Corporate Forms and Policies
Business & Personal Conduct
Anti-Bribery Policy
Geographic Coverage
Document Owner
Last Reviewed

Global
EVP, General Counsel and Corporate Secretary
MVP, Legal and Compliance
Dec 6, 2023

Policy Philosophy & Purpose
Gartner is committed to conducting our business with the highest ethical and legal
standards. Many countries where Gartner does business have laws that make bribery of
public and private sector officials a crime. This document establishes Gartner’s policy forensuring compliance with anti-bribery laws, including the United States Foreign Corrupt
Practices Act (“FCPA”), the United Kingdom Bribery Act (“U.K. Bribery Act”), legislation
enacted under the Organisation for Economic Co-operation and Development Convention
on Combating Bribery of Foreign Public Officials in International Business Transactions(“OECD Convention”), and similar laws of other countries.

Scope & Applicability
This Anti-Bribery Policy (the “Policy”) applies to all business activities conducted by
Gartner employees (“Gartner Associates”) at Gartner Inc. and its subsidiaries andaffiliates (“Gartner”). This Policy may be supplemented by policies applicable to aparticular country or region or a particular business unit; these supplemental policies
supersede any conflicting portion of this Policy. As specified in our Supplier Code of
Conduct, all third parties doing business with Gartner are required to comply with allapplicable anti-bribery laws.
To ensure that Gartner Associates and risk-based Gartner representatives(authorized agents and representatives acting on Gartner’s behalf, such as
intermediaries, sales agents, independent contractors (e.g., consulting stringers), andother third parties acting on Gartner’s behalf (“Gartner Representatives”)) are familiar
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without advance notice, subject to the requirements of local law, where applicable.

© 2023 Gartner, Inc. and/or its affiliates. All rights reserved. Gartner is a registeredtrademark of Gartner, Inc. or its affiliates.

with applicable anti-bribery laws, Gartner provides targeted anti-bribery training andresources.

PolicyA.

All Bribes are Prohibited

Gartner has zero-tolerance for bribery. This Policy is designed to familiarize Gartner
Associates with the requirements of international anti-bribery laws and Gartner’s rules
to help ensure that no Gartner Associate violates the law. If you have questions about
permissible conduct under the laws of any country where we do business, or therequirements discussed below, please direct them to Ethics & Compliance atLegalCompliance@gartner.com or your local Legal & Compliance team member.
Gartner strictly prohibits bribery, corruption, and kickbacks (“Bribery”) in all forms, inall our business dealings, in every country where we do business. This prohibition
applies to public sector bribery (government) and private sector bribery (commercial);
the prohibition applies to active bribery (giving a bribe) and passive bribery (accepting
a bribe).
Bribery is the direct or indirect offer to give anything of value to, or request or receive
anything of value from, a government official or commercial person or entity, with theintent to corruptly influence that Government Official, Commercial Person or entity, toaward new business, continue existing business, to gain any improper advantage, orto influence any act or decision of a person or entity. (For Key Definitions see ExhibitA)
Do not engage in activities that create the appearance of impropriety. Do not use
third parties (e.g., Gartner Representatives) to take actions that you areprohibited from taking. Similarly, do not do in your personal capacity what you areprohibited from doing in a business capacity. Gartner can be liable for the failure
to prevent bribery.
1. Know Your Third Parties
Gartner uses third parties (such as suppliers and Gartner Representatives) to help usdeliver our products and services in the marketplace. Gartner Associates must only
deal with those third parties that are legitimate businesses with a reputation for
integrity and ensure that Gartner Representatives do the same. Gartner can be liable
for the actions of its third parties, including joint venture partners and companies it
acquires or those over which it exercises control. Retention of Gartner
Representatives can present a significant risk to Gartner. As such, Gartner
Representatives and their subcontractors are prohibited from making corrupt
payments. (See Supplier Code of Conduct)
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Gartner reserves the right to add, modify or delete any provisions of this policy
without advance notice, subject to the requirements of local law, where applicable.

© 2023 Gartner, Inc. and/or its affiliates. All rights reserved. Gartner is a registeredtrademark of Gartner, Inc. or its affiliates.

