Code of
Conduct© 2023 Gartner, Inc. and/or its affiliates. All rights reserved. 1904360

Code of Conduct

Message from our CEO
Dear Colleagues:
At Gartner, we guide the leaders who shape theworld. We deliver actionable, objective insightthat drives smarter decisions and stronger
performance against a backdrop of rapid,
technology-driven change. Our insights, guidance
and tools often mean the difference between
success and failure for our clients. This uniqueposition makes us a force for good in the world.

The Gartner Code of Conduct is our guide forsetting expectations about how associates should
conduct themselves in the communities weserve — both outside and inside the company.
Our leaders across the organization embrace
the Code because it protects and advances ourbrand and sets our people up for the greatest
possible success.

As we grow, our global impact continues toexpand. As part of our duty to our clients, ourassociates and our great company, we have animperative to consistently uphold the highest
levels of integrity in everything we do.

Each year, we ask every associate to affirm they
have read, understand and comply with the Gartner
Code of Conduct. If you have questions, please ask
your manager or your HR partner for guidance.

Integrity is a commitment to the highest ethicalstandards. It’s about how we operate on a
global scale — consistently, authentically andtruthfully. And it’s a behavior-based virtue that we
continuously reinforce as we grow.

the channels outlined in this Code. Thank you foryour continued commitment to Gartner and ourworld-class work environment.
Sincerely,

Gene Hall
Chief Executive Officer

We are steadfast in honoring our no-retaliation
policy for those who raise good-faith concerns.
If you see inappropriate behavior, questionablebusiness practices, possible misconduct or othersituations that you believe violate the Code or any
other Gartner policy, please report them through2

Code of Conduct

Our purpose
We guide the leaders who
shape the world.

Our mission
We deliver actionable,
objective insight that drives
smarter decisions andstronger performance onan organization’s missioncritical priorities.

Code of Conduct

Contents
Our Culture

Our Integrity

We have a purposefulcultureSpeak up: Your voice
matters
Speak-up reporting
channelsManagers: Listen and act
Making ethical decisions
Investigations

Our Respect for
One Another

Our ComplianceWith the Law

Our Protectionof Assets

Our Community
ImpactDiscrimination andharassment: Zero
tolerance

Anti-bribery: Conducting
business appropriately

Conflicts of interest

Giving and volunteering

Financial responsibility
and internal controls

Environmental
sustainability

Fair compensation andequal employment
Embracing diversity,
equity and inclusion

Gifts and entertainment:
Avoiding even theperception of impropriety
Avoiding financial crime

Safety and security

Antitrust: Promoting faircompetition

Drugs and alcohol

Fair dealing

Protection of humanrights

Insider trading
Data privacy
Industrial security

Protecting our businessand reputation byfollowing our internal
controls
Information andcybersecurity
Protecting confidential
information
Protecting Gartner
content
Respecting IP rights
Communicating clearlyand professionally
Social media
Independence andobjectivity
Holding highexpectations for our
suppliers

4Our Culture

Our Integrity

Our Respect for One Another

Our Compliance With the Law

Our Protection of Assets

Our Community Impact

Code of Conduct

Our Culture
We have a purposeful culture5Our Culture

Our Integrity

Our Respect for One Another

Our Compliance With the Law

Our Protection of Assets

Our Community Impact

Code of Conduct

We have a purposeful culture

We impactclients’ missioncritical priorities

We do theright thingsand great
results follow

We embodya no-limits
mindsetWe uphold thehighest ethicalstandards

We makeobjective,
fact-based
decisions

We prioritize
relentlessly

We get better,
faster, stronger
every year

We win asa team

We embrace
diversity, areinclusive andrespectful

We are humble
and hungry

6Our Culture

Our Integrity

Our Respect for One Another

Our Compliance With the Law

Our Protection of Assets

Our Community Impact

Code of Conduct

Our Integrity
Speak up: Your voice matters
Speak-up reporting channels
Managers: Listen and act
Making ethical decisions
Investigations

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Our Culture

Our Integrity

Our Respect for One Another

Our Compliance With the Law

Our Protection of Assets

Our Community Impact

Code of Conduct

Speak up: Your voice matters
Part of participating in a culture of integrity is being willing to speak up whensomething doesn’t seem right. If you are concerned that the law, this Code or
our policies have been violated or are about to be violated, it’s important thatyou speak up. Even if you only have a question about a policy, a process or asituation that “just didn’t feel right,” it is always better to ask the question.

We do not tolerate retaliation
Gartner does not tolerate retaliation of any kind against anyone who reports
a concern in good faith, participates honestly in an investigation or who
helps to investigate or resolve the issue brought forward. Any associate who
engages in retaliatory behavior will be subject to disciplinary action, up to andincluding termination of employment. It is a violation of this Code to makefalse accusations, lie to investigators or interfere with any investigation.
To learn more about speaking up, visit the Speak Up Resource Center.

