Codeof BusinessConduct & Ethics

Introduction

Our People

Our Company

Our Communities

Resources

What’s inside
Introduction

Our Company

Our Communities

A Message from our CEO . . . . . . . . . . . . . 3

Conflicts of Interest . . . . . . . . . . . . . . 18

Environmental Responsibility . . . . . . . . . . 38

Our Mission, Purpose, Vision, and Values . . . . . . 4

Fair Dealing and Competition . . . . . . . . . . 21

Supply Chain Responsibility . . . . . . . . . . . 39

About our Code . . . . . . . . . . . . . . . . . 5

Compliance with Laws . . . . . . . . . . . . . 22

Volunteering and Charitable Giving . . . . . . . . 39

Making Good Decisions . . . . . . . . . . . . . . 6

Antitrust . . . . . . . . . . . . . . . . . . . 23

Political Process, Contributions, and Lobbying . . . 40

Speaking Up . . . . . . . . . . . . . . . . . . 7

Anti-Bribery and Anti-Corruption . . . . . . . . 24

Administration of the Code . . . . . . . . . . . 41

Consequences for Violating the Code . . . . . . . 9

Gifts, Meals, and Entertainment . . . . . . . . . 25

Waivers and Amendments . . . . . . . . . . . 41

Responsibilities of Managers . . . . . . . . . . 10

Anti-Money Laundering . . . . . . . . . . . . 27
Global Trade Compliance . . . . . . . . . . . . 27

Our People

Insider Trading . . . . . . . . . . . . . . . . 28

Diversity, Equity, Inclusion, and Belonging (DEIB) . . 12

Confidentiality . . . . . . . . . . . . . . . . 29

Equal Opportunities . . . . . . . . . . . . . . 13

Privacy and Data Protection . . . . . . . . . . . 30

Harassment . . . . . . . . . . . . . . . . . . 14

Company Systems and Assets . . . . . . . . . . 31

Health and Safety . . . . . . . . . . . . . . . 15

Information Security . . . . . . . . . . . . . . 32

Human Rights . . . . . . . . . . . . . . . . . 16

Recordkeeping and Reporting . . . . . . . . . . 33

Resources
Other Notices . . . . . . . . . . . . . . . . . 42
Policy and Reference Links . . . . . . . . . . . . 43

Speaking on Behalf of the Company . . . . . . . 35
Social Media . . . . . . . . . . . . . . . . . . 36
Page 2Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Company

Our Communities

Resources

A Message from our CEO
Dynatrace lives and works by our Core Values.
They serve as the guiding principles in realizing our
Mission, Purpose, and Vision, and form the basis forour culture. They guide how we act as individuals andas a company.

Innovate with Passion
Our Core
Engage with Purpose
Values are:Win with Integrity
This Code of Business Conduct & Ethics helps ensurethat our Core Values remain central to everything we
do. It is the roadmap that guides our interactions,decisions, and behaviors and directly impacts our ability
to recruit and retain the best talent, partner with top
organizations, and maintain trusting relationships withour customers and partners.

Page 3This Code provides a comprehensive framework for the legal and ethicalresponsibilities that we all share, pointing us to the information andresources needed to make sound decisions in our roles at Dynatrace.
By adhering to this Code, we not only uphold our commitment tointegrity, but also strengthen the foundation upon which our
success is built.
If an issue arises that this Code can’t help you answer, or if you haveconcerns about possible violations of law or company policy, pleasereach out to your manager, your People & Culture Business Partner,
our Global Ethics & Compliance Office, or another reporting channel
mentioned in this Code. But no matter whom you contact, speaking up
is essential to a culture of integrity.
Thank you for your commitment to upholding our Core Values
and embracing the principles outlined in this Code.

Rick McConnell
Chief Executive Officer

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Company

Our Communities

Resources

Our Mission, Purpose,
Vision, and Values• Our Mission is to deliver answers andintelligent automation from data.
• Our Purpose is to enable flawlessand secure digital interactions.
• Our Vision is a world where software
works perfectly.
• Our Values are Innovate with Passion,
Engage with Purpose, and Win with Integrity.

For additional information about ourshared beliefs and principles, please see
the Dynatrace Culture Code.

Page 4Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Company

Our Communities

Resources

About our CodeThis Code of Business Conduct & Ethics (the Code)applies to all Dynatrace employees and officers.
It also applies to members of the Dynatrace Board of
Directors when they act in their capacity as directors.
We also expect contractors, temporary workers, interns,
consultants, partners, and agents performing services
for us to be familiar with the Code and to comply with it
when acting on Dynatrace’s behalf.
The Code doesn’t address every possible situationthat you might face in your work. Accordingly, we
expect you to use good judgment and common sense
to determine whether a course of action is consistent
with our ethical and legal standards. Ask for guidance
when you’re uncertain and speak up when you believe
something isn’t right. The “Speaking Up” section of theCode highlights the different ways that you can seek
guidance, ask questions, and report concerns.

The Code applies in all countries where Dynatraceor you are located and where the company
conducts business. As a global company, there
may be circumstances where local law, other legal
requirements, or local customs differ from our Code,or where we have supplemented the Code to address
local requirements. If you become aware of any
conflicts, please contact the Dynatrace Global Ethics &Compliance Office for guidance. When in doubt, the best
approach is to follow the stricter requirement and to
think of the Code as reflecting minimum standards foryou to follow.

The Code is designed to be a practicalresource to help you uphold
Dynatrace’s Core Values and act ethicallyand responsibly.
The Code provides the foundation for ourcommitment to integrity and includes
policies, standards, and guidelines related
to how we conduct business.

As part of demonstrating commitment to the Code,new employees, officers, and directors are required
to acknowledge the Code as part of the onboarding
process. On an annual basis, employees are required tore-acknowledge the Code. In this Code, we sometimes
refer to our employees as “Dynatracers”.
We also maintain a Supplier Code of Conduct that sets forth
expectations for our third-party suppliers and vendors.

Page 5Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Making Good
Decisions

Our Company

Our Communities

Resources

There may be times when you’re unsure what typeof action or decision to takeIn these situations, ask yourself the following questions:

Each of us has a responsibility to act ethicallyand with integrity.
As part of this responsibility:• Use the Code to guide how you workand make decisions• Use good judgment• Do the right thing

Is itlegal?

