ANTI-CORRUPTION COMPLIANCE POLICY AND GUIDELINESCONFIDENTIAL
This document and the information set forth herein
are the proprietary property of Informatica and are
to be held in confidence. No part of this document
may be copied, reproduced or disclosed to third
parties without the expressed written consent ofInformatica.

DCN:

LGL-GBL-2

Revision:

4.6

OriginationDate:

12/2011

Published Date:

4/30/2024

Valid From:

05/01/2024

Valid To:

09/30/2024

Owner:

Maura Sharp, GVP & Deputy General Counsel,
Employment and Compliance,

Approver:

Board Audit Committee
Approval designates management commitment.

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Anti-Corruption Compliance Policy and Guidelines

Table of Contents
1.

Purpose ......................................................................................................................... 3

2.

Scope............................................................................................................................. 3

3.

Definitions ..................................................................................................................... 44.

Policy ............................................................................................................................. 4
Introduction ................................................................................................................................... 5
Compliance Guidelines .................................................................................................................. 5
Summary of the FCPA .................................................................................................................... 5
Summary of the UK Bribery Act ...................................................................................................... 5
Who is a Foreign Official?............................................................................................................... 6
Prohibited Payments...................................................................................................................... 6
Permissible Payments ................................................................................................................... 7
Third Party Liability ...................................................................................................................... 10
Joint Ventures ............................................................................................................................. 12
Accounting and Recordkeeping Requirements.............................................................................. 12
Penalties ..................................................................................................................................... 12
Reporting Violations .................................................................................................................... 13
Audit of Anti-Corruption Compliance ............................................................................................ 13

5.

Compliance .................................................................................................................. 14

6.

Primary Sources .......................................................................................................... 14

7.

Secondary Sources ...................................................................................................... 14

8.

Document Control and Revision History ....................................................................... 14

9.

Policy Approval ............................................................................................................ 15

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1. Purpose
Informatica Inc. and its consolidated subsidiaries (collectively referred to as “Informatica” or the“Company”) are committed to maintaining the highest level of professional and ethical standards in the
conduct of their business in all countries in which they operate or otherwise have business connections,
including the United States. The Company’s reputation for honesty, integrity, and fair dealing is aninvaluable component of the Company’s financial success, and of the personal satisfaction of its
employees.
One of the U.S. laws directly relevant to that commitment is the U.S. Foreign Corrupt Practices Act, known
as the “FCPA.” The FCPA is a criminal statute that prohibits all U.S. companies and persons from
corruptly offering, promising, paying, or authorizing the payment of anything of value to any foreign
official to influence that official in the performance of his or her official duties. This prohibition applies
whether the offer or payment is made directly, or through a third person. Thus, in some instances, theCompany could be held liable for payments made by its joint venture partners or sales agents. The FCPA
also requires certain entities to maintain an accounting system that ensures reasonably detailed andaccurate records of all of its financial transactions and a system of internal accounting controls that
protects against off-book accounts and disbursements and other unauthorized payments. The penalties
for violating the FCPA are very severe and potentially devastating to both the Company and theindividuals involved.
A similar law is the United Kingdom’s Bribery Act 2010 (the “UK Bribery Act”). Like the FCPA, the UK
Bribery Act prohibits promising, offering, or providing either directly or indirectly anything of value toforeign (i.e. non-UK) government officials for the purpose of retaining business or obtaining business ora business advantage. The UK Bribery Act, however, also prohibits such conduct in the privatecommercial context — i.e. promising, offering, or providing anything of value, either directly or through athird party, with the intent to induce an individual to, or reward them for, improperly performing a function,
where such individual is in a position of trust or is carrying out a function that requires the individual toact in good faith or impartially. Furthermore, the UK Bribery Act prohibits the receipt of an improper
payment and, most importantly, imposes strict liability on UK corporations and those doing business in
the UK for bribery by those who perform services for or on behalf of the corporation.

2. Scope
This policy applies to all Informatica information assets, regardless of form or format, used in supportof the business and information systems, including systems managed or hosted by third parties onbehalf of Informatica. The material contained herein applies to employees, partners, consultants, agents,
vendors, distributors and contractors who use or are granted access to Informatica facilities orinformation systems. Collectively these human resources shall be referred to as “Informatica
Personnel”.

