Trust and reputation • Unique identifiers, such as
be required to complete an assessment of the impact
employee ID, social security
of the data transfer. In this situation, however, sending When we are committed to safeguarding all personal data as if it were our own, we build DXC’s
number, biometrics (e.g.,
encrypted and password-protected spreadsheets to an reputation as a reliable, trustworthy company.
fingerprints) or anything else
approved vendor could be permissible. To be certain, that could be used to identify
you should consult with Global Data Protection for DELIVER We deliver excellence when we: someone
advice on your specific case. • Communicate transparently about why and how personal data is collected, used and stored • Financial, medical or
• Collect only the personal data that is needed for a specific business purpose, store it securely demographic data
and dispose of it when it is no longer needed

• Protect personal data by sharing it only with those who have a legitimate business need and legal
right to access it

• Adopt DXC security policy controls when storing or transferring personal data to prevent
Resources:
opportunities for unauthorized access
Enterprise Employee
• Follow all DXC privacy and security policies, as well as contractual requirements Privacy Notice

Global Privacy and Data

Protection Policy
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for our colleagues for our customers for our investors with our partners for our communities

Delivering excellence
for our customers
strengthens our relationships and reputation and is
the springboard for shared success and growth.

Deal honestly and keep commitments

We are fair, transparent and truthful in all our business dealings.

Safeguard customer data

We protect our customers’ confidential business information and personal data as if it were our own.

Outperform competitors fairly and honestly

Delivering excellence every time is our competitive edge.

Gain an ethical edge

We are smart and ethical in monitoring our competitive landscape.

Understand special requirements of government customers

We are proud to serve government customers around the world and comply fully with the specific requirements and laws that apply to them.

Cross borders with care

As a global company, we follow all international trade laws affecting the movement of materials, people and data.

Give and receive appropriate gifts and hospitality

We win business and build relationships based on trust and mutual benefit, giving and receiving gifts and hospitality appropriately.

Use artificial intelligence responsibly

We embrace the possibilities of artificial intelligence while taking care to avoid unintended consequences of its use.

Take a stand against corruption

We win the right way — or we walk away.
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for our colleagues for our customers for our investors with our partners for our communities

Being fair and truthful with

our business partners Deal honestly and keep commitments
promotes dependable
relationships that help us
deliver excellence. COMMIT We are fair, transparent and truthful in all our business dealings.

CONNECT Values and culture

Doing what we say we are going to do is at the heart of our Deliver value. We hold ourselves
accountable for meeting our commitments.

Customers and business

Truthful and accurate communication about our products and services is essential to meeting
commitments to our customers. Being fair and truthful with our business partners promotes
dependable relationships that help us deliver excellence.

Trust and reputation

Treating customers, colleagues and business partners fairly and being transparent with them is
the right thing to do. It enhances our reputation as a company that places trust above transactions.

DELIVER We deliver excellence when we:

• Market and sell our products and services honestly, based on their merits

• Prepare bid proposals based on properly estimated cost and pricing data

• Always maintain the integrity of the bidding process and negotiate contracts in good faith

• Focus on the positive attributes of our offerings, rather than disparaging competitors

• Require all our business partners to follow these requirements

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for our colleagues for our customers for our investors with our partners for our communities

Safeguard customer data Our Deliver value means that

we are transparent with our
customers about how we
COMMIT We protect our customers’ confidential business information and personal data as process and protect the data
if it were our own.
they entrust to us.
CONNECT Values and culture
Our Deliver value means that we are transparent with our customers about how we process and
protect the data they entrust to us.

Customers and business

To deliver excellence for our customers, we require access to confidential business information and
personal data owned by them or their own customers. We take great care to protect this data, as we
appreciate how precious it is.

Trust and reputation

We are doing much more than safeguarding data; we are securing the future for our customers and
DXC while building our reputation as a trusted partner.

Resources:
DELIVER We deliver excellence when we:
Global Cyber Security
• Are transparent with our customers about why and how personal and confidential business page on myDXC
information is collected, used and stored
Information Security
• Collect only customer data that is needed for the specific service or solution we are delivering Policy

• Store customer data securely and dispose of it in accordance with customer requirements Global Privacy and Data
Protection Policy
• Share customer data only with DXC colleagues or business partners who have a legitimate
business need to access it Records and Data
Management Policy
• Educate ourselves on appropriate safeguards when storing or sharing customer data to minimize
DXC Resiliency page on
opportunities for unauthorized access
myDXC
• Access customer data only through DXC- or customer-approved systems using the required
Security Awareness
security controls
Handbook for DXC
• Follow all relevant DXC policies and standards Personnel
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for our colleagues for our customers for our investors with our partners for our communities

How we win matters as Outperform competitors fairly and honestly

much as what we win in the
marketplace; our values guide
our success. COMMIT Delivering excellence every time is our competitive edge.

CONNECT Values and culture

How we win matters as much as what we win in the marketplace; our values guide our success.

Customers and business

Individuals and teams giving their best is how we deliver excellence for customers. It differentiates
our services and solutions and enables us to grow with our customers.

Trust and reputation

We believe in free and fair markets and compete vigorously and ethically to build our brand and
reputation.

