Empowering
the Digital Future2021 Environmental, Social, and Governance Report

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ETHICS & GOVERNANCE

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1 Introduction
5 Approach
10 Ethics and Governance
13 Products
17 Environmental Stewardship
20 People & Culture
25 Community Impact
37 Performance Data Table
43 SASB and GRI Index

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COMMUNITY IMPACTPERFORMANCE DATA TABLESASB AND GRI INDEXFive billion people are connected to the internet

education program we co-created to help protect

Product donation: In FY21, our products helped

and their digital lives are growing exponentially.

and empower children and families to live theirnearly 10,000 nonprofits keep their devices andOver the past 12 months, we have spent evendigital lives safely. In FY21, we also launched Surf

data secure. In response to COVID-19, we also

more time online – socializing, streaming, learning,

Smart 2.0 with the World Association of Girl

offered a five-month complimentary subscriptionbanking, shopping, and more. While this has

Guides and Girl Scouts, an update to our program

to Norton™ Family to help parents manage their

allowed us to stay connected with family, friends,

focused on equipping girls and young women withchildren’s online activities. These donations andand communities, it has also made our mission of

the knowledge and skills required to help protect

our donations to global nonprofits, had a retailprotecting and empowering everyone to live theirthemselves and others online.

value of over $4 million.

Diversity, equity, and inclusion: We believe

Environmental stewardship: We work to reduce

NortonLifeLock is a global leader in consumer

diversity is a driver of innovation and helps us

greenhouse gas (GHG) emissions by creating

Cyber Safety, empowering nearly 80 million users

make products that meet the needs of the broad

efficiencies and utilizing renewable energy. In

in more than 150 countries. Fiscal year 2021 wasspectrum of people we serve. In FY21, females

FY21, we achieved a 52% reduction in Scope 1very strong for us as we returned the Company

represented 33% of our global workforce, andand 2 GHG emissions compared to FY20. We

to growth and increased our direct customer

underrepresented team members represented 13%

also launched Earth Champions Start at Home, acount by nearly three million. We continue toof our U.S. workforce. We reached an importantcompetition challenging employees to take 10

push the boundaries of Cyber Safety – adding

milestone by achieving gender for the independent

small actions over 10 weeks to make a big impact,

new products and accelerating innovation acrossmembers of our Board of Directors, and wetogether.

security, privacy, and identity.

continued to fund the Reboot Representation

digital lives safely more relevant than ever before.

Letter fromVincent PiletteCorporate responsibility and positive social impact
remain core to our business strategy and are a
key part of fulfilling our corporate vision. Buildinga brand centered on trust is critically important,the number of Black, Latina, and Native American
women graduating with computing degrees by2025.

Our work is supported by a culture of innovation,
guided by a driven Leadership Team, and executedby our talented team members who share apassion for making the digital world a safer place.
We are building a company that is redefining

and our focus on environmental, social, andEmployee volunteering and giving: We arewhat Cyber Safety means for consumers andgovernance topics helps us earn this trust fromproud of our year-long culture of giving and theand succeeding by creating value for all of ourour users, employees, investors, and shareholders.

enthusiasm with which employees joined our

stakeholders. Our future is bright, and we are justA few of our FY21 Corporate Responsibility

virtual volunteer program. We donated 407,800

getting started.

accomplishments are highlighted below.

meals to help feed our neighbors, contributed

Cyber Safety training and education: In April 2021,
we made a $1 million commitment to National
PTA to expand The Smart Talk, the Cyber Safety

INTRODUCTIONTABLE OF CONTENTS

Tech Coalition, which is committed to doubling

ETHICS & GOVERNANCE
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nearly $200,000 on Giving Tuesday, and 19%
of employees participated in our philanthropic

Vincent PiletteChief Executive Officer, NortonLifeLockmatching program.

PRODUCTSSTEWARDSHIPCOMMUNITY IMPACTPERFORMANCE DATA DATATABLETABLESASB AND GRI INDEXDATA ENVIRONMENTALPRIVACYCOMMUNITIES PEOPLE & CULTURE
ENVIRONMENTOUR PEOPLE
GRI AND SASB INDEX

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The past year shined new light on the power and agility of the private sector to
tackle unprecedented global challenges by harnessing its purpose and working
together with stakeholders far and wide.
In our increasingly complex and connected world, technology has the power totransform how we live our lives – but only if we have the tools and knowledge to
use it safely. In FY21, NortonLifeLock’s Leadership Team and its approximately
2,800 employees took the Company's vision to protect and empower people tolive their digital lives safely to new levels in its drive to transform Cyber Safety andbecome consumers’ most trusted online ally.
As NortonLifeLock continues to expand its business internationally, Corporate
Responsibility has remained a core part of our operating model. From Ireland to
India, the Company is partnering with local organizations to help reduce the digital
divide, equip schools and students with the technology they need to continue
online education, and to protect children from online predators.

Letter fromSue Barsamian

Ethical conduct, integrity, and good governance remain the building blocksof our business success. The Nominating and Governance Committee of our
Board of Directors has oversight of Corporate Responsibility issues and receives
quarterly updates on topics such as diversity, ethics, environmental stewardship,
and community investment. Our global culture of responsibility, and the positive
contributions we make to the customers, employees, communities, and otherstakeholders that we serve drives value for our business.
I hope while reading this report you get a sense of the passion, capabilities, anddrive that NortonLifeLock’s team brings to work each day. We are united in ourefforts to build a safe and sustainable future.

Sue Barsamian
Board Member and Nominating andGovernance Committee Chair, NortonLifeLock

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About NortonLifeLock Inc.

Headquarters

Launched

TEMPE, ARIZONA, USA

NOVEMBER 4, 2019

AnnualRevenue1

2.6

Employees
WORLDWIDE 2,8001

SectorTECHNOLOGYBILLION

50% of people
have been a victim
of cybercrime2

There are 10
victims ofcybercrime every
second2

Approximately
80 million users trust
NortonLifeLock with
their personal information

NortonLifeLock.com
1 As of April 2, 2021.
2 Based on an online survey of 10,030 adults in 10 countries conducted by The Harris Poll on behalf of NortonLifeLock, February 2021.

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Our Vision is to protect and empower people to live theirdigital lives safely
About NortonLifeLock Inc.
NortonLifeLock Inc. (NASDAQ: NLOK)
is a global leader in consumer Cyber
Safety, protecting and empowering
people to live their digital lives safely.
We are the consumer’s trusted ally in
an increasingly complex and connectedworld. Learn more about how we’retransforming Cyber Safety at
www.NortonLifeLock.com.

2

Devices includes computers, smartphones, and tablets.

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Approach
Corporate Responsibility strategy and commitment
NortonLifeLock’s commitment to Corporate
Responsibility is a critical anchor of theCompany’s mission and operating philosophy.
In FY21, we reimagined our Corporate
Responsibility program to better fit with
our new, more focused business priorities.
Our new Corporate Responsibility mission
is to bring together our team, expertise,and powerful technology to build a safe,
inclusive, and sustainable future for people,
their information, and the digital world. We
call our Corporate Responsibility efforts
NortonLifeLock Cares.

Prioritizing our ESG efforts
Our first step in this process wasan assessment to identify criticalenvironmental, social, and governance (ESG)
priorities, opportunities, and risks. Moredetails of this assessment, which included
a rigorous quantitative assessment, internaland external interviews, and analysis, can befound in our 2020 Corporate Responsibility
Report on page 9. We will conduct an issue
prioritization assessment every three tofive years.

The output of this assessment helps us todetermine our priority ESG topics and is oneof the resources that guides our strategy anddisclosures, including this report. The priority
topics that resulted from our 2020 priority ESG
issue assessment are:• Education and Training for Cyber Safety• Data Privacy and Protection• Diversity, Equity, and Inclusion• Talent Development and Engagement• Climate and Energy

I am unbelievably proud of what our team has accomplished this year. We have relaunched a strategic andimpactful Corporate Responsibility program that utilizes the best of what we have to offer to support ourcommunities, protect our planet, and help our team members thrive. We’ve created a culture of giving, embedded
diversity and inclusion across our grant funding, and doubled our efforts to increase digital safety literacy, all while
adapting our program to the growth our business has achieved. And it’s not going unnoticed; we’re being recognizedby many of the world’s leading ESG benchmarks for our performance and commitment to transparency.”– Kim Allman, Head of Corporate Responsibility and Government Affairs, NortonLifeLock

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Launching our first ESG Report
We have a long history of sharing an annual
account of our commitments and progresson the environmental, social, and governance(ESG) topics most important to our businessand our stakeholders. In our 2020 Corporate
Responsibility Report, we provided our
first Sustainability Accounting Standards
Board (SASB) Index, shared the results ofour priority ESG issue assessment, andpublished a broad set of investor-oriented
ESG performance metrics. The 2020 reportprovided a foundation for our transition to an
ESG Report this year.

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Corporate Responsibility objectives

Setting strategic and achievable Corporate
Responsibility objectives helps to clarify ourpriorities, guides our work, and improves
our performance. After completing an issue
prioritization assessment, the next step in our
FY21 Corporate Responsibility strategy process
was to set objectives for our ESG priority
topics. We completed a peer and Corporate
Responsibility leader benchmark, analyzed key
ESG ratings and rankings, and discussed theseobjectives with internal leaders across theCompany. Our objectives support our Company’sbusiness goals and focus on the unique positive
impact we can have on the world.

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PRIORITY TOPICOBJECTIVE

KEY EFFORTS IN FY21

Education and Training
for Cyber Safety

Leverage NortonLifeLock’s leading
expertise and technology in Cyber
Safety to help protect communities.

Many malicious phone and computer applications, known as stalkerware,
are used to harass, control, and harm people. We are a founding memberof the Coalition Against Stalkerware. We donate our products to survivors
to help keep their personal data protected, and we conduct Cyber
Safety trainings to help empower victims and survivors to reduce theirvulnerability. Learn more on page 30.

Data Privacy andProtection

Raise awareness of NortonLifeLockas a privacy leader.

We are committed to safeguarding our customer, partner, and employee
data as well as offering products, including Norton™ Privacy Monitor
Assistant, that help consumers protect their own personal data whereverit lives. Learn more on pages 10-12.

Diversity, Equity, andInclusion

Invest in high-impact nonprofits
to bring more women andunderrepresented groups into
cybersecurity and tech.

We made a three-year commitment to the Reboot Representation techcoalition, which is committed to doubling the number of Black, Latina,
and Native American women graduating with computing degrees by2025. Learn more on pages 27 and 31.

Talent Development andEngagement / Employee
Volunteering and Giving

Drive opportunities for employee
volunteering and giving and increase
employee participation rate.

In FY21, we launched a virtual volunteer program with team building
opportunities and joint events with our Diversity and Inclusion
Communities. Learn more on pages 25-27.

Climate and Energy

Establish NortonLifeLock as anenvironmentally responsible
business.

We finalized and launched our new environmental strategy and achieved
an 52% reduction in Scope 1 and 2 greenhouse gas emissions between
FY20 and FY21. Learn more on pages 17-18.

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Engaging our stakeholders
NortonLifeLock has identified stakeholders
as groups or individuals with an interest in orconcern with our business. We also consider
those our business affects in various ways.
Engaging our stakeholders — employees,
investors, customers, communities, governmental
and nongovernmental organizations, suppliers,
and industry groups — provides us with insight
into shifting external expectations and informs
our Corporate Responsibility strategy.
We frequently engage with our stakeholders
on ESG topics through working groups,
conferences, one-on-one discussions, and digitalcommunications.

STAKEHOLDERS

KEY ENGAGEMENTS IN FY21

Consumers

Helping people understand the importance of Cyber Safety is a critical piece of fulfilling our Company vision. We
recently launched a new campaign, Opt-in to Cyber Safety, that uses a bit of humor to help people recognize weare constantly on the edge of “unsafe."

Employees

We conduct quarterly all-employee pulse surveys to measure ongoing employee engagement and encourage
feedback on specific topic areas. In Q4 of FY21, our survey included questions on diversity, equity, and inclusion(DEI), which confirmed our DEI strategy is aligned with employee needs and expectations.

Investors

In May 2021, we hosted our first Investor Day showcasing NortonLifeLock’s long-term strategy. The event featured
a live video Q&A with the Company’s leadership, as well as watch-on-demand presentations.

Communities

We are a longtime partner of National PTA and together co-created the fun, free digital safety education program
The Smart Talk. In early 2021, we announced a new $1 million commitment to expand The Smart Talk to serve
more families over two years.

Read about ESG oversight in the Ethics andGovernance section of this report.

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Corporate Responsibility process
NortonLifeLock’s Corporate Responsibility business process is based on
stakeholder input and tied to our corporate values and priorities

SUSTAINABLE

Corporate Responsibility Reporting
and Communications

DEVELOPMENT

Partnerships Across Our Business (People & Culture,
Workplace Solutions, IT, Product, Procurement)

GOALS

Stakeholder Engagement, External
Memberships and Partnerships

Board Oversight

Supporting The United Nations
As a signatory to the United Nations Global
Compact, we continue to support their ten

Corporate Responsibility Program
Performance Measurement

Prioritizing Strategic Focus Areas

principles, and this report serves as ourannual Communication on Progress. We
also support the United Nations Sustainable
Development Goals (SDGs) and recognize
the opportunity to align our core businesscapabilities with society’s most pressing
needs. We provide metrics and highlights

Corporate Responsibility Program
Implementation

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Corporate Responsibility Goal Setting

to quantify and illustrate our impact andcontributions to the SDGs on page 36.