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3. Definitions
Active Bribery – the offense committed by a person giving, paying, promising, offering, or authorizing thepayment, directly or indirectly through a third party, with the intent to induce another to not act with goodfaith or impartiality, or to abuse a position of trust, or to reward such improper action.
Anti-Corruption Laws – applicable statues, laws, rules, or regulations, of any jurisidiction prohibiting
bribery or corruption (whether governmental or commercial), or that otherwise prohibit the corrupt
payment, offer, transfer, promise, or authorization of a payment or anything of value (including gifts,
entertainment, donations, and favors), directly or indirectly, to any person, including any Foreign Official.
The FCPA and the UK Bribery Act are two examples of Anti-Corruption Laws, but other examples exist in
virtually every location where Informatica does business.
Facilitating Payments - payments, usually of a nominal amount, made to ensure non-discretionary
governmental actions, such as processing visas or business permits.
Foreign Officials - include all paid, full-time employees of a non-U.S. government department or agency(whether in the executive, legislative or judicial branches of government and whether at the national,
provincial, state or local level). Government officials can also include part-time workers, unpaid workers,
individuals who do not have an office in a non-U.S. government facility, and anyone acting under adelegation of authority from a non-U.S. government to carry out government responsibilities. They also
include officers and employees of companies or entities which have non-U.S. government ownership orcontrol, such as state-owned enterprises and government-controlled universities and hospitals. A“Foreign Official” under the UK Bribery Act (and for purposes of this policy) carries the same definition
as above, only such person must be a non-UK— rather than non-U.S. — official.
Passive Bribery – the offense committed by a person requesting, agreeing to receive, or acceptance ofan improper payment of anything of value.
Red Flag - a red flag is used as a warning of danger.

4. Policy
To facilitate day-to-day compliance with Informatica’s obligations under the FCPA, the UK Bribery Act,and other Anti-Corruption Laws in places where the Company conducts business, as well as our ethicalstandards, Informatica has adopted this Anti-Corruption Compliance Policy and Guidelines (the “Policy”),
which will be managed by the Company’s Legal Department. To implement this Policy effectively, every
person in our company must make a personal commitment to it. While we do not expect every personin the Company to become an expert in the applicable anti-bribery laws, we do expect all personnel toadhere to the Company’s ethical standards, to be cognizant of the FCPA, the UK Bribery Act, and otherAnti-Corruption Laws, and to seek guidance from the Company’s Legal Department whenever any
uncertainty regarding those laws or standards arises.

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Introduction
This Policy and associated guidelines are intended for use by all Informatica personnel, including
members of its board of directors, affiliates, agents, and employees, to ensure compliance with the FCPA,
the UK Bribery Act and other anti-bribery laws and regulations in places where Informatica conducts
business (the “Anti-Corruption Laws”). They provide details concerning the requirements of the FCPA
and UK Bribery Act and the compliance procedures that must be followed by all Company personnel, nomatter where they are located.

Compliance Guidelines
Summary of the FCPAThe FCPA has two major components: (1) the anti-bribery prohibitions; and (2) the accounting andrecordkeeping requirements. Both components apply to the Company’s business activities conductedin the United States and abroad. The FCPA anti-bribery prohibitions forbid a U.S. company or its
employee or representative from corruptly giving, paying, promising, offering, or authorizing the payment,
directly or indirectly through a third party, anything of value to any “foreign official” (a broad term whose
scope is discussed below) to persuade that official to help the company, or any other person, obtain or
keep business. The FCPA bars corrupt payments even if: (1) the benefit is for someone other than theparty making the payment; (2) the business sought is not with the government; (3) the payment does notwork, and no business is awarded; or (4) the foreign official initially suggested the payment.
The FCPA also requires the Company and its majority-owned affiliates to keep accurate and complete
records of the financial transactions in which it engages. The Company must make good faith efforts toensure that the ventures in which it owns a minority interest and the third parties it engages to perform
work on the Company’s behalf also keep such records.

NOTE: Compliance with the FCPA must be undertaken on a case-by-case basis and can be complex.
Employees should not try to solve FCPA problems on their own. If a question arises regarding any
improper payment related issue, please consult immediately with the Legal Department.