Is it
ethical andconsistent
with our Core
Values andculture?

Does itcomply with
the Code andDynatrace’s
otherpolicies?

Am I
comfortablewith theaction or
decision?

Does myproposed action
or decision seem
preferable toany alternativethat I’ve
considered?

Would I be
OK if myaction or
decision was
public?

If the answer
to any of thesequestions is“no” or “notsure”, ask for
guidance
before acting

If the answer
to all of thesequestions is“yes”, you canproceed or
move forward• Consider Dynatrace’s Core Values and standardsof behavior or actions that align with them
• Raise concerns and ask questions

If you’re in need of guidance, speak up.
Please see the next page of the Code for information about the different alternatives available to you to do so.

Page 6...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Our People

Introduction

Our Company

Our Communities

Resources

Speaking Up
If you have a good faith concern about a possible
violation of our Code, other Dynatrace policies andprocedures, or applicable laws, rules, or regulations
related to Dynatrace business, you must speak up
about it. You should also speak up if you have a questionor need guidance.
You have several options available to you:
Global Ethics &Compliance Office(which is part of
our Legal Team)

People & Culture
Business PartnerYour immediate
manager

Speak Up
PortalYour immediate manager

Dynatrace Speak Up portal

The best starting point will usually be your manager,
who will often be able to provide you with guidance andanswers. However, if the conduct in question involves
your manager, if you have reported the conduct inquestion to your manager and you don’t believe that yourmanager has dealt with it properly, or if you don’t feel
comfortable discussing the matter with your manager,
you should raise the matter through another channel.

We also have a confidential Speak Up portal that you
can use to raise any good faith concerns relating to
inappropriate, fraudulent, unethical, or illegal behavior,including concerns about retaliation.

Other internal resources
You can speak with your People & Culture Business
Partner or our Global Ethics & Compliance Office (whichis part of the Dynatrace Legal Team). Communications
with members of the Dynatrace Legal Team that are
made for the purpose of providing or receiving legal
advice may be considered privileged communications.
You should also be aware that the Dynatrace Legal
Team represents the company and does not act aspersonal lawyers to employees.

The Speak Up portal is operated by a third party.
Concerns can be reported 24/7 online through thewebsite linked below or by phone. You can reportconcerns or ask questions in multiple languages.
Our Speak Up phone number is +1 800-493-0611(toll-free in the United States).
Please visit the website linked below for international
toll-free numbers assigned to other countries.
www.dynatrace.com/ethics

You

Page 7

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Company

Our Communities

Resources

Speaking Up
Anonymous reporting
All calls and reports to the Speak Up portal are confidential andmay be made anonymously, where permitted by local law. Keepin mind that in some circumstances, it might be difficult or even
impossible for Dynatrace to thoroughly investigate anonymousconcerns. We encourage you to share your identity when reporting a
concern. Regardless of how you submit them, Dynatrace encourages
you to raise concerns, and does not tolerate retaliation against those
who do so in good faith.
Investigations
We take concerns reported to us seriously and we handle them on acase-by-case basis. We have processes in place to investigate concerns
raised. You should not conduct your own investigation into a matter.
As part of looking into concerns, we maintain confidentiality to thefullest extent possible.
Cooperation
You’re expected to cooperate with the company in any investigation of apotential violation of the Code, any other company policy or procedure, or
any law, rule, or regulation. Failing to cooperate may result in disciplinary
action, up to and including termination.

Page 8Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Company

Our Communities

Resources

Speaking Up
No false accusations
You should not use our reporting channels in bad faith
or in a false or frivolous manner or to report grievancesthat do not involve the Code or other ethics, legal, orcompliance-related issues.
While we prefer that you raise concerns internally,
nothing in the Code, any agreement you may have with
Dynatrace, or any Dynatrace policy prevents, restricts,
or limits you from reporting concerns or violations oflaw to government agencies or officials or throughcourts. For additional information, please see the “Other
Notices” section of this Code and our Whistleblower
Complaint Handling Policy.

Retaliation is a negative consequence that you
experience as a result of raising a concern, asking aquestion, or participating in an investigation. Examplesof retaliation might include an inappropriate demotion,
receiving an unfair performance review, an unjustified
reduction in your salary/bonus, job reassignment,
threats, being excluded from meetings, or otherharassment.
If you believe you’ve been retaliated against or you’ve
witnessed retaliation against someone else, report
it through one of our channels. Anyone who is foundto have engaged in retaliation will be subject todisciplinary action, up to and including termination.

No retaliation
We’re committed to maintaining a culture where you
feel comfortable raising concerns and helping withinvestigations. We never tolerate any retaliation against
anyone who, acting in good faith on the basis of areasonable belief, reports suspected misconduct or is
asked to participate in an investigation.

Page 9Consequences forviolating the Code
If it’s determined that you violated the Code,you may be subject to disciplinary action that
Dynatrace determines to be appropriate under
the circumstances and in accordance withapplicable law, up to and including terminationof employment.
Dynatrace may also contact or refer matters to law
enforcement or disclose matters to a regulator or
self-regulatory organization, as appropriate.

“Good faith” doesn’t mean that you have to
be right (when looking back in hindsight).
It means that you honestly believe it to be trueand you’ve provided all relevant information.

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Company

Our Communities

Resources

Responsibilities of Managers
While all of us should act ethically and with integrity, if you’re a manager, you have additional
responsibilities. You help set the tone and reinforce the culture at Dynatrace.
You should:• Lead by example and role model the behavior that you’d like to see in others• Create an “open door” culture and environment where colleagues are comfortable raisingconcerns or asking questions• Listen when matters are brought to your attention and respond promptly to members of yourteam or other Dynatracers who raise concerns or ask questions• Provide adequate and appropriate guidance to your team related to your team’s role
• Ensure your team completes all required company-wide compliance training• Promptly address, report, or escalate issues and problems when they arise if you believe they
violate the Code, the law, our policies, or the way we are committed to conducting business
Managers and other leaders sometimes need help in determining the proper course of action.
When in doubt, ask for guidance.