DELIVER We deliver excellence when we:

• Recognize that competition (antitrust) laws are complex with severe penalties for violations

• Act independently and not in coordination with competitors unless there is a legitimate business
arrangement (e.g., a joint venture or teaming relationship)

• Avoid any formal or informal agreements with competitors that limit competition

• Respect competitive bidding processes, and do not rig or fix the outcomes or help anyone else do so

• Seek approval from Regulatory Compliance before participating in trade associations and other
groups that require frequent contact with competitors

Resources:
Fair Competition Policy
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for our colleagues for our customers for our investors with our partners for our communities

Gain an ethical edge Understanding how we can

serve customers better than our
competitors is not about spying
COMMIT We are smart and ethical in monitoring our competitive landscape.
and stealing secrets; it comes
from the insight and imagination
CONNECT Values and culture
Our Do the Right Thing value means only seeking out information about competitors that we can
we bring to publicly available
acquire ethically. information.
Customers and business
Understanding how we can serve customers better than our competitors is not about spying and
stealing secrets; it comes from the insight and imagination we bring to publicly available information.

Trust and reputation

At DXC, we lead by example; we will never compromise our integrity to gain an advantage through
illegal or unethical means.

DELIVER We deliver excellence when we:

• Seek market information only through public sources, such as news media, industry surveys,
financial reports and publicly accessible internet sites

• Never ask current or former employees of a competitor to reveal confidential or proprietary

information

• Never use dishonest, deceptive or invasive tactics to obtain competitive intelligence

• Educate market research partners about the importance of acquiring information legally
and ethically
Resources:
Fair Competition Policy
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for our colleagues for our customers for our investors with our partners for our communities

Every last detail Understand special requirements of

We strive to deliver excellence for all our customers, government customers
so why might there be special requirements when
we are serving governments?
COMMIT We are proud to serve government customers around the world and comply fully
with the specific requirements and laws that apply to them.
As a government contractor, we have earned special trust
and status, which come with additional responsibilities.
We often provide critical infrastructure services or support
CONNECT Values and culture
Serving government customers honors both our Deliver and Community values. We bring the
initiatives that are vital to national security.
technology and expertise that support public infrastructure and services across the world.

Some DXC colleagues have the highest levels of government Customers and business
clearances, and our facilities also need to be secure. We understand that government contracts often have very different requirements from those of
We must follow the detailed contracting and delivery commercial contracts, with severe penalties for noncompliance.
requirements. Failing to meet our obligations precisely
Trust and reputation
could expose us to significant penalties, legal liability and
even debarment from future government work. By earning and preserving the trust of our government customers, DXC can make a positive difference
in the lives of tens of millions of citizens.
We go above and beyond to protect our reputation in the
marketplace to help our government customers improve DELIVER We deliver excellence when we:
life and business for their citizens.
• Know and follow the specific procurement, contracting and performance requirements of the
governments we serve

• Comply with all contract terms and required bidding, pricing and quality standards

• Protect secret, classified or otherwise confidential or controlled information

• Comply with relevant IT security, data and asset management policies and applicable regulations Resources:
Conflicts of Interest
• Charge time, travel, material and other expenses accurately; claim only allowable costs; and follow
Policy
appropriate accounting practices
Gifts and Hospitality
• Follow applicable laws, regulations and rules
Policy
• Ensure all government-required documentation is current, accurate and complete (e.g., proposals, Travel, Expense &
quotes, invoices, tests, certifications, communications) Reimbursement Policy

• Comply with restrictions on gifts, gratuities, job offers, etc. to government officials and their relatives
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for our colleagues for our customers for our investors with our partners for our communities

It is essential that we comply

with global trade regulations,
Cross borders with care Leading by example
especially those that restrict
I am a U.S.-based employee managing a team of
or ban DXC from doing
business with certain countries. COMMIT As a global company, we follow all international trade laws affecting the movement developers that serves banking industry customers. I
have family in Venezuela and need to visit an uncle who
Any export activities with of materials, people and data.
is seriously ill. I will be away for a couple of weeks. One
the following countries are
currently restricted: CONNECT Values and culture of our projects has entered a critical phase, and I need
to stay in touch to oversee the team. I’m aware that the
• Belarus We deliver excellence through our global resources and relationships. Complying with applicable trade
U.S. government has recently relaxed sanctions against
controls is the right thing to do, and it supports important economic and national security objectives.
• Crimea, Donetsk and Venezuela, but I’m not sure whether this means I can
Luhansk regions of Ukraine Customers and business travel there with my DXC laptop and phone.
• Cuba Collaborating internationally with customers, colleagues and business partners may involve materials,
• Iran data or people crossing borders. We must always follow whatever regulations affect these movements.
Any DXC employee who plans to work abroad should
• North Korea (Democratic Trust and reputation
first consult Global Mobility. In addition to work
People’s Republic of Korea)
By committing to following international laws and avoiding trade control violations, we grow our authorization, payroll, tax and other issues, there may
• Russia reputation as a trustworthy, long-term business partner. be limitations or a complete prohibition on working in
• Sudan certain countries because of sanctions. Whether you can

• Syria
DELIVER We deliver excellence when we: take your devices and work in Venezuela will depend on
• Identify and classify the technologies, services and other items that are subject to export exactly which customer accounts you are serving and
• Venezuela
or import controls whether you have access to export-controlled source
code or technology. Regulatory Compliance can advise
• Appropriately mark documents, software and other controlled items so that recipients know
you in detail on sanctions issues.
to protect them

• Carefully screen customers and vendors to ensure that transactions do not involve restricted
or sanctioned parties