Summary of the UK Bribery Act
The UK Bribery Act contains four key provisions. First, Section 1 of the UK Bribery Act, known as aprohibition on “active bribery,” prohibits the offering, promising, or providing of things of value to any
person, directly or indirectly, with the intent to induce another to not act with good faith or impartiality, or
to abuse a position of trust, or to reward such improper action.
Second, Section 2, known as a prohibition on “passive bribery,” prohibits the requesting, agreeing toreceive, or acceptance of an improper payment of anything of value. It is, thus, a violation of this Policy
for any Company employee to receive, or agree to receive, anything of value with intent to not act in goodfaith, impartiality, or otherwise abuse a position of trust.
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Third, Section 6 of the UK Bribery Act, like the FCPA, creates an offense for providing improper payments
to foreign officials. An offense is committed even if the foreign official takes no action or does not accept
the bribe.
Fourth, Section 7 of the UK Bribery Act holds UK corporations or entities doing business in the UK strictly
liable if an “Associated Person” commits one of the three violations noted above. For purposes of the UK
Bribery Act, an “Associated Person” includes a person who performs services for or on behalf of theCompany. It is important to note that this definition is intentionally broad and covers not only Company
employees, but also Company vendors, sales representatives, business partners, and the like. It istherefore extremely important for any person covered by this Policy to conduct the required due diligenceon any person providing a service for or on behalf of the Company.

NOTE: Compliance with the UK Bribery Act must be undertaken on a case-by-case basis and can becomplex. Employees should not try to solve UK Bribery Act problems on their own. If a question arises
regarding any improper payment related issue, please consult immediately with the Legal Department.

Who is a Foreign Official?
The term “foreign official” is defined broadly under the FCPA. Foreign officials include all paid, full-time
employees of a non-U.S. government department or agency (whether in the executive, legislative or
judicial branches of government and whether at the national, provincial, state or local level). Government
officials can also include part-time workers, unpaid workers, individuals who do not have an office in a
non-U.S. government facility, and anyone acting under a delegation of authority from a non-U.S.
government to carry out government responsibilities. They also include officers and employees ofcompanies or entities which have non-U.S. government ownership or control, such as state-owned
enterprises and government-controlled universities and hospitals. A “Foreign Official” under the UK
Bribery Act (and for purposes of this Policy) carries the same definition as above, only such person must
be a non-UK— rather than non-U.S. — official. However, payments to UK government officials may still
violate UK law. Any questions about an individual’s potential government status should be raised with
the Legal Department.

NOTE: It is important to note that the FCPA and UK Bribery Act prohibit payments to individual “foreign

officials.” Bona fide payments to a government entity are not prohibited unless the Company has somereason to know that the payment will actually end up in the hands of an individual official.

Prohibited Payments
The FCPA and the UK Bribery Act prohibit offering, promising, or giving “anything of value” to a foreign
official to get or keep business. The UK Bribery Act also prohibits giving or offering anything of value toInformatica Confidential

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purely private parties (i.e. non-government officials) if intended to induce them to not act in good faith or
impartially, or to abuse a position of trust or reward the party for such improper conduct. A payment toencourage anyone not to do business with another company, to the extent it would result in a businessadvantage to Informatica, could also form the basis of a violation. Violations under the FCPA and UK
Bribery Act are not limited to the giving of cash payments. Gifts, entertainment, excessive businesspromotional activities, covering or reimbursing hospitality or travel expenses, in-kind or politicalcontributions, charitable contributions, investment opportunities, subcontracts, stock options, and similar
items are all things of value that can violate the FCPA or UK Bribery Act.
The FCPA contains a narrow exception that allows for “facilitating payments,” which are bribes, usuallyof a nominal amount, made to ensure non-discretionary governmental actions, such as processing visas
or business permits. The exception does not cover payments made to induce a government official or
employee to ignore his or her lawful duty or to exercise discretion in the award of business.
Despite this exception, and because the UK Bribery Act and some other Anti-Corruption Laws do not
permit facilitating payments, it is against Company policy to make facilitating payments (unless the healthor safety of an employee is at risk). If you have any question whether a payment qualifies as a facilitating
payment or whether an exception may be granted from this Policy to make a facilitating payment, contact
the Legal Department. If a facilitating payment must be made to ensure the health or safety of an
employee or other person, the event should be fully and properly reported to the Legal Department withinseventy-two hours.