All suppliers must be onboarded via Gartner’s Spend Management Platform, whererisk-based questions determine whether Anti-Bribery and Anti-Corruption (“ABAC”)
due diligence is required. Suppliers also acknowledge Gartner’s Supplier Code of
Conduct. (The Supplier Onboarding Process is described in more detail in Exhibit B.)
Do not ignore signs of unethical conduct by third parties. If you are working with athird party, you have a responsibility to look out for red flags. (See Red Flags in
Exhibit C) Any red flags must be reported to the Ethics & Compliance team byemailing LegalCompliance@gartner.com.
You may not sell or provide Gartner products or services to clients identified asprohibited by Ethics & Compliance for sanctions or other financial crime compliancereasons and you may not give gifts or entertain individuals associated with thoseclients. How do you know if a company is prohibited? There is a red flag associatedwith the entity in the Gartner client management system (and related sources). That
red flag means that you must contact Ethics & Compliance before any interaction.
Note that the system only has information related to clients and prospects. For
suppliers, you may not do business with any company listed on the ”Prohibited
Supplier List”.
You must involve Ethics & Compliance in any merger, acquisition, joint venture, orinvestment in which Gartner will have a controlling interest or exercise control toenable proper due diligence and appropriate controls.
Failure to prevent bribery, by ignoring, covering up, or failing to act, is also a crime,
which is of particular concern when working with Gartner Representatives and theirsubcontractors.
2. Transactions Must be Transparent
Transactions that are transparent reduce the risk of Bribery. Ensure contracts
accurately reflect the economics of the agreement. Unusual arrangements, such asside agreements and prepayments, may be used to cover up improper payments. If
the payment terms are confusing, ask why.
Avoid any relationship or activity that might impair, or appear to impair, your ability torender fair and appropriate business decisions.
Be mindful of situations where anything of value is offered during pending deals,
negotiations, or Request for Proposals (RFPs) with current or potential clients or
suppliers. Avoid situations where you have or may have a conflict of interest, may
stand to benefit personally, or appear to benefit personally.

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Gartner reserves the right to add, modify or delete any provisions of this policy
without advance notice, subject to the requirements of local law, where applicable.

© 2023 Gartner, Inc. and/or its affiliates. All rights reserved. Gartner is a registeredtrademark of Gartner, Inc. or its affiliates.

In addition, ensure that invoices from Gartner Representatives are sufficiently
detailed so that you can clearly understand and review the service performed andthat any such invoices attach documentation to support expenses.

3. Gifts, Hospitality & Travel Must be Reasonable
Gartner Associates may not offer, provide, or receive Gifts & Hospitality or pay
expenses unless they are (1) transparent, proportionate, reasonable, non-lavish, andbona fide, (2) have a legitimate business justification; and (3) do not violate the lawsof the country of the recipient. In determining what might be a “reasonable” 1 level of
Gifts & Hospitality for legitimate business purposes, be guided by the level of
expenditure required to provide necessary transportation, meals, lodging, andentertainment at a modest, non-lavish level, ensuring that the expenditure would notexceed the level of a permissible expense under Gartner’s own Global Travel &Expense Policy. Note that small business courtesies, such as modest gifts orlunches, intended merely to promote goodwill, generally are permitted, unlessprohibited by local law.2 Before offering Gifts & Hospitality review and comply with theGift Policy and the Global Travel & Expense Policy. Gartner Associates must avoid
Gifts & Hospitality from current or potential new suppliers during sourcing events orcontract negotiations. (See the Gift Policy).
Be aware that some recipients have policies by which they must abide. Gartner may
at times be required to execute commitment letters that may have strict restrictions
that prohibit gifts or hospitality of any value. Check those policies or commitment
letters before offering gifts, hospitality, or travel.
Gartner is always required to maintain accurate and transparent records andinternal controls to comply with the law.
4. Hiring Decisions Must Not Benefit Government Officials or Commercial
Persons
All hiring decisions should be made through Gartner’s normal hiring process. Do nothire someone for a job or an internship who is suggested by or related to a
Government Official or Commercial Person to help Gartner retain or obtain businessor secure a business advantage.

1 Also take into consideration the recipient’s ability to influence decisions about Gartner business (e.g., RFPs); consider whether

there could be an objective perception of bribery.
2 Small business courtesies of no more than $150 (or lower amounts as per local country policies) like the above are generally
are permitted with written approval from your manager or someone higher in your business unit (please refer to the Gift Policy
and your country’s local policies for more details).
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Gartner reserves the right to add, modify or delete any provisions of this policy
without advance notice, subject to the requirements of local law, where applicable.