Page 10...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our
PeopleOur People

Our Company

Our Communities

ResourcesIntroduction

Our People

Our Company

Our Communities

Resources

Diversity, Equity, Inclusion, and Belonging (DEIB)At Dynatrace, we respect and value our diverse
backgrounds, identities, experiences, characteristics,
and perspectives.
DEIB is critical to our mission, and we’re committed
to maintaining a culture where every Dynatracer feels
respected, safe, included, and valued. When diversity
meets collaboration—a way of working embedded in our
DNA—we create powerful innovations that support ourcustomers around the world.
As a global company, we’re also mindful that conduct
which may be acceptable in one country may be viewed
differently in another.

Page 12

To support and advance DEIB at Dynatrace:• Be respectful of others’ differences and views and keep an open mind
• Treat others how they want to be treated—and how you’d want to be treated• Appreciate the unique ways that others contribute to our company• Think about how your words and actions may be interpreted or perceived by others• Be mindful of potential unconscious biases and microinequities and seek to eliminate them
• Consider joining or supporting one of our company’s Dynaspaces, which are Employee
Resource Groups (ERGs) focused on fostering an inclusive workplace...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Company

Our Communities

Resources

Equal Opportunities
We base employment decisions such as hiring, promotion, compensation, and disciplinary
action on an individual’s merit, qualifications, experience, and abilities. We prohibit
discrimination or unequal treatment based on, or because of, protected characteristics,
which can vary around the world.
Characteristics protected by law can include:• Age• Marital or family status• Alienage or citizenship• Military or veteran status• Ancestry• National origin• Color• Race• Disability (mental and physical)• Religion (including religious dress and grooming practices)• Ethnicity• Sex (including pregnancy, sexual orientation, gender identity,
or gender expression)• Genetic information• Any other characteristic protected by law

We also make reasonable accommodations or adjustments for qualified individuals withdisabilities and colleagues with needs related to their religious observance or practice.
A reasonable accommodation/adjustment for these purposes is a modification or adjustment
to job duties or the work environment that enables an individual to perform the essentialfunctions of a job without putting undue hardship on Dynatrace.

Page 13...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Company

Our Communities

Resources

Harassment
Harassment is unwelcome conduct based upon an individual’s protected characteristics that creates an intimidating,hostile, or offensive work environment. We don’t tolerate harassment of any kind in our workplaces or anywhere we’reconducting business—including in offices, virtual meetings, e-mail, social media, and other communications, or at off-site
events. Harassment can occur during work hours and outside of it. Harassment can be overt and intentional and it
can also include unintentional behavior. Even if local law doesn’t prohibit this type of conduct, you’re held to a higher
standard under our Code.

To help provide a positive, safe, andwelcoming work environment:• Treat others with dignity and respect• Act with empathy and kindness

Harassment can take many forms, and can be verbal, physical, visual, or sexual in nature.

• Use care with your words and actions—be mindful of behavior that can beconsidered a microaggression

Examples of harassment can include:• Bullying or abusive conduct that can be threatening, aggressive, humiliating, or demeaning• Don’t ignore behavior that may be aform of harassment—say something orreport it (whether you experiencesomething directly, hear about it, or
witness it)• Slurs, disparaging remarks, insults, inappropriate jokes, teasing, using disrespectful or harmful words or actions,or sabotaging/undermining someone’s work performance• Displaying or sharing offensive material
Sexual harassment can include unwelcome propositions, demands, or advances, as well as unwelcome physicalcontact or inappropriate remarks of a sexual nature.
Harassment isn’t just something that can occur between Dynatracers. Harassment can also involve customers, partners,
suppliers, and advisors—and anyone else who interacts with Dynatracers.
All of these forms of harassment are prohibited by the Code.

Page 14...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Company

Our Communities

Resources

Health and Safety
We follow laws and local guidelines to maintain a safe, healthy, and secure workplace. You should speak up if you’reaware of, or suspect, any safety issues or concerns in our workplaces.
Drugs and alcohol
Dynatrace cares about the health and safety of ouremployees. Employees are prohibited from using alcoholor any drug in a way that, in either case, results in
impaired performance, inappropriate behavior, orendangers the safety of themselves or others while
doing work for the company or while on company
business, regardless of location.
Illegal drugs in our offices, while working, or atcompany-attended or company-sponsored events arestrictly prohibited. This prohibition specifically includes
the unlawful manufacture, distribution, dispensing,possession, or use of a controlled substance in our
offices, while working, or when otherwise conducting
Dynatrace business.
Contact People Ops or a People Business Partner if you
have any concerns about drug or alcohol use at thecompany or at a company sponsored event.

Page 15

We offer employee assistance programs(EAPs) if you need help with drug or
alcohol abuse. Additional information isavailable on Dynatrace’s SharePoint.

Threats, violence, and weapons
We do not tolerate any level of violence or the threat ofviolence in the workplace, and no one should ever bringa weapon into a Dynatrace workplace.
Threats can also include verbal assaults and otheraggressive and intimidating behavior—these are
not acceptable.
Contact your manager or another Dynatrace leader
immediately about any threats or concerns in this area.

...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Company

Our Communities

Resources

Human Rights
We respect the fundamental rights, freedoms, andstandards of treatment of all people and we expect
other companies that we work with to do the same.
Respecting human rights is important to our values,
reputation, and our supply chain sustainability. We alignour practices with the United Nations Universal
Declaration of Human Rights and the International
Labour Organization Declaration on Fundamental
Principles and Rights at Work.

As outlined in our Human Rights Policy, we prohibit
all forms of forced labor, including illegal child labor,
all forms of slavery, and any form of human trafficking.
If you suspect or become aware of any human rights
issues in our operations or in our relationships with
suppliers, partners, and other third parties, speak up
and report it.

Our Human Rights Policy guides our commitment to:• Protect internationally proclaimed human rights inour business as well as advancing DEIB
• Compensating employees fairly• Respecting freedom of association and collective
bargaining• Providing a safe, productive, and healthy workplacefor Dynatrace employees

Page 16

When selecting suppliers, partners, andother third parties, we should evaluate
their commitments to respecting
human rights—whether through theirown policies or by their agreement tocomply with the Dynatrace Supplier
Code of Conduct. See the “Supply Chain
Responsibility” section of the Code for
additional information.