Resources: • Recognize that the laws of more than one country may apply to a particular transaction
International Trade • Avoid carrying DXC devices, connecting to DXC systems or working while visiting embargoed
Policy
or sanctioned countries
Sanctions Compliance
Policy • Contact DXC Integrity Regulatory Compliance with any questions regarding
international trade laws, sanctions or plans to travel to an embargoed or sanctioned country
Anti-Corruption Policy
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for our colleagues for our customers for our investors with our partners for our communities

Leading by example Give and receive appropriate gifts Giving and receiving gifts
and hospitality can help us

I’m attending a business conference. At lunch today, I and hospitality build positive relationships
with our customers and
happened to sit next to a representative of a DXC vendor. business partners. However,
some gifts, such as those
We had a friendly conversation and she invited me to a
below, may never be offered,
dinner that her company is hosting tomorrow night at an COMMIT We win business and build relationships based on trust and mutual benefit, giving
given or received under any
upscale restaurant. When I mentioned this to my colleague, and receiving gifts and hospitality appropriately. circumstances:
he asked if I knew that this vendor is currently bidding for a
big DXC contract. I did not know this, but since I am not part CONNECT Values and culture • Cash or cash equivalents,
such as stock, debit cards
of DXC Procurement, I assume it is okay for me to attend Our Do the Right Thing value means we always act with integrity. We cannot allow even the and, in some circumstances,
the dinner. Is that right? appearance of improper influence on business decision making. gift cards*

• SIDE BAR Customers and business

Business courtesies such as appropriate gifts and hospitality help us build goodwill and deepen
• Gifts or hospitality to or
from the family member of
a government official
Gifts and hospitality that otherwise might be appropriate commercial relationships — but only when we honor our values and follow our policies. • Items purchased with
can be problematic in certain circumstances. When unreimbursed personal funds
vendors are bidding for DXC’s business, we must Trust and reputation
• Items one could resell or
demonstrate our objectivity and impartiality. We must Giving or receiving gifts and hospitality that are extravagant or lack a legitimate business purpose exchange for value
avoid anything that risks even the appearance of erodes trust. It can also damage our reputation and violate the law.
• Service or other noncash
favoritism or compromised judgment. Even though you
benefit (such as a promise of
are not personally involved in the bid process, you are DELIVER We deliver excellence when we: employment, personal favor,
still representing DXC. You should politely decline the direct payment of bills, etc.)
• Only offer or accept gifts and hospitality that are legal, appropriate under local customs and
dinner invitation on the grounds that attending would compliant with our Gifts and Hospitality Policy Please refer to the Gifts
not be appropriate while the bid process is ongoing. and Hospitality Policy for a
• Are open and transparent, requesting approval when required and
complete list of prohibited
making appropriate disclosures in our Gifts & Hospitality Register
gifts and hospitality.
• Politely decline the offer of gifts and hospitality that do not comply
with company policy
Resources: *G
 ift cards not exceeding $100
• Do not request business courtesies from others or make them feel may be allowable in limited
Anti-Corruption Policy
obligated to provide something to do business with DXC circumstances if they are (1)
Gifts and Hospitality permissible under applicable
• Report any concerns to DXC Integrity Policy law; (2) not given to government
recipients; and (3) follow the
Gifts & Hospitality pre-approval process in the
Register Gifts and Hospitality Policy.
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for our colleagues for our customers for our investors with our partners for our communities

Use artificial intelligence responsibly

COMMIT We embrace the possibilities of artificial intelligence (AI) while taking care to avoid Being transparent with
unintended consequences of its use.
customers about when and
CONNECT Values and culture how we use AI is essential
We are excited by the possibilities of AI in helping us be more efficient and productive at scale. Our Do to building trust.
the Right Thing and Care values prompt us to be mindful of how our use of technology might create
risks that we need to manage.

Customers and business

As a technology pioneer, DXC is constantly seeking new ways to elevate our performance and expand
our capacity for excellence; we do so responsibly, knowing there is no excellence without integrity.

Trust and reputation

Being transparent with customers about when and how we use AI is essential to building trust. They
can be confident that they are reaping the benefits of innovative technology without unnecessary risk.

DELIVER We deliver excellence when we:

• Seek to use AI in an ethical way that minimizes the potential for harm to others

• Are transparent and disclose the use of AI Resources:

• Avoid using our own or others’ confidential or proprietary information as an AI tool prompt or AI Principles
otherwise
Acceptable Use Policy
• Review AI output for factual accuracy, appropriateness and the avoidance of copyright infringement,
Sensitivity Labeling Policy
plagiarism and embedded bias
Information Security
• Ensure that any use of AI complies with applicable laws, regulations and DXC policies Policy

• Understand that AI-related guidance may change from time to time as DXC actively explores the Intellectual Property
appropriate use of AI tools Policy

• Seek approval from the AI Council prior to using a generative AI tool Global Privacy and Data
Protection Policy
• Contact the Office of AI when we have business, legal or ethical questions or need additional guidance
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for our colleagues for our customers for our investors with our partners for our communities

