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Conflicts of Interest Policy
Geographic Coverage Global
Policy Owner

SVP, General Counsel & Corporate Secretary

Last Reviewed

June 9, 2023

Policy Philosophy & Purpose
Business decisions must be made with integrity and not influenced by conflicts of interest. Asa company known for delivering actionable, objective insights to executives and theirteams, it is important that Gartner associates recognize that sometimes personal interests
may hinder their objectivity.
A Conflict of Interest occurs when an associate’s personal interests - family, friendships,
financial - compromise the associate’s judgment, decisions, or actions at work. Actual conflictsof interest are prohibited. A potential conflict of interest exists when it appears that anassociate’s interests conflict with Gartner’s interests, but disclosing that potential conflict,seeking approval, and complying with guardrails implemented to eliminate the conflict address
the situation.

Scope and Applicability
This policy applies to every Gartner associate. In certain cases, it may impact Gartner
associates’ Immediate Families and Relatives.* See the Definitions Section to learn how
Gartner defines these groups and other capitalized terms in this policy.

Policy Detail
Disclosure and Approval Process
All associates with a conflict of interest (either an actual or a potential conflict) must
disclose via the Disclosure and Approval Process. The disclosure will be reviewed byrelevant teams, including Gartner’s Ethics & Compliance team, and approval will beprovided based on this 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.

Common Conflicts of Interest
The following are examples of common conflicts of interest; it is not an exhaustive list.
Even if a particular situation is not expressly mentioned, it may be a conflict of interest andassociates should self-report via the Disclosure and Approval Process.

Financial Interests
A.
Competitors. Associates may not have a Financial Interest in an entity thatcompetes with Gartner.
B. Companies in Industries Evaluated by Gartner. The following associates are
subject to Financial Interest restrictions based on their roles.
Operating Committee
Members of Gartner’s Operating Committee (OC) may not have a Financial Interest
in any entity that is evaluated by Gartner or over which an OC member may exert
an influence by virtue of their role at Gartner.
Research & Advisory
Research & Advisory (R&A) associates who evaluate products or services or makeproduct or service recommendations, their Team Managers (TM), and members of
their Immediate Family, may not have a Financial Interest in any entity within theirresearch coverage area.
If such a R&A associate or TM’s Relative is employed by an entity in their researchcoverage area, the associate or TM must promptly notify their manager, disclose
this in the Disclosure and Approval Process, and also make the appropriate
disclosure as part of the Annual R&A Associate Attestation.
Consulting
Consulting associates who evaluate products or services as part of fulfillingengagements or supervise such engagements , and members of their Immediate
Families, may not have a Financial Interest in any company whose products orservices they evaluate in the engagements they participate in or supervise.
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If such a Consulting associate’s Relative is employed by an entity included, or anentity that may be included, in the evaluation, the consulting associate must
promptly notify their manager, disclose this in the Disclosure and Approval
Process, and also make the appropriate disclosure as part of the Annual
Consulting Attestation.
C. Suppliers. If an associate is in a position to influence supplier decisions (or can beperceived to influence supplier decisions), neither that associate nor members of thatassociate’s Immediate Family may have a Financial Interest in any entity that does orseeks to do business with Gartner and must promptly disclose this through theDisclosure and Approval Process. While associates in Procurement (and those whoPage 2
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.

supervise them) are the associates typically affected by this rule, it applies to any
associate that participates in purchasing decisions.
Further, unless previously agreed upon, it is important that all associates do not share,endorse, opine on, or become a testimonial for or otherwise disclose any of Gartner'ssuppliers. To do so could imply endorsement or disparagement, which could jeopardize
Gartner’s independence and objectivity.
Without prior approval, associates may not enter into agreements on behalf of Gartnerwith any outside entity if they know that the entity is a “related party” to a Gartner
associate (that is, the contract would financially benefit, either directly or indirectly, anassociate or their Relatives). For example, Procurement associates may not negotiate thepurchase of office equipment for Gartner when they know that an associate’s mother owns
this office-equipment provider.