© 2023 Gartner, Inc. and/or its affiliates. All rights reserved. Gartner is a registeredtrademark of Gartner, Inc. or its affiliates.

5. Do Not Make Facilitation Payments
Facilitation payments are prohibited. Exceptions are possible in very rare or
extraordinary circumstances where a Gartner Associate’s safety may be at stake.
When possible, first consult with and obtain authorization from Ethics & Compliance.
If that is not possible, you must report the situation and payment immediately.
6. Charitable Contributions May Not Be Made to Obtain an
Unlawful Business Advantage
In general, Gartner does not make charitable contributions, except where required bylaw, but rather matches the charitable contributions of its associates. (See the Gift
Policy to learn about Gartner’s charity match program called GartnerGives.) Even acharitable contribution can be considered a bribe if the charity has ties to agovernment official or commercial person, or a member of his or her family, withdecision-making authority over Gartner business.
7. Political Contributions May Not Be Made to Obtain an Unlawful Business
Advantage
Gartner does not participate in any political activities. You are free to make politicalcontributions, but you must only do so in your personal capacity. Gartner’s Gift Policy
prohibits political contributions on behalf of Gartner. This means you should not makeor promise any political or campaign contributions, including in-kind contributions, onbehalf of, or as a representative of, Gartner. This prohibition includes using Gartner’s
assets or resources in connection with a contribution.
B.

Accurate Books and Records and Internal Accounting Controls

Gartner’s books and records must reflect the true and accurate nature of everytransaction. Never circumvent Gartner’s internal controls for the accounting anddistribution of assets. Do not establish or use any undisclosed or unrecorded
company funds, such as “off book” accounts for any purpose. Never make false,
misleading, incomplete, inaccurate, or artificial entries in Gartner’s books and records(including Gartner tools and systems). You are prohibited from using personal funds
or third parties to circumvent procedures and controls or to accomplish what isotherwise prohibited.
You must fully document, including receipts and invoices, all expense transactions
involving travel, hospitality, or entertainment provided to, or paid for by, an outside
person. All such expenses must be accurately characterized and accounted for in our
corporate records, regardless of their size. Documentation must include the name,title, and company of the individual(s) involved, business justification, and mustcomply with Gartner’s Global Travel and Expense Policy requirements.
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Gartner reserves the right to add, modify or delete any provisions of this policy
without advance notice, subject to the requirements of local law, where applicable.

© 2023 Gartner, Inc. and/or its affiliates. All rights reserved. Gartner is a registeredtrademark of Gartner, Inc. or its affiliates.

C.

Cooperation

Gartner may, under certain circumstances, perform a more detailed review of certaintransactions or conduct audits and investigations. As part of these reviews, Gartner
requires that you cooperate with the company, internal and outside counsel, internaland external auditors, agencies, or similar parties. Failure to cooperate with anauthorized review violates this Policy.
D.

Raise Concerns & Ask Questions - Reporting Requirement

If you find yourself subjected to any form of demand or request to accept or pay a
bribe or other form of improper payment or advantage or are asked to participate inany way in a bribery scheme, you must immediately report such occurrence to Ethics& Compliance at LegalCompliance@gartner.com. Alleged violations of this Policy orapplicable law may also be reported confidentially on an anonymous basis (where
allowed by local law) without fear of retaliation using the Gartner Ethics Helpline (seealso the Speak Up Resource Center).
You have a responsibility to report any suspicious activity that may cause a violationof this Policy. Ignoring red flags or other signs of a potentially illegal payment is itself
a violation of this Policy subject to disciplinary action.
E.

No Retaliation

Gartner has zero tolerance for retaliation. You will not suffer demotion, penalty orother adverse employment action or retaliatory consequences for not paying or
accepting bribes or making improper payments, even when Gartner may losebusiness because of your refusal to do so. Nor will you face retaliation for reporting,in good faith, suspicious activity or potential violation of this Policy. If you doexperience retaliation, it should be reported as you would any other form of
misconduct.
F.