Speak upThroughout this Code you will see this speak-up
call-out that will direct you to our reporting channels.

8Our Culture

Our Integrity

Our Respect for One Another

Our Compliance With the Law

Our Protection of Assets

Our Community Impact

Code of Conduct

Speak-up reporting channels
These are the reporting channels to use to raise an issue or concern, or ask a question. Feel free to choose the channel with which you are most comfortable:

Your manager

Someone outside your team

The Gartner Ethics Helpline

You can start by talking to yourmanager. Managers are often able toanswer questions or direct you to the rightresource. For some concerns, managers
must escalate to the appropriate reporting
channel (their management, HR, Legal &Compliance, or Ombuds, depending on
the issue).

You can always talk to any other manager
in your business unit, your (or any other)
HR partner, Legal & Compliance, orOmbuds if the concern relates to Gartner’s
independence and objectivity.

Our third-party helpline allows for locallanguage, anonymous reporting (ifdesired and legal in your location), 24
hours a day, 7 days a week. If you don't
feel comfortable speaking to the otherreporting channels, you can contact the
Gartner Ethics Helpline — you will finda link to toll-free numbers and a way toreport online.

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Our Integrity

Our Respect for One Another

Our Compliance With the Law

Our Protection of Assets

Our Community Impact

Code of Conduct

Managers: Listen and act
As leaders, we must create a workplace where associates feel comfortablecoming forward with questions and concerns, and we must support
associates who speak up. We never retaliate against associates for raisingconcerns in good faith. If someone comes to you with a concern, you havea special responsibility to listen and act. Handling concerns appropriately is
critical to preserving trust and protecting Gartner.
As a manager, when you receive a concern that warrants escalation, youmust immediately bring it to one of the reporting channels. Do not startinvestigating yourself. If you have a question, contact your HR partner orLegal & Compliance.
Remember that by speaking up, the associate is doing something difficultand important. Respond respectfully. Thank them for speaking up, even if
you disagree. Show that you’re focused on resolving the issue. We must
maintain confidentiality to the extent possible, so do not discuss theconversation with anyone other than to contact a reporting channel.

Lead by example
If your role involves leading or managing people, we expect you to:• Talk about the Code and our values. Read the Code and makeethics conversations a regular part of your interactions.
• Reward integrity. Recognize and reward associates for doing
the right thing.
• Be accountable for training. Ensure your team completes
required training on time, every time.
• Know what you don’t know. Know where to go for answers when
you or your associates have questions that you can’t resolve.

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Our Integrity

Our Respect for One Another

Our Compliance With the Law

Our Protection of Assets

Our Community Impact

Code of Conduct

Making ethical decisions
Commit to the highest ethical standards. When a questionable situation arises, use the following tool to help you determine the best course of action:

Gartner Ethical Decision Tool
When you face an ethical dilemma, ask yourself:

Does theaction I’m
considering
feel right?

Yes

Is it in line with
our Code of
Conduct, ourvalues and ourpolicies?

If you answered “yes” to all of thesequestions, then the decision to move
forward is probably OK.

Does it serve
the interestsof our clients,
co-workers,
company andcommunity?

Not sure

Am I willing
to be held
accountable
for this action?

Ask your manager or another internal
resource for guidance.

Would I feel
comfortable if
this were madepublic?

How do you
respond?

No

Stop. Don’t do it. The action could haveserious consequences. Seek help.

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Our Culture

Our Integrity

Our Respect for One Another

Our Compliance With the Law

Our Protection of Assets

Our Community Impact

Code of Conduct

Investigations
Gartner has a defined process for handling concerns to ensure the following
outcomes:• The correct resources are assigned so that all concerns are investigatedobjectively and resolved appropriately.
• Anyone raising a concern in good faith or participating honestly in an
investigation is protected from retaliation.
• Reporters may report anonymously, where permitted by law, without fearof retaliation.

If you have reported anonymously through the Gartner Ethics Helpline, theappropriate associate will contact you by posting a response with the helpline.
You may reply to the post while still maintaining anonymity, if you choose.
If you have self-identified and reported through the helpline or reported
directly to one of our reporting channels, then the appropriate associate willcontact you to obtain additional information.
Gartner will endeavor to keep a reporter’s identity confidential to thegreatest extent possible while conducting a thorough investigation.
Please know that any person accused of wrongdoing will be treated fairly
and objectively.

Speak up

For guidance on how to speak up, visit
the reporting channels.