Permissible Payments
The two sections below provide limited exceptions to the general prohibition against providing anythingof value to a foreign official. If you have any doubt whether a payment falls within these exceptions,consult with the Legal Department prior to engaging in the transaction.
Gifts
It is customary in many parts of the world to occasionally give nominal gifts to customers and otherparties that have a business relationship with the Company. Under this Policy, a nominal gift can bemade by a Company employee to a foreign official or private party if: (a) the giving of the gift does notmeet the elements of violation of either law (i.e., the gift is not given to obtain or retain business, gain an
improper advantage, or to induce an individual to not act in good faith or impartially or abuse a positionof trust); (b) the gift is lawful under the written laws of the country where the gift is being given; (c) thegift constitutes a bona fide promotion or goodwill expenditure; (d) the gift is not in the form of cash; (e)the gift is of nominal value (on an individual and aggregate basis); and (f) the gift is accurately recordedin the Company’s books and records.
While no dollar amount is specified under the FCPA or the UK Bribery Act, in general, no gift with a valueof more than US$100 should be given by an Informatica employee or third party working on behalf of theCompany to a foreign official without prior review and written approval by the General Counsel. For a gift
to a foreign official with a value of US$100 or less, prior written approval needs to be obtained only fromthe employee’s supervisor. For Informatica promotional or advertising items with a value of less than
US$100, such as pens or coffee mugs, no approval is necessary. The number of items given, however,must be reasonable and the gift must otherwise abide by the above-described requirements. In no case
may the total value of all promotional items given to an individual exceed US$500 in any 12-month period.
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Informatica employees should not give gifts to, or accept gifts from, a private party for an improper
purpose, i.e. where the gift creates a conflict of interest or is intended to cause the recipient to not act
in good faith or otherwise abuse a position of trust. Informatica employees may, however, provide
inexpensive gifts, having a maximum value of US$100, to private parties. Sometimes local customs
may dictate that Informatica employees exchange more valuable gifts with suppliers or customers. In
those instances, Informatica employees must first obtain written approval from the employee’s
supervisor. Such gifts should always be appropriate to the circumstances and should never be of a kindthat could create an appearance of impropriety. The nature and cost of any gift given by an Informatica
employee must be accurately recorded in Informatica’s books and records.

NOTE: If you have any doubt whether a payment falls within this exception, contact the Legal
Department.

Business, Travel and Entertainment Expenses for Foreign Officials and Private Parties
Informatica employees may provide certain types of entertainment and travel to foreign officials provided
that such entertainment and travel expenses are: (a) bona fide and related to a legitimate businesspurpose (i.e., promoting or demonstrating products or executing performance of a contract with a foreign
government); (b) reasonable in amount; and (c) legal under the written laws of the foreign official’s homecountry. The UK Bribery Act does not specifically permit companies to provide entertainment and travel
expenses to foreign officials. However, like the FCPA, if such expenses are reasonable and are notintended to improperly influence the official in the performance of his or her official functions, they will
not be a violation of the UK Bribery Act.
While the FCPA contains no prohibition on providing things of value to purely private persons, the UK
Bribery Act and other U.S. laws that apply to Informatica prohibit providing anything of value to any
person, including private, commercial parties, if it is intended to induce that person to not act in goodfaith or impartially, or to abuse a position of trust, or to reward such improper conduct. Accordingly, any
payments for the entertainment or travel of private persons must be reasonable and customary and must
not raise an inference that such expenditures were provided in order to improperly influence the private
person to not act with good faith.
For information on all entertainment, travel and travel-related expenses, including but not limited toairfare, accommodations, and entertainment and meals during a trip, please refer to Informatica’s Global
Travel and Expense Policy. Entertainment and travel expenses related to government officials, whether
provided by Informatica directly or on the Company’s behalf by a third party (such as a partner) must be
approved, in advance and in writing, by the Chief Legal Officer.
For business-related meals provided to government officials or private parties that are not associatedwith travel, reasonable and customary expenses for lunch should not exceed US$25 per person and fordinner they should not exceed US$150 per person without prior approval from your manager. All otherrequirements documented in the Global Travel and Expense Policy also apply.

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It is important to note that expenditures involving foreign officials are generally more heavily scrutinized
by government authorities than expenditures involving private parties. Moreover, because both the FCPA
and UK Bribery Act prohibit improper provisions to foreign officials, one violation of this sort could expose
the Company to liability in both the U.S. and the U.K. As a result, the following requirements pertaining
to foreign officials must be scrupulously followed by Informatica employees.
•

The travel is for a legitimate business purpose that is related to the official’s performance of
his lawful duties, such as to attend a demonstration of a Company product or service;•

The expenditure is legal under local law, the laws of the country where the foreign official
resides, where the expenditure for the travel is incurred, and/or where the travel and related
expenses are provided;•

Informatica is not paying for the travel expenses of any family members or friends
accompanying the foreign official;•

No stopovers are planned that are not directly connected to the business purpose of the travel,
unless the stopover is at the expense of the foreign official and results in no additional cost
to Informatica;•

The foreign official’s supervisor has prior notice of the trip, preferably documented by a letter
requesting that Informatica pay for the expenses in question;•

No cash per-diem payments to a foreign official are provided; and•Payments for travel or related expenses are made directly to the appropriate airline, hotel, orother vendor. Only in the event that it is not possible to make such direct payment, may
reimbursement be made directly to a foreign official if a receipt for the expense is provided.