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FY21 ESG highlights

$1.9M

$407K

~9,90033%

56%

IN CHARITABLE
GIVINGIN EMPLOYEE MATCHING
GIFT DONATIONSNONPROFITS RECEIVED
SOFTWARE DONATIONSGLOBAL GENDER
DIVERSITY

OF BOARD DIRECTORSARE DIVERSE*

52%

3.5K

250K

EMISSIONSREDUCTIONTREES PLANTEDDETECTIONS OF MALICIOUS
STALKERWARE

2021
RECOGNITION

Continuing to build a Company centered on trust isa huge opportunity for NortonLifeLock. Delivering
positive environmental and social impact, and operating
our businesses with integrity helps reinforce this trust with
consumers and increases the strength of our brands."– Krista Todd, Chief Marketing Officer, NortonLifeLock*Underrepresented Community (Ethnic Diversity and/or LGBTQ+)INTRODUCTION

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Ethics & Governance
Today’s consumer expects and deserves a partner they cantrust to do the right thing — a Company that embraces strong
principles and ethics. A high standard of ethics and good governance
are NortonLifeLock’s greatest strength as we advocate, innovate,communicate, and execute as a team.”– Vincent Pilette, Chief Executive Officer, NortonLifeLock

ESG oversight
Leadership for Corporate Responsibility
comes from the top. Our Head of Corporate
Responsibility and Government Affairs reports
to our Chief Marketing Officer and meetsregularly with our CEO and Leadership Teamto share Corporate Responsibility strategy andprogram updates, and to provide educationon our Company’s ESG progress and priority
areas.
The Nominating and Governance Committeeof our Board of Directors has oversight over
the Company’s Corporate Responsibility
strategy, and our full Board of Directors
receives a quarterly ESG update.

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This quarterly update includes performancedata and program information acrossenvironmental stewardship, ethics,
community investment, and more;progress made toward our Corporate
Responsibility objectives; and information
on emerging ESG priorities (for example
cryptocurrency and its environmental
impacts). As an example, our environmental
strategy launched in FY21 was sharedand shaped through ongoing dialogue andengagements with both our Leadership
Team and Board.

Corporate governanceWe believe that NortonLifeLock’s long-term
interests are best served when the Company
proactively considers and addresses the interestsand concerns of stakeholders. To that end, we
engage in honest and open communication
about our Company’s financial and governanceactivities. We have made our NortonLifeLock Codeof Conduct, the composition of our corporate
committees, our political disclosure andaccountability, and our Company charters publicly
available on our website. Read more about ourapproach to Corporate Governance on our website
and in our Annual Report here.

Our mission to protect everyone’s digital life is a criticalone. Seeing our Company’s commitment and progressin addressing ESG opportunities and risks has been pivotal inrealizing the full potential of our Company to create value forour stakeholders.”

Read more about ESG management in the
Approach section of this report.

ETHICS & GOVERNANCE

PRODUCTSENVIRONMENTAL STEWARDSHIP– Natalie Derse, Chief Financial Officer, NortonLifeLock

PEOPLE & CULTURE

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Our Board of Directors is charged withrepresenting the interests of our stockholders
and ensuring that the Company is managed inalignment with our commitment to Corporate
Responsibility as outlined in this report.
The Board is comprised of nine directors,
and there are four primary committeesof the Board: the Audit Committee, theCompensation and Leadership Development
Committee, the Nominating and GovernanceCommittee, and the Technology andCybersecurity Committee. The Board
established this last Committee at theend of FY21. It has direct oversight of theCompany’s technology strategy, initiatives,and investments, as well as internal andexternal cybersecurity and information
technology risks. The Board has delegatedvarious responsibilities and authorities tothese different committees, as described in
our FY2021 Annual Report.
A milestone this past year was reachinggender parity for the independent members of
our Board of Directors with the appointmentof two female directors – Emily Heath, SeniorVice President, Chief Trust and Security
Officer at DocuSign, and Sherrese Smith,Partner, Corporate Department, and Vice-Chairof the firm’s data privacy and cybersecurity

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practice at Paul Hastings LLC. The two new
directors bring deep and direct experience indata privacy, cybersecurity, and information
security.
Read more about our Board structure,
governance, and activities on our website andin our Annual Report here.

Executive compensation
The overriding principle driving our executive
compensation programs continues to be
our belief that it benefits our employees,
customers, partners, and stockholders tohave management’s compensation tied to ournear- and long-term performance. In general,these pay programs reward achievementof challenging performance goals thatalign with our business strategy. We havea continued and heightened commitment
to pay-for-performance and to corporate
governance best practices. Read more
about our Company’s approach to executive
compensation in our Annual Report here.

EthicsNortonLifeLock is committed to conducting
its business fairly and honestly. Our reputation
is a valuable business asset, and ethical andlegal conduct at all levels of our business isessential for our continued success.

ETHICS & GOVERNANCE

PRODUCTSThe NortonLifeLock Code of Conduct aligns
our business practices with our values anddefines what we expect of Board members,
officers, employees, and contractors. Our
Code of Conduct is offered in four languages(English, French, German, and Japanese). Our
Partner Code of Conduct applies to business
partners involved in the distribution, resale, orcommercialization of NortonLifeLock products
and services, whether a direct or indirect
partner. Additional ethical safeguards include
our Global Supplier Code of Conduct, Global

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Procurement Policy, Global Anti-Corruption
and Bribery Policy, and Global Antitrust andCompetition Policy.
Each year employees participate in a
mandatory Code of Conduct training. In
FY22, we highlighted modules on humanrights and modern slavery, anti-bribery andcorruption, managing conflicts of interest, anddiversity, equity, and inclusion. In total, 100% of
employees completed the training (excluding
employees on leaves of absence).

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Employees must follow NortonLifeLock’s
Information Security Policy and Standards.
In FY21, we offered security trainings,
including Secure from the Start and ourannual Security Awareness training, privacy
trainings on the General Data Protection
Regulation (GDPR) and the California
Consumer Privacy Act (CCPA), as well as
training related to global trade sanctions,creating a harassment-free workplace, andpreventing sexual harassment. Employees
can ask questions or report any ethicalconcerns or violations of our Code of
Conduct through EthicsLine. The anonymous
hotline is available 24 hours a day via the web
or telephone.
Read about ethical product development in
the Products section of this report.

Enterprise risk
management
NortonLifeLock’s enterprise risk
management (ERM) practices are focusedon identifying and managing risks that could
impact the achievement of our strategy andbusiness objectives. This includes reducing
the likelihood that events will occur, or if they
do occur, managing the impacts.

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We have incorporated climate risk into
our ERM process. The Board of Directors
and supporting committees of theBoard are responsible for the oversightof NortonLifeLock’s risk management
practices. Based upon the nature of the risk,
the Board or appropriate committee regularly
reviews the identification, measurement,
prioritization, management, and monitoringof enterprise risks. The CEO and Leadership
Team are responsible for the overallmanagement of enterprise risks, specifically

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the prioritization and allocation of resources
to manage NortonLifeLock’s risk profile
to an acceptable level. An Enterprise Risk
Committee is in place to periodically review
enterprise risks and confirm that appropriate
risk response plans are in place and operating
effectively. Category risk owners provide selfassurance and are responsible for the inherent
and residual risk of their respective categories.
Internal Audit is responsible for independently
assessing the enterprise risk profile for
NortonLifeLock and validating the results

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against management’s self-assessed profile.
The identification, assessment, prioritization,and reporting of enterprise risks, and the
response to those risks, is an ongoing process.
NortonLifeLock describes our material risks
in our forward-looking statement, in the Risk
Factors of our Annual Report on Form 10K, our Quarterly Reports on Form 10-Q, andother public filings and press releases. These
resources are available at https://investor.
nortonlifelock.com.

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Products
Protecting and empowering people to live their digital lives safely is what we do so the world canenjoy the amazing benefits and joy technology brings us. We are focused on data protection
excellence, implementing privacy best practices, and delivering a portfolio of innovative products
and services that protect each aspect of our customers’ digital lives.

Privacy Excellence

Leading Cyber Safety Products

Governance

Expanding our Portfolio• Privacy Operating Model (POM)• Avira acquisition• Global Privacy Policy

Related Products• Operational Privacy Compliance• Norton™ Secure VPN• Product and Service Privacy Notices• Norton™ Crypto

Programs• SafePic™ by Norton Labs

• Privacy Business Leads Program• BotSight™ by Norton Labs

• Trainings (Code of Conduct, compliance-

Product Innovation + R&D

related, and business functional trainings)• Norton Labs

Regulatory Compliance• EU Data Protection• Privacy Portal + Data Subject Rights
Self-Serve Module• Norton Research Group
Education & Awareness

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ETHICS & GOVERNANCE

Our Product teams build tools to help protect
all aspects of a person’s digital life. For
example, Norton™ Privacy Monitor Assistantprovides greater control over online privacy
by scanning popular sites for personal
information to allow individuals to exercise
their privacy rights. Norton™ Secure VPN uses
encryption to help secure private information
like passwords, bank details, and credit card
numbers sent and received when using
Wi-Fi, and was significantly improved andstrengthened in FY21.
Additionally, we continue to offer free guidanceand education on online privacy to various
groups, including school-aged children,
university students, and professionals.

• Internet Security Center• Preparing for CPRAINTRODUCTION

We are committed to data privacy andprotection in two ways – building products
and processes to protect the privacy of ourcustomers, and safeguarding the personal
data of our customers, employees, vendors,
and partners.

Leading Cyber Safety Products• Norton™ Privacy Monitor Assistant• Global Privacy Statement

Privacy at
NortonLifeLock

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Introducing Avira
We continue to expand our productportfolio through strategic acquisitions
and partnerships. In January
2021, we closed the acquisition ofGermany-based Avira, which provides
a consumer-focused portfolio ofcybersecurity and privacy solutions
to a strong base in Europe and key
emerging markets. Avira also has along history of Corporate Responsibility– including team-building volunteer
events and charitable giving. We lookforward to sharing more about Avira in
our FY22 report.

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Our Internet Security Center includes thelatest threat news and expert articles on
malware, privacy, online scams, digital safety
for children, identity theft, and more. This year,
in an effort to help consumers understandthe technological implications of working andschooling from home during the pandemic,
we focused on data analysis and consumerfriendly publications that were aimed at
helping consumers navigate the security andprivacy implications of the pandemic and its
unique circumstances.

We provide a Global Privacy Statement toPrivacy training

explain our personal data processing practices

In FY21, 100% of active employees completed

Privacy excellence

allowing for both identification of breakdowns

Privacy complianceand opportunities for improvement.

NortonLifeLock’s Privacy Legal team

NortonLifeLock’s Privacy Operating Model(including collection of personal data, individual
privacy rights, referrals/marketing, children’s
privacy, and more). We also provide Productand Service Privacy Notices to explain in detail
how personal data is collected and used byeach of our products. Many corporate privacy
programs focus solely on these types of polices
and statements. At NortonLifeLock, a dedicatedcompliance operations team tests andmeasures elements of our privacy program,(POM), shown on page 11 of the 2020

We’ve also seen substantial value in the

Corporate Responsibility Report, creates

ability to increase and deepen our cross-accountability for privacy from the Board

functional collaboration. Our Privacy Businessand Leadership Team to the employees who

Lead program provides privacy experts at

implement privacy-protecting processes

the front lines of the Company. Through thisand handle personal information daily. The

program, the Privacy Legal team engages with

POM is based on a “three lines of defense”

employees responsible for tactical creation,model and provides proactive governanceimplementation, and evolution of products andand accountability at multiple levels of theprocesses on issues of privacy. In FY21, theCompany. NortonLifeLock’s Privacy Principles

Privacy Business Leads provided input into theare outlined in our Global Privacy Policy, theFY22 privacy training plans, leading to muchinternal policy that guides our actions on

broader privacy training opportunities than had

privacy. Our Code of Conduct also includes aoriginally been envisioned. Privacy Legal also

high-level privacy overview and details employee

provides a “privacy by design” framework that

requirements for handling personal data.

guides our approach to privacy when designing

our Code of Conduct, Security, and FTC
trainings. In addition, employees received
role-specific privacy trainings that addressed
topics such as the California Consumer
Protection Act (CCPA) and cookie compliance.
Additionally, our People & Culture teammembers received training focused onprotecting employee privacy in a humanresources and facilities context.

dynamically adapts to the latest regulatory
guidance, while monitoring new and evolving
regulation globally. For example, in FY21 theteam focused on European data protection
compliance throughout the year as therequirements for international transfers of EU
personal data continue to develop. Additionally,
NortonLifeLock implemented a self-serve
web form for data subject rights requests,
in support of the General Data Protection
Regulation, CCPA, and other legislation. While
NortonLifeLock already enabled customers to
exercise their privacy right through calling our
support teams, we are always looking to makethe process easier and more accessible.

products.