...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our
Company

Our Company

Our Communities

ResourcesIntroduction

Our People

Conflicts of Interest
Many of us engage in, or are asked to participate in, outside
activities that broaden both our personal and professional
interests. Some of us may have friends or family members that
may want to do business with Dynatrace or come work here.
These situations create a potential conflict of interest because
your personal interest and motivation may interfere—or appear
to interfere—with your duties and obligations as a Dynatrace
employee and with the company’s interests.
Conflicts such as these may make it difficult to perform yourwork objectively and effectively. Conflicts of interest also canharm our reputation.

The existence of a conflict of interest isn’t
automatically a violation of our Code. However,
failure to disclose it is. So, when in doubt, be
open and transparent. Please see the next two
pages of the Code for additional guidance.

Page 18

Our Communities

Our Company

Resources

Questions to Ask and Disclosure Requirements
When faced with a potential conflict of interest, ask yourself:

Would thiscreate or beperceivedby others as
somethingthat’sbenefitingme, my friends,
or family atthe expenseof Dynatrace?

Would thisnegatively
impact myability to do
my job at
Dynatrace?

Could myjudgment becompromised?

Would thisharm myreputation or
Dynatrace’s?

If the answer
to any of thesequestionsis “yes” or“maybe” oryou aren’t
sure how toanswer them,
you may havea potential
conflict ofinterest.

If the answer
to any of thesequestions is“no” and you’ve
also reviewed
the guidanceon the next
page of theCode, you might
not have aconflict ofinterest.

Initially, discuss the matter with your manager. With the input of your manager,
disclose any potential conflict to the Dynatrace Global Ethics & Compliance Office. Pleaseawait a response/guidance before taking action.

...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Company

Our Communities

Resources

Conflicts of Interest
Conflicts of interest can arise in many situations. While it’s not possible to list every situation that can cause a conflict, some common examples include:
Personal relationships• Referring for employment, hiring or directly or
indirectly supervising someone with whom you’rerelated or have a close relationship• Participating in the selection process for a supplier
that’s owned by or employs someone with whom
you’re related or have a close relationship• Engaging in a romantic relationship with a direct
report or other subordinate employee

Relatives and family members can
include a spouse or domestic partner,child, mother, father, in-laws, aunts,
uncles, nieces, nephews, cousins,
grandparents, grandchildren, step,
adoptive and foster relationships andother individuals who may reside inyour home.

Family members
A member of your family receives some personal
benefit (whether improper or not) as a result of yourposition with the company. These benefits can include
cash, gifts, entertainment, services, discounts, loans,guarantees, or being selected by Dynatrace as asupplier, consultant, or partner.

Page 19

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Company

Our Communities

Resources

Conflicts of Interest
Additional common examples of situations that can cause a conflict include:
Outside employment/activities
Taking on outside employment, consulting,or volunteering if it:• Interferes with your judgment or ability to perform yourDynatrace job duties• Involves working for a competitor or supplier• Uses Dynatrace confidential information, systems,
or assets

Outside boards—You may join the board of a private business or other organization that has no
relation to Dynatrace or our business. You must receive approval from the Dynatrace Global Ethics& Compliance Office before accepting an appointment to the advisory or governing board of anorganization whose interests are related to, or may conflict with, Dynatrace’s. Dynatrace employees
must receive approval from the Chief Legal Officer before serving as a director of another publicly
traded company.

Gifts, meals, and entertainment

Financial interests

Business/corporate opportunities

Receiving gifts, meals, and entertainment can give rise
to a conflict of interest in certain situations.

Having a financial interest or investment in anothercompany or organization (such as a supplier, partner,
or competitor) if it would create, or create theappearance of, a conflict of interest with Dynatrace.
As a general guideline, it’s permissible for you to
own or invest less than 1% of the outstanding stockof another company or organization that you’re not
involved in advising or participating in businessdecisions—including through a mutual fund.

• Taking for yourself a business or corporate
opportunity that was discovered through the useof Dynatrace property, information, or your position

Please see the “Gifts, Meals, and Entertainment” sectionof this Code for additional information.

Page 20• Using company property, information, or your position
for personal gain
• Competing with Dynatrace (either directly or indirectly)

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Communities

Our Company

Resources

Fair Dealing and Competition
You should deal honestly, ethically, and fairly with
Dynatrace’s suppliers, customers, competitors, andemployees. Statements regarding our products andservices (and comparative statements regarding ourcompetitors’ products and services) should not be untrue,
misleading, deceptive, or fraudulent. You must not takeunfair advantage of anyone through manipulation,
concealment, abuse of privileged information,
misrepresentation of material facts, or any other unfair
dealing practice.
Obtaining information about our competitors is a normal
business practice—but it has to be conducted properly
through lawful and ethical channels.
This means that we:

In addition, if you’re offered competitive information thatyou believe shouldn’t be disclosed to Dynatrace (either
because it’s confidential to another company or has beenobtained illegally or unethically), don’t accept the informationand notify your manager. Examples can include customer
lists, pricing information, and strategic/marketing plans.
You also must abide by any legal obligations that you may haveto a former employer. These obligations may include restrictions
on the use and disclosure of your former employer’s confidential
information, restrictions on the solicitation of former colleagues
to work at the company, and non-competition obligations.
For additional information related to dealing with our supply chain,see the “Supply Chain Responsibility” section of this Code.

• Do not conceal or misrepresent our identity to gain
access to a competitor’s product or service• Do not engage third parties to help us gain competitive
intelligence through misrepresentation• Use public and other permitted sources of information• Use good judgment and avoid the appearance ofanything that might be viewed as inappropriate

Page 21

Healthy competition is a good thing for ourbusiness and we should win on the merits.
For additional information, please also
refer to the “Antitrust” section of the Code.

...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Communities

Our Company

Resources

Compliance with Laws
As a global company, Dynatrace is subject to laws,
rules, and regulations around the world. You should
learn about, understand, and comply with applicablelaws, rules, and regulations that relate to your position
and/or location.
If you have questions or need guidance, please contact
the Dynatrace Global Ethics & Compliance Office.

Laws, rules, and regulations can change
from time to time and they can sometimes
be complex. Failure to comply can harm
our reputation and could also result in
financial costs to our company.