Charitable Contributions
Requests from customers for individuals and/or Informatica to make charitable contributions to specificcharities those customers support are becoming more common. After discussing with your manager,
these special cases should be brought to the attention of the Corporate Compliance team for review andapproval in advance of the contribution being made or committed to. Factors such as the businesspurpose for which the contribution is being made, alignment with our Informatica Involved goals, theamount and timing of the contribution and other situation-specific factors will be reviewed to determine
if the contribution can be made.
Political Contributions
The Company may communicate its position on important issues to elected representatives and othergovernment officials. It is, however, the Company’s policy to comply with all applicable laws regarding
political contributions. Donations to political campaigns or causes could violate campaign finance laws
and Anti-Corruption Laws, especially if contributions are made to a campaign at the request or
suggestion of a government official.
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To mitigate the risk of violating the law, no Company funds, facilities, or services of any kind may beprovided to any candidate or prospective candidate for public office, to any political party, or to any
political initiative, referendum, or other form of political campaign unless pre-approved in writing by the
Chief Legal Officer.

Third Party Liability
The FCPA and UK Bribery Act establish liability for payments made indirectly to an official or private
person as well as payments made directly. The Company and individual directors, officers, or employees
may be liable for a payment made by a third party, such as a distributor, reseller, joint venture partner,
agent, or consultant, if the Company makes a payment or transfers other value to that third party“knowing” that it will be given to a government official. Under the FCPA, a firm belief that the third party
will pass through all or part of the value received from the Company to a foreign official, or an awarenessof facts that create a “high probability” of such a pass-through, also constitute knowledge under this law.
Under the UK Bribery Act, Informatica could be held strictly liable if a third party makes or receives a bribeeven if the Company has no actual knowledge of the bribe. As such, third parties must be investigatedprior to their engagement with the Company to ensure their commitment to FCPA and UK Bribery Act
compliance. When seeking to engage a third party, please refer to the Informatica New Partner Policy
and the Informatica Channel Partner Certification Policy (for Partners) and the Global Procurement Policy(for vendors and suppliers, including those providing contingent workers) for guidance on initiating an
investigation of the third party’s background and reputation, also referred to as conducting due diligence.
Company personnel should be particularly alert to any “red flags” that may be encountered during due
diligence or throughout the relationship with third parties. “Red flags,” as discussed in more detail below,
can arise with any third parties involved with the Company’s business operations, but arise more
frequently in dealings with joint venture partners and foreign agents (such as promoters, sales agents or
consultants). The basic rule is simple: a red flag cannot be ignored; it must be addressed.
“Red flags” can arise at any stage of a transaction -- during due diligence, during contract negotiations,in the course of operations, or at termination. “Red flags” that do not present serious issues at one stageof a transaction or relationship may pose significant liability risks when they appear at a different stage
or in combination with a different overall set of facts. Thus, the significance of “red flags” must be
considered in context rather than in isolation. All “red flags” must immediately be investigated andappropriately addressed.

NOTE: If you become aware of facts that may be “red flags” but are not sure how to respond to them,
you should immediately contact the Legal Department.

The following are some “red flags” that may arise with third parties and must be properly addressed:•

A reference check reveals the third party’s flawed background or reputation;

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The transaction involves a country known for corrupt payments;•

The third party is suggested by a government official, particularly one withdiscretionary authority over the business at issue;•

The third party objects to audit rights or FCPA or UK Bribery Act representations in
Company agreements;•

The third party refuses to sign Informatica’s anti-corruption / anti-bribery certificationin any given year, as required by the Informatica Channel Partner Certification Policy;•

The third party pays for or covers the costs associated with the travel and/or
entertainment of a government official;•

The third party has a close personal or family relationship, or a business relationship,with a government official or relative of an official;•

The third party requests unusual contract terms or payment arrangements that raise
local law issues, such as payment in cash, payment in another country’s currency, or
payment in a third country;•

The third party requires that his or her identity or, if the third party is a company, theidentity of the company’s owners, principals or employees, not be disclosed;•

The third party’s commission exceeds the “going rate” or must be paid in cash;•

The third party indicates that a particular amount of money is needed in order to "getthe business" or "make the necessary arrangements;"•

The third party requests that the Company prepare or accept false invoices or any
other type of false documentation; or•

The third party requests payment in a third country (i.e., not where services are
rendered, or where the third party resides), or to an account in another party’s name.