Corruption red flags

Leading by example Take a stand against corruption Before engaging vendors and
other business partners, we
screen them to ensure that they
I’m a member of the project team that is planning to
operate with the same high
open a new delivery center in an emerging market. Some
necessary government permits have been delayed for
COMMIT We win the right way — or we walk away. ethical standards as DXC. We
monitor existing relationships,
and this is especially important
months. A local official is offering to expedite the approval
CONNECT Values and culture
in countries where there is a
process for a modest one-time fee. Can we pay it? Our Do the Right Thing and Community values demand that we take a stand against bribery and other higher incidence of corruption.
corrupt practices. Corruption is not only illegal, but it also harms communities. We are watchful for indicators of
corruption risk, such as:
Customers and business
The official appears to be seeking a facilitation or • Unusually close relationships
“grease” payment. That is the term for a small payment Our customers expect us to earn their business and select suppliers honestly. Excellence, both with government officials
that secures or speeds up routine, nondiscretionary expected and delivered, is what wins the day, not improper influence. • Requests for commission
and legal government actions. Most national laws, payments before a transaction
Trust and reputation
is complete
including the U.S. Foreign Corrupt Practices Act and the
Resisting all forms of corruption builds trust and tells the world we will only do business the right way. • Fees that are disproportionate
U.K. Bribery Act, prohibit even very minor facilitation
to services provided
payments — and so do we. We see them as bribes,
which we never pay. The local team should see whether
DELIVER We deliver excellence when we:
• Suggestions that we work with
• Never offer or accept bribes, kickbacks or anything of value that could improperly influence — specific people due to a “special
they can speak with someone other than this official
relationship”
to get the permits issued. If they cannot resolve the or appear to influence — a business decision
situation, DXC Integrity is ready to help. • Apparent conflicts of interest
• Avoid promising or providing anything of value to public officials or anyone else to gain a business
• Requests to record an expense
advantage
differently than its true nature
• Record all transactions truthfully so that the nature of anything given or received is clear and
accurate

• Never use an external party to do anything that we are not permitted to do ourselves

• Comply with the Gifts and Hospitality Policy, always considering how our actions might
be perceived by others Resources:
Anti-Corruption Policy

Gifts and Hospitality

Policy

Gifts & Hospitality

Register
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for our colleagues for our customers for our investors with our partners for our communities

Delivering excellence
for our investors
builds a dynamic and resilient organization that can
sustain value creation and growth.

Avoid conflicts of interest

We make smart choices for our company and customers, unaffected by personal interests or relationships.

Use company systems and resources responsibly

We use and protect company systems and resources responsibly to help us deliver excellence and value.

Protect our confidential information and intellectual property

We recognize and protect the business value of our confidential information and intellectual property.

Respect others’ intellectual property rights

We respect the intellectual property rights of others as we want them to respect ours.

Create and maintain accurate records

We keep accurate records so we can operate effectively and provide timely, truthful and valuable information
to those who rely on it.

Record time and charge costs honestly

We charge labor and other costs honestly and are careful to avoid errors.

Safeguard inside information

We never use or share inside information about DXC or another company to trade on the stock market.

Create shared value through sustainable operations

We are committed to policies and practices that grow our business while having a positive impact in the wider world.
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for our colleagues for our customers for our investors with our partners for our communities

Leading by example Avoid conflicts of interest What is a conflict of interest?

As DXC employees, we must not

I am a developer and have been advising my brother on an
allow personal financial interests
app for his technology startup. He does not compete with
DXC. He can’t pay me for consulting, but plans to give me a
COMMIT We make smart choices for our company and customers, unaffected by personal or relationships interfere with
interests or relationships. decision making in our jobs.
15 percent stake in the business. Does the situation create
a problem, and what are my obligations?
CONNECT Values and culture A conflict of interest may exist

DXC’s values demand that we always do the right thing. We never give even the appearance of where what we think may be

anything improper. best for us personally — or

Thank you for being proactive in considering the for friends or family — could
Customers and business compromise our objectivity and
potential impact of this outside activity on your work
at DXC. Our virtual-first working model gives us the We base our business decisions and actions on full information, thorough preparation and objective professionalism at work. This
flexibility to balance our work with our personal lives; at criteria. is not to say that our personal
the same time, DXC trusts us not to abuse this privilege interests are less important
Trust and reputation
and expects us to follow company policy. You should than DXC’s interests; the point
follow the disclosure process in our Conflicts of Interest Acting honestly, transparently and reliably builds trust and helps sustain the delivery of excellence. is simply that, when working
Policy. While there may be a potential for a conflict of for DXC, our decision making
interest, disclosing it provides the chance to manage it DELIVER We deliver excellence when we: should be based on what is best
appropriately. The factors that we will consider include • Proactively identify situations that could put our personal interests in conflict with the for our business and customers.
the potential for interference with your availability, company’s interests
energy and focus in your DXC job; the likelihood of your
• Disclose actual, potential or perceived conflicts of interest and speak up when we aren’t sure
brother’s business becoming a DXC customer, supplier
or competitor; and the financial significance of your • Remove ourselves from the decision-making process when a conflict of interest may exist
proposed ownership stake.
• Don’t allow the desire to help friends and family influence our decisions at work

• Avoid being influenced by the prospect of financial gain for ourselves or our family members
Resources:
• Win business and build relationships based on trust and mutual value — never through
inappropriate gifts or hospitality Conflicts of Interest
Policy
• Never keep for ourselves opportunities gained through company position or resources
Gifts and Hospitality
• Give our best effort at work every day, not allowing outside jobs or other activities to hinder Policy

our contributions to our business

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for our colleagues for our customers for our investors with our partners for our communities

Use company systems and resources responsibly

Our assets represent the
COMMIT We use and protect company systems and resources responsibly to help us deliver value we have created for our
excellence and value.
investors. We use them wisely
CONNECT Values and culture to fuel our growth by delivering
Being good stewards of our assets — physical, financial, technological and reputational — honors excellence for customers.
our Deliver, Do the Right Thing and Community values. It also protects the building blocks for our
future growth.