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Now customers and other data subjects
can submit their requests directly via the
NortonLifeLock privacy portal. We also beganplanning for the California Privacy Rights Act of
2020, though the majority of its provisions will
not become operative until January 1, 2023.
Additionally, our Company continued toprioritize customer and employee dataprotection throughout the challenging andshifting environment of a global pandemic.
Our Privacy Legal team provided support todata management, customer support, people
management, and facilities on an ongoing anditerative basis, adapting to the requirements ofexternal authorities.

Information security
We maintain a comprehensive technology
and cybersecurity program to support theeffectiveness of our systems and prepare for
information security risks, including regular
oversight of our programs for security monitoringfor internal and external threats to safeguard theconfidentiality and integrity of our information
assets. We test our business continuity plans
and incident response procedures at least
annually, and 100% of our information security
management system is aligned to ISO 27001.
Our Head of Cyber Security is ultimately
responsible for our cybersecurity program and

INTRODUCTION

APPROACH

meets at least twice annually with the Board of
Directors or the Audit Committee of the Boardof Directors to brief them on technology andinformation security matters. Recently, ourBoard of Directors established a Technology
and Cybersecurity Committee of the Board.
All Board Directors have Cyber Safety andtechnology expertise and experience.
We have implemented security monitoring
capabilities designed to alert us to suspicious
activity and developed an incident response
program that includes periodic testing andis designed to restore business operations
as quickly and as orderly as possible in theevent of a breach. In addition, employees
participate in ongoing mandatory annual
trainings and receive communications
regarding the cybersecurity environment toincrease awareness. Our IT infrastructure andinformation security management systems
have been audited by external auditors in thelast fiscal year, and we conduct third-party
vulnerability analysis including simulated
hacker attacks. Additionally, we carry insurance
that provides protection against the potential
losses arising from a cybersecurity incident.
Read more in our FY2021 Annual Report on
page 11.
For more about Privacy at NortonLifeLockvisit: https://www.nortonlifelock.com/privacy.

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PRODUCTS

Product innovation
and R&D
As people’s digital habits change andcyberthreats evolve, we embrace innovationand have developed a global research anddevelopment (R&D) strategy across our Cyber
Safety platform. In FY21, R&D expenses were$267 million, representing approximately 10%of net revenues. As technical leadership isessential to our success, we expect to continue
to commit substantial resources to R&D.
Norton Labs drives a large part of ourtechnological innovation strategy. These teams,
which include engineers, technology researchexperts, and leading threat and security
researchers, work in partnership with our Chief

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COMMUNITY IMPACT

Product Officer and Engineering and Productteams to develop prototypes, release beta apps,
and get new versions of existing offerings andentirely new offerings to our customers.
Our FY21 innovation and research strategy
included a radical new approach. We adopted
a “rapid innovation” methodology, in order toproduce self-contained innovation prototypes
that can be released directly to consumers.
This approach minimizes the time between the
research lifecycle and the delivery to consumers,
allowing us to improve the overall consumer
security and privacy posture.
Our research teams focus on addressing
consumer needs, including defending consumer
device security, identity protection, digital
privacy, and home and family safety.

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In FY21, we focused on disinformation andlimiting its social impact. Norton Labs created
BotSight, a tool capable of identifying andflagging bots and disinformation on Twitter.
BotSight, available to consumers for free,annotates a user’s Twitter feed, indicating
the likelihood of a post or account being abot, thus enabling users to better distinguishdisinformation online.
We also focused on consumer privacy protection
and launched a cookie tracking tool and SafePic
in FY21. Our cookie tracking tool provides
consumers with visibility into the tracking activity
they encounter as they browse the internet.
This technology is recognized by the researchcommunity as one of the most complete
and in-depth tracking analysis frameworks
that is currently available, and we are in theprocess of incorporating this technology into
our product offerings. SafePic, available on theApple AppStore, scans and classifies a user’s
photo album and identifies sensitive photos anddocuments, such as licenses and passports, byemploying artificial intelligence classification
methods. The user is then offered the option to
obscure the photos or encrypt them and addthem to a secure photo vault.
The Labs team also developed a prototype
named Detox to analyze online content andidentify hateful speech and cyberbullying. The
prototype can be used in three different modes/

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ETHICS & GOVERNANCE

PRODUCTS

levels of protection and will be made available
to consumers as part of our Norton™ Family
protection tools. And we continued our work
to combat stalkerware, to further improve theprotection we provide to domestic violence
victims, potential victims, and survivors. In thespace of scam detection, we launched a research
project aiming to understand and prevent scamsof the 70+ population. As part of this project, wevisited care facilities where we performed surveys
and training. We also performed a systematic
analysis of the most common types of scams
affecting this population (phishing and romancescams). Similar to stalkerware, this ongoingwork aims to protect a particularly vulnerablesocial group from threats targeted to their unique
circumstances.

to better understand and mitigate the direct
and indirect environmental impacts of Norton™
Crypto. We have become a supporter of theCrypto Climate Accord and support the Accord’s
objectives to decarbonize the global crypto
industry by prioritizing climate stewardship andsupporting the industry’s transition to net-zerogreenhouse gas emissions by 2040.

Ethical product innovation

Like all types of currency in the world,
cryptocurrency can be used for unethical means.
All transactions are public to those within the
network and confirmed by a transaction ledger
called the blockchain. We are dedicated to
product innovation practices that are transparent,
responsible, and compliant with applicable laws
and regulations, and are assessing the feasibilityof a product innovation review process that would
consider ESG impacts.

As part of our focus to protect customers’ everevolving digital lives, we regularly update andlaunch products that contribute to real-world
privacy and security challenges. As an example,
in June 2021, NortonLifeLock unveiled Norton™
Crypto. For years, many coinminers have had
to take risks in their quest for cryptocurrency,
disabling their security in order to run coinmining.
Norton™ Crypto delivers a secure, reliable way for
consumers to mine for Ethereum without opening
themselves and their devices up to these pitfalls.

In addition, many of our product innovations
support social good. Our efforts to combat
disinformation are central to global efforts toguard against the spread of messages aiming tomanipulate public opinion. Our scam research
has focused on countering the ways the 70+
population is being taken advantage of online. And
we continue to focus our research on supporting
people that need protection most, including
domestic violence victims and survivors andchildren.

Mining cryptocurrency requires a large amount ofenergy, and we are currently developing a strategy

Read about product donation in the Community
Impact section of this report.

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Environmental StewardshipProtecting our planet is key to ensuring a safe and sustainable
future. With a sharp focus on efficient business operations,innovative approaches to product development and packaging, andengagement with employees and environmental leaders, we believe
we can contribute to a future where the natural world is thriving. We
call this environmental stewardship, and one of our key Corporate
Responsibility objectives is to establish NortonLifeLock as anenvironmentally responsible business.
NortonLifeLock’s Environmental Management Policy is publicly
available and details our approach to managing environmental
impacts across our production operations, business facilities, andsupply chain, as well impacts associated with our products andservices.

A reimagined strategy

Just as we work to advance our business, we also continue torefine our approach to Corporate Responsibility. After a year
spent diligently assessing and planning, we have reimagined ourenvironmental strategy to fit our more focused business priorities,
establish us as a leader among our peers, identify the most practicaland impactful opportunities for improvements, and further embedenvironmental considerations into our core business.
Based on extensive benchmarking and deep analysis of ourbusiness, we defined the five following pillars to drive ourenvironmental stewardship efforts: climate and energy; sustainableproducts; supply chain; engagement; and reporting.

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This year we focused on diving deep into ESG trends, understanding our Company’s footprint, andanalyzing where we can make the most meaningful improvements. With our new environmental
strategy defined, we have a roadmap to hit the ground running and look forward to continuing the ongoingtransformation of our business into one that serves our customers while protecting the planet.”– Amanda Davis, Senior Corporate Responsibility and Environmental Manager, NortonLifeLock

NortonLifeLock Environmental Stewardship Pillars
Climate andEnergySustainable
Products

Reduce greenhousegas emissions fromour operations.

Promote highstandards forenvironmental
stewardship in our
supply chain

Establishing ourbaseline and setting
science-basedtargets for Scope 1
and 2 emissions

Conducting first
product lifecycle
analysis (LCA)

ETHICS & GOVERNANCE

PRODUCTSENVIRONMENTAL STEWARDSHIPSupply Chain

Engagement

Reporting

Reduce theenvironmental
footprint of our
products acrosstheir life cycle

Engage and educate
employees onenvironmental
topics. Partner with
NGOs to accelerate
and amplify our work

Be transparent
about ourprogress andcommitments

Assessing suppliersustainability goals
and gaps

Launching employee
campaigns andexpanding NGO
partnerships

Incorporatingclimate risks into
corporate ERM andtransitioning to ESG
report format

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PILLAR 1: Climate and energy
We work to minimize greenhouse gas (GHG)
emissions across our entire value chain. This
includes the buildings where our employees work,
the data centers that power our products, how
and when our employees travel, the practicesof our suppliers, and the use of our products.
As a consumer company offering mostly digitalproducts, we have identified GHG reductions
from data center and office energy use (Scope 1
and 2 emissions) and employee travel (Scope 3
emissions) to be our most immediate priorities.

52%

reduction in Scope 1
and 2 GHG emissions
between FY20 and
FY21

In order to begin reducing our emissions, we
needed to measure our footprint. In FY20, we
collaborated with our Workplace and IT teams
to establish a GHG inventory. This measurement
process considered our energy use and associatedemissions across our offices, data centers, andfrom business travel. Based on this work, weestablished our GHG baseline using FY21 dataand expanded our inventory to include all relevant
Scope 3 emissions sources. This baseline is an
important first step toward setting science-basedtargets, measuring annual progress, and making
meaningful emissions reductions.

INTRODUCTION

APPROACHIn FY21, we used 190,206 gigajoules ofelectricity, 21% of which was from renewablesources. Increasing our renewable energy use
is an important priority going forward. We arepleased to have achieved a 52% reductionin Scope 1 and 2 GHG emissions between
FY20 and FY21. This was primarily driven bya significant consolidation of our data center
operations and a reduction in refrigerant
losses, and office closures in response to thepandemic also contributed to the decrease.
In FY22, we became members of CERES andsigned their Business Letter of Support for A
Federal Clean Electricity Standard to support
transformation of the U.S. electric power
grid to 100% clean energy by 2035. We areworking to set a science-based Scope 1 and2 emissions reduction goal and plan to set
emissions reduction goals for employee travel
and commuting (both Scope 3 emissions).
We also are working with our Travel team to
add sustainability aspects and metrics into
the NortonLifeLock Travel Policy and plancommunications to inform our workforce
about the revised policy. Finally, we arereviewing our remote-work policy and looking
at how to measure those emissions. We havepaused our participation in Business in theCommunity Ireland’s Low Carbon Pledge until
next year when we plan to have established ascience-based GHG emissions reduction goal.

ETHICS & GOVERNANCE

PRODUCTSPILLAR 2: Sustainable products
Although NortonLifeLock’s products areprimarily digital – in FY21, 90% of our
products were delivered digitally – we remain
focused on minimizing our impacts, where
possible, for the approximately 6.5 million
physical units shipped this year. For example,
in FY21, 30% of our physical products, many
similar to the size of a credit card, were madewith and packaged in Forest StewardshipCouncil (FSC) certified paper3.
In early FY22, we launched our first productenvironmental lifecycle analysis (LCA). This
LCA will identify impact hot spots and help usprioritize reduction efforts.

It will also enable us to define productspecific goals and targets to take productsustainability to the next level. Our LCA report,
which we plan to make publicly available in
October 2021, will provide rich information on
product sustainability for our leadership, sales
teams, customers, and investors.
In addition to product sustainability, 100%of our products comply with the European
Union’s Registration, Evaluation, Authorisation
and Restriction of Chemicals (REACH)
regulation, which manages the risks ofhazardous substances in products.

3 FSC certification checks that products come from responsibly managed forests that provide environmental, social, and economic
benefits to their communities.

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PILLAR 3: Supply chain sustainability

PILLAR 4: Engagement

We promote high ethical standards forenvironmental protections throughout our
supply chain. We focus on transparency andregular engagement with stakeholders to shareand refine our approach, policies, and supply
chain management practices.

We work to educate and excite employees
about environmental topics and partner with
non-governmental organizations (NGOs) toaccelerate and amplify our work. In FY21,
we launched our Earth Champions Start at
Home employee challenge (see sidebar), andemployees helped build an AquaTower in India
funded through our partnership with the Planet
Water Foundation.

Our Global Supplier Code of Conduct isaligned with the Responsible Business
Alliance Code of Conduct and sets forth the
responsible business standards to which we
expect suppliers, their employees, and any
subcontracted parties to adhere. In FY21, 100%of our Tier 1 physical product suppliers agreed
to our Corporate Responsibility requirements
outlined in our Global Supplier Code of Conduct.
Our two main suppliers, which produce over
97% of our global physical product by spend,
also maintain environmental management
systems that are ISO 14001 certified.
In FY21, we completed an initial screeningof GHG emissions in the supply chain using
procurement data to identify high carbon andhigh spend hot spots. We plan to continue
assessing supplier climate goals and gaps and,in the future, will look to establish emissions
reduction goals for our supply chain.
Read about our commitment to human rights
in the Community Impact section of thisreport.