If you become aware of the violation of any law, rule,or regulation by the company, it’s your responsibility topromptly report the matter to your manager or to the
Dynatrace Global Ethics & Compliance Office.
As stated earlier in the Code, while we prefer that you raise
concerns internally, nothing in the Code, any agreement
you may have with Dynatrace, or any Dynatrace policy
prevents, restricts, or limits you from reporting concerns
or violations of law to government agencies or officials
or through courts. For additional information, please
see the “Other Notices” section of this Code and ourWhistleblower Complaint Handling Policy.

Page 22...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Communities

Our Company

Resources

Antitrust
We comply with applicable antitrust and competition
laws, and we seek to avoid situations that could put
us at risk. Antitrust and competition laws prohibit
arrangements or actions that could unreasonably
restrict a free and competitive marketplace.
This means that we don’t engage in discussions
or agreements (whether formal or informal)
with competitors to:

We also don’t force customers to buy something thatthey don’t want by improperly tying the offering tosomething that they do want.
As antitrust and competition laws are complex and canvary from country to country, you should consult with
the Dynatrace Global Ethics & Compliance Office before
taking action that might be viewed as anti-competitive.

• Fix or set prices or other terms of sale
• Divide or allocate sales opportunities or territories• Prevent another company from entering the market• Agree not to solicit each other’s customers• Boycott particular customers or suppliers• Rig or coordinate bids

If someone from another company raises
a topic with you that you believe might
be anti-competitive, you should stop theconversation. It’s best to then contact
the Dynatrace Global Ethics & Compliance
Office for guidance.

• Share confidential information about pricing, profits,costs, sale terms, customers, discounts, promotions,marketing plans, or other sensitive information.

Page 23...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Communities

Our Company

Resources

Anti-Bribery and Anti-Corruption
As a Dynatrace Core Value, we Win With Integrity, which means, in part, that we don’t permit or tolerate bribery or
corruption. The consequences for violating anti-bribery and anti-corruption laws can be significant to both you and thecompany from a reputational, legal, and financial standpoint. We behave with integrity in our business dealings, whichmeans that we:
Do not offer, give, solicit, or accept bribes or
kickbacks to obtain business, retain business,or gain an unfair advantage
Bribery can include payments or the offer of paymentsof anything of value (not just cash). Gifts, meals,
entertainment, promises of jobs, and charitableor political contributions can be considered bribes
if offered in exchange for a decision or favorable
treatment. Kickbacks can include receiving discounts,
favors, or preferential treatment in exchange forsomething else.
Do not make facilitation or “grease” payments,
even if they’re legal or standard practice in the
country where requested
A facilitation or “grease” payment is a small payment ofcash or something else of value made to a government
employee to secure or speed up the performance of aroutine government action, such as issuing a permit orapproval. These do not include official payments.

Page 24

Use extra care when interacting withgovernment or public officials. For
additional guidance, see the “Gifts, Meals,
and Entertainment” section of this Code.

Record payments and receipts honestly andaccurately
Conduct appropriate due diligence on customers,
suppliers, and other business partners

For additional information, please also
refer to our Anti-Corruption Policy.

Keep in mind that this Code and our other policies
may be stricter than a local country’s laws, rules, andregulations.
Anti-bribery and anti-corruption laws often prohibit
indirect payments. We also expect partners, agents,and other third parties acting on our behalf to meetthese standards. Don’t ignore any “red flags” if you
believe that a third party may be making illegal
payments or engaging in corrupt behavior when acting
on behalf of Dynatrace. You should report any activity
that you suspect may violate this Code or applicablelaws, rules, and regulations in this area.

...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Communities

Our Company

Resources

Gifts, Meals, and Entertainment
Accepting or providing gifts, meals, entertainment,
travel, and other gratuities and amenities can help build
and strengthen business relationships. However, they
can also create conflicts of interest, perceived conflictsof interest, or suggest improper conduct.
This section of the Code is focused on business-related
gifts, meals, and entertainment to and from people andfirms outside of Dynatrace. Gifts between Dynatracers
should not compromise, or appear to compromise, thepropriety of relationships and should comply with our
Global Travel and Expense Policy.
When giving or receiving gifts, meals, and entertainment,
you should ensure that they are legal, appropriate,
reasonable, and connected to a legitimate business purpose.

If you need guidance or have questions,please contact the Dynatrace Global Ethics& Compliance Office.

Page 25

When deciding whether it is appropriate to offer or accept something,
you should consider the following factors:
PurposeValue

Reputation

Type

What’s the reason for the gift?
Could the gift be viewed as abribe or an offer to induce any
action or inaction or influence
someone? Could the gift makethe recipient feel that theyneed to return a favor?

Is the gift excessive in value?
Does it seem overly generous?

Would you or Dynatrace beembarrassed, or would you or
the company look poorly, if
details about the gift were
publicly known?

You should never give or
receive gifts in cash
(regardless of the amount).

Legal
Does the gift comply withapplicable laws and thepolicies of both the giving
and receiving companies?
Is the recipient a government
employee? Special considerations
may apply (as discussed on thenext page).

Transparency
Is there openness about thegift or is it being provided in amore secretive manner? Is it
being provided directly to andfrom people with a business
relationship (as opposed tothrough an intermediary or toa family member of someone)?

TimingIs the gift being given or
received around the timeof a contract negotiation,
renewal, or other important
corporate decision?
Did someone ask for a gift?

You should not give or receive
cash equivalents (e.g., gift cards)
of $250 or more without approval
from the Dynatrace Global Ethics& Compliance Office.
Multiple gifts given or received
from the same person orentity should not exceed thisamount in a calendar year.

Frequency
Is this an infrequent gift or has
there been anything else
recently given or accepted?

...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Company

Our Communities

Resources

Gifts, Meals, and Entertainment
Specific examples of gifts, meals, and entertainmentthat often are acceptable include:• Promotional items with a company logo
• Customary holiday gifts sent to an office asa thank you• Meals and entertainment of modest or
reasonable value• Routine tickets to a local sporting or cultural event• Invitations to an industry conference, trade show,
or event (with the registration fee waived or reduced)
if the primary purpose is to discuss business ordevelop business relationships• Prizes randomly given or received through raffles,
contests, or industry events

Government employees
Before offering anything of value—which
includes gifts, meals, entertainment, travel,and other gratuities or amenities—to agovernment employee, you’re required toobtain the prior approval of the Dynatrace
Global Ethics & Compliance Office. Somegovernment employees are easy to identify,
but government employees can also
include elected officials, law enforcement,
inspectors, and employees of state owned
or controlled firms and universities.
Travel and expense policy

Also keep in mind that you can’t use a third party to givesomething that you’re not permitted to give directly, anda third party can’t receive something that you’re notpermitted to receive directly.