Customers and business

Our assets represent the value we have created for our investors. We use them wisely to fuel our
growth by delivering excellence for customers.

Trust and reputation

Our assets give us leverage in using the power of technology to build better futures for our customers,
colleagues, environment and communities.

DELIVER We deliver excellence when we:

• Handle DXC’s assets with care, protecting them from theft, fraud, damage and loss

• Protect the technology assets assigned to us, keeping devices and their data secure

• Use DXC-owned and managed devices responsibly, in accordance with our Acceptable Use Policy

• Safeguard our systems, being vigilant for phishing, social engineering, malware, ransomware and
other cyberattacks that could put our network, information or operations at risk

• Report circumstances where we suspect company assets are at risk and cooperate with all audits
and investigations Resources:
Acceptable Use Policy
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for our colleagues for our customers for our investors with our partners for our communities

Protect our confidential information and intellectual property

Our ability to deliver excellence COMMIT We recognize and protect the business value of our confidential information and
intellectual property (IP).
for customers depends on
safeguarding information they
CONNECT Values and culture
and others entrust to us, as well We are proud of our collective, accumulated knowledge. It is powered by know-how and confidential
as our own. information, which we must protect from unauthorized disclosure.

Customers and business

We might lose our competitive advantage if DXC’s confidential information became public or if we
did not protect our IP.

Trust and reputation

Our ability to deliver excellence for customers depends on safeguarding information they and others
entrust to us, as well as our own.

DELIVER We deliver excellence when we:

• Use best practices to protect DXC’s confidential information

• Share confidential information belonging to DXC customers, business partners and others only with
those who are authorized and have a business need to know it, with appropriate protections

• Do not discuss confidential matters when there is a risk of being overheard

• Avoid putting confidential information in emails without encryption or other appropriate security
measures

• Never use DXC’s confidential information for personal gain or to benefit anyone outside the company
Resources:
• Remember that the obligation to protect DXC’s confidential information continues after leaving the
Intellectual Property
company
Policy
• Preserve the value of our innovation through patents, copyrights, trademarks and other IP protections Sensitivity Labeling
as appropriate Policy

• Consult with Legal if we have questions or concerns

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for our colleagues for our customers for our investors with our partners for our communities

Respect others’ intellectual property rights We grow our business

through our own
COMMIT We respect the intellectual property (IP) rights of others as we want them to respect ours. ingenuity and effort, not
by taking credit for or
CONNECT Values and culture
misappropriating ideas that
Our Do the Right Thing value includes a commitment to the Golden Rule: the principle of treating others as we
wish to be treated. are not our own.
Customers and business
We grow our business through our own ingenuity and effort, not by taking credit for or misappropriating ideas
that are not our own.

Trust and reputation

As a trustworthy corporate citizen, DXC will never make use of others’ IP without permission. Doing so is wrong
and could expose DXC to legal, financial and reputational risk.

DELIVER We deliver excellence when we:

• Respect others’ patents, copyrights, trademarks and trade secrets

• Do not bring to DXC or use a former employer’s confidential information or IP (or encourage anyone else to do
so) without authorization

• Obtain the appropriate licenses or permissions when using third-party copyrighted material, such as software,
images or written content

• Report suspected theft or misuse of proprietary data or IP belonging to DXC or a DXC customer

• Respect moral rights (attribution and integrity) of authors and rights holders under applicable copyright laws

• Protect DXC’s rights by disclosing the creation of IP to the Patent Review Board prior to commercialization or
publication

• Respect the license requirements applicable to third-party, open-source software used by DXC

• Promptly report any concerns or suspected infringements using the SpeakUp Line
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for our colleagues for our customers for our investors with our partners for our communities

Create and maintain accurate records

In growing our customers
and business, we rely on
COMMIT We keep accurate records so we can operate effectively and provide timely, truthful
financial and operational and valuable information to those who rely on it.
information that is
accessible and accurate. CONNECT Values and culture
Our Deliver and Collaborate values inspire us to continuously improve knowledge sharing, decision
making and efficiency; this demands excellent records and data management.

Customers and business

In growing our customers and business, we rely on financial and operational information that is
accessible and accurate.

Trust and reputation

Keeping accurate records is essential to fulfilling our regulatory obligations as a public company.
Investors and other stakeholders are entitled to rely on truthful and complete disclosures about our
financial and operational performance.

DELIVER We deliver excellence when we:

• Record business transactions clearly, accurately and for the right period

• Are transparent when reporting project progress to customers and leadership

• Correct any errors as soon as we discover them, notifying anyone affected

• Securely maintain and, when appropriate, dispose of records according to established retention
requirements

• Comply with legal holds and never conceal or destroy records or data until the hold is lifted

• Are vigilant for fraud, dishonesty or other suspicious activity, including the falsification of records Resources:
or misrepresentation of facts Records and Data
Management Policy
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for our colleagues for our customers for our investors with our partners for our communities

Supervise with C.A.R.E.

