CODE OF BUSINESS CONDUCTAugust 18, 2020
One Gigamon Culture
Gigamon’s products deliver unified network visibility and analytics on all information-in-transit, from raw
packets to apps, across physical, virtual and cloud infrastructure. As a team, we embrace a singular “OneGigamon” culture and in doing so we collaborate as colleagues along with partners and customers to best
serve our customers in a productive, team-oriented, ethical and responsible manner. As part of our culture
we put “Employees First” as we understand that a company’s success is built upon its greatest asset – ouremployees. By placing our employees first, they are motivated to deliver and outperform, which translates
into our customers receiving the best quality products and services we can deliver. It is foundational to our
One Gigamon culture that we act with integrity and treat others with respect.
Policy Overview
This Code of Business Conduct flows from our commitment to our One Gigamon culture. We work together
to serve our customers with integrity and the highest ethical standards. As such, we believe it is unacceptable
to bypass appropriate processes and behaviors by cutting legal or ethical corners for the benefit of Gigamon
Inc. or its subsidiaries (collectively, "Gigamon”) for any reason.
This code is intended to deter not only actual wrongdoing, but the appearance of wrongdoing or impropriety.
Doing (and being seen to do) the right thing is more important than winning, and we will not risk our
reputation or the trust of our customers and partners in order to win a deal.
This code is designed to ensure that employees:••••

execute business ethically and with integrity;
avoid apparent or actual conflicts of interest;
comply with the letter and spirit of all laws and Gigamon policies wherever we transact business;andpromptly report suspected violations of this code.

To whom does the code apply?
The code applies to all of us: our board of directors, executives, managers, employees and independent
contractors of Gigamon and its subsidiaries. In addition to our own compliance, all of us are accountable for
ensuring that our subordinates and independent contractors comply with this policy.
Honest and Ethical Conduct
Consistent with our core values, Gigamon personnel must act and perform their duties ethically, honestly andwith integrity - doing the right thing even when "no one is looking." We make and keep commitments – wedo not bypass or avoid policies and procedures. No ‘wink of an eye’ or ‘nod of the head’.

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Conflicts of Interest
A conflict of interest may exist where the interests or benefits of one person or entity conflict or appear toconflict with the interests or benefits of Gigamon. Your decisions and actions related to Gigamon should bebased on the best interests of Gigamon and not based on personal relationships or benefits, either for
yourself or for others. Gigamon personnel must never use or attempt to use their position with Gigamon to
obtain improper benefits for themselves or a third party.
A conflict of interest may arise in many situations. While we cannot list them all, some examples include:
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serving as a director, employee or contractor for a company that has a business relationship with
Gigamon or is a competitor of Gigamon;
having a financial interest in a competitor, supplier or customer of Gigamon, other than holding
a direct interest of less than 1% in the stock of a publicly traded company or holding a widely
traded mutual fund that owns stock in a publicly traded company;
receiving something of value from a supplier, vendor, customer, channel partner or competitorof Gigamon beyond modest entertainment or nominal gifts in the ordinary course of business,such as appropriate meals, entertainment, travel reimbursement, gifts and/or logo wear inaccordance with Gigamon’s Global Travel & Expense Policy; or
directly or indirectly using for personal gain, rather than for the benefit of Gigamon, a business
opportunity that relates to Gigamon’s business and that became available to you through yourrole with Gigamon.

Evaluating whether a conflict of interest exists can be difficult and may involve a number of considerations.
We encourage you to seek guidance from the Chief Financial Officer or General Counsel when you have any
questions or doubts, and before entering into any arrangement that you think may present a conflict ofinterest.
Compliance
Gigamon strives to comply with all applicable laws and regulations. It is your personal responsibility to adhere
to the standards and restrictions imposed by all applicable laws and regulations. The same applies to policies
we adopt, and, even if conduct complies with the letter of the law or our policies, we must avoid conductthat will have an adverse impact on the trust and confidence of our customers, partners or investors.
For example, regardless of local practices or actions by competitors, you must never directly or indirectly
make a payment (cash or any other items of value) to a foreign official or government employee to obtain or
retain business for Gigamon, or to acquire any improper advantage. You must fully comply with all anticorruption laws of the countries in which we do business. For more information, please review our Gigamon
Anti-Corruption Policy.
Reported violations of this code will be investigated and appropriate action taken, up to and including
termination of employment and legal proceedings.
ReportingIf you have a concern regarding conduct that you believe may be a violation of a law, regulation or Gigamon
policy, or you simply are unsure whether a situation violates any applicable law, regulation or Gigamon
policy, please:

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discuss the situation with your manager, HR representative, or the General Counsel or Chief
Financial Officer.
if you don't believe your concern is being adequately addressed, or you are not comfortablespeaking with the above-noted contacts, or you believe you are potentially the subject ofretaliation for good-faith reporting of a concern, please report your concern throughethics@gigamon.com.
If you wish to report a concern anonymously, you should send a post/mail letter to the attentionof our General Counsel, 3300 Olcott Street, Santa Clara, CA, 95054. In any anonymous report,
please include as much detail as possible so that we can best investigate your concern.

We expect our employees to do their best to comply with this policy. Do not stay silent in the face of apotential violation. A manager is required to report up to his or her manager (or to the General Counsel or
CFO) any information that he or she becomes aware of regarding a potential violation. If you have knowledgeof a potential violation and fail to report it via the process set forth above, you too may be subject todisciplinary action under this code.
No Retaliation
Gigamon will not retaliate against (or permit a manager to retaliate against) any individual for filing a goodfaith concern regarding non-compliance with this policy or for participating in the investigation of any suchcomplaint.
Waivers and Amendments of this CodeAny amendment or waiver of any provision of this Code of Conduct must be approved in writing by the Boardof Directors or, if appropriate, its delegate(s). We are committed to continuously reviewing and updating ourpolicies. We therefore may amend this code at any time and for any reason.

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