Violation of Policy

If you violate this Policy, you will be subject to disciplinary action, up to and including
termination of employment. The FCPA, the U.K. Bribery Act, the OECD Convention,and other laws also provide for criminal and civil liability, fines, and penalties forviolations by the Company and culpable individuals. As an example, those who
violate the FCPA are subject to fines and imprisonment.

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Gartner reserves the right to add, modify or delete any provisions of this policy
without advance notice, subject to the requirements of local law, where applicable.

© 2023 Gartner, Inc. and/or its affiliates. All rights reserved. Gartner is a registeredtrademark of Gartner, Inc. or its affiliates.

Revision History
Published Date

Reason for Revision

9-Jul-2019

Full policy review and update.

28-Mar-2022

Updated all policy/content links to point to Insider Gartner.

5-Aug-2022

Simplified and streamlined the policy.

18-May-2023

Non-material change made to the first sentence of Section 1. Know Your
Third Parties, to align with the forthcoming Code of Conduct revision.
Revised the Document Owner titles.

6-Dec-2023

Corrected Supplier Code of Conduct link. Revised the Document Owner title
to EVP General Counsel and Corporate Secretary.

Page 7
Gartner reserves the right to add, modify or delete any provisions of this policy
without advance notice, subject to the requirements of local law, where applicable.

© 2023 Gartner, Inc. and/or its affiliates. All rights reserved. Gartner is a registeredtrademark of Gartner, Inc. or its affiliates.

Exhibit A - Key Definitions
Anything of Value includes cash or cash equivalents; a job or internship; areference, referral, or endorsement; a loan, favorable contract terms or promises of
future business; gifts, meals, entertainment, hospitality, travel; charitable or politicalcontributions; tickets to events or parties; or anything else of value including anythingthat is valuable to the recipient, even if it would not be valuable to anyone else.
Bribery is the direct or indirect offer to give anything of value to, or request or receive
anything of value from, a government official or commercial person or entity, with theintent to corruptly influence that Government Official, Commercial Person or entity, toaward new business, continue existing business, to gain any improper advantage, orto influence any act or decision of a person or entity.
Commercial Person means an individual working in the private sector.
Corruptly Influence is broadly defined to mean that the offer, payment, promise orgift must be intended to induce the recipient to misuse their official/business position.
This could include causing the recipient to fail to perform an official/business function.
Facilitation Payments are known as a ‘grease payments’ or ‘speed payments’
usually made in cash, paid to a Government Official typically to facilitate, or expedite
the performance of a routine action or service to which the person or company
making the payment is legally entitled to receive.
Improper Advantage is broadly defined to mean something to which the Company is
not clearly entitled.
Indirect Payments are payments of anything of value that our representatives,
agents and intermediaries make on our behalf.
Gartner Representatives are authorized agents and representatives acting on
Gartner’s behalf, such as intermediaries, sales agents, independent contractors (e.g.,
consulting stringers), and other third parties acting on Gartner’s behalf.
Gifts & Hospitality are things of value provided to a third party. A gift is somethingof value provided where there is no host. Hospitality includes things of value likemeals or entertainment where there is a host. If there is no host, then hospitality
becomes a gift.

Page 8Gartner reserves the right to add, modify or delete any provisions of this policy
without advance notice, subject to the requirements of local law, where applicable.

© 2023 Gartner, Inc. and/or its affiliates. All rights reserved. Gartner is a registeredtrademark of Gartner, Inc. or its affiliates.

Governmental Official is defined broadly to include:•

Any officer or employee of a government agency or department, (domestic
or foreign, federal, state, or local), including anyone who holds a legislative,administrative, or judicial position of any kind, whether appointed or elected(this includes even an administrative-level employee, such as an executive
assistant)•anyone who exercises a public function or acts in an official capacity on
behalf of a country or territory (or any subdivision of a country or territory)or any public agency of that country or territory (or subdivision thereof)•

any officer, employee, or anyone else who exercises a public function for oracts in an official capacity on behalf of an entity partly or wholly owned orcontrolled by a country or municipality (e.g., a government owned entity)•

a candidate for public office or officer or employee of a political party•

any officer or employee of a public international organization (e.g., theUnited Nations, the World Bank)•an individual in an unpaid or honorary government position, including acommittee, panel, commission, or other advisory position•an academic at a government/public institution•

an employee (even a low-level employee) of government or public hospital•a member of a royal family or monarchy

If you have any questions as to whether any individual is a Government Official or
any entity if a government owned entity, please contact Ethics & Compliance atLegalCompliance@gartner.com.
Kickback is the return of a sum already paid or due as a reward for awarding further
business.