Record time and charge costs honestly If you supervise others, you are accountable for the
accuracy of their time and cost charging. You must
emphasize to team members the importance of
entries that are:
COMMIT We charge labor and other costs honestly and are careful to avoid errors.
• Complete. Contain all the required information
CONNECT Values and culture
• Accurate. Reflect the correct activity, time period and
Our Deliver and Do the Right Thing values demand honesty and accuracy in tracking time and charging account
costs. This enables informed business decisions and efficient supply and demand management.
• Reliable. Provide timely and truthful information to
Customers and business those relying on it
Prompt and careful time and expense recording enables DXC to forecast project resourcing needs, • Ethical. Consistent with DXC’s policies and values
calculate labor rates and generate accurate invoices.

Trust and reputation

Maintaining truthful time and cost reports helps establish DXC as an accountable, trustworthy
business partner.

DELIVER We deliver excellence when we:

• Complete daily or weekly time reports punctually

• Charge time and other costs accurately, in accordance with our policies

• Never knowingly charge an incorrect account or inappropriately shift costs

• Never direct others to violate timekeeping and other cost-charging policies

• Submit expense reimbursement claims accurately and honestly

Resources:
Time Entry Policy
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for our colleagues for our customers for our investors with our partners for our communities

Leading by example Safeguard inside information What is inside information

and why must we protect it?

My brother recently lost his job. He is looking to rebalance The financial markets function
efficiently and fairly when they
his investment portfolio and asked me if I recommend
investing in DXC’s stock. I am aware that DXC will soon
COMMIT We never use or share inside information about DXC or another company to trade are transparent. This means
on the stock market. not allowing any investors
announce a new offering in an area that has huge growth to gain an unfair advantage
potential. For me, this makes DXC’s stock a great buy. Can I
CONNECT Values and culture through access to information
that is not public.
share this recommendation with my brother?
We honor our Community and Do the Right Thing values by preventing the release of nonpublic
In the course of our work, we
information, otherwise known as inside information, which could potentially be misused to trade
may know information about
securities. DXC (or other companies with
Definitely not. The information you have has not yet been which we do business) that
Customers and business is not known to the public.
shared publicly, and it would undoubtedly be relevant to
We are responsible for protecting not only DXC’s inside information, but also that entrusted to us by Knowing this information
an investment decision. This makes it material nonpublic
makes us “insiders.” Using it
information, and it would give your brother an unfair customers and others. to buy, sell or reallocate stock
trading advantage. Tell your brother that, unfortunately, or other company securities
Trust and reputation
you cannot advise him at the present time; he should do is called “insider trading.”
By preventing insider trading, we do our part to secure the transparency and integrity of the financial It is illegal. Passing such
his own research or seek professional advice. Any time
information to others so that
you are unsure whether information you have about markets.
they may trade — known as
DXC or another company is inside information, contact “tipping” — is also illegal.
DXC Integrity or DXC Legal for guidance. DELIVER We deliver excellence when we:
Insider trading can result
• Never use inside information to trade shares in DXC or any other publicly traded company — in heavy fines and even
unless and until such information has been made public imprisonment.

• Do not share inside information with anyone outside the company, including family members,
relatives or friends

• Share inside information with colleagues only on a need-to-know basis

• Take care to protect inside information from accidental disclosure

• Avoid “tipping” — passing along material, nonpublic information about any company to
anyone who may be tempted to make investments or trades based on that information
Resources:
Insider Trading Policy
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for our colleagues for our customers for our investors with our partners for our communities

Create shared value through sustainable operations Our sustainability commitment is

rooted in our values. They remind
us why it is important to balance
COMMIT We are committed to policies and practices that grow our business while having a
financial, social and environmental
positive impact in the wider world.
considerations in our business
CONNECT Values and culture operations.
Our sustainability commitment is rooted in our values. They remind us why it is important to balance
financial, social and environmental considerations in our business operations.

Customers and business

We collaborate with our customers and communities to take on shared global challenges. We strive to
minimize DXC’s environmental impact while delivering benefits to a broad spectrum of stakeholders.

Trust and reputation

As a large global corporation, we understand that society gives us license to operate. We hold
ourselves and our business partners accountable to preserve the trust placed in us. Resources:
Commitment to the
DELIVER We deliver excellence when we: Paris Agreement

• Recognize that sustainable value creation begins with a growth mindset and caring about Environmental Policy
the future Environmental, Social
and Governance
• Prioritize trust over mere transactions to build long-term business and community relationships
documents
• Embrace accountability for the environmental and social — as well as financial — dimensions of Environment, Social and
our performance; we make public disclosures based on internationally recognized standards and Governance Strategy
frameworks
Health and Safety Policy
• Modify business processes and individual actions to reduce carbon emissions and paper usage Human Rights Statement
and increase efficiency in our use of energy and water
Modern Slavery
• Drive commitment to sustainable, ethical operations throughout DXC’s value chain; we prohibit Statement

unacceptable practices like corruption, modern slavery and discrimination UN Global Compact
letter
• Promote trust and psychological safety in the work environment, so our people can feel
comfortable, engaged and productive over the long term
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for our colleagues for our customers for our investors with our partners for our communities

Delivering excellence
with our partners
increases our impact and reach as we serve those
who depend on us.

Source responsibly
We source technology, materials and services ethically and sustainably and expect our business partners to
do the same.