Page 26

Keep in mind Dynatrace’s Global Traveland Expense Policy for our guidelines andprocedures related to business travel.

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Communities

Our Company

Resources

Anti-Money Laundering
Money laundering is the process of creating the appearance that funds obtained from criminal activities are legitimate or originated from a lawful source.
We comply with applicable anti-money laundering laws.
This means that we:• Follow “Know Your Customer” or “KYC” procedures• Only accept payments from, and send payments to, customers, suppliers, partners, and others who we do business with
• Report any red flags or suspicious activity by customers, partners, or others that might suggest improper financial transactions or processes

Global Trade Compliance
As a global company, our business activities are subject to various international trade compliance laws. Violations can result in penalties and fines for our company.
This includes the following areas:
Export and Import controls

Trade embargoes and sanctions

Anti-boycott

Exports and imports of certain types of software,technology, and products may be subject tolicensing requirements.

We are prohibited from conducting business withcertain sanctioned countries and specific entities
and individuals.

We must not participate in unsanctioned boycotts orrefusals to trade or do business with certain countries.

Dynatrace’s policy is to comply with these regulations and prohibitions even if compliance may result in the loss of some business opportunities. You should learn and understand theextent to which global trade controls apply to transactions that relate to your job at Dynatrace. Contact the Dynatrace Global Ethics & Compliance Office if you need guidance.

Page 27...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Communities

Our Company

Resources

Insider Trading
If you trade in Dynatrace stock (which is a form of
securities), you need to comply with applicable laws.
You should be aware that misuse of material nonpublic
information can be a violation of insider trading laws
and can result in severe penalties.

In simple terms, material information is any type of
information that could reasonably be expected to affectthe market price of company securities. Both positive andnegative information may be material. Material information
can include:

You may not buy, sell, or otherwise trade in Dynatrace
securities—whether for your own account or for theaccount of another—if you possess material nonpublic
information about Dynatrace. It’s against our Codeand also illegal. You also may not disclose material
nonpublic information about Dynatrace to others who
may trade on the basis of that information—this iscalled “tipping” and it’s also a form of insider trading.
These prohibitions also apply to trading in the securitiesof other public companies, including Dynatrace’s
customers, suppliers, partners, and other enterprises
with which we are working, when you have material
nonpublic information about them.

• Earnings results and any projections of future
earnings or losses, or other earnings guidance

Information about Dynatrace is “material” if it could
reasonably be expected to affect the investment or
voting decisions of a stockholder or investor, or if
the disclosure of the information could reasonably
be expected to significantly alter the total mix of
information in the marketplace about the company.
Page 28

Information is “nonpublic” if it has not been disseminatedin a manner making it available to investors generally—such as through an SEC filing, the distribution of apress release through a widely disseminated news or
wire service, or by other means that are reasonably
designed to provide broad public access.
If you’re not sure whether certain information is consideredmaterial or nonpublic, contact the Dynatrace Global Ethics &Compliance Office for guidance before trading.

• Pending or proposed corporate mergers, acquisitions,tender offers, joint ventures or dispositions ofsignificant assets

For additional information, refer to our Insider
Trading Policy.

• Changes in management or the Board of Directors• Significant actual or threatened litigation or
governmental investigations or major developments
in such matters• A cybersecurity or other technology-related risk orincident, including the discovery of significant
vulnerabilities or breaches• Significant developments regarding the Dynatrace platform,
our offerings, customers, partners, contracts or financing
sources (e.g., the acquisition or loss of a contract)• A significant pending or unannounced contract with apartner or customer...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Communities

Our Company

Resources

Confidentiality
As a general rule, you’re expected to safeguard, maintain,
and protect information that is confidential, strategic, or
proprietary to Dynatrace. This includes information related
to our company as well as our customers, suppliers,
business partners, employees, and others. Part of thisobligation includes preventing confidential informationfrom being improperly accessed, shared, or lost.
• You should only share confidential information ona “need to know” basis and when you’re authorized
to do so. This applies to information sharing within
our company to other Dynatracers as well as externally.
• Be careful to avoid inadvertent disclosures ofconfidential information in a public place where yourconversation may be overheard.
• When you’re authorized to share confidential
information outside of the company, ensure that an
appropriate non-disclosure agreement (NDA) is inplace or that we have an agreement that includes
confidentiality provisions that cover the information
sharing.
Contact the Dynatrace Global Ethics & Compliance
Office for guidance and assistance.

Page 29

Confidential information includes all nonpublic informationthat might be of use to competitors or could be harmful to
Dynatrace or its customers if disclosed. Confidential information
can include:• Company financial results, information, data, and reports• Internal e-mails and other types of internal correspondence• Processes and know-how• Plans and strategies• Trade and business secrets• Recordings or transcripts of meetings or calls

These obligations regarding confidentiality andtrade secrets continue to apply after youremployment with Dynatrace ends.
Please see the “Other Notices” section of this Codefor exceptions to the general obligation to maintainconfidentiality that’s described in this section andelsewhere in this Code.

...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Communities

Our Company

Resources

Privacy and Data Protection
We’re committed to handling personal information about individuals in accordance with applicable laws that apply to
us around the world. As part of our business operations, we collect and use personal information regarding customers,
employees, contractors, suppliers, and other third parties.
Our customers trust us to help them innovate and operate more efficiently. Integral to this trust is our ability to help
keep their data safe and to provide features in our platform that align to their data protection and privacy requirements.
Employees entrust us with their personal information when they join Dynatrace.

Personal information is anything that—by itself or in combination
with other information—could reasonably be used to identify
someone. Sometimes, personally identifiable information isreferred to as “PII”.
Examples of personal information include (but not are limited to):• Names• Identification numbers• E-mail addresses

We don’t disclose others’ personal
information except on a need-to-knowbasis and when we’re legally permitted to
do so. If you work with personal informationas part of your job at Dynatrace, you should
understand how to comply with applicablelegal requirements as well as our policies.
You should contact the Dynatrace Privacy Officewith any questions about personal information or
our privacy practices. For additional information,refer to our Data Protection Policy.