NOTE: All contracts with foreign agents must contain appropriate provisions requiring the agent tocomply with the FCPA and/or UK Bribery Act. Moreover, all third parties will be required to sign an antibribery compliance certificate indicating their understanding of the law and the Company’s Policy.

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Joint Ventures
Informatica is potentially liable for the activities of its joint venture partners, and of its joint venture
entities themselves, whether it is a majority or minority owner or partner. In either case, the Company
must take reasonable steps to ensure the venture’s activities comply with the FCPA and UK Bribery Act
anti-bribery prohibitions and the FCPA’s recordkeeping requirements. Such steps do not impose anaffirmative duty to investigate each and every action performed by a joint venturer. Rather, in the eventthat the Company learns of a joint venturer's potential or real violation, or if the Company becomes awareof red flags related to the joint venturer's activities, Informatica should take reasonable steps todetermine and/or prevent a violation from occurring.
While all Company personnel must be a part of the compliance effort, directors and officers in foreign
ventures may face issues appropriately presented to those in a management role and must be preparedto address them. For example, as a minority partner, Informatica may not always have the power to stop
an improper payment from happening. Nonetheless, the Company must take every step available to it toprevent such occurrences.

Accounting and Recordkeeping Requirements
As mentioned above, the FCPA imposes strict accounting, recordkeeping, and internal controls
requirements on “issuers,” including Informatica, in its foreign operations. For these reasons and as amatter of Company policy, Informatica personnel must accurately and completely describe all
expenditures, including facilitating payments, and should never inaccurately describe or seek tomischaracterize the nature or amount of a transaction, including those associated with travel andentertainment. All records relating to FCPA compliance matters shall be maintained for a minimum of
five years, and diligent efforts should be used to maintain original documents. Company personnel
should never accede to requests for false invoices or for payment of expenses that are unusual,excessive, inadequately described, or otherwise raise questions under this Policy. Moreover, Company
personnel should ensure that all transactions are executed in accordance with management’s
authorization and that there are no off-book accounts or unauthorized payments. Consult the Legal
Department if you have any questions or concerns regarding these requirements.

Penalties
The SEC and the DOJ share enforcement responsibility for the FCPA. The UK Bribery Act is enforced by
the Serious Fraud Office of the government of the United Kingdom. In addition, Informatica will takeappropriate action against those persons whose actions violate these guidelines, which may include
immediate termination of employment or business relationship.
Violations of the FCPA’s Anti-Bribery Provisions
Criminal penalties for violations of the FCPA's anti-bribery provisions can be quite severe. Corporations
and other business entities are subject to a fine of up to $2,000,000 per violation. Officers, directors,
stockholders, employees, and agents are subject to a fine of up to $100,000 per violation andimprisonment for up to five years. Under federal criminal laws other than the FCPA, individuals may be
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fined up to $250,000 or up to twice the amount of the gross gain or loss if the defendant derives economic
gain from the offense or causes economic loss to another person.
The Attorney General or the SEC may bring a civil action for a fine of up to $10,000 per violation against
any “issuer” as well as any officer, director, employee, or agent of a firm, or stockholder acting on behalfof the issuer, who violates the anti-bribery provisions.
Violations of the FCPA’s Accounting Provisions
The accounting provisions provide for penalties similar to those levied for most securities law violations,such as civil injunctive action or monetary penalties. Penalties for issuers typically range between$50,000 and $500,000.
Penalties for willful violations are more severe. Individuals who willfully violate the accounting provisions
face fines of up to $5,000,000 per violation, imprisonment of up to 20 years, or both. Issuers that willfully
violate the accounting provisions face fines up to $25,000,000 per violation.
Violations of the UK Bribery Act
Individuals found guilty of providing or receiving improper provisions in violation of Sections 1, 2 or 6 of
the UK Bribery Act face up to 10 years in prison. Fines for individuals and companies may also be
substantial, as there is no statutory limit to monetary penalties under the UK Bribery Act.
Reporting Violations
Any employee or third party acting on behalf of the Company who learns of or suspects a violation of thisPolicy should promptly report the matter to the General Counsel or call the Ethics Hotline at 1-877-2957941 or submit a report at http://informatica.ethicspoint.com. For those employees located outside of
the U.S., specific dialing instructions by location are available at http://informatica.ethicspoint.com.
Audit of Anti-Corruption Compliance
Compliance with this Policy and the required controls may be reviewed and tested by designatedmembers of the Finance and/or Legal Departments. This review may include the following:
•
•
•
•
•
•
•