Select trusted partners

We select business partners who share our commitment to excellence, ethical conduct and responsible risk
management.
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for our colleagues for our customers for our investors with our partners for our communities

Source responsibly

COMMIT We source technology, materials and services ethically and sustainably and expect
our business partners to do the same.
DXC’s size and global footprint
mean we must seize the CONNECT Values and culture
opportunity for leadership and We honor our Community, Care and Do the Right Thing values by working only with suppliers who
positive influence throughout share our commitment to ethical sourcing.

our ecosystem. Customers and business

As well as suppliers, we partner with our customers and communities to drive positive change
throughout DXC’s supply chain. The DXC Responsible Supply Chain Principles set out our
commitments and expectations in this regard.

Trust and reputation

DXC’s size and global footprint mean we must seize the opportunity for leadership and positive
influence throughout our ecosystem.

DELIVER We deliver excellence when we:

• Require suppliers to comply with the DXC Responsible Supply Chain Principles and applicable laws
related to human rights; health and safety; fair labor practices; conflict minerals; the environment;
bribery and corruption; and equality

• Routinely assess the performance of our key suppliers based on ethical and commercial criteria
Resources:
• Safeguard the procurement process from improper influence, including nepotism, inappropriate
Responsible Supply
gifts and hospitality, and bribery or other forms of corruption
Chain Principles
• Act immediately on issues identified in our supply chain Environmental Policy

Human Rights Statement

Modern Slavery
Statement
Delivering excellence Delivering excellence Delivering excellence Delivering excellence Delivering excellence
Contents SpeakUp Line 37
for our colleagues for our customers for our investors with our partners for our communities

Select trusted partners We expect our business

partners to do the right
thing as they collaborate
COMMIT We select business partners who share our commitment to excellence, ethical
conduct and responsible risk management. with us to deliver
excellence.
CONNECT Values and culture
We expect our business partners to do the right thing as they collaborate with us to deliver excellence.

Customers and business

We choose vendors and suppliers based on merit and the needs of our customers and business.
They must meet our exacting standards for performance and ethical conduct.

Trust and reputation

Our partners’ actions and business practices reflect directly on DXC. We insist they operate in a
manner that preserves the trust we have built with our customers and the public.

DELIVER We deliver excellence when we:

• Select the right partners for the job through risk-based due diligence, which includes careful
consideration of their track record and reputation for integrity

• Evaluate prospective and existing partners based on objective criteria such as quality, price,
service and ability to meet our business needs

• Expect our partners to act consistently with this Code and DXC policies and complete all required
DXC training

• Treat all current and potential partners equally and fairly, regardless of the transaction value or Resources:
duration of the relationship Responsible Supply
Chain Principles
• Protect the confidential information and intellectual property our partners entrust to us as if it
Supplier Contracting and
were our own
Purchasing Policy
Third-Party Risk
Management Policy
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for our colleagues for our customers for our investors with our partners for our communities

Delivering excellence
for our communities
enables us to make a positive difference in the places
where we live and work.

Communicate with one voice

We build our brand and stakeholder relationships through clear, consistent and truthful communications.

Engage responsibly in the political process

We participate thoughtfully in the political process, advocating for DXC’s interests around the world while
bringing positive change to our communities.

Respect and protect human rights

We embed respect for human rights throughout our operations and sphere of influence.

Invest in our communities

We are committed to investing our time, talents and resources to help our communities prosper.
Delivering excellence Delivering excellence Delivering excellence Delivering excellence Delivering excellence
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for our colleagues for our customers for our investors with our partners for our communities

Leading by example Communicate with one voice

As I was scrolling through my LinkedIn feed, a comment
on a DXC post caught my eye. In my view, the comment
was unfairly critical of DXC’s position on an important
COMMIT We build our brand and stakeholder relationships through clear, consistent and
truthful communications.
issue. I would like to post my own comment in response,
standing up for DXC and pointing out some flawed logic.
CONNECT Values and culture
Can I do this if I am respectful and make it clear that I
Since we strive always to keep our word, we must be thoughtful, transparent and honest in what we
am expressing my personal opinion?
say publicly, in person and online.

Customers and business

It’s great that you want to be an ambassador for DXC We know when to rely on the specific skills and experience of our Communications and Investor
and are being thoughtful about your social media Relations teams to handle inquiries or to communicate on DXC’s behalf.
engagement. As a DXC colleague, you are free to express
Trust and reputation
an opinion in public if you do so professionally and
indicate that you are not speaking on the company’s Communicating with customers, investors and other stakeholders in an authentic and respectful
behalf. Since this concerns an official DXC post, the manner can build trust and loyalty.
comment you saw will probably already have been
picked up by Communications. You should confirm that DELIVER We deliver excellence when we:
they are aware and can address it as appropriate. • Always communicate professionally, regardless of medium

• Refer media, analyst or shareholder requests to Corporate Communications or

Investor Relations, as appropriate

• Speak on DXC’s behalf only when authorized to do so

• Clearly distinguish private opinions from DXC’s official position

• Embrace the opportunity to be responsible ambassadors for DXC’s brand

Resources:
• Pause to consider whether social media posts could be misinterpreted or could reflect on Brand Central
us negatively as individuals or as DXC
Financial Disclosures to
the Public

Social Media Policy

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for our colleagues for our customers for our investors with our partners for our communities

We ensure that our political

participation, as a company and
Engage responsibly in the political process as individuals, is appropriate and
transparent.
COMMIT We participate thoughtfully in the political process, advocating for DXC’s interests
around the world while bringing positive change to our communities.

CONNECT Values and culture

We honor our Care and Community values by encouraging everyone to exercise their civic rights. In
supporting causes we care about, we separate personal politics from the company.