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India-based SayTrees strives to raiseawareness of the importance of trees tohuman health, halt biodiversity loss, andreestablish indigenous forests through tree
planting. With support from NortonLifeLock,
SayTrees has planted 3,500 saplings,
including teak, mango, neem, banyan, andguava, on vacant plots in Bangalore andChennai. The saplings, which are planted
close together to produce a rich, dense, andefficient protective indigenous forest, will be
nurtured and protected by SayTrees over the
next two years.
In FY22, we have additional solar and waterprojects planned with Planet Water andplan to develop an NGO environmental
engagement strategy in Europe.

PILLAR 5: Reporting

We also financially support Grid Alternatives
in the United States, a national leader in
helping underserved communities nationwide
get clean, affordable, renewable energy,transportation, and jobs.

ETHICS & GOVERNANCE

PRODUCTS

We continue to focus on transparent
disclosure of our environmental performance.
We added Scope 3 emissions, waste,
and water usage to the data table at the backof this report, and this year transitioned to an
ESG Report, making it easier for stakeholders
to access environmental stewardship data.
We are also working toward alignment withthe recommendations of the Task Force on
Climate-related Financial Disclosure (TCFD).
Read more about reporting in the Approachsection of this report.

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COMMUNITY IMPACT

Earth champions start at home
We know that when it comes to saving ourplanet, small actions matter. In FY21, we held
our first employee engagement campaign
Earth Champions Start at Home. We challenged
employees to take 10 small actions over 10
weeks to make a big impact, together. Fromturning off their water taps and lights todecreasing food waste to reducing plastics andchoosing recycled paper products, we shared
one tangible action employees could take eachweek to reduce their environmental impact.
A total of 314 participation hours were logged,
and employees won $1,000 worth of “cause
cards” that can be used to donate to a nonprofitof their choice. In one week, employees saved
more than 460 gallons of water by turning off
their taps while brushing their teeth.
As part of the challenge, we also partneredwith SolarBuddy to host an interactive virtual
volunteer event. The virtual team-building
event, Solve the 17, asked employees todevelop a solution to one of the 17 Sustainable
Development Goals.

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People & Culture
NortonLifeLock is committed to building a strong,diverse, and passionate team — a team that stands
together to protect our customers like no one else
can. Our vision and values are the foundation foreverything we do. Part of our employee experience
focuses on inclusivity, learning and development,coaching, recognition, and engagement. Together,
these create an ecosystem for every teammember to feel empowered, valued, and heard. We
also work hard to attract, retain, and develop thebest talent who help protect and empower people
around the globe to live their digital lives safely.

Our NortonLifeLock Communities include:

We live by our core values – values thatcelebrate diversity, promote teamwork,and encourage every team member tocontribute and grow.
development and advancement (equity) and canbring their whole selves to work and feel valued
every day (inclusion).

We have an inclusive culture where employeesof every race, ethnicity, age, religion, gender
identity or expression, sexual orientation, ability,
background, and experience are celebrated andcan bring their full selves to work every day.

We invest in building an inclusive, diverse
workforce because it aligns with our values
and because we believe it makes us a higher
performing company where we can learn and Win
Together. Nearly 80 million people from different
ethnicities, cultures, abilities, ages, and more trust
us with their digital safety. Continuing to build ateam that reflects the diversity of our customers
helps position us to do even greater things in the
future.

Our Diversity, Equity, and Inclusion (DEI) strategy
focuses on attracting, retaining, and developing
the best talent across all backgrounds andguides our efforts to fulfill our DEI mission. Thismission is to increase our global representationof underrepresented groups at all levels(diversity), where everyone has an opportunity for

We are proud to have made progress on increasing
representation in FY21. In FY21, we increased
female representation from 31% to 33% with thepercentage of females in leadership increasingfrom 27% to 30%. We reached an importantmilestone by achieving gender parity for the
independent members of our Board of Directors,

Diversity, equity, andinclusion

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Company values

ETHICS & GOVERNANCE

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something we have been working towards
since becoming NortonLifeLock. We havealso increased underrepresented racial/ethnic representation from 11% in FY20 to
13% in FY21.
We are committed to equal pay for equal
work and monitor pay equity as part of ourongoing diversity and inclusion efforts.

ENVIRONMENTAL STEWARDSHIP• Advocate: Think Consumer First• Be Empowered: Own It• Communicate: Be Open and Authentic• Execute: Smart and Scrappy• Win Together: Innovate and Grow

Our inclusive culture is the foundation of NortonLifeLock’s
diversity efforts and a competitive advantage. We understandthe value of diversity, equity, and inclusion, and as a Company ofaction, we are working to create that reality. Our Company has madeprogress towards diversity, equity, and inclusion, however, we still
have a long way to go. ”– Kara Jordan, Chief People & Culture Officer, NortonLifeLock

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Our diversity, equity, and inclusion (DEI) strategy in action

We conduct quarterly all-employee pulse surveys and in Q4 of FY21, our survey was focused on DEI andOur DEI strategy is built upon four foundational pillars: measurement and accountability; fostering
an inclusive environment; diversifying our workforce; and development and retention. We havea dedicated DEI team reporting into our Chief People & Culture Officer who has leadership

introduced an Inclusion Metric that will be measured regularly. Employee responses confirmed our DEI
strategy is aligned with employee needs and expectations.
Throughout the year, diversity topics are featured in All Hands conversations, published in blogs, and featured

accountability for our DEI strategy and programs. She reports directly to our CEO and is partin weekly Learning Journeys. Additionally, our DEI team curates learning modules through our e-learningof our Leadership Team. The Nominating and Governance and Compensation and Leadership
Development Committees of our Board of Directors provides oversight and are actively engaged in
our DEI strategy. We share our DEI progress with the Board on a quarterly basis.

platform where different diversity topics, including inclusive leadership, being an ally, and microaggressions,are featured each month. Also, for the first time, in FY21 we added a diversity and inclusion training module
to our employee Code of Conduct training. One hundred percent of employees completed this training.

Measurement and accountability

Diversifying our workforce

We set clear multi-year goals at the leadership level, establish

We advertise open positions on diverse hiring sites including Blackstrategic programs to deliver on these goals, and track the data

Tech Jobs and Women Who Code. We have simplified our backgroundto assess our progress. In FY21, we began delivering quarterly

checks to remove unnecessary restrictions not relevant to our jobs

diversity scorecards to senior leaders that include teamand made job descriptions more flexible and inclusive. Our Talent

representation data, as well as our goals to increase our female

Acquisition team has worked to implement diverse interview panels

representation globally and our underrepresented racial/ethnic

for Product Team interviews, as well as gender diverse interview

groups, including Black representation, in the U.S.

panels for other functions.

Development and retention

Fostering an inclusive environment

We are intentional when it comes to developing and upskilling

Our seven employee resource groups, called NortonLifeLock

our team members, including targeted development for our

Communities, are critical to our DEI strategy. Throughunderrepresented groups. In FY21, two cohorts completed McKinsey

Community events and initiatives, employees globally come& Company’s Black Leadership Academy. After the conclusion of thetogether to learn, support, mentor, and celebrate with one

Program, our CEO and Chief People & Culture Officer had a roundtable

another. Our Leadership Team directly engages with ourwith the participants to gather feedback on their experience. To

Communities directly and each quarter hosts roundtables with
our Community Champions to discuss our DEI initiatives, theCommunities’ goals, and needs to meet their mission. To date, our CEO, Chief People & Culture
Officer, and Chief Marketing Officer have met with our Champions for an open and candid dialogue
about how leadership can be involved in supporting the efforts of each community. We also
expanded our voluntary Self-ID initiative in the U.S. to include sexual orientation and pronouns.

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ETHICS & GOVERNANCE

PRODUCTS

further develop leaders and employees at all levels of the organization,
we launched a global mentoring program using a platform that was designed and built in-house. When
conducting Talent Reviews and having succession planning discussions with leaders, we are intentional
and look at the diversity of the bench strength. We also provide focused learning and development
opportunities to all employees on DEI-specific topics.

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Get to know our Communities

In January, our NOBLE (NortonLifeLock’s Black Life

This year our N-PRIDE Community hosted our first global

Empowerment) Community hosted Dwana Franklin-Davis, CEO

virtual PRIDE Parade, which included conversations withof Reboot Representation, for a Company-wide fireside chat.

LGBTQ+ identifying leaders from inside and outside theDwana was joined by NortonLifeLock’s CEO and Chief People

Company. Deena Fidas, Out & Equal’s Managing Director,& Culture Officer to discuss creating a more equitable andand NortonLifeLock Board member Emily Heath joined

diverse tech sector. This was followed by an open discussion

employees to discuss the history of PRIDE, the movement

to hear employee experiences and restate the Company’s DEI

for equality, and how N-PRIDE provides opportunities tocommitments. NOBLE also hosted a highly engaging Juneteenth

connect, learn, share perspectives, and celebrate in a joyfulawareness and education virtual event in June that was globallyand supportive environment.

attended by employees and leadership.

The engagement in our first virtual PRIDE parade was

Taking part in McKinsey’s Black Leadership Academy wasabsolutely incredible. The collective passion and dedication

an incredibly impactful opportunity. After the experience, I was

in our Company was front and center, and you walked away

inspired to reach others and signed on as the Co-Champion for

knowing we are part of a community that is authentic,

the NOBLE Community. I am excited to grow and expand our

inclusive, and real.”

Community at NortonLifeLock.”– Gayathri Rajendiran, Senior Community Program– LeShawn Woods, Senior Sales Operation Manager and NOBLE

Our WONDER Community works to support and encourage thedevelopment and advancement of women. In celebration of Women’s
History Month, WONDER hosted a series of #IamRemarkable
workshops, an initiative created to empower women and increase
self-promotion and confidence. Going forward, WONDER will offer
the 90-minute workshop regularly. In April, WONDER also sponsoreda powerful and candid fireside chat with three of four female Board
members. The event focused on persevering through difficult
situations and acknowledging the importance of failure in one’s
success, and speakers provided interview tips.
I have worked for several companies where I felt the focus ondiversity was lacking. When I joined NortonLifeLock it felt great to bepart of a Company that invests in diversity and inclusion and wants
to keep an open and sometimes challenging dialogue going with thepeople it impacts every day. I feel our Company is leading the way increating a workplace that values and empowers everyone.”– Yoshiko Blake, Support Product Analyst and WONDER

Manager and N-PRIDE Co-Champion, NortonLifeLock

Co-Champion, NortonLifeLock

Co-Champion, NortonLifeLock

Read more about our DEI efforts on pages 21 and 27.
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Human capitalmanagement
Our Board of Directors has long recognizedthat our employees are our most important
asset and is engaged with management
to support our efforts to be an employerof choice for top talent. Our human capitalmanagement strategy reflects our uniquevalues and growth mindset. While the full
Board and leadership discuss human capitalmanagement with regards to its role in ouroverall long-term strategy, our Compensationand Leadership Development Committee has
responsibility for overseeing human capitalmanagement at NortonLifeLock. For moredetails on the Board’s role in oversight of
human capital management, visit our FY2021
Annual Report.

Talent development andengagement
In FY21, we continued our focus on Talent
Development, with continued investment

inspiring innovative ideas and business

Team members globally have access 24/7

We offer manager bootcamp for our People

progress, and helping employees achieve

to a growing database of virtual trainings in

Leaders. These virtual sessions, hosted bytheir career goals. All employees are eligible tofields including Leadership and Management,

Talent Development and subject-matterreceive a performance review.

Technical Skills, Business Acumen Skills,

experts, speak to the elements, dynamics,

and Health and Wellness. As an example,

process, and procedures of managing others

we offered a course on cryptocurrency as

at NortonLifeLock.

across our teams by providing access to career

Nvesting in our team members

development resources, trainings, and support.

In early FY22, we launched Nvest eLearning,

Our Talent Development team, in partnership

our online learning platform4. Through ourwith our people leaders, looks to identify

partnership with a platform of 20,000+

current skill gaps, upskill employees, identify
emerging skills, and support employees throughmentoring, while supporting our DEI initiatives,

INTRODUCTION

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on-demand e-learning modules, we curate avariety of interactive modules and learning
paths.
ETHICS & GOVERNANCE

our Product teams planned for the launchof Norton™ Crypto. The platform also has a
feedback mechanism built in to help our teamassess if the initiatives are providing value.

These bootcamp sessions are supplemented
by special learning paths in Nvest eLearningthat provide tangible lessons and insight into
what makes a good leader at NortonLifeLock.

4 Available to full-time employees and interns.

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These frequent bootcamps are primarily

engaging and inviting experience to newoffered to People Leaders, though they arehires, highlighting learning and development,

open to anyone, and to date, approximately

our mentorship culture, as well as how to

300 people have participated.

get involved in our Corporate Responsibility
program and Communities.

Establishing a culture of mentorship
Our internal global mentorship program,Employee engagement

Nvest Mentoring, launched in February

We conduct quarterly all-employee pulse

2021 to foster career development, newsurveys to measure ongoing employee

perspectives, and personal connections.

sentiment and encourage feedback on

The program begins with software thatspecific focus areas. Based on these surveys,

automatically pairs mentors with mentees

our current Employee Net Promoter scorebased on common attributes. We have overshows our employees are happy at work and

250 participants and have received positive

would recommend us to their peers.

feedback on the program.