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Our Integrity

Our Respect for One Another

Our Compliance With the Law

Our Protection of Assets

Our Community Impact

Code of Conduct

Our Respect for
One AnotherDiscrimination and harassment:
Zero tolerance
Fair compensation and equal employment
Embracing diversity, equity and inclusion
Safety and security
Drugs and alcohol
Protection of human rights

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Our Culture

Our Integrity

Our Respect for One Another

Our Compliance With the Law

Discrimination and harassment:
Zero tolerance
Gartner strives to maintain a workplace based on decency, dignity andmutual respect. We prohibit discrimination, harassment and behavior thatcreates a hostile, offensive or threatening work environment, based on race,color, creed, religion, sex, sexual orientation, gender identity, marital status,
citizenship status, age, national origin, ancestry, disability, veteran status,
pregnancy or any other legally protected status.
This prohibition applies to all associates across all business units locatedaround the world. Speak up and remember that Gartner does not tolerate
retaliation for raising a concern in good faith or participating honestly in an
investigation.
Read and follow the Discrimination and Harassment Free Workplace Policy
as well as your local policy available in the Discrimination & Harassment Free
Workplace Resource Center. If you have additional questions, please contact
your HR partner.

Our Protection of Assets

Our Community Impact

Code of Conduct

Fair compensation and equal employment
Gartner adheres to a pay-for-performance compensation model; our goal is
to deliver equal pay for associates in equivalent roles, with similar experienceand responsibility, delivering similar levels of performance.
Gartner also remains committed to following applicable wage and hour laws in
the countries in which we operate.
Read and follow our policies, procedures and guidelines:• Equal Employment Opportunity Policy• Reasonable Accommodations Policy• Health and Safety Policy• Guidelines Regarding Gender Transition
If you have additional questions, please contact your HR partner.

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Our Culture

Our Integrity

Our Respect for One Another

Our Compliance With the Law

Our Protection of Assets

Our Community Impact

Code of Conduct

Embracing diversity, equity and inclusion
We are an inclusive organization that values people with diverse backgrounds
and experiences.
“Together as One” is our mission to ensure everyone feels included, respected
and valued. Embracing these ideals as part of our culture enables us to attract
and retain the best talent, and to inspire a high-performance organization thatgets better, faster and stronger every year.
To articulate our vision, we created shared definitions of diversity, equity
and inclusion:
Diversity — a collective mixture of differences and similarities
Equity — fair treatment and equality of access to opportunity, information andresources for all
Inclusion — the achievement of a work environment where all people feel
respected, accepted, supported and valued
As a Gartner associate, you have a role to play in fostering diversity, equity
and inclusion:

Our employee resource groups (ERGs) are voluntary, associate-led and open
to all. They support the associate experience by providing opportunities
to connect our communities and celebrate our history, heritage and key
moments that matter.

“We are a multicultural, global business, serving clients inmore than 100 countries around the world. Our teams arecomposed of individuals from different geographies, cultures,
ethnicities, religions, races, genders, sexual orientations,abilities and generations. We are united in our mission, andwe work together to solve problems. In doing so, we operate
at the highest ethical standards, with respect for all, across
our associates, clients and communities.”
Gene Hall, CEO• Listen with respect, patience and empathy, creating an environment
conducive to dialogue.
• Ask questions and remain open to different perspectives.
• Seek to expand your awareness and learn about one another in a safe space.
• Celebrate the unique contributions of others.
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Our Culture

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Safety and security
Gartner is committed to supporting associate safety and security, protecting
the integrity of Gartner’s brand and safeguarding Gartner assets. We
always aim to maintain or improve safety and security through appropriate
risk management principles and by implementing best practices andtechnologies. Safety and security are everyone’s responsibility.

Read and follow the policies below to keep Gartner safe and secure:

At Gartner, we:• Weapons and Prohibited Items Policy• Create a work environment that helps to safeguard associate health andwell-being• “What to Do If”: Emergency Response Guide• Work to provide a safe and secure workplace, with zero tolerance forviolence or harassment• Global Safety & Security• Physical Security Policy• Prohibiting Workplace Violence Policy

If you have additional questions, contact Global Safety & Security.

• Share information on global risks and how to respond to emergencies
Associate responsibilities
Everyone at Gartner, regardless of location, position or role, must adhere toand promote a culture of safety and security. This includes, but is not limited
to, attendance at a Gartner event, using a Gartner office, or traveling on
Gartner business.

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Our Compliance With the Law

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Drugs and alcohol

Protection of human rights

We do not tolerate the use, sale or purchase of any illegal substances while
participating in business-related activities, including those held after hours
or off-site. There is zero tolerance for the use of any illegal substances duringbusiness events.

Gartner is committed to human rights in the workplace. Each associate hasa responsibility to uphold this commitment, which includes respecting the
dignity and worth of all employees.

• Associates may not be impaired due to use of alcohol or other substances
while on Gartner premises or conducting business-related activities offpremises or at any Gartner-sponsored or business-related function.

Read and follow the Human Rights Policy and our Modern Slavery Statement.
If you have additional questions, contact Legal & Compliance.

• While associates of legal age may consume alcohol in moderation atcompany-sponsored events, do not pressure or encourage others to
consume alcohol.
• If you have a concern about an associate’s safety or well-being, contact yourmanager or HR partner.
Read and follow the Drug, Alcohol and Tobacco Policy. If you have additionalquestions, please contact your HR partner.