Customers and business

From time to time, DXC may support political candidates or advocate for legislation that benefits our
business and customers.

Trust and reputation

We ensure that our political participation, as a company and as individuals, is appropriate and
transparent. Doing so preserves trust and prevents damage to our reputation.

DELIVER We deliver excellence when we:

• Engage individually in the political process using only our own time and money

• Avoid lobbying or endorsing political candidates or parties on DXC’s behalf without authorization

• Avoid using DXC assets, facilities or other resources in connection with private political
participation

• Inform DXC Integrity if we are planning to run for office

• Contribute to a DXC political action committee voluntarily and never pressure colleagues or
business partners to do so

• Comply with all applicable laws, lobbying and disclosure requirements, as well as the Resources:
Government Affairs & Interactions Policy Government Affairs &
Interactions Policy
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for our colleagues for our customers for our investors with our partners for our communities

We deliver excellence for Respect and protect human rights

customers and colleagues
only if everyone involved is COMMIT We embed respect for human rights throughout our operations and sphere of
treated with respect, fairness influence.

and dignity.
CONNECT Values and culture
Our Care and Community values compel us to respect and protect the fundamental rights of everyone
working directly for or otherwise supporting DXC.

Customers and business

We deliver excellence for customers and colleagues only if everyone involved is treated with respect,
fairness and dignity.

Trust and reputation

DXC is committed to using our size and global reach to promote positive social change in our
operations and communities.

DELIVER We deliver excellence when we:

• Commit to fair employment and compensation practices, following applicable laws and ethical
standards

• Condemn and prohibit the use of child labor or forced labor throughout our global operations and
supply chain
Resources:
Abusive Conduct &
• Provide a safe and healthy work environment free from violence, harassment, intimidation and
Harassment Policy
other unsafe or disruptive conditions
Global Diversity and
• Promote diversity and ensure equal opportunity and fair treatment for all Non-Discrimination
Policy
• Prevent and address abusive conduct and harassment in the workplace
Health and Safety Policy
• Uphold the freedom of association and recognize the right to collective bargaining
Human Rights Statement
• Ensure the lawful treatment and confidential handling of sensitive information, including Modern Slavery
personally identifiable information and personal data Statement

• Facilitate the effective reporting, investigation and remediation of human rights concerns
Delivering excellence Delivering excellence Delivering excellence Delivering excellence Delivering excellence
Contents SpeakUp Line 42
for our colleagues for our customers for our investors with our partners for our communities

Invest in our communities Growing our communities

DXC is committed to making a positive impact in
the places we live and work. We’re proud of all the
COMMIT We are committed to investing our time, talents and resources to help our
initiatives our colleagues take part in. Here are two
communities prosper.
examples:

CONNECT Values and culture

Our Community value inspires us to look for ways to have a meaningful impact in the communities
in which DXC operates.

Customers and business

As a global leader in our industry, DXC uses the power of technology to leverage the impact our The DXC Dandelion Program. The DXC Dandelion
colleagues can have in the communities in which they live and work. Program is a holistic employment experience that
supports people with autism, attention-deficit/
Trust and reputation
hyperactivity disorder and dyslexia as they pursue
Being an active partner in our communities not only reinforces our sense of purpose, but it also long-term careers in the IT industry. DXC prioritizes the
earns the respect of those who might consider working with us. success of neurodiverse colleagues in the workplace
by providing them with onsite training, mentoring and
DELIVER We deliver excellence when we: advocacy from DXC neurodiversity support consultants.
• Give our time, energy and talents to projects that help our communities thrive

• Participate in DXC-sponsored community volunteering opportunities

• Volunteer on a personal level, provided this does not interfere with our job responsibilities or
create other conflicts of interest
Our partnership with Manchester United
• Obtain proper approval before donating company funds or making contributions in the company’s Foundation. DXC has collaborated with Manchester
name United Foundation on initiatives that use technology
• Avoid pressuring others to contribute to charitable causes or to seek anything in return for to empower young people, such as the Digital Futures
community contributions Academy, a 4-year educational program that helps
Resources:
secondary school students in Greater Manchester,
Charitable Giving U.K., build the digital and social skills they need to
Policy become community leaders.
 43

Closing message from our

chief ethics and compliance officer
Colleagues,
It is my privilege to lead DXC Integrity. The mission of my team is to inspire, guide and enable us all to grow DXC’s
business by doing the right thing. When we focus on how we interact with others and achieve our goals, we build
trust and contribute to a positive, ethical culture grounded in our values. This allows us to bring our authentic
“When we focus on how selves to work, safe in the knowledge that we are empowered to speak up with ideas, questions and concerns.
With that in mind, we minimize risks to our business while embracing opportunities to deliver excellence for
we interact with others our customers and colleagues.

and achieve our goals, we Thank you for speaking up and for your commitment to delivering excellence with integrity.

build trust and contribute Sincerely,

to a positive, ethical culture Moe Mohlenkamp

Vice President, Chief Ethics and Compliance Officer
grounded in our values.” DXC Technology

— Moe Mohlenkamp
About DXC Technology
DXC Technology (NYSE: DXC) helps global companies run their mission-critical systems and operations while modernizing IT, optimizing
data architectures, and ensuring security and scalability across public, private and hybrid clouds. The world’s largest companies and
public sector organizations trust DXC to deploy services to drive new levels of performance, competitiveness, and customer experience
across their IT estates. Learn more about how we deliver excellence for our customers and colleagues at DXC.com.

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