Gifts and Entertainment
Giving and receiving Gifts, and exchanging other customary business courtesies andentertainment of nominal value with Gartner clients, providers, and organizations covered
in research are only allowed when they comply with Gartner’s Gift Policy and Global
Travel and Expense Policy (i.e., infrequent, not lavish, within monetary threshold) because
Gartner never makes, nor wants to give the perception that it makes, business decisions
based on the Gifts or entertainment associates may receive. Giving and receiving lavish orexcessive Gifts, as well as providing or accepting lavish or excessive Hospitality to or from
Gartner prospects, clients, suppliers, or other providers with whom Gartner conducts
business may violate global anti-bribery and anti-corruption laws and Gartner’s corporate
policies. (See the Anti-Bribery Policy.)

Outside Activities
Participation in activities outside of work must be done at the associates’ expense and on
their own time. Associates may not use Gartner’s products, influence, facilities, or otherresources for their personal benefit or the benefit of any outside entity, company ororganization. Other criteria may apply based on the associate’s role or Business Unit
(BU).
Authoring books or other publications (including open-source
contributions)
Associates may write books unrelated to their work at Gartner (for example,
writing a children’s book or a book on sewing) without approval. However,while employed at Gartner, associates may not independently publish
books, articles, or any other publications on topics evaluated by Gartner.
Open-source contributions are permissible, as long as they:
1. Have their own standalone source code repository.
2. Don’t reuse or rely on Gartner code.
3. Don’t facilitate illegal activities (for example, crypto mixers).
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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.

Non-profit Board of Directors / Advisory Board of Directors &Volunteer activities
Participating on non-profit boards and in non-profit volunteering activities do
not require approval, except for non-profit industry/Trade Associations,which associates must submit through the Disclosure and Approval
Process. Associates’ participation as officers, directors, advisors orcommittee chairperson/members of a non-profit organization are in theirindividual capacities, are not on behalf of Gartner, and any views expressed
are their own (associates are responsible for ensuring the non-profit boards
understand this).
Any outside employment or joining a For-profit Board of Directors or
Advisory Board of Directors
Associates seeking employment outside of Gartner, or those wishing toserve as officers, directors, advisors, partners, or owners with any for-profit
entity, must first have their manager’s written approval. Approval will not begiven if the organization:
1. Competes, directly or indirectly, with Gartner or any of its products orservices; for example, offers strategic, objective insight to executives
and their teams, or writes research for consumers to make informed
purchasing decisions;
2. Manufacturers, markets, or distributes products or services that
Gartner evaluates to help clients make decisions, or such coverageis planned soon;
3. Conflicts, or appears to conflict, with the interests of Gartner or
damages Gartner’s reputation; for example, the outside employment
involves the same skills or is closely related to the associate’s workat Gartner; or
4. Requires significant time during working hours.
Associates engaged in any outside employment may not:1. Use Gartner resources; or
2. Solicit associates, clients or prospects (i.e., no cross-pollination).
Associates must disclose these activities via the Disclosure and Approval Process.

Political Contributions
Associates are not authorized to make or approve any contributions or expenditures ofcompany funds or use company facilities, equipment, or supplies to support or oppose
political activity in any jurisdiction.
While associates may make personal political contributions, they should never beconnected to their work at Gartner and there should never be a quid pro quo or suggestionthat it was made to influence any business decisions. This can violate not only this 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.

but also may violate, or appear to violate, anti-corruption laws. (See the Anti-BriberyPolicy.)

Public OfficePrior to pursuing an elected or other appointed public office, associates must obtainwritten approval from their manager and submit a request through the Disclosure andApproval Process. Unless required by law, Gartner will not pay for time spent running for
public office, serving as an elected official, or campaigning for a political candidate.
Associates are responsible for making it clear that their positions are personal ones andare not made on behalf of Gartner.

Public Speaking
Some associates, including R&A associates, Consultants, Executive Partners, andLeadership Partners, create intellectual capital that is sold to Gartner clients. For thatreason, when they speak at public forums on topics evaluated by R&A, their opinions
should align with the respective published research. Associates in these roles should
submit a request to speak publicly through the Disclosure and Approval Process.
Associates in other roles may speak at public forums in a personal capacity and do notneed to seek approval; however, they are responsible for making it clear that any opinions
expressed are their personal views and do not represent the views of Gartner.