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Our Culture

Our Integrity

Our Respect for One Another

Our Compliance With the Law

Our Protection of Assets

Our Community Impact

Code of Conduct

Our ComplianceWith the Law
Anti-bribery: Conducting
business appropriately
Gifts and entertainment: Avoiding
even the perception of impropriety
Avoiding financial crime
Antitrust: Promoting fair competition
Fair dealing
Insider trading
Data privacy
Industrial security

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Our Culture

Our Integrity

Our Respect for One Another

Our Compliance With the Law

Our Protection of Assets

Our Community Impact

Anti-bribery: Conducting business appropriately

Key definitions

Gartner strictly prohibits corruption in all forms, in all our business dealings,
in every country where we do business. You must not pay bribes to, or accept
bribes from, anyone, anywhere, at any time, for any reason. There are antibribery laws that apply to you wherever you are located.

Anything of value

Specifically, Gartner does not offer, promise or give anything of value toanyone, including a government official, to improperly obtain new business,to retain existing business, to secure an improper advantage or to influence
any act or decision of a person or entity. Gartner does not make facilitation
payments, which are payments made to a government official to speed
up routine government actions, for example, processing visas, supplying
utilities, delivering mail. For the definition of government officials see theAnti-Bribery Policy.

Code of Conduct

Anything of value includes cash or cash equivalents; a
job or internship; a reference, referral or endorsement;a loan, favorable contract terms or promises of futurebusiness; gifts, meals, entertainment, hospitality or
travel; charitable or political contributions; tickets toevents or parties; or anything else of value, including
anything that is valuable to the recipient, even if itwould not be valuable to anyone else.
Red flags• Commission substantially above going rate

Gartner uses third parties, such as suppliers and those who act on Gartner’s
behalf (e.g., contractors and agents), to help Gartner deliver its products andservices in the marketplace. You must only deal with legitimate third parties
with a reputation for integrity. Gartner can be liable for the actions of its
third parties, and we never let a third party do what we cannot do ourselves.
Gartner conducts due diligence on our third parties, and we never ignore“red flags” that indicate a third party may be making improper payments orengaging in corrupt behavior on Gartner’s behalf (for red flags see the AntiBribery Policy).

• Vaguely described services or plan for performing thework is vague and/or suggests a reliance on contacts
or relationships

Read and follow the Anti-Bribery Policy. If you have additional questions view
the Anti-Financial Crime Resource Center and contact Ethics & Compliance.

• Incomplete or inaccurate information on required
disclosures, e.g., refusal to disclose ownership• Requests for payment to a numbered account, third
party or consultant• Proposes the use of a shell company• Requests or demands to use a specific third party• Lack of qualifications or resources to perform real work

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Our Culture

Our Integrity

Our Respect for One Another

Our Compliance With the Law

Gifts and entertainment: Avoiding even theperception of impropriety
Gifts, meals and entertainment are normal aspects of business so long as
they are reasonable, not lavish, not frequent and serve a business purpose as
defined in the Gift Policy and Global Travel and Expense Policy.
• See the policies for monetary thresholds. Local laws may be stricter or morecomprehensive, so pay attention to the country-specific rules in each policy.
• Know whether the intended recipient or invitee is a government official
before making a purchase or issuing an invitation, as the rules forgovernment officials are stricter than nongovernment officials and can varyfrom country to country.
• Do not give gifts or host a client, prospect or supplier during contract
negotiations or sourcing events. The appearance of impropriety can damage
our reputation.
• Do not give or receive cash or cash equivalents as gifts to or from third
parties (e.g., gift cards, loans, stocks or other securities).

Our Protection of Assets

Our Community Impact

Code of Conduct

True or False
It is OK to give, or authorize another party togive, a payment to a government official to win
a new deal as long as you know and trust the
government official.

False

Be careful when dealing with government
officials, including employees of state-owned
enterprises. Payments of anything of value toanyone, including government officials, for the
improper purpose of obtaining or retaining
business, is a bribe. Gartner conducts due
diligence on transactions involving government
officials, and it is not sufficient that you “knowand trust” the individual. For assistance with
anti-bribery due diligence, please contact
Ethics & Compliance.
Improper payments can expose both you andGartner to criminal liability.

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Our Compliance With the Law

Our Protection of Assets

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Code of Conduct

Question
Act legally and ethically
Conduct business appropriately
Read and follow the Anti-Bribery Policy, Gift Policy and Global Traveland Expense Policy. Contact Ethics & Compliance to report any red
flags you encounter in your business dealings, or if you have additionalquestions about anti-bribery or gifts or entertainment.

You’re an account executive who’s been
discussing an Executive Programs renewal witha license holder, the CIO of a company that ispartially state-owned. The CIO has asked if you
would be willing to hire their child as an intern
for the summer in one of our offices. The license
holder implied that offering the child the position
might help Gartner secure the renewal. Is it OK
for you to ensure the CIO’s child gets a position?