Page 9Gartner reserves the right to add, modify or delete any provisions of this policy
without advance notice, subject to the requirements of local law, where applicable.

© 2023 Gartner, Inc. and/or its affiliates. All rights reserved. Gartner is a registeredtrademark of Gartner, Inc. or its affiliates.

Exhibit B – Supplier Onboarding Process
Gartner Associates are responsible for ensuring that any supplier you intend to workwith, especially third parties who act on behalf of Gartner (e.g., Gartner
Representatives) and third parties who will interact with Government Officials areentered accurately into Gartner’s suppler management platform to enable a proper
review by the Ethics & Compliance team.
As part of this process, every supplier and its principals are run against sanctions andwatchlists, state owned company lists, and adverse media lists. Each supplier isprovided with Gartner’s Supplier Code of Conduct and must certify that it will comply
with its terms.
As part of supplier onboarding, the business unit seeking to retain the supplier must
accurately complete a Business Unit Questionnaire to gather relevant information andthe supplier must complete a Supplier Questionnaire to gather additional information.
Based on the answers to these questionnaires, an Anti-Bribery Anti-Corruption(ABAC) Control Program may be triggered based on risk. If triggered, the ABAC
Control Program requires the supplier to complete an ABAC Questionnaire.
While the ABAC Questionnaire is reviewed by the Ethics & Compliance team, yourresponsibility is to make sure that the supplier you would like to engage with promptly
completes the ABAC Questionnaire prior to commencing work. If you have any
questions, please reach out to LegalCompliance@gartner.com. For additional
information on the supplier management process or platform please consult theProcure to Pay (P2P) team and the Global Procurement Policy.

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Gartner reserves the right to add, modify or delete any provisions of this policy
without advance notice, subject to the requirements of local law, where applicable.

© 2023 Gartner, Inc. and/or its affiliates. All rights reserved. Gartner is a registeredtrademark of Gartner, Inc. or its affiliates.

Exhibit C - Red Flags
A non-exhaustive list of possible red flags that may indicate warning signs regarding
potential violations of this Policy is listed below:
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•

Poor business reputation, reputation for making improper payments orunethical conduct
Requests for cash transactions or payments
Commission substantially above going rate
Unusual payment mechanism
Over-invoicing
Vaguely described services
Excessive travel and entertainment reimbursement requests
Requests for reimbursement of poorly documented expenses
Sales agent, consultant, or third-party relationships with public
sector clients
Facilitation payments
Political contributions
History of corruption in countries where business is conducted
Incomplete or inaccurate information on required disclosures, e.g.,refusal to disclose ownership
Requests for payment to a numbered account or third party or consultant
Requests for payments outside of the territory
Requests that checks be made payable to “cash” or “bearer”
Close family ties to high-ranking government officials or other decision
makersBusiness partner, agent or customer is owned or controlled bygovernment-owned or controlled entity
Refusal to certify compliance
Suggestion that otherwise illegal conduct is acceptable because it is
the norm or custom in a particular country.
Lack of qualifications or resources to perform real work
Plan for performing the work is vague and/or suggests a relianceon contacts or relationships
Lack of transparency in accounting and expense records
Proposed the use of shell companies
Insistence that identity remain confidential or that the relationshipremain secret
Requests or demands to use a specific third party

When you encounter a red flag or are unsure if something is a red flag, consult Ethics& Compliance at LegalCompliance@gartner.com.
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Gartner reserves the right to add, modify or delete any provisions of this policy
without advance notice, subject to the requirements of local law, where applicable.

© 2023 Gartner, Inc. and/or its affiliates. All rights reserved. Gartner is a registeredtrademark of Gartner, Inc. or its affiliates.