• Phone numbers• Location data (such as IP addresses)

Page 30...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Communities

Our Company

Resources

Company Systems and Assets
You’re trusted to use Dynatrace’s systems and assets properly and responsibly and protect them against loss, theft,misuse, or damage (which can have a direct impact on our company’s profitability). Company systems and assets include,
but are not limited to, laptops and other computer equipment; company-owned cell phones; software and hardware;
offices and labs; customer, supplier, and partner lists; and corporate information.
Dynatrace’s assets also include intellectual property (IP), such as patents, copyrights, trademarks, trade secrets, and know-how
and other information regarding how our products and solutions work. You should protect our IP and remember that Dynatraceowns any work product that you develop or design in your work at the company, to the extent permitted by law.

You should use the company’s systems, assets, information, trade secrets
and services for legitimate and authorized business purposes.
This means:• Limit personal use of company systems and assets within reason
and for appropriate uses
• Immediately report any loss, theft, misuse, or damage of company
systems and assets

Improperly handled computer
systems and assets can expose
Dynatrace to bad actors, potentiallyputting our company, customers,
and other stakeholders at risk.
For additional information, refer tothe “Information Security” section of
the Code below, our IT - Acceptable
Use Policy, and our AI - Responsible
Use Policy.

• Spend the company’s money in an appropriate way

Page 31...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Communities

Our Company

Resources

Information Security
All Dynatracers are critical to information security. Familiarize yourself with applicable Dynatrace policies that are
posted in the Employee Digital Enablement (EDE) section of our SharePoint and complete all required training.
To protect our information systems:• Use a Dynatrace e-mail address when conducting business• Use caution to avoid phishing and other suspicious e-mails• Use a VPN when available• Obtain EDE authorization before installing third party software
on your work laptop or computer• Passwords shouldn’t be written down and left in a place where
unauthorized persons might discover them

• Laptops and mobile devices shouldn’t be left unattended
or out of your line of sight in public places• When traveling, try to use wall plugs and your own chargers
instead of USB chargers built into hotel and airport desks,
lamps and other devices• All items that may hold data belonging to Dynatrace or ourcustomers should be disposed of in a way that data held on thedevice is securely destroyed in accordance with applicable standards• Store Dynatrace’s data in EDE-approved repositories

For additional information, see the “Company Systems andAssets” section of this Code, our IT - Acceptable Use Policy,• Only use authorized artificial intelligence (AI) tools and use
these tools in compliance with our AI - Responsible Use Policy. and our AI - Responsible Use Policy.

If you know of, or suspect, that any Dynatrace confidential information, personal data, information technology,
or information system has or may have been compromised as part of a security breach, you must report it
through the EDE section of our Sharepoint or by sending an email to corporatesecurity@dynatrace.com.

Page 32...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Communities

Our Company

Resources

Recordkeeping and Reporting
Accurate information is essential to our company’s ability
to meet legal and regulatory obligations and it’s also
important to our reputation.
Dynatrace, Inc. is a public company listed on the New York
Stock Exchange or NYSE. It is Dynatrace policy to provide
full, fair, accurate, timely, and understandable disclosurein reports and documents filed with, or submitted to, theU.S. Securities and Exchange Commission (SEC) and in ourother public communications.
All Dynatrace books, records, and accounts need to be
maintained in accordance with all applicable regulations
and standards and accurately reflect the true nature of
the transactions they record. Employees involved in theprocess of preparing our public disclosures and filings
have a special responsibility in this area, but each of us
contributes as part of Dynatrace conducting business.

Page 33• Our publicly disclosed financial statements that are
filed with the SEC are required to conform togenerally accepted accounting principles (GAAP)and the company’s accounting policies

Comply with any “legal holds” (related
to litigation, investigations, or othermatters) that the Dynatrace Legal Teammay communicate to you. Legal holds may
require you to retain e-mail, records, andother information.

• No undisclosed or unrecorded account or fund is to beestablished for any purpose• No false or misleading entries are to be made in thecompany’s books or records for any reason• No disbursement of corporate funds or othercorporate property may be made without adequate
supporting documentation• Follow applicable internal controls and policies• Report any records that appear to be inaccurate,
false, or misleading...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Company

Our Communities

Resources

Recordkeeping and Reporting
Concerns or questions regarding accounting, internal
accounting controls, or auditing or securities law
matters will be directed to the Audit Committee of
the Dynatrace Board of Directors or a designee of the
Audit Committee in accordance with the procedures
established by the Audit Committee for receiving,retaining, and treating complaints regarding accounting,internal accounting controls, or auditing matters.
You can also communicate directly with the Audit
Committee or its designee regarding such mattersby e-mailing corporatesecretary@dynatrace.com(anonymity cannot be maintained) or through one of theother reporting channels described in the “Speaking Up”
section of this Code, which provide an option for anonymity.
If you’re asked for information or records as partof an audit or investigation that’s being conductedby Dynatrace, our auditors, or another third party,
you should be transparent and provide accurate andcomplete information.

Page 34

You may not enter into any undisclosed orunapproved “side letters” with customers
or other business partners.

A “side letter” is any promise, deal, bargain or otherarrangement, whether written or verbal, that is
separate or different in any way from the terms
documented in the applicable governing agreement
and may include a conversation, e-mail or letter thatvaries or supplements the terms and conditions of thegoverning agreement.

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Communities

Our Company

Resources

Speaking on Behalf of the Company
We have authorized spokespersons and look to appropriate
members of Dynatrace senior management and the
Dynatrace Board of Directors to provide the company’s
official views and statements on various issues. This
helps us provide consistent and accurate messaging toour different stakeholders.
From time to time, you may be contacted by someone
externally for information concerning Dynatrace, suchas the media, marketing professionals, securities analysts,
investment advisers, or stockholders.
Unless you’re an authorized Dynatrace spokesperson oran appropriate member of Dynatrace senior management,
you shouldn’t discuss internal company matters with, ordisclose internal company information to, anyone
outside the company, except as required in the performanceof your company duties.