Speak up

For guidance on how to speak up, visit
the reporting channels.

AnswerNo. Offering the CIO’s child a job or internshipin exchange for a business advantage could beconsidered bribery. It would also violate Gartner
policies, which make clear that we hire solely on
the basis of merit, and candidates interviewing
for a position must go through the normal hiring
process. Conduct involving bribery is harmful
to our reputation. If you learn of an offer similar
to this one, please report it using one of thereporting channels.

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Our Protection of Assets

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Code of Conduct

Avoiding financial crime
Trade sanctions
Trade sanctions are legal, financial restrictions imposed by governments
or international bodies to isolate or exclude an individual, entity or country
from the global economy due to legal or public policy considerations. Trade
sanctions prohibit Gartner from doing business in certain geographies,
including Cuba, Iran, North Korea, the Crimea Region and Syria.
Know your clients and your suppliers. Having a better understanding of theindividuals and entities with which we do business will not only help build
better business relationships and further your prospects, it will also help
ensure we do not violate trade sanctions or export control laws. Onboard
all third parties using the appropriate Gartner system so that the properdue diligence and sanctions screening is conducted, and do not agree toparticipate in any boycotts.
Read and follow the Trade Sanctions Policy. If you have additional questions, view
the Anti-Financial Crime Resource Center or contact Ethics & Compliance.

Money laundering
Money laundering is the process of concealing illicit funds by moving themthrough legitimate businesses to hide their criminal origin. Money laundering
can be difficult to detect; it would have a devastating effect on our reputation.
Best practices
Always look for the following warning signs of potential money laundering:• Attempts to make payments in cash or from an unusual source• Arrangements that involve the transfer of funds to or from countries orentities not related to the transaction or client• Unusually complex deals that don’t reflect a real business purpose• Attempts to evade tax or record-keeping and reporting requirements• Deals with third parties that have not been vetted
Read and follow the Anti-Money Laundering Policy. If you have additionalquestions, view the Anti-Financial Crime Resource Center or contact Ethics& Compliance.

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Antitrust: Promoting fair competition

Fair dealing

Antitrust and competition laws prohibit agreements and business practices
that restrain or monopolize trade. We must be vigilant when participating intrade industry associations or communicating with third parties, including
clients, suppliers and competitors, to avoid the perception of limiting
or restricting competition. We do this by never discussing or facilitating
discussions about confidential information, including pricing, strategic
business plans, or terms and conditions of sales.

Doing what is right and acting ethically is at the core of our culture. Our
associates, clients, suppliers and other stakeholders know they can trust
Gartner to be fair and honest. Each associate should deal fairly with theircolleagues and all of Gartner’s stakeholders, including our competitors. We
do not take unfair advantage through manipulation, concealment, abuse of
proprietary or confidential information, misrepresentation of material facts or
any intentional unfair dealing or practice.

• Do not discuss confidential business information with our competitors.
• Do not facilitate the sharing of confidential business information among ourclients or prospects.
• Do not agree to divide markets, customers or territories; do not agree toboycott customers, suppliers or other competitors.
• Never share confidential, nonpublic information, nor do we seek it throughdeception, theft or unlawful or unethical means.
• Never use your prior employer’s confidential or sensitive businessinformation or seek such information from anyone we hire.
Facilitating peer interactions is a great value-add for Gartner clients — atconferences, through Gartner Peer Connect and in other forums. When webring together competitors, including our clients, we need to ensure we —and they — adhere to our Antitrust Policy.
Read and follow the Antitrust Policy. If you have additional questions, view the
Antitrust Resource Center or contact Ethics & Compliance.
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Insider trading
We treat our investors with fairness and transparency, maintaining a highstandard of integrity. Using inside information to gain an unfair advantage over
our investors would not only breach the trust they place in us but would also
violate insider trading laws.

What does “material, nonpublic information” look like?

Key rules• Financial results and projections• You may not trade securities (including stocks, bonds, options) based onmaterial, nonpublic information about Gartner or any other publicly traded
company (including information about our clients or companies that wecover, companies whose stock may be affected by our actions or those thatare our competitors). This would constitute illegal insider trading.

• Lawsuits• You may not disclose material, nonpublic information to other people sothat they can improperly trade those securities. This would be consideredtipping, and it is also illegal.

Information is “material” if a reasonable investor would consider it important indeciding whether to buy, sell or hold a company’s securities. Some examples
include:• Mergers, acquisitions or divestitures• New securities offerings• Major changes in senior management• Significant new product announcements• Cybersecurity risks and incidents, including vulnerabilities and breaches
Insider trading and tipping can result in substantial civil and criminal penalties,
which could mean fines or even jail.
Read and follow the Insider Trading Policy and Regulation Fair Disclosure
Policy. If you have additional questions, contact Legal & Compliance.