Pay and benefits

In FY22, we plan to expand the program to

We have a variety of Total Rewards programs

reach new participants, add an option to

supporting employees globally, which includes

join a cohort, and offer virtual, on-demand

but is not limited to a flexible workplace,coaching opportunities through Nvest.

medical insurance, paid time-off, employee
assistance program, disability, life insurance,

Welcoming new talent to NortonLifeLock
Through deep engagement with leaders andpeople managers across our business, weretirement and pension programs, equity
grants, employee stock purchase, competitivecompensation, and recognition programs.

made various improvements to streamline
and redefine our hiring process.
Our talent acquisition process drives hiring
efficiency. We provide full visibility on every
hire to our leadership, including our CEO.
Talent Acquisition works to provide an

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Community Impact
Employeevolunteering andgivingWe provide employees withfive days of paid volunteer
time off each year.

Employees want careers that allow themtime employees needed to respond to theDoers and our Matching Grants program, we

pandemic’s impacts. Our challenge was to findmatch up to $2,000 per employee per year for

positive change, and align with theiran effective way for employees to help others.

eligible nonprofits. In total, our employees andown personal purpose. We empower our

Our Corporate Responsibility team pivoted

We also continued to amplify employee
financial contributions by providing a $15
donation for every hour of volunteer service
an employee contributes through our Dollars
for Doers program. Through Dollars forto contribute to communities, create

employees to support the causes they carequickly, launching virtual volunteer opportunities

about through volunteering and giving. In
FY21, we remained committed to driving
opportunities for volunteering and giving byleveraging virtual ways to reach and engage
employees.

NortonLifeLock together provided $407,844
in funds to nonprofits in FY21.

in partnership with WeHero. We worked closely

The Corporate Responsibility team alsowith our NortonLifeLock Communities (what weparticipates in new hire onboarding by

call employee resource groups, as describedsharing information about NortonLifeLock’s

on page 21) on joint events and engaged ourcommitment to Corporate Responsibility andLeadership Team to champion team-building

how to get involved in volunteering and giving.

opportunities. We also shifted our focus to

A culture of giving

employee giving campaigns as many of our

As part of our global Employee Volunteer

nonprofit partners desperately needed funding.

Program prior to the COVID-19 pandemic,

As the year progressed, this new model proved

volunteer leaders at each of our large sites

to work well and enable our global workforce topartnered with our Corporate Responsibility

continue to make a meaningful difference fromteam to provide in-person volunteer
opportunities to employees at the local level.
We soon realized this strategy was no longer
viable given COVID-19 safety protocols, thetransition to remote work, and the additional

INTRODUCTION“In 2020, we were a relatively new Company withnew leadership and knew we could bring people
together through supporting our communities. It has been
tremendously exciting to witness how virtual volunteeringbrought our internal teams and leaders together, allowing us
to have a significant impact in a time of such great need. ”

APPROACH

any location.
Moving forward, we will continue to monitor– Kimberly Bishop, Corporate Responsibility Manager,
NortonLifeLock

our program and look to a hybrid approach as
some employees return to the office.

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I have been proud to continue
virtual volunteering despite the
COVID-19 lockdown with Team Everestand to organize virtual volunteer events for
my office in Chennai, India. Team Everest,

Leading the way

Giving together

Team-based volunteering helps bring
employees together and reinforces ourculture of giving. NortonLifeLock leadership
championed the opportunity to serve ourcommunities by volunteering virtually. This
included NortonLifeLock CEO Vincent Pilette
who virtually brought together his team toassemble kits filled with school supplies. All
together, they provided school supplies to 30
students in need in partnership with the Kids
in Need Foundation.

We also offer special 2:1 matching campaigns
to respond to current events, such as on
Giving Tuesday. In FY21, our employees
across the globe donated more than
$66,600. Together with NortonLifeLock’s
match, we contributed a total of $196,792 toorganizations ranging from UNICEF and The
Tomorrow Fund to The Trevor Project andmany more.
Read more on the CR Blog.

Read more on the CR Blog.

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ETHICS & GOVERNANCE

one of the biggest youth-run nonprofits in

Supporting local causes

PRODUCTS

India, works to provide quality education

In Ireland, employees provided Cyber Safety
training to more than 40 nonprofit organizations.
As a result of the training, two nonprofits reached
out for help following security incidents. Our
Customer Care team was able to assist bothquickly, providing upgraded product donations
and guidance. Ten Dublin-based employees also
volunteered with the “Time to Read” program,providing one-on-one reading sessions withlocal children from St. Philip primary school
in Blanchardstown over eight weeks. Of theexperience, one employee said, “Time to Read
was one of the highlights of my year. I loved
getting to know the children and seeing themevery Tuesday brightened my day!”

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to financially challenged children throughtuition and scholarships, skill development,
and more. NortonLifeLock employees in
Chennai have volunteered to help Team
Everest by providing mentorship andlife-skills development to college-age
scholars. Our volunteers are also helping
students hone Cyber Safety skills by
hosting digital safety sessions and working
to raise awareness about Team Everest’sscholarship program, which serves 400
parentless and single-parented children.”– Kumar Lakshminarayanan,
Senior Knowledge Engineer,
NortonLifeLock

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SpotlightPartnering with Our NortonLifeLock Communities
We partner closely with our NortonLifeLock Communities (what we call employee resource groups, as described on page 21) to host meaningful opportunities for employees to give their time and resources.

In partnership with our WONDER Community(Women Outreach and Development
Resources), we hosted numerous International
Women’s Day events. Employees joined acareer workshop that supported women
reentering the workforce with Dress for
Success in Dublin, Ireland, provided 30-minutevirtual mentoring sessions to girls each day
for a week in India, and supported high school
students through a career panel and breakout
sessions in Arizona.

Together with N-PRIDE, we hosted an
event to assemble care kits for one•n•ten, anonprofit dedicated to serving and assisting
LGBTQ+ youth ages 14 to 24. We provided
items including a journal and list of mental
health resources, as well as personalized
letters of encouragement and support. We
also recently completed two important
grants to Out & Equal and the Human Rights
Campaign Foundation.

In January, in partnership with NOBLE (NortonLifeLock’s Black Life Empowerment), we hosted
Dwana Franklin-Davis, CEO of Reboot Representation, for a Company-wide presentationand fireside chat with NortonLifeLock’s CEO and Head of People & Culture on creating amore equitable and diverse tech sector. We also ran a special 2:1 matching gift campaign
for nonprofit organizations addressing racial and social injustice. Organizations supported
included the NAACP Defense Fund, Equal Justice Initiative, Color of Change, Black Lives
Matter, Black Health Alliance, The American Civil Liberties Union (ACLU), Southern Poverty
Law Center, and The Bail Project among others. Altogether, we raised more than $66,000.
Read more on the CR Blog.

Read more on the CR Blog.

Read more on the CR Blog.

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Community impact
programs
We are proud to support the communities
where our team members live and work. Ourcommunity impact programs include productdonations; signature programs that leverage
our unique expertise in increasing digital safety
literacy; and philanthropic giving focused on
digital safety education, diversity, equity, andinclusion, environmental action, and disaster
response.

Product donations
From small public libraries that sponsor
literacy programs to schools trying to shifteffectively to online learning, nonprofit
organizations worldwide face rising demandson their services. Compounding the issue istheir lack of resources to secure employee andvolunteer digital information. NortonLifeLock’s
product donation program exists to help
these organizations stay safe online in an
increasingly interconnected world.
We give product directly to nonprofits thatneed it and to TechSoup, a nonprofit that helps
us increase the reach of our product donations
by charging nonprofits a small service fee to
use our technology solutions.

INTRODUCTION

APPROACH$4M

value throughdonated products
in FY21In FY21, NortonLifeLock products helped
more than 9,900 nonprofits and public
libraries keep their devices and data secure.
In response to COVID-19, we also offered afive-month complimentary subscription to
Norton™ Family to help parents monitor andmanage their children’s online activities. In
total, more than 97,000 people signed up forthe complimentary subscription, representing a
retail value of more than $2 million in donatedproduct offering. With these donations and ourdonations to TechSoup, we provided a total ofmore than $4 million in donated products in
FY21.

This includes organizations serving youth
facing mental health issues, domestic
violence survivors and victims, the 70+
population, and foster youth. Our Corporate
Responsibility team is working with ourEngineering and Sales teams to build theframework for the program. Working withthese cross-functional teams, we are making
the nonprofit experience easier and aligning
it with the process we have in place forpaying customers. We plan to launch thepilot in the United States in FY22 while wesimultaneously continue to improve theglobal program.

Though we have been a longtime partner of
TechSoup, in FY21, we provided funding to
TechSoup itself for the first time to launcha pilot program to help us not only expand
the overall reach of our donated products
but to reach nonprofit organizations serving
populations we feel need our products most.

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Signature programs
increase digital safety and online privacy

Taking charge ofyour digital life

literacy worldwide, helping protect andPaige Hanson,

empower children, families, and domestic

NortonLifeLock’s Chief ofviolence survivors to live their digital lives

Cyber Safety Education,safely.

regularly shares digital

We leverage our unique expertise tosafety tips to help people

Amidst the COVID-19 pandemic, the use

stay safe online.

of the internet has increased rapidly,
providing an invaluable way for people
around the world to remain connected. But
the pandemic also unveiled and intensified

In early 2021, we announced a new $1 millionpressing issues for young people, fromcommitment to expand The Smart Talk tocyberbullying to exposure to violent content,

serve more families over two years. First, weand increased risks for domestic violence

are dedicating resources to make The Smart

victims and survivors.

Talk relevant and helpful to families spanningmany different backgrounds and languages.

In FY21, nearly half of our grant funding

National PTA will be consulting with experts

focused on education and training. We
expanded our work with two of our longtime partners – the World Association ofGirl Guides and Girl Scouts (WAGGGS)
and National PTA – to help kids fromall backgrounds navigate their digital
lives more effectively and safely. And weincreased our efforts to put an end totechnology abuse and empower domestic
violence victims and survivors.

Serving more families than ever before
NortonLifeLock and National PTA work
together to help families create an open,
evolving conversation about digital technology
safety. In 2016, we co-created the fun, freeeducation program The Smart Talk. The
program addresses privacy, screen time, social
media etiquette, app usage, texting and calling,and helps families set tech ground rules fortheir household together.

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who specialize in diversity and inclusion andseeking feedback from families. Additionally,
the grant will enable tech and content updates
to make the program even more relevant totoday’s tech consumers. Finally, the funds will
help us expand our reach and impact. In past
years, we’ve reached roughly 25 PTAs annually,
but with this new grant, we expect to be able
to reach approximately 180 local PTAs over the
next two school years.
Read more on the CR Blog.

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Helping girls Surf Smart
NortonLifeLock has supported the World
Association of Girl Guides and Girl Scouts(WAGGGS) with online safety education since2011 when we first co-created Surf Smart. This

Protecting the sensitive data of
women peacebuilders

internet safety curriculum provides Girl Guides
and Girl Scouts with the knowledge and skills toprotect themselves and others online.

Putting an end to technology abuse

In February 2021, together we launched Surf
Smart 2.0 Generation Digital. The new curriculum
and facilitator’s guide – available to all 152
WAGGGS countries/member organizations andin all four official WAGGGS languages – includes
a focus on cyberbullying and more knowledge
about WhatsApp, Facebook, and other social
media platforms. Surf Smart 2.0 helps Girl
Guides and Girl Scouts use the internet not only
to communicate, learn, and have fun, but also toraise their voices as responsible citizens. Since
2012, Surf Smart has reached more than
350,000 girls and young women in over 44
countries. We expect to reach an additional
200,000 girls by December 2021.
Read more on the CR Blog.

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We believe stalkerware presents a major –and often ignored – threat to consumers.
Over the years, NortonLifeLock researchers
have examined this technology threat, worked
to take it out of the hands of abusers, andcreated tools to help victims and potential
victims protect themselves and be free ofharassment, violence, and attacks.
We are a founding member of the Coalition
Against Stalkerware, pooling our expertisewith domestic violence organizations
and other cybersecurity companies tohelp protect people from this dangerous
technology. We’ve furthered our efforts
through a recent $75,000 grant to
the National Network to End Domestic

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Violence to help provide engaging, interactive
trainings and support its Technology Safety
program, Safety Net.
During FY21, we also joined with the New
York City Mayor’s Office to End Domestic andGender-Based Violence, which operates the
New York City Family Justice Centers. The
centers provide vital social services, civil legal
and criminal justice assistance for survivorsof domestic and gender-based violence andtheir children. Through this partnership, we’ve
provided 2,000 Norton™ 360 licenses andconducted three Cyber Safety and productinformation trainings with center staff who
are supporting survivors.

PEOPLE & CULTURE

Report we announced a pilot programin partnership with The Kroc Institutefor Peace and Justice at the Universityof San Diego to help protect the digital
lives of women building peace in theircommunities. As part of the FY21 pilot, we
provided Norton™ 360 Deluxe licenses andNorton™ Secure VPN products to support
39 women peacebuilders with training,
empowering them with the knowledge theyneed to protect their identities, sensitive
data, and their lives. Due to the pandemic
and staffing changes at The Kroc Institute,the program was paused for the remainderof FY21. We plan to provide additional
product donations and trainings in fall 2021.

Read more on the CR Blog.