Review of the documentation and the communication of the Policy and relevant standards
and controls to Informatica officers, directors, and employees;
Review of and assurance that communications and training are targeted to key employees;
Review of procedures to ensure delivery and receipt of training to key employees;
Review of procedures to ensure certification (and documentation) by employees ofcompliance with the Policy;
Assurance that agreements and relationships with third parties are supported by proper
documentation, including:Due diligence reports;
Pre-engagement review and approval;

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Incorporation of anti-corruption and anti-bribery assurances in agreements and contracts;
Review of payments to applicable third parties for reasonableness in terms and forauthorization; andReview and reconciliation of selected foreign bank accounts and any petty cash accounts
and disbursements.

The designated members of the Finance and/or Legal Departments shall report their findings to senior
management (CEO, CFO, etc.). Based upon those findings, the Legal Department, in coordination withsenior management, shall amend or modify this Policy as necessary to improve and optimize
Informatica’s mechanisms and controls in order to ensure that Informatica meets all applicable legal andethical standards.

5. Compliance
Compliance with this Policy is required. Departures from our business standards and the requirements
documented in this Policy will not be tolerated. Informatica will take appropriate action against those
persons whose actions violate the Policy, which may include immediate termination of employment
or business relationship.

6. Primary Sources••

Foreign Corrupt Practices Act
United Kingdom’s Bribery Act of 2010

7. Secondary Sources••••

Code of Business Conduct
Global Travel and Expense Policy
INFA New Partner Policy
INFA Partner Certification Policy

8. Document Control and Revision History
Date

Participants

Scope

December, 2011

Legal General Counsel

Policy formalized, approved and adopted

January, 2018

Legal General Counsel

Policy amended.

Informatica Confidential

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Anti-Corruption Compliance Policy and Guidelines

March, 2019

Corporate Compliance
Programs Committee

Policy reviewed and approved.

April, 2020

Corporate Compliance
Programs Committee

Policy amended, reviewed and approved.

June, 2020

Jim Trovato

Policy reformatted to apply standard Policy template.

March, 2020

Jim Trovato

Minor typos and formatting

June, 2021

Jim Trovato

Added new Charitable Donations section

July, 2021

Jim Trovato

Added new Political Contributions section and otherrevisions

August, 2021

Informatica Inc. Boardof Directors

Updates for public company status.

March, 2022

Jim Trovato

Annual Review. Changed Owner and Approver to alignwith corporate governance requirements. Added DCN
for this policy.

April 30, 2023

Kim Useforge

Annual Review. Minor typos formatting changes.

9. Policy Approval
Approver Name

Date

Kathryn Harr, General Counsel

December, 2011

Kathryn Harr, General Counsel

January, 2018

Maura Sharp, VP & Deputy General Counsel, Employment and Compliance,
Legal

March, 2019

Maura Sharp, VP & Deputy General Counsel, Employment and Compliance,
Legal

April, 2020

Maura Sharp, VP & Deputy General Counsel, Employment and Compliance,
Legal

April, 2021

Maura Sharp, VP & Deputy General Counsel, Employment and Compliance,
Legal

June, 2021

Maura Sharp, VP & Deputy General Counsel, Employment and Compliance,
Legal following Informatica Inc. Board of Directors approval

August, 2021

Informatica Confidential

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Anti-Corruption Compliance Policy and Guidelines

Maura Sharp, VP & Deputy General Counsel, Employment and Compliance,
Legal

April, 2022

Maura Sharp, GVP, Deputy General Counsel, Employment and Compliance,
Legal following Informatica Inc. Board of Directors Audit Committee
approval.

April, 2023

Maura Sharp, VP & Deputy General Counsel, Employment and Compliance,
Legal

April, 2024

Informatica Confidential

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