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Data privacy
Protecting personal data

Earning and maintaining clients’ trust

Gartner’s business depends on our ability to collect, use and handle many
types of data, including personal data about individuals at client organizations.
Clients, associates and other third parties provide their personal data to
Gartner because they trust us to use, handle and protect that data properly.
If we lose that trust, our reputation and our business could be at risk.

Our data security and privacy (together, “data protection”) efforts mean:

Key take-aways
When dealing with personal data, always ask yourself:• Should I have access to this data?
• Am I allowed to use it for this purpose?
• Do I have consent to contact this individual or disclose their data?
If the answers are unclear, contact the Data Protection Team.

• We respect individuals’ choices about the collection/use of theirpersonal data.
• We only use personal data for appropriate business purposes.
• We implement appropriate administrative, technical and physicalsecurity controls.
• We comply with applicable data protection laws.
• We report all suspected data breaches or improper data use to the
Data Protection Team.
Read and follow the Privacy Policy. If you have additional questions,visit the Privacy & Data Protection Resource Center or contact the Data
Protection Team.

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Industrial security
Gartner has certain clearances that allow certain Gartner entities andassociates access to classified and controlled unclassified information (CUI).
We ensure that such information is managed according to relevant laws.
Because we are entrusted with classified information and CUI from ourclients, mishandling such information can damage Gartner’s reputation, put
a strain on client relations and result in penalties, fines and even debarment
from doing our work. Classified information can only be accessed pursuant
to our agreements.
To avoid these consequences and protect information we:• Handle, store, disseminate and dispose of classified information and CUI in
accordance with applicable requirements and laws
• Comply with and seek to exceed client and national security policy
requirements• Ensure recipients have the proper security clearance and need-to-know prior
to disclosing information
Report all unauthorized disclosures of classified information and CUI.
If you have additional questions, visit the Industrial Security Resource Center.

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Our Protectionof Assets
Conflicts of interest
Financial responsibility and internal controls
Protecting our business and reputation byfollowing our internal controls
Information and cybersecurity
Protecting confidential information
Protecting Gartner content
Respecting IP rights
Communicating clearly and professionally
Social media
Independence and objectivity
Holding high expectations for our suppliers27

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Conflicts of interest
A conflict of interest occurs when your personal interests — family,
friendships, financials — compromise your judgment, decisions or actions atwork. Actual conflicts of interests are prohibited. For example, you cannot takefor yourself any business opportunity meant for Gartner or steer business toan immediate family member or an entity in which the associate has a financial
interest. A potential conflict of interest exists when it appears that yourinterests could conflict with Gartner’s interests, but disclosing that potential
conflict and seeking approval addresses the situation.
Conflicts of interest must be disclosed promptly for review. Having a conflictof interest is not necessarily a violation of the Code, but failing to disclose it is.
Below are examples of potential conflicts of interest:• Taking on outside employment or advisory work
• Becoming a member of a board of directors or advisory board• Managing or hiring a relative or someone with whom you have a close
personal relationshipKey definitions
Immediate family member
An immediate family member is an associate’s
spouse, domestic life partner or equivalent,
dependent children or dependent parents. A
separated spouse, separated domestic life partner
or equivalent will be considered part of theassociate’s immediate family if the associate files
a joint tax return with the separated spouse.
Relative
A relative is a spouse or domestic life partner,
parent, child, sibling, grandparent, grandchild,in-law, nephew, niece, cousin, aunt or uncle.

• Having an intimate relationship at work
• Holding financial interests in companies or businesses that are competitorsof, suppliers to or evaluated by Gartner (depending on your role at Gartner)
Read and follow the Conflicts of Interest Policy, and disclose conflicts via theDisclosure and Approval Process. If you have additional questions, contact
Ethics & Compliance.
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Financial responsibility and internal controls
We keep complete and accurate financial books and records that properlyreflect the substance of transactions and comply with generally accepted
accounting principles, Gartner accounting policies and internal control
requirements. As a publicly traded company, Gartner complies with allapplicable financial reporting and disclosure rules and regulations.
We cooperate with internal and external auditors and investigations.

Before signing a document or authorizing a transaction, ensure you have theauthority to do so. Before approving a transaction, consider the businessrationale and verify the facts and circumstances.

The failure to comply with applicable laws and policies, falsifying,
misrepresenting, omitting or concealing any facts or information in
our business records, encouraging others to do so, or facilitating or
participating in the financial misconduct of any third party with whom
we do business will result in disciplinary action up to and including
termination of employment. It may also result in criminal penalties forindividuals and Gartner.

Read and follow the Gartner Authority Matrix Policy. If you have additionalquestions, contact Legal & Compliance.

If you become aware of or suspect any fraud, misrepresentation, reporting
inaccuracy, or violation of accounting or internal control requirements, speak
up and report it using one of the reporting channels.