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In our 2020 Corporate Responsibility

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Philanthropic giving
In addition to supporting digital safety education, our philanthropic giving also focuses on increasing
diversity, equity, and inclusion, inspiring environmental action, and supporting disaster response
efforts. In FY21, we continued to provide even more comprehensive support to organizations withwhich we engage. In addition to financial assistance, we look for opportunities to provide productdonations and employee volunteer opportunities to round out our support.

10,688organizations supported through financial
investments, software donations, andemployee matching programs

Increasing diversity in techFighting hunger and giving hope

Tackling digital poverty in Ireland

Happy Minds for Healthy Kids

In FY19, we made a three-year commitment
to support the Reboot Representation Tech
Coalition, which is committed to doubling thenumber of Black, Latina, and Native American
women graduating with computing degrees
by 2025. In FY21, we continued this support
with a $200,000 grant. We also reevaluatedour entire grant portfolio, to make sure ourcommitment to diversity, equity, and inclusion(DEI) is incorporated into each grant we fund.

To help food banks address increased
demand during COVID-19, NortonLifeLockpartnered with food programs in the UnitedStates, Ireland, and India. In total, we donated$170,000 to help provide 407,800 meals to ourneighbors in need. We also launched an athome food drive for team members across theglobe to further our impact.

To help combat digital poverty in
Ireland, NortonLifeLock has partneredwith Empower, an Irish charity focused onsocial inclusion, local development, andaddressing digital inclusion. As part of its
Connect and Include Initiative, we provided 15
laptops, 50 Norton 360™ software donations,and a financial grant to reduce the digital
divide in Fingal.

NortonLifeLock employees based in Dubai
helped lead our participation in the Happy
Minds for Healthy Kids initiative in partnershipwith the Dubai Health Authority. This one-ofa-kind virtual course campaign aims to raiseawareness about children’s mental health andcyberbullying. As part of our participation,
Paige Hanson, NortonLifeLock’s Chief ofCyber Safety Education, provided two lessons:“Cyberbullying – Digital Safety 101 for Kids”
and “Cybersecurity 101 for Kids and Parents.”

Read more on the CR Blog.

Read more on the CR Blog.

Read more about our DEI efforts on pages 21
and 27.

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Spotlight

Making an impact in India
Article 135 of the India Company Act introduced the first mandatory Corporate Responsibility law
in the world, requiring large companies to spend at least 2% of their annual profits on giving to the
local community. To meet this mandate, we turned to our India-based employees and to our strategic
partner SoStakes, a monitoring and evaluation firm, to choose charities doing important work on
the ground in India. While the COVID-19 pandemic created challenges for our partners, each foundinnovative ways to make an impact in FY21 as described below.
Bal Raksha Bharat, commonly known as Save the Children India, seeks to
improve the lives of marginalized children. In FY21, with NortonLifeLock’s
support, more than 3,000 students and teachers in 10 schools in Pune
were equipped with online education and technology, such as tablets andcomputers, prior to pandemic lockdowns.

The Agastya International Foundation runs mobile hands-on scienceeducation programs for economically disadvantaged children andgovernment teachers. Initially, funding from NortonLifeLock was intended tohelp Agastya instructors visit schools in mobile vans equipped with laptops
to conduct digital classes for students in grades 6 to 10. When COVID-19 hit,
instructors shifted to a virtual format and continued meeting with students
in one-hour sessions five days a week as well as hosting three online science
fairs. In total, the program has reached 2,237 students at 18 schools, creating 23,280 exposures (eachexposure is defined as a two-hour face-to-face interaction with a teacher or community member).
ATREE, a conservation research and education institution, is focusedon strengthening and diversifying the livelihoods of coffee farmers fromthe Soliga ethnic group and conserving the forests within their Biligiri
Rangaswamy Hills community. In collaboration with the Rainforest
Alliance and with NortonLifeLock support, ATREE has provided training onsustainable coffee-farming practices, product development, and marketing tomore than 650 Soliga coffee farmers.

The orientation and training of teachers on ICT education has been very beneficial. Most of theteachers previously had no idea about using online platforms for education, and now they are wellversed on using smartphones and tablets. Seventy to eighty percent of our students attend online
classes regularly, and the tablets have been critically important for learning.”– Mr. Kishore Kamble, Teacher, Manjari Farm ZPPS
We partner with NASSCOM to run the Cyber Security Skills Development
Initiative, a training program designed to create greater employability
opportunities for under-resourced female engineering graduates by equipping
women with the right job skills. In 2021, the initiative trained 121 women and
108 women secured the Certified Ethical Hacker certification. To date, 25
women from the program have been placed into jobs.

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ETHICS & GOVERNANCE

PRODUCTSAs COVID-19 ravaged communities across India in May 2021, NortonLifeLock responded with acorporate donation, providing nearly $29,000 in support to government hospitals and state healthdepartments. We also offered employees a special 2:1 match opportunity to contribute much needed
funds to ActionAid to help with the crisis. Seventy employees donated through the campaign, and wetogether sent more than $18,000 to ActionAid.
Read more on the CR Blog.

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Commitment tohuman rights
NortonLifeLock works to protect human rights inour own operations and throughout our supply
chain. Our Human Rights Policy Statement,
available in English, Spanish, and Portuguese,builds on our commitment to uphold the
10 principles of the United Nations Global
Compact, and is aligned with the Universal
Declaration of Human Rights. This commitment
is also enshrined in our Code of Conduct, Global
Supplier Code of Conduct, and UK Modern
Slavery Act Statement.
We expect directors, officers, employees,
interns, and contractors of NortonLifeLock,as well as third-parties acting on behalf of theCompany, to be aware of the implications ofviolating any aspect of our Code of Conduct
and Global Supplier Code of Conduct.

0%

theft are critical issues to our consumers,
and we advocate for legislation that protects
consumers and curbs cybercrime.

of our Tier 1 physical product suppliers are
considered high risk for human trafficking

which manufacture and distribute over 97% of
our physical products globally by spend, wereconsidered “low risk” for human trafficking
based on the Company's own review.
In FY22, we also added questions to our
supplier audits around human rights.
Additionally, we held a virtual corporate
responsibility audit of these two primary
suppliers and found they had no human rights
breaches in the past three years.

Visit our website for a full list of our Corporate
Responsibility Policies and Statements.

Public policy andadvocacy
Our Government Affairs team manages
participation in discourse regarding public
policies that affect our consumers and business.
Data protection, online privacy, and identity

Political disclosure andaccountability
Since 2001, NortonLifeLock has maintained a
Global Political Contributions Policy, a formal
policy regarding political activities, political
disclosure, and accountability. The Board’s
Nominating and Governance Committeemonitors compliance with this policy.
NortonLifeLock currently does not make any
contributions to political candidates and, as
of April 2020, does not maintain a politicalaction committee.

NortonLifeLock employees received humanrights training in early FY22 as part of ourannual mandatory Code of Conduct training.
We are also pleased to report that zero humanrights issues were reported through EthicsLine,
our anonymous third-party managed
compliance hotline, in FY21.
We regularly engage with our suppliers to share
best practices. In FY21, our two main suppliers,

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Policy engagement andawareness
Our Government Affairs team raises
awareness and provides key data andinsight to elected officials, their staff, media,
and through industry coalitions. While muchcybersecurity legislation focuses on theneeds of enterprises and nation states, ourteam focuses on advocating for people’s
right to live their digital lives safely.
In FY21, key advocacy priorities for us
continued to be protecting consumers fromCOVID-19 relief and credit reporting scams,
healthcare fraud, unemployment insurance

INTRODUCTION

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fraud, and the increased risk of identity
theft as people spent more time online. We
also worked with the U.S. Small Business
Administration to address the risk of fraud
and identity theft affecting small businesses.
At the federal level, the Improving Digital
Identity Act of 2020, which was championedby the Better Identity Coalition, was introducedin the U.S. Congress in September 2020. As
we look to FY22, our Government Affairs
team will continue to work with legislators toraise awareness of how they can best protect
consumers against identity theft, fraud, credit
scams, and cyberthreats.

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Policy partnerships
In FY22, we became members of CERES andsigned their Business Letter of Support for A
Federal Clean Electricity Standard to support
transformation of the U.S. electric power gridto 100% clean energy by 2035. In FY21, we
continued our involvement in the Better Identity
Coalition, which works alongside policymakers
to improve digital security, privacy, and identity
protection through education and collaboration.
We also continued our work as a memberof the National Institute of Standards andTechnology’s (NIST) National Cybersecurity
Center of Excellence, a collaborative hub where

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industry organizations, government agencies,
and academic institutions work together toaddress the United States’ most pressing
cybersecurity issues. We also participate in
the National Cyber Security Alliance, Silicon
Valley Tax Directors Group, Information
Technology Industry Council (ITI), and siton the SAFECode Board of Directors. We do
not allow membership dues to be used forpolitical purposes. For more information on
our engagement with respect to environmental
issues, read page 19.
Visit our website for more information on
Transparency on Political Engagement.

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About this report
NortonLifeLock has a long history of sharing an annual account of ourprogress in delivering on our environmental, social, and governancecommitments. In our 2020 Corporate Responsibility Report, we provided
our first Sustainability Accounting Standards Board (SASB) Index andshared the results of our priority issue assessment. In FY21, we haveenhanced our reporting strategy further to respond to stakeholder feedback
and provide a concise account of our ESG performance, transparency
around ESG-related risks and opportunities, and decision-useful,comparable data and information.
We have developed this report using the SASB Standards, a set of 77
standards focused on connecting business and investors on the financial
impacts of sustainability, as well as with the Global Reporting Initiative (GRI)
Sustainability Reporting Standards at the “Core in Accordance” level.
“NortonLifeLock,” “we,” “us,” “our,” and “the Company” refer toNortonLifeLock Inc. and all of its subsidiaries. The report covers theCompany’s activities between April 4, 2020 and April 2, 2021. We havealso included relevant examples of impact that occurred in calendar year
2021. The activities, performance, and data detailed in the report relate
to NortonLifeLock Inc.’s worldwide operations unless otherwise stated.
Corporate Responsibility activities, performance, and data detailed in thereport do not include Avira employees.
We welcome your questions about this report and about NortonLifeLock
Cares via CR@nortonlifelock.com.

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United Nations Sustainable Development Goals highlights
Ensure inclusive and equitable quality education and promote lifelong
learning opportunities for all.

Reduce inequality within and among countries.

• Expanded our partnership with National PTA with a $1 million commitment to enhance
The Smart Talk

• Continued three-year commitment to Reboot Representation, which iscommitted to doubling the number of Black, Latina, and Native American women
graduating with computing degrees by 2025

• Together with the World Association of Girl Guides and Girl Scouts, launched Surf Smart
2.0 Generation Digital• Added a diversity and inclusion training module to our employee Code of
Conduct training. One hundred percent of employees completed this training• Supported online learning for more than 3,000 students during COVID-19 shutdowns in
Pune, India, through our work with Save the Children• Helped the Agastya International Foundation provide virtual science education programs
five days a week to more than 2,235 economically disadvantaged children across 18
schools in India

Achieve gender equality and empower all women and girls.
• Increased female representation in our global workforce from 31% to 33%, and inleadership roles from 27% to 30%• Achieved gender parity for the independent members of our Board of Directors• Joined with the New York City Mayor’s Office to End Domestic and Gender-Based
Violence, providing 2,000 Norton™ 360 licenses and conducting three Cyber Safety andproduct information trainings with staff who are supporting survivors• Partnered with Connect and Include Initiative to reduce the digital divide in Fingal,
Ireland

Ensure sustainable consumption and production patterns.
• Delivered 90% of our products digitally without a physical footprint• Made and packaged 30% of our physical products with Forest StewardshipCouncil (FSC) certified paper• Launched employee engagement campaign Earth Champions Start at Home,
challenging employees to take 10 small actions over 10 weeks to help the planet

Take urgent action to combat climate change and its impacts.

• Supported 39 women peacebuilders with training, empowering them with theknowledge they need to protect their identities, sensitive data, and their lives• Established our GHG baseline, an important first step toward setting sciencebased targets, measuring annual progress, and making meaningful reductions
across our Scope 1, 2, and 3 emissions

Promote sustained, inclusive and sustainable economic growth, full andproductive employment and decent work for all.

