Guide to our Code of Ethics and Compliance - Cognizant

1 Guide TO OUR. code OF Ethics . AND Compliance . 2017. CONTENTS. 03 08 13. From Our CEO Our Core Values Taking Principled Actions 04 09 14. Doing Business the Preventing Corruption Key Considerations Right Way 05 10 15. Avoiding Conflicts Reporting a Concern Who Should Follow of Interest Our code of Ethics 06 11. Competing Fairly What Cognizant and Honestly Associates Must Do 07 12. Acting Responsibly What Cognizant Managers Must Do FROM. OUR CEO. At Cognizant , we don't cut corners, bend the rules or look for shortcuts. Every time we interact with clients, partners, competitors, and each other, we carry a piece of Cognizant 's reputation with us. Every day, we work to fortify our strong tradition of Ethics , integrity and transparency.

2 Our code of Ethics , together with our Core Values, reflects the best and highest standards of business conduct. It's up to all of us to maintain those high standards in everything we do.. FRANCISCO. D'SOUZA. Chief Executive Officer 03. DOING BUSINESS. THE RIGHT WAY. Compliance means doing business the right way. We are all responsible for maintaining our culture of Compliance while FOUR SIMPLE RULES TO. living our values. REMEMBER: 01 03. Uphold our core Obey applicable laws, value of integrity in rules and regulations. all you do. 02 04. Understand and Report all suspected follow our code violations of the of Ethics , policies code of Ethics and statements. without retaliation. 04. WHO SHOULD FOLLOW. OUR code OF Ethics .

3 Our Core Values & code of Ethics ( code of Ethics ) must be followed by anyone who works for or represents Cognizant . ABOUT THIS. Guide . Who does this include? Cognizant directors, officers, and employees worldwide This Guide provides a summary Cognizant business units and subsidiaries, joint ventures over of Cognizant 's code of Ethics , which Cognizant has operational control policies and statements not the Business partners, and third-party representatives worldwide full policies themselves. (collectively, Associates ). For our complete code of Ethics , Cognizant Associates who work with third parties such as go to: consultants, agents, sales representatives and independent contractors must require that these parties agree to comply with our code of Ethics and relevant aspects of our policies and statements.

4 05. WHAT Cognizant . ASSOCIATES MUST DO. LEARN BE VIGILANT. Be familiar with, understand and uphold our code of Ethics . Report any suspected violations of our code of Ethics , policies Learn the details of any part of our code of Ethics , and statements or law. policies and statements that are relevant to your specific Cooperate in Cognizant investigations related to our code of daily responsibilities. Ethics , policies and statements. BE AWARE COMMIT. Be aware of developments in your business or functional Complete Cognizant 's required Compliance training courses area that might impact Cognizant 's Compliance with laws and on time. regulations or our reputation. Execute an annual certification acknowledging your commitment to the principles in our code of Ethics .

5 06. WHAT Cognizant . MANAGERS MUST DO. Cognizant holds its managers accountable for fostering an LEAD. atmosphere of Compliance in which associates clearly understand Foster a spirit of Ethics , integrity, and lawfulness by their obligations and feel at ease to raise a concern absent any personally leading Compliance efforts. fear of retaliation. Communicate the importance of Compliance at every appropriate opportunity. EDUCATE Never retaliate or tolerate retaliation against any individual Promote a culture of Compliance in which Associates for making a good-faith report. understand their responsibilities and feel comfortable asking questions. COMMUNICATE. Ensure that Associates understand that business results are Immediately inform our Chief Compliance Officer if you receive never more important than ethical conduct and Compliance a report of suspected violation of our code of Ethics , policies, with our code of Ethics .

6 Statements or law. Ensure that Associates know that they can always report suspected violations of law or the code of Ethics without fear of retaliation. 07. OUR CORE. VALUES. 01 04. Our Core Values define the behaviors that make us successful in the marketplace. As you conduct business on Cognizant 's behalf, always ask yourself Transparency Collaboration whether your actions are consistent with these core values, our code of Ethics , policies and statements. 02 05. Passion Customer Focus 03 06. Empowerment Integrity 08. Prevent corrupt activity whenever and wherever possible. PREVENTING Always report any sign of corruption or unethical behavior, even if you're not absolutely sure. CORRUPTION. BE AWARE.

7 THE Cognizant WAY A bribe is any payment or Anything of Value offered or provided to improperly We don't give or receive bribes to anyone We always keep accurate business influence a decision-maker or to obtain for any purpose. Bribing a government records. Never misconstrue or mislabel an unfair business advantage. official is illegal no matter where it a transaction in our books and records. occurs. Never offer or accept bribes Ensure that timesheets, travel and Anything of Value includes items such as cash, bonuses, gifts, favors, charitable when working with governments or expense reports, financial statements, donations, political contributions, offers any customers. We never give gifts, customer billing and other records are of employment, offers of hospitality/.

8 Entertainment, or anything of value in honest and accurate. entertainment, kickbacks, or any other exchange for a business or personal type of preferential benefit. benefit. We don't use third parties to work A facilitation payment is generally a small around our policies. Don't ask or allow payment made to a low-level Government We don't make facilitation payments anyone else to act on your behalf in a way Official for the purpose of securing or in most cases. Cognizant prohibits that violates company policies. expediting the performance of a routine, facilitation payments absent prior nondiscretionary government action. approval in exceptional cases from the Chief Legal Officer/General Counsel. LEARN MORE.

9 (RESOURCES). Anti-Corruption Statement Gifts and Entertainment Statement Go to for detailed information and resources. 09. Putting our personal interests before Cognizant 's creates a conflict of interest AVOIDING CONFLICTS and is not allowed. You have a duty to report any possible conflicts of interest right away. OF INTEREST. ALWAYS REMEMBER. THE Cognizant WAY A conflict of interest is not automatically a violation of Cognizant 's code of Ethics . We don't take on outside employment We avoid working directly with those with However, a failure to promptly disclose a that conflicts with company work. Avoid whom we have a close personal or family conflict is always a violation. In fact, many outside employment even voluntary or relationship.

10 Don't hire, supervise, report conflicts can be cleared or easily resolved charitable work that conflicts with or to, review, evaluate, or purchase goods once reported. Seeking pre-approval for potential conflicts (and otherwise may interfere with Cognizant 's interests. or services from close personal friends or disclosing conflicts) allows the Company relatives, and do not engage in an intimate to mitigate risks which may interfere with We avoid making personal investments or romantic relationship with a direct or your business decisions. or financial arrangements that could indirect report or supervisor. conflict with our work commitments. Don't hold a substantial financial interest in We don't seek or pursue business KEEP IN MIND.