Speak up

For guidance on how to speak up,
visit the reporting channels.

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Protecting our business and reputation
by following our internal controls• For instructions on proper expensing, please visit the Travel and Expense
Resource Center.
• Associates must follow the Global Procurement Policy when establishing
new relationships with suppliers and engaging in ongoing activities withexisting suppliers.
• Use Gartner-approved contracts templates and adhere to our contracts,
including confidentiality obligations, reporting requirements and othercontract terms.
• Follow proper contracting procedures in all agreements you make onbehalf of Gartner. This means no side letters or “off the book” agreementsthat commit Gartner to an obligation outside of company policy or explicit
client entitlements.
• Retain and dispose of records in accordance with Gartner’s Global Record
Retention Policy and Storage Policy and related schedules.
• Comply with legal holds. If you are notified that you are subject to a legal
hold (a request to retain materials related to an investigation or lawsuit), do
not alter or destroy any documents until the hold has been lifted.
• Conduct Gartner business only using your Gartner-approved systems andcommunication channels.

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Information and cybersecurity
We protect against, detect and respond to information security threats toGartner’s assets, networks and data. We continuously monitor for threats,
inappropriate disclosures and unauthorized access. We follow all Information
Security policies and procedures and have access controls in place to ensure
only those with legitimate business reasons have access to information.
Follow these security measures• Use unique, strong passwords and protect those passwords (e.g., not sharing
passwords with others or other systems, using a password manager).
• Use only Gartner-approved systems, tools, hardware, software, extensions,plug-ins, drivers and applications.

Never use Gartner’s information technology assets to post, upload,
download, store, transmit or distribute any threatening, false, slanderous
or obscene acts or materials (e.g., pornography). Personal use of Gartner’sequipment is limited and cannot interfere with work usage. Further, you areprohibited from engaging in fraud, theft, embezzlement or misappropriationof company property.
Read and follow the policies on the Information Security Policies Center.
If you have additional questions, contact Information Security or the Gartner
Help Desk.

• Be diligent when looking for signs of phishing or malicious intent, and reportsuspicious emails and IT incidents.
• Protect your Gartner email address using it only for legitimate businesspurposes and using a personal email address for nonwork-related activities.
Gartner conducts due diligence on suppliers who will have access to oursystems to ensure appropriate controls. We do not grant third parties accessto our systems without consent and signoff by Information Security.

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Protecting confidential information
Clients entrust us with their confidential information because we use it tohelp them make better decisions every day. With this information comes
tremendous responsibility. We must protect against inadvertent disclosure
outside of Gartner and use the information only for the purpose of helping
our clients.
Inappropriate sharing of this information would jeopardize the very foundationof our business. Even when discussing this information internally, we share it
only with those who have a need to know and only in the pursuit of helping
clients. Further, when you leave Gartner, you may not take any confidential
information with you, nor may you share any of this information with yournew employer.
We protect Gartner-confidential information, such as research methodologies,
research work in progress, unpublished financial data, product and strategy
roadmaps, know-how, trade secrets and employee information. We also
protect entities that do business with Gartner, including clients, suppliers andsupplier price lists.

Question
You are an account executive and want to impress
your prospect by sharing a few names of clientsin the prospect’s same industry. Is this allowed?

AnswerNo. You may not share the fact that a company
is a client unless that client has agreed to be areference. Our clients highly value that levelof confidentiality.

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As with personal data, when dealing with confidential information, always
ask yourself:• Should I have access to this confidential information?
• Am I allowed to use it for this purpose?
If sharing it with a colleague, does the recipient have a “need to know”? Am I
permitted to disclose it to them?
Read and follow the Information Classification Policy. If you have additionalquestions, contact Legal & Compliance.

When discussing either client-confidential or
Gartner-confidential information, be hyperawareof your environment, especially when you are in
public or open places, online or participating on
the web (e.g., via social media posts).

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Protecting Gartner content

Communicating clearly and professionally

To protect Gartner’s objectivity and proprietary research, we have strict
standards that must be followed for how others are granted permission to use
our Gartner name and intellectual property (IP) outside Gartner. Never agree
that a client or third party can own Gartner IP.

We speak with one voice and communicate accurately, consistently and incompliance with regulatory and legal obligations. Only authorized Gartner
representatives are permitted to speak on behalf of Gartner, including to
the media, on social media or at events, conferences or tradeshows.

Read and follow the Content Compliance Policy. If you have additionalquestions, contact Legal & Compliance.

Media inquiries: We direct all media inquiries to the Gartner Media
Relations Team.

Respecting IP rights

Investor relations: We direct any outreach from the financial community
to the Investor Relations Team.

Regarding the use of third party IP that Gartner does not own (such as
photographs or screenshots, music, cartoons and video clips, or datacompilations), it is important to know that this content is generally protectedby IP law and may only be used with permission from the owner.