• Reduced Scope 1 and 2 GHG emissions by 52% between FY20 and FY21

• Became a supporter of the Crypto Climate Accord and its objectives to transition
the global crypto industry to net-zero GHG emissions by 2040

• Two employee cohorts completed McKinsey & Company’s Black Leadership Academy• In FY21, none of our Tier 1 physical product suppliers were considered high risk forhuman trafficking• With our partner NASSCOM in India, trained 121 women in cybersecurity skills andhelped 108 secure the Certified Ethical Hacker certification

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2021 Performance Data Tables
Financial Performance
FY21

FY20

2,551

2,490

Americas72%74%

Europe, Middle East, and Africa (EMEA)

16%

15%

Asia Pacific and Japan (APJ)

12%

11%

362

393

1,293

1,742

Income tax benefit expense (in millions of $)

176

241

Effective income tax rate

20%

29%

Net income (loss)

554

3,887

Revenue (in millions of $)Total revenue
Revenue by region

Cost of revenue (in millions of $)Total cost of revenue
Operating expense (in millions of $)Total operating expense
Income tax

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2021 Performance Data Tables
FY21 Gender Diversity
FY21
Total

FY20

FemaleMaleWorkforce

33%

Leadership

Not Declared

Total

FemaleMale

Not Declared

67%

31%

69%

30%

69%

27%

73%

2,809

930

1,874

5

3,655

1,149

2,500

6

Americas

1,246

505

737

4

1,818

660

1,157

1

Asia Pacific, Japan (APJ)

771

247

523

1

292

85

203

4

Europe, Middle East, and Africa (EMEA)

93

32

61

0

324

143

180

1

India

699

146

553

0

1,221

261

960

0

Executive (VP or above)

26

6

19

1

55

8

47

0

Manager (non-executive without direct reports)

1,099

296

801

2

1,380

365

1,012

3

Individual contributor (non-executive without direct reports)

1,684

628

1,054

2

2,220

776

1,441

3

7

5

5

0

Not Reported

GLOBAL GENDER DIVERSITY

Employment contract
Permanent (employees)

Workforce by region

Employee category

Board of Directors
Board of Directors

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2021 Performance Data Tables
FY21 U.S. Ethnic Diversity
U.S. RACE / ETHNICITY TOTAL (%)

FY21

FY20

Underrepresented racial / ethnic groups

13%

11%

Non-underrepresented racial / ethnic groups

84%

87%

Not declared2%2%% White47%

48%% Asian

37%

39%% Black

6%

3%% Hispanic

4%4%American Indian / Alaska Native

0.2%

0.4%

Native Hawaiian / Other Pacific Islander

0.2%

0.4%

Decline to specify

2%2%

Underrepresented racial / ethnic groups

11%

9%

Non-underrepresented racial / ethnic groups

87%

89%

Not declared

2%

2%

Leadership (%)

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2021 Performance Data Tables
Environmental Stewardship
FY21

FY20

Total Scope 1 and 2 market-based

19,44740,827

Scope 1 (natural gas, diesel, propane, refrigerants, gasoline)

1,494

6,881

Scope 2 market-based (purchased electricity and heating)

17,91433,946

Scope 2 location-based (purchased electricity and heating)

15,77829,253Purchased goods and services

66,605

Not reported

Capital goods

174

Not reported

Operational waste

272

Not reported

Business travel (air)39

14,949

Employee commute (including working from home)

1,898

Not reported

Scope 1 and 2 market-based

7.4

16

Scope 10.6

2.8

Scope 2 market-based

6.8

14

Scope 3 (air travel)0

Not reported

Greenhouse Gas Emissions (metric tons of CO2e)*

Scope 3 Emissions

Emissions intensity*FY20 Greenhouse Gas Emissions data has been restated to correct an error.
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2021 Performance Data Tables
Environmental Stewardship (cont.)
FY21

FY20

Total energy consumption Scope 1 and 2

190,206

297,428

Scope 1 (natural gas, diesel, propane, gasoline, onsite solar)

29,32324,362

Scope 2 (purchased electricity and heating)

160,883

273,066

73

119

Total electricity consumption from renewable sources (gigajoules)

43,59634,373

Total electricity consumption from renewable sources (%)5

21%

24%

Total waste

3,868

Not reported

Waste sent to landfill244

Not reported

Waste recycled

3,259

Not reported

Waste composted

365

Not reported

Waste diversion rate (%)

94%

Not reported

245,424

Not reported

47%

Not reported

Number of environmental fines

00

Amount of environmental fines

00Energy Consumption (gigajoules)

Energy intensity (all scopes per million dollars of revenue)

Waste (metric tons)

Water
Water withdrawals (cubic meters)
Water withdrawals from water stressed regions (%)

Environmental Fines

5 Includes renewable energy included in the power mix delivered by our utility suppliers where information is available. Excludes renewables in the average/regional grid electricity.

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2021 Performance Data Tables
Philanthropic Giving

Grants by Focus Area
FY21

FY20

Philanthropic Giving (in thousands of $)Total giving

6,383,200

13,606,314

Grants1,899,168

1,511,920

Matching gifts, Dollars for Doers

407,844

811,962

Software donations through TechSoup(retail value of licenses)

2,039,251

10,957,432

Software donations through Norton Family offering(retail value of licenses)

2,036,937

N/A

Licenses donated110,364

243,072

Organizations supported through financial investments,
software donations, and employee matching programs

10,668Not
reported

Employee giving ($)

254,687

582,620

Volunteer hours

3,039

18,726FY21

FY20

Diversity, equity, and inclusion

29%

14%

Cyber Safety education and training

47%

32%

Environmental stewardship8%9%Community impact(STEM, disaster response, privacy, etc.)

15%

8%

Employee Contributions

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2021 Content Index
SUSTAINABILITY ACCOUNTING STANDARDS BOARD (SASB) INDEXSASB is an independent nonprofit organization that sets standards to guide the disclosure of sustainability information by companies to their investors. The following Index maps our disclosures to theSoftware & IT Services Sustainability Accounting Standard.

Topic

Accounting / Activity Metric(s)Location/Response

SASB CodeEnvironmental Footprint ofHardware Infrastructure(1) Total energy consumed, (2) percentage
grid electricity, (3) percentage renewable(1) 190,206 gigajoules

TC-SI-130a.1(2) 77%(3) 21%

Environmental Footprint ofHardware Infrastructure(1) Total water withdrawn, (2) total water
consumed, percentage of each in regionswith High or Extremely High Baseline Water
Stress(1) 245,424 cubic meters

TC-SI-130a.2

Environmental Footprint ofHardware Infrastructure

Discussion of the integration ofenvironmental considerations into strategicplanning for data center needs

Environmental Policy Statement

TC-SI-130a.3

Data Privacy & Freedom ofExpression

Description of policies and practices relating
to behavioral advertising and user privacy

NortonLifeLock policies and practices with respect to user privacy are outlined in the Privacy Center and associatedpages linked. These documents describe how NortonLifeLock collects, uses, shares and retains user information.
Please see:

TC-SI-220a.1(2) 114,270 cubic meters

https://www.nortonlifelock.com/us/en/privacy/global-privacy-statement/
https://www.nortonlifelock.com/us/en/privacy/privacy-notices/
https://www.nortonlifelock.com/us/en/privacy/product-privacy-notices/for comprehensive disclosures regarding the processing of user information.
Data Privacy & Freedom ofExpression

Number of users whose information is used
for secondary purposes

None

TC-SI-220a.2

Data Privacy & Freedom ofExpression

Total amount of monetary losses as a resultof legal proceedings associated with user
privacy

None

TC-SI-220a.3

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2021 Content Index
Topic

Accounting / Activity Metric(s)Location/Response

SASB Code

Data Privacy & Freedom ofExpression(1) Number of law enforcement requests foruser information, (2) number of users whose
information was requested, (3) percentage
resulting in disclosure(1) 33

TC-SI-220a.4

Data Privacy & Freedom ofExpression

List of countries where core products orservices are subject to government-required
monitoring, blocking, content filtering, or
censoring

NortonLifeLock does not allow any monitoring or censoring in our products. We do not provide any goods or services tothe US-embargoed countries: Cuba, Iran, North Korea, Crimea region of Ukraine, and Syria.

TC-SI-220a.5

Data Security(1) Number of data breaches, (2) percentage
involving personally identifiable information(PII), (3) number of users affected(1), (2), (3) While NortonLifeLock tracks data breaches and provides required notifications, we do not share thisinformation outside of the organization except where required.

TC-SI-230a.1

Data Security

Description of approach to identifying andaddressing data security risks, including useof third-party cybersecurity standards

We maintain a comprehensive technology and cybersecurity program to support the effectiveness of our systems andprepare for information security risks, including regular oversight of our programs for security monitoring for internaland external threats to safeguard the confidentiality and integrity of our information assets. We test our incident response
procedures at least annually, and 100% of our information security management system is aligned to ISO 27001.

TC-SI-230a.2(2) 33(3) 72%
NortonLifeLock only provides user data to law enforcement when compelled to do so, for example after being servedwith a subpoena or other judicial order requiring production of data.

Our Head of Cyber Security is ultimately responsible for our cybersecurity program and meets at least twice annually with
the Board of Directors or the Audit Committee of the Board of Directors to brief them on technology and information
security matters. Recently, our Board of Directors established a Technology and Cybersecurity Committee of the Board.
Global Cyber Security performs monthly vulnerability scans of its infrastructure and granularly tracks the status of
the vulnerabilities throughout the vulnerability management lifecycle as described in the Vulnerability and PatchManagement Standard. To enhance our vulnerability management program, agents have been installed to provide morenear real-time reporting of new vulnerabilities. Vulnerabilities are tracked in accordance with the following lifecycle:
Identification, Prioritization, Remediation, and Metrics.
Recruiting & Managing a Global,
Diverse & Skilled Workforce

Percentage of employees that are (1) foreign
nationals and (2) located offshore(1) 10% of employees are foreign nationals

Recruiting & Managing a Global,
Diverse & Skilled Workforce

Employee engagement as a percentage

We conduct quarterly all-employee pulse surveys to measure ongoing employee engagement. Engagement scores areused for internal purposes and are shared with all employees as part of our ongoing listen and action dialogue.

TC-SI-330a.2

Recruiting & Managing a Global,
Diverse & Skilled Workforce

Percentage of gender and racial/ethnic
group representation for (1) management,(2) technical staff, and (3) all other
employees(1) Females in Leadership (Global): 30%; Underrepresented Racial / Ethnic Groups in Leadership (U.S.): 11%

TC-SI-330a.3

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TC-SI-330a.1(2) 56% of employees are located offshore from the entity’s country of domicile(2) Not provided(3) Female in Workforce (Global): 33%; Underrepresented Racial / Ethnic Groups in Workforce (U.S.): 13%

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2021 Content Index
Topic

Accounting / Activity Metric(s)Location/Response

SASB CodeIntellectual Property Protection& Competitive Behavior

Total amount of monetary losses as aresult of legal proceedings associated with
anticompetitive behavior regulations

None

TC-SI-520a.1

Managing Systemic Risks fromTechnology Disruptions

Number of (1) performance issues and(2) service disruptions; (3) total customer
downtime(1) 1

TC-SI-550a.1

Description of business continuity risks
related to disruptions of operations

NortonLifeLock’s risk management program includes the people, processes, and technologies design to create andpreserve value for shareholders. Risk management practices are aligned with the Company’s vision, mission, strategies
and objectives. Accordingly, our risk management practices consider the risks related to disruptions of operations.

Managing Systemic Risks fromTechnology Disruptions(2) 3(3) 6:04 hours
TC-SI-550a.2

Our Business Resiliency efforts consist of three programs: Crisis Management, Business Continuity, and IT Disaster
Recovery. Our programs consider risk to key functions and operations to prevent the Company from sustaining
unacceptable financial, regulatory, safety, security, employee, customer, or operational impacts and minimizing any
public or industry reputational impacts. A business impact assessment (BIA) is used to identify critical businessactivities with associated maximum allowable outages and recovery time objectives. Documented plans containobjectives and procedures for incident response, recovery, and communication. Annually, critical plans are tested toconfirm identified strategies are effective, relevant, applicable, and effectively mitigate realistic scenarios. Action items
and areas of opportunity are tracked during the exercise and plan modifications are made accordingly and documented.
(1) Number of licenses or subscriptions, (2)percentage cloudbased(1) Cloud Subscriptions

TC-SI-000.A

a. AWS – 156
b. Azure – 61(2) 100% Cloud Based

Data processing capacity, (2) percentage
outsourced(1) 110 Nodes in on-prem and 7700 Cloud Nodes

Amount of data storage, (2) percentage
outsourced(1) NortonLifeLock has roughly 1.5PB storage capacity under its operational control

INTRODUCTION

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ETHICS & GOVERNANCE

TC-SI-000.B(2) 95% Outsourced to Cloud
TC-SI-000.C(2) 98% Outsourced to Cloud

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2021 Content Index
GLOBAL REPORTING INITIATIVE (GRI) INDEX
GRI’s standards provide a set of voluntary indicators on the economic, environmental, and governance impacts of a company’s performance. The index below applies guidance from the 2016 version of the
Global Reporting Initiative (GRI) Standards; “2016” refers to the Standards issue date, not the date of information presented in this report. We have also provided a cross reference to the United Nations Global
Compact (UNGC) where applicable.

Disclosure

GRI Description

FY21 Answer

UNGC Cross-reference

102-1

Name of the organization

NortonLifeLock, Inc.