Exhibit D: Frequently Asked Questions
1. The FCPA is a United States law. I am not located in the US; do I haveto worry about it?
A. Yes. Gartner is a US-based company and therefore the FCPA applies to all
Gartner Associates. Also, the FCPA reaches conduct that occurs beyond theUS.
2. The UK Bribery Act is the law in the United Kingdom. We are a US
Company, why does this apply to us?
A. We have operations in the UK and like the FCPA, the UK Bribery Act, reaches
conduct beyond its shores.
3. How do I know whether there are any local laws where I am located that arestricter than this Policy?
A. Ask your local Legal & Compliance team member.
4. Why is it important for Gartner Associates to be aware of what Gartner
Representatives are doing?
A. As Gartner Associates, you must be aware of what Gartner Representatives
may do because their actions have consequences. Gartner can be held liable
for the actions of Gartner Representatives, so it is important that Gartner
Associates exercise oversight and caution in their relationships with Gartner
Representatives.
5. What should I do if I receive a lavish gift from a prospective vendor?
A. Do not accept a lavish gift from a prospective vendor, prospective client,current vendor, or current client. Consult the Gift Policy for how to handle thesituation.
6. You work with a sales agent and are told that because of the extra time andeffort required to properly represent Gartner’s interests in a highly
competitive bid, the agent’s usual commission must be increased. The
agent is confident that, through their contacts, they can position Gartner to
win the bid. What do you do?
A. You must learn more about the increased commission request, the businessjustification for it, and what meetings took place to understand whether it isPage 12
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without advance notice, subject to the requirements of local law, where applicable.

© 2023 Gartner, Inc. and/or its affiliates. All rights reserved. Gartner is a registeredtrademark of Gartner, Inc. or its affiliates.

likely that the agent intends to influence the decision-maker on the bid bysharing a portion of their commission. Never agree to pay an increased
commission without investigating the circumstances of the request andsatisfying yourself that the agent does not intend to offer a bribe. If you havequestions regarding the propriety of an arrangement, contact Ethics &Compliance.
7. You are a sales agent and learn that a huge government procurement
project is about to be awarded. You submitted the RFP, but learn that incountry X, it is common to hire individuals who know their way aroundand know how to “get things done.” You get introduced to one of these
individuals and they tell you that their customary fee is $2,000 in cash:$1,000 for them and $1,000 to “get the job done.” What should you do?
A. You must explain that you cannot engage their services, even if it may cause
Gartner to lose the bid. Paying fees to intermediaries to improperly obtainbusiness is a bribe in violation of Gartner Policy and applicable laws. You mustalso immediately contact Ethics & Compliance and disclose this conversation.
You did the right thing; it is still important to share the situation.
8. If a client requests that you use a specific supplier that you do not thinkis necessary to get the job done, should you retain the supplier?
A. You should ask questions to understand the business justification for usingthat supplier, and, if you are not convinced, do not use them. Also, if you
uncover that the supplier is somehow related to the client, that is a red flag thata bribe may be paid.
9. You are asked to approve an expense report submitted by a member of thesales team that includes a dinner with a client costing $1,500. The money isalready spent, is there anything I should do?
A. Before approving the expense report, investigate the details surrounding thedinner. Your goal is to ensure that it was not lavish and was reasonable. Lookat how many people attended; where did the dinner take place; was alcohol
served; what was the business purpose of the dinner? Your answer will also
depend on whether the clients were Government Officials because the rules
around what can be spent on Government Officials are stricter and would haverequired manager approval in advance.
10. I have received an invoice from a Gartner Representative and while
the amount is correct per the contract, the description reads “forservices rendered”. Is it ok if I approve this invoice for payment?
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without advance notice, subject to the requirements of local law, where applicable.

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A. Do not approve the invoice for payment without first requesting an invoice with
sufficient detail to identify the specific services provided. “Services rendered” istoo vague and could be hiding a bribe.
11. What is the practical difference between gifts, meals, and entertainment?
A. Meals and entertainment require the presence of a host. For example, if a
Gartner Associate invited clients to a baseball game, the Gartner Associatemust be present. If a Gartner Associate is not present, then the tickets to thebaseball game are considered a gift and must meet all the requirements forgifts.

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Gartner reserves the right to add, modify or delete any provisions of this policy
without advance notice, subject to the requirements of local law, where applicable.

© 2023 Gartner, Inc. and/or its affiliates. All rights reserved. Gartner is a registeredtrademark of Gartner, Inc. or its affiliates.