Government regulator, law enforcement or external law firm: We respond
appropriately to and cooperate with regulators and law enforcement. We
direct any outreach from a government entity (outside of service fulfillment),a regulator, an external lawyer or law enforcement to Legal & Compliance.

For example, if you think a photo of a rock star will really help make your point
in a conference presentation, you need permission from the owner of thephoto before you may present it. You may need permission from the rock star,
too. Do not fall prey to the common misconception that materials you find on
the internet are free to use.
Visit the Intellectual Property Resource Center. If you have additionalquestions, contact IP Legal.

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Social media

Independence and objectivity

Social media is part of all our lives. It gives us opportunities to build our
personal brands and the Gartner brand. But, we should be keenly aware thatevery action we take on social media can be visible to the public eye, so
we must choose our words carefully, make sure our point of view is sound,
understand that our comments may be read out of context and never say
anything that would portray Gartner in a negative light.

Our clients make critical business decisions based on Gartner insights,
data, tools and interactions. They trust that we are independent of outside
influence. They count on our expert evaluations and applied methodologies
to be objective. Independence and objectivity are synonymous with the
Gartner brand. All associates, in every part of the business, are responsible
for protecting this most valuable brand asset.

Anything you write — even if you delete it — could later be used as evidence
to challenge you and Gartner in a legal and reputational way.

Read and follow Gartner’s Guiding Principles on Independence andObjectivity. If you have additional questions, contact Ombuds.

When you adopt your “professional persona” on social media, approach
subjects in a thoughtful and professional manner, as a representative ofGartner. Associates who create our intellectual capital, including experts,
consultants, executive partners and leadership partners, have a heightened
responsibility to represent Gartner’s approved research positions.
Read and follow the Social Media Policy. If you have additional questions,please contact the Social Media Team.

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Holding high expectations for our suppliers
Basic principles of our Supplier Code of Conduct

We view our suppliers as partners in delivering on our commitments, andjust as we hold ourselves to the highest standards of ethical conduct, we
expect the same from each of our suppliers. In fact, we pride ourselves on thestrong relationships we build with suppliers and our shared focus on ethics,
compliance with the law, fair practices, integrity, safety and quality.

• A commitment to a work environment that values diversity, respect andintegrity

To ensure consistency and mutual commitment, Gartner requires that our
suppliers (including their employees, representatives and subcontractors)
comply with the Gartner Supplier Code of Conduct.

• Execution of business in a responsible manner, with integrity and high ethicalstandards, and in compliance with all regulatory and legal requirements• Protection of Gartner’s confidential information and use of good privacy anddata security practices• Respect for international human rights principles• Acknowledgment of and compliance with the Gartner Supplier Code of
Conduct
Ensure any suppliers you hire are onboarded in accordance with Gartner’s
policies. If you hire suppliers, familiarize yourself with the Gartner Supplier
Code of Conduct. If you have additional questions, contact the Source toContract Team.

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Our Community
ImpactGiving and volunteering
Environmental sustainability

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Giving and volunteering
Our associates live and work in many countries and territories around theworld and are deeply embedded in their communities. We are proud of
the global impact associates have on their communities. Gartner strives tosupport each of you in making a positive change where you live, work andserve our clients. We celebrate this spirit of community and caring both within
and outside Gartner.

Understand the rules for charitable giving

Empowering associates• All charitable donations must be made as an individual associate expense.

The Gartner Gives program empowers associate giving by:

We continue to increase the number of nonprofit organizations eligible for the
Gartner Gives Charity Match.

• Matching associate contributions to nonprofit organizations up to $5,000
in a calendar year
• Supporting associate volunteerism• Do not make charitable donations as a quid pro quo in a Gartner business
context.
• Charitable donations may not be expensed on behalf of Gartner, unlessrequired by local law.

For more information about matching gifts and volunteer opportunities, visit
Gartner Gives. If you have additional questions, contact AskHR@gartner.com
or CSR@gartner.com.

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Environmental sustainability
We strive to minimize our environmental impact and embed sustainable
best practices into our operations. We view combating climate change andreducing greenhouse gas emissions as a necessary part of that broader
strategy. We embed sustainability into our business and work across business
units to implement our decarbonization approach. Our commitment is toachieve net-zero greenhouse gas emissions by 2035 in accordance with the
Science Based Targets initiative’s Net-Zero Standard.
We are committed to promoting sound environmental practices in our work,and associates play a critical role in this work.
See the Corporate Responsibility Report. If you have additional questions,contact sustainability@gartner.com.

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Enforcement and waivers
The Code of Conduct is important to us. Violationof the Code of Conduct may result in disciplinary
action, up to and including termination of
employment. Only the Board of Directors may waive
a provision of the Code of Conduct for a director or
executive officer. Any waiver that is granted will be
publicly disclosed as required by listing requirements
and applicable laws, rules and regulations.

General questions
If you have general questions about the Codeof Conduct, feel free to reach out to one of thereporting channels.

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