Business Conduct Guidelines

1 Trust Comes FirstBUSINESS Conduct Guidelines Business Conduct GUIDELINES2 Table of Contents1. 3. 4. 2. Trust Means We Commit to Integrity and The Business Conduct The Importance of Integrity and Speaking Up Where and How to No Retaliation External Inquiries, Contacts and Speaking Publicly and Social Media Trust Means We Are Honest, Accurate and Be Reporting and Recording Understanding Financial Controls and Making Commitments and Obtaining Retaining RecordsTrust Means We Protect Employees, Kyndryl Assets and the Assets Belonging to Others Maintaining a Safe and Productive Work Protecting and Using Kyndryl Assets and Those Owned by Sharing and Receiving Proprietary and Confidential Avoiding Inadvertent Guarding Against Protecting Assets, Business Interests and Employees Managing Personal Leaving KyndrylTrust Means We Respect Intellectual Property Protecting Kyndryl Intellectual Using Third-Party Software, Apps, Cloud-Based Services and Using Open Source Developing Applications for Mobile Protecting Trademarks and Domain Names Business Conduct GUIDELINES35.

2 7. 8. Trust Means We Compete, Win Business and Treat Others Ethically Working with Organizations Outside of Working with Government Entities and Working with Working with Kyndryl Business Partners, Resellers and Others Dealing with Competing Ethically Acquiring and Using Information About Others6. Trust Means We Meet Our Legal Obligations Protecting Against Corruption Giving and Receiving Business Amenities and Avoiding Money Laundering and Funding Terrorist Selling in the Public Visiting Kyndryl Property Government Officials and Candidates for Public Complying with International Trade Requirements Complying with Antiboycott Meeting Cross-Border Travel Protecting the EnvironmentTrust Means We Separate Our Personal Interests from Our Business Acting on Your Own Avoiding Conflicts of Steering Clear of Insider Participating in Public Service and Political ActivityNotice of Certain Additional Rights.

3 Other Kyndryl Policies, Directives and Guidelines Business Conduct Conduct The Business Conduct GuidelinesThe Business Conduct Guidelines (BCGs) provide general guidance for resolving a variety of legal and ethical The Importance of Integrity and Compliance Integrity and compliance are vital to Kyndryl s success and yours. Our integrity, reputation and brand are in your hands, and we rely on you to protect them!No matter where your workplace is whether you work with employees, clients, Business partners, suppliers or other parties in person, over the phone, online or by any other means follow our Values, the BCGs and other applicable corporate directives, such as Kyndryl policies, corporate instructions and Guidelines ( corporate Directives).

4 And comply with all laws and regulations that apply to Kyndryl s Business . Always use good judgment in your work. If you have questions about interpreting or applying the BCGs, corporate Directives, or laws and regulations applicable to Kyndryl, don t guess. Ask for help. It s your responsibility to consult your manager or Kyndryl Counsel, or use one of Kyndryl Communication you violate the BCGs, other corporate Directives or the law, Kyndryl may take any action regarding your employment, including termination of employment, subject to applicable law. Failing to comply with laws could also result in fines, lawsuits, loss of Business privileges and, in some cases, Speaking Up Where and How to Report Kyndryl expects you to report potential wrongdoing whether a violation of the BCGs or other unethical or unlawful Conduct involving you are aware of or suspect a violation of the BCGs or other unethical or unlawful Conduct , immediately report the matter through any of Kyndryl s communication channels.

5 Your manager, unless your report involves someone in your management chain in which case use another reporting channel Human Resources Kyndryl s Audit team for violations related to financial recording and reporting, Business process violations and inappropriate use of assets Kyndryl s Security team for threats or acts of violence, loss or theft of Kyndryl assets, or violation of law on company premisesTrust Means We Commit to Integrity and ComplianceAs our Business continues to transform, you may find yourself working in exciting new areas like healthcare, financial services, education or mobile application development, some of which are highly regulated.

6 Any change in your work responsibilities may carry new responsibilities under the BCGs or new legal out!Watch out! Business Conduct GUIDELINES61. TRUST MEANS WE COMMIT TO INTEGRITY AND COMPLIANCE Kyndryl s Health & Safety team for work-related health and safety issues Kyndryl s cybersecurity team for cybersecurity or data incidents, potential or actual system and data breaches and inadvertent disclosures Kyndryl Counsel Kyndryl Compliance teamKyndryl will promptly review your report of actual or potential violations of the BCGs or other unlawful or unethical Conduct . Kyndryl will not tolerate threats or acts of retaliation against you for making any CooperationKyndryl needs your cooperation to Conduct investigations and audits for Kyndryl s internal controls and to respond to inquiries, audits or investigations by clients, regulators or others.

7 You must fully cooperate in these matters. For example, promptly, completely and truthfully comply with all Kyndryl requests; participate in meetings and interviews in a timely manner when requested; and provide and keep all relevant information (electronic or otherwise) as directed by No RetaliationKyndryl prohibits threats or acts of retaliation for (1) reporting in good faith potential wrongdoing or inappropriate behavior, (2) refusing to act in violation of the Business Conduct Guidelines , corporate policies or law, or (3) cooperating with an investigation. If you believe you have been retaliated against, report it through one of Kyndryl s communication channels, and Kyndryl will take appropriate you know?

8 Did you know?You can raise a concern anonymously. Submit your concerns online or by e-mail, regular mail or phone. Also, an employee is not prohibited from reporting possible violations of law or regulation to a government agency, as permitted by Conduct External Inquiries, Contacts and Communications Kyndryl s Business is monitored by journalists, consultants, IT and securities analysts, investors, regulators and others. These people may see you as having valuable expertise, and they may ask you to give your insights to them, with or without compensation. If contacted, do not respond to them for Kyndryl, whether in person, online through social media, by telephone or otherwise.

9 Instead, promptly notify the contacts below to identify both the appropriate person to respond and the appropriate response: Communications, if contacted by journalists or bloggers Analyst Relations, if contacted by consultants or IT analysts Investor Relations, if contacted by securities analysts or investors corporate Environmental Affairs, if contacted by environmental groups, government agencies, Business associations, or individuals about any matter involving environmental policy, declarations, principles, practices, or programs Government and Regulatory Affairs, if contacted about public policy or lobbying matters Kyndryl Counsel, if you receive a request for information, a legal notice or an audit request related to Kyndryl s Business from a client, attorney.

10 Investigator, law enforcement or other government official or if you are asked to testify on behalf of Kyndryl in a legal proceeding or before an agency, legislative or other public hearingNothing in the BCGs prohibits you from communicating directly with any government agency or entity, without prior consent of, or notification to, Kyndryl to the extent permitted by law and applicable rules of professional Speaking Publicly and Social Media When you speak out in a public forum or on social media, you must make it clear that you do so as an individual. Do not give the appearance of speaking or acting on Kyndryl s behalf only certain people are authorized to do so.