Reciprocal and Self Dealing
Associates may not condition Gartner’s decision to purchase a supplier’s goods orservices on that entity’s agreement to purchase Gartner’s goods or services. A Gartner
supplier may also be a Gartner client, but the decision of both Gartner and the supplier touse each other’s goods and services must be made independently.

Personal or Romantic Relationships
Personal or romantic relationships between associates in circumstances where one
individual has direct or indirect influence or control over the other's hiring, firing,promotions, performance management, compensation, or other conditions of employment
create actual conflicts of interest and are therefore prohibited.
Personal or romantic relationships between associates who are not in a direct or indirect
reporting relationship are generally permissible as long as they are consensual and do not
negatively affect Gartner’s business, the participants’ working relationship, or associate
dynamics. Gartner expects that associates in a romantic relationship will conduct
themselves in a businesslike manner at work and minimize the impact of the relationshipin the workplace.

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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.

Supervising or Hiring Relatives
Associates may have Relatives that work for Gartner. No associate may participate in theselection or hiring process of a Relative. The associate may not directly or indirectlysupervise a Relative or use their position to influence or attempt to influence any aspect ofa Relative’s employment at Gartner.

Speak UpIf you are concerned that the law or this policy has been or may be violated, it is importantthat you speak up. If you have a question, are confused, or a situation “just doesn't feelright,” it is always better to ask for help.
Speak Up Reporting Channels
These are the reporting channels to use to raise a question or concern:
1. Talk to your manager. You can start by talking to your manager. If
unable to provide an answer, it’s your manager’s job to help you find one orescalate a complaint.
2. Talk to someone outside your team. You can always talk with any othermanager in your business unit, your (or any other) Human Resources
partner, or Legal & Compliance.
3. Contact the Gartner Helpline. Our third-party helpline allows foranonymous reporting 24 hours a day, 7 days a week, in many different
languages. Contact the Gartner Ethics Helpline — you will find a link to tollfree numbers and a way to report online.
We do not tolerate retaliation
Gartner does not tolerate retaliation of any kind against anyone who reports a concern ingood faith. Any associate that engages in retaliatory behavior will be subject to disciplinary
action, up to and including termination of employment.

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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.

Definitions
Conflicts of Interest - A conflict of interest exists if you engage in any personal or businessrelated activity, including holding a Financial Interest, that (i) could actually or potentiallyinterfere with your responsibilities or judgment on behalf of the company or its clients, or (ii)conflicts, or appears to conflict in any way, with the interests, or damages the reputation, of thecompany.
Financial Interest is any ownership interest in publicly traded or private companies, or loans
from outside organizations (except personal loans, mortgage loans, and similar loans fromcommercial or savings banks). However, it does not include stocks in mutual funds orexchange traded funds (ETFs), or other forms of ownership as may be pre-approved in writing
by Gartner’s General Counsel or their designee on a case-by-case basis.
Gifts & Hospitality are things of value provided to a third party. A gift is something of value
provided where there is no host. Hospitality includes things of value like meals orentertainment where there is a host. If there is no host, then hospitality becomes a gift.
Immediate Family is an associate's spouse, domestic life partner or equivalent, dependent
children or dependent parents. A separated spouse, separated domestic life partner, orequivalent, will be considered part of the associate’s Immediate Family if the associate files ajoint tax return with the separated spouse.
Relative is a spouse or domestic life partner, parent, child, sibling, grandparent, grandchild, inlaw, nephew, niece, cousin, aunt or uncle.
Trade associations consist of businesses that operate in a specific industry.

Further Information
Related Policies
Anti-Bribery Policy
Code of Conduct
Gift Policy
Global Travel and Expense Policy
Personal Relationships at Work
Supplier Feedback Policy

Revision History
Published Date

Reason for Revision

09/06/2023

Updated text on open-source contributions

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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.

23/05/2023

Full policy review and update.

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.