102-2

Activities, brands, products,
and services

Company profile FY2021 10-K, p. 4-7

102-3

Location of headquarters

60 E Rio Salado Pkwy
STE 1000
Tempe, AZ 85281

102-4

Location of operations

NortonLifelock Worldwide | NortonLifelock

102-5

Ownership and legal form

Publicly Traded C-Corporation
FY2021 10-K, p. 4

102-6

Markets served

FY2021 10-K, p. 4

102-7

Scale of the organization

FY2021 10-K, p. 4-9

102-8

Information on employees
and other workers

FY2021 10-K, p. 8-9
Performance Tables, p. 37-42
People & Culture: p 20-24

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2021 Content Index
Disclosure

GRI Description

FY21 Answer

UNGC Cross-reference

102-9

Supply chain

Environmental Stewardship: p 17-19

Human Rights, Labour, Environment:
Relevant policies, procedures,
activities

Global Supplier Code of Conduct
Corporate Responsibility Policies
NortonLifeLock outsources all manufacturing of our physical products. We have two main suppliers, both of which are under contract
and required to abide by our Supplier Code of Conduct. The main products sourced are board/paper designed products containing a
digital code key.
102-10Significant changes to theorganization and its supply chain

About this Report, p. 35

102-11

Precautionary Principle

The Precautionary Principle is not applied specifically across the organization, nor in the development and introduction of new
products. NortonLifeLock uses a model similar to the Precautionary Principle for risk management with regard to business
continuity. Our Crisis Management and Continuity Management teams determine the impact likelihood of each threat occurring andconduct exercises to obtain a full understanding of possible impact. This allows us to determine and report any unacceptable single
points of failure. Formula used to determine risk: risk value = threat impact x threat probability.

or approach102-12External initiatives

We are a participant in the UN Global Compact.

102-13

Membership of associations

Association of Corporate Citizenship Professionals (ACCP)

Human Rights, Labour, Environment:
Relevant policies, procedures,
activities

The Better Identity Coalition
Business in the Community Ireland
CERES
Coalition Against Stalkerware
Information Technology Industry Council
One Tree Planted
Software Assurance Forum for Excellence in Code (SAFECode)102-14

Statement from senior

Messages from the Chief Executive Officer and Board Member, p. 1, 2

CEO statement including continued
support of the United Nations Global
Compact

decision-maker

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2021 Content Index
Disclosure

GRI Description

FY21 Answer

UNGC Cross-reference

102-16

Values, principles, standards, andnorms of behavior

Governance and Ethics, p. 10-12

Human Rights, Labour,
Environment, Anti-Corruption:
Relevant policies, procedures,
activities

Code of Conduct

Our Approach, p. 5-8

102-182021 Proxy Statement, p. 6-10
Charter of the Nominating and Governance Committee of the Board of Directors

Governance structure

Corporate Governance102-40

List of stakeholder groups

Stakeholder engagement, p. 7

102-41

Collective bargaining

FY2021 10-K, p. 8

Labour: Relevant policies,
procedures, activities

agreements

Labour: Measurement of outcomes
102-42

Identifying and selecting
stakeholders

Stakeholder engagement, p. 7

102-43

Approach to stakeholder
engagement

NortonLifeLock undertakes extensive engagement across a variety of our different stakeholders from formal surveys of employees
and customers to more informal discussions and partnerships with our communities. The frequency and nature of the engagement
depends on a variety of factors including the nature of the relationship and the preferences of our stakeholders. A variety of
stakeholders' opinions are solicited to support the assessment of priority topic areas in the ESG report including advocacy groups,
employees, thought leaders and topic area experts.
Stakeholder engagement, p. 7

102-44

Key topics and concerns raised

An ESG priority assessment process was completed in FY21, which integrated feedback from a variety of stakeholders through aformal survey and interview process. Feedback from these stakeholder engagements was used to assess and prioritize ESG topic
areas. Topic areas were prioritized based on both stakeholder feedback as well as internal company criteria such as alignment with
NortonLifeLock policies and values. Topic areas identified as high priority are discussed in the ESG Report to respond to stakeholder
expectations.

Human Rights, Labour,
Environment, Anti-Corruption:
Relevant policies, procedures,
activities

Approach (ESG priority assessment & Stakeholder Engagement), p. 5 and 7

102-45

Entities included in the

FY2021 10-K, p. 45

consolidated financial
statements

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2021 Content Index
Disclosure

GRI Description

FY21 Answer

102-46

Defining report content and topic
boundaries

Approach, p. 5-8

102-47

List of material topics6

Approach, p. 5-8

102-48

Restatements of informationNone

102-49Changes in reporting

About this Report, p. 35

102-50

Reporting period

About this Report, p. 35

UNGC Cross-reference

About this Report, p. 35

Fiscal Year 2021: April 2020 - April 2021
102-51

Date of most recent report

Our last Corporate Responsibility report was published in November 2020.

102-52

Reporting cycle

Annual102-53

Contact point for questions

CR@nortonlifelock.com

Time period covered by
Communication on Progress (COP)

regarding the report102-54Claims of reporting in accordance

About this Report, p. 35

with the GRI Standards
102-55

GRI content index

GRI Index

102-56External assurance

None

Environment: Measurement ofoutcomes

6 In this report, we may use the terms "material" or "materiality," but we are not using these terms as defined by the securities laws of the United States nor in the context of financial statements or financial reporting.

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2021 Content Index
Disclosure

GRI Description

FY21 Answer

201-1

Direct economic value generated and distributed

Performance Tables, p. 37-42

UNGC Cross-reference

FY2021 10-K
201-2

Financial implications and other risks and opportunities due to climate change

We have conducted an analysis of our climate change risk but have not
identified any climate-related risks with the potential to have a substantive
financial or strategic impact on our business.

Environment: Relevant policies,
procedures, activities

205-1

Operations assessed for risks related to corruption

One hundred percent of operations were assessed for risks relating tocorruption.

Anti-corruption: Relevant
policies, procedures, activities

Our FY21 Fraud Risk Assessment considered: bid-rigging, purchasing
schemes, sales schemes, extortion, kickbacks, and more.
205-2

Communication and training about anticorruption policies and procedures

Anti-Corruption remains a key topic within our mandatory annual Code of
Conduct training.

Anti-corruption: Relevant
policies, procedures, activities

205-3

Confirmed incidents of corruption and actions taken

None

Anti-corruption: Measurementof outcomes

206-1

Legal actions for anti-competitive behavior, anti-trust, and monopoly practices

On July 2, 2019, the U.S. Department of Justice (DOJ) issued a Civil
Investigative Demand to NortonLifeLock Inc. (f/k/a Symantec Corporation)
concerning the Anti Malware Testing Standard Organization’s (“AMTSO”)
testing standard and potential anticompetitive agreements among industry
stakeholders. On June 5, 2020, the DOJ notified the Company’s counsel that it
had closed its investigation, and the Company subsequently received a closing
letter.

401-1

New employee hires and employee turnover

New Hires: 416 (16%)

Labour: Measurement ofoutcomes

Voluntary Turnover: 279 (11%)

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2021 Content Index
Disclosure

GRI Description

FY21 Answer

UNGC Cross-reference

401-2

Full-time benefits not provided to temporary/ part-time employees

Employees actively working at least twenty (20) hours per week are eligible
to participate in NortonLifeLock’s Benefit Programs. Employees who actively
work less than 20 hours per week are eligible, at a pro-rated rate, for our paid
time off/vacation and company paid holidays.

Labour: Relevant policies,
procedures, activities·

Life insurance·

Healthcare·

Disability·

Leaves of Absence·

Retirement

·

EAP

·

Voluntary Insurance Programs·

Wellness

401-3

Parental leave

100%

Labour: Relevant policies,
procedures, activities

404-2

Programs for upgrading employee skills and transition assistance programs

People & Culture, p. 20-24

Labour: Relevant policies,
procedures, activities

405-1

Diversity of governance bodies and employees

Performance Tables, p. 37-42

Labour: Measurement ofoutcomes

FY2021 10-K, p. 8-9
Board• Gender: 44% (4/9) women• Age: 44% (4/9) between 30-50; 56% (5/9) 50+; none under 30• Underrepresented community (Ethnic diversity and/or LGBTQ+): 33% (3/9)
Employees• Age: <30: 16%; 30-50: 72%; >50: 12%• Females in Leadership (Global): 30%• Female in Workforce (Global): 33%• Underrepresented Racial/Ethnic Groups in Leadership (U.S.): 11%• Underrepresented Racial/Ethnic Groups (U.S.): 13%

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2021 Content Index
Disclosure

GRI Description

FY21 Answer

UNGC Cross-reference

412-2

Employee training on HR policies or procedures

NortonLifeLock requires all employees to take training on our Code of Conduct.
In 2021, we highlighted modules on human rights and modern slavery, antibribery and corruption, managing conflicts of interest, and diversity, equity,and inclusion. In total, 100% of employees completed the training (excluding
employees on leaves of absence).

Human Rights: Relevant
policies, procedures, activities

Commitment to Human Rights, p. 33

Human Rights: Relevant
policies, procedures, activities

414-1

New suppliers that were screened using social criteria

We did not onboard any new physical product suppliers in FY21.

414-2

Negative social impacts in the supply chain and actions taken(a) 2(a) Number of suppliers assessed for social impacts(b) 0(b) Number of suppliers identified as having significant actual and potential negativesocial impacts(c) 0(c) Significant actual and potential negative social impacts identified in the supply chain(e) 0(d) Percentage of suppliers identified as having significant actual and potential negativesocial impacts with which improvements were agreed upon as a result of assessment

Labour: Relevant policies,
procedures, activities

Human Rights: Measurement ofoutcomes
Human Rights: Measurement ofoutcomes(d) 0(e) Percentage of suppliers identified as having significant actual and potential negativesocial impacts with which relationships were terminated as a result of assessment, and
why
417-3

Requirements for product and service information and labeling

None

418-1

Substantiated complaints concerning breaches of customer privacy and losses ofcustomer data

Details are confidential.

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2021 Content Index
GRI Material TopicGRI Management Approach Cross-reference7

Relevant External Entities FY21

UNGC Cross-reference

GRI 201: Economic
Performance

FY2021 10-K, p. 23-34

Communities; Customers; Governments and regulators; Investors; Suppliers

GRI 205: Anti-corruption

Governance and Ethics, p. 10-12
Code of Conduct
Conflict Minerals Policy

ECONOMIC

Anti-corruption: Relevant
policies, procedures, activities

ENVIRONMENTAL
GRI 302: Energy

Environmental Stewardship, p. 17-19
Environmental Policy Statement

Communities; Customers; Governments and regulators; Investors; Suppliers

Environment: Relevant policies,
procedures, activities

GRI 305: Emissions 2016

Environmental Stewardship, p. 17-19
Environmental Policy Statement

Communities; Customers; Governments and regulators; Investors; Suppliers

Environment: Relevant policies,
procedures, activities

SOCIALGRI 401: Employment

Code of Conduct
Human Rights Policy

Human Rights: Relevant
policies, procedures, activities
Labour: Relevant policies,
procedures, activities

GRI 404: Training and
Education

People & Culture, p. 20-24

Labour: Relevant policies,
procedures, activities

GRI 405: Diversity andEqual Opportunity

People & Culture, p. 20-24
Human Rights Policy

Human Rights: Relevant
policies, procedures, activities
Labour: Relevant policies,
procedures, activities

GRI 412: Human Rights
2016

Commitment to Human Rights, p. 33
Code of Conduct
Conflict Minerals Policy
Human Rights Policy
Corporate Responsibility Policies

Human Rights: Relevant
policies, procedures, activities

GRI 417: Marketing andLabeling

FY2021 10-K, p. 4

Customers
Governments and regulators

GRI 418: Customer Privacy

Products, p. 13-16
NortonLifeLock Privacy
NortonLifeLock Product and Services Privacy Notices
Global Privacy Statement

Customers
Governments and regulators

Human Rights: Relevant
policies, procedures, activities

7 Includes disclosures 103-1 Explanation of the material topic and its boundary, 103-2 The management approach and its components, and 103-3 Evaluation of the management approach.

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Forward-looking statements
This report has disclosed information which may be considered forward-looking statementsthat are subject to safe harbors under the Securities Act of 1933, as amended (the Securities
Act) and the Exchange Act of 1934, as amended (the Exchange Act). In some cases, you
can identify these forward-looking statements by the use of terms such as ‘‘expect,’’ ‘‘plans,’’‘‘anticipate,’’ ‘‘believe,’’ ‘‘estimate,’’ ‘‘predict,’’ ‘‘goal,’’ ‘‘intend,’’ “future,” “plan,” “strategy,” “continueto,” “will,” and or similar expressions, and variations or negatives of these words, but theabsence of these words does not mean that a statement is not forward-looking. All statements
other than statements of historical fact are statements that could be deemed forward-looking
statements, including, but not limited to, our ESG commitments, strategies and initiatives;
our business plans and strategy; our technology and services; our opportunities for growth;and our stakeholder engagement efforts. Forward-looking statements are based on current
expectations and assumptions that are subject to risks and uncertainties that may cause
actual results to differ materially. We do not undertake any obligation to update these forwardlooking statements to reflect events occurring or circumstances arising after the date of thisreport. While we believe that our current expectations and assumptions are reasonable, there
are many risks and uncertainties that could cause actual results to differ materially fromforward-looking statements made herein including, most prominently, the risks discussed
under the heading “Risk Factors” in our most recent reports on Form 10-K and Form 10-Q filedwith the U.S. Securities and Exchange Commission (“SEC”) as well as other factors describedfrom time to time in our filings with the SEC. Such forward-looking statements are made only
as of the date of this report. If we do update one or more forward-looking statements, noinference should be made that we will make additional updates with respect to those or otherforward-looking statements.

INTRODUCTION

APPROACH

ETHICS & GOVERNANCE

PRODUCTSENVIRONMENTAL STEWARDSHIPPEOPLE & CULTURE

COMMUNITY IMPACTPERFORMANCE DATA TABLESASB AND GRI INDEX

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