If you receive any inquiries of this nature, you should
decline to comment and refer the person to one of thefollowing teams:
Stockholder ormember of thefinancial community

Investor Relations

Media, news,
or a blogger

Public Relations

Regulatory or
government agency

Legal

We encourage Dynatracers to speakat conferences and events. However, if
you’re planning to speak externally ata conference, on a webcast or podcast,or be interviewed in your capacity as a
Dynatrace employee, you should obtainapproval in advance from your manager
and the Dynatrace Public Relations team(unless you’re an authorized spokesperson
for the company).

You can reach Dynatrace Investor Relations at ir@dynatrace.com and Dynatrace Public Relations at pr-team@dynatrace.com.
Legal matters can be submitted to the Dynatrace Global Ethics & Compliance Office.

Page 35...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Communities

Our Company

Resources

Social MediaWe recognize and encourage Dynatracer participation in social media in a responsible manner.
Social media can be a great way to share information about Dynatrace and promote our brand.
However, social media mistakes can negatively affect our company’s reputation and how
customers and others perceive Dynatrace.
If you’re active on social media, this means that:• When posting or otherwise communicating about any
Dynatrace business, topics, or matters related to ourindustry, don’t misrepresent yourself—it should beclear that you’re a Dynatrace employee• If need be, to avoid any confusion, make it clear thatyour views are your own and that you’re not speaking
on behalf of Dynatrace. You shouldn’t tag a Dynatraceaccount if you’re sharing personal opinions unrelated
to Dynatrace business or matters• You shouldn’t disclose any confidential or private
information about Dynatrace’s business operations,products, or services or our customers, suppliers,
partners, or others unless you’ve been authorized
to do soPage 36• You should be mindful of what you post orcommunicate, even if it’s not related to
Dynatrace. Think carefully before postingor hitting “send”

If you come across something inaccurate orconcerning about Dynatrace on social media,
report it to the Dynatrace Social Media team,
who will look into the matter and handle thesituation. For additional information, refer
to our Social Media Policy.

...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our
Communities

Our Company

Our Communities

ResourcesIntroduction

Our People

Our Company

Our Communities

Resources

Environmental Responsibility
Dynatrace is committed to monitoring and managing ourbusiness operations to better understand and continuously
reduce our negative impact on the environment.
We believe that environmental sustainability andaccountability are critical for our future. As part ofour environmental initiatives, we should look foropportunities to:

When you’re evaluating new projects
or initiatives, consider environmental
or sustainability-related factors anddifferent alternatives when there is abusiness case to do so.

• Minimize our carbon footprint• Prioritize the use of clean energy• Adopt operationally sustainable practices in our
workplaces—such as turning off lights that aren’t
being used, minimizing waste, and looking foropportunities to recycle• Learn about environmental initiatives ongoingat Dynatrace

Page 38...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Company

Resources

Our Communities

Supply Chain Responsibility
We believe our commitment to conducting our businessin an ethical, legal, and environmentally and socially
responsible manner is a shared commitment that extends
to our vendors, contractors, subcontractors, consultants,
and other service providers.

action if we identify adverse human rights impacts
resulting from, or caused by, our business activities.
If you work with suppliers, you should familiarize yourself
with our Supplier Code of Conduct, which defines the basic
business practices that we require of our suppliers.

• Base decisions on key factors and objective criteriasuch as relevant experience, service quality,
pricing/cost, and reputation

We look to reflect our Core Values in our business withthird parties through our procurement policies andpractices, including requirements relating to human rights
and modern slavery, and adherence to our Supplier Codeof Conduct. We perform due diligence designed to identify
and prevent human rights risks to people in our businessand supply chain. We are committed to taking remedial

If you’re involved in selecting a supplier:• After a contract has been signed, understand what’s
been agreed to, monitor ongoing commitments, andaddress ongoing compliance• Follow applicable Dynatrace Procurement policies andpractices for completing any required risk
assessments/evaluations, receiving proposals/bids,
negotiating and contracting, receiving appropriate
approvals, and onboarding• Avoid potential or actual conflicts of interest(or disclose them if they arise)• Report any violations or concerns with suppliers using
one of our “Speaking up” channels

Volunteering and Charitable Giving
Dynatrace encourages you to become involved in your community and to give back. We contribute to our communities through our support of employee volunteer work.
For additional information, see the Volunteer Time Off section of our SharePoint.
Dynatrace makes corporate donations to various causes and organizations whose values and interests are consistent with our company’s. You should receive the applicable internal
approval before contributing any company funds or property to a charitable organization. You should request approval through the Dynatrace Global Ethics & Compliance Office.

Page 39...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Company

Our Communities

Resources

Political Process, Contributions,and Lobbying
Dynatrace respects your right to support political parties
and candidates of your choice and to take part in politicalactivities. However, furthering your own political activities
and interests—including campaign work or fundraising—should be done on your own time, outside of Dynatrace
work and without using our offices or other resources.
Business contributions to political campaigns are strictly
regulated by federal, state, and local law in the U.S. andmany other jurisdictions. You may not, except with theprior approval of the Chief Financial Officer, use any
Dynatrace funds for political contributions of any kind toany political candidate or holder of any national, state,
or local government office or any political action
committee, or PAC.

Similarly, any lobbying on Dynatrace’s behalf needs
to be coordinated and compliant with applicable laws.
Before contacting any government officials on behalf ofDynatrace about legislation, regulations, or government
policies, you must obtain approval in advance from the
Dynatrace Global Ethics & Compliance Office.

You should notify Dynatrace by contacting
the Dynatrace Global Ethics & Compliance
Office if you’re planning to run for anelected or appointed office.

There are also laws that sometimes restrict employees
and their family members from making personal
political contributions if Dynatrace is a vendor or supplierof the federal, state, or local government or bidding on
a new contract. If no restrictions apply to you, you may
make personal contributions to political candidates andcampaigns, but you may not represent that you
are making contributions on Dynatrace’s behalf.
Page 40...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Company

Our Communities

Resources

Administration of the CodeDynatrace’s management, under the supervision of the Dynatrace Board of Directors or a committee of the Board or, in the case of accounting, internal accounting controls, auditing or
securities law matters, the Board’s Audit Committee, is responsible to monitor compliance with the Code, and when appropriate, impose and enforce appropriate disciplinary measuresfor violations of the Code.
Dynatrace’s management periodically reports to the Board or the Audit Committee on our compliance efforts, including, without limitation, alleged violations of the Code and theactions taken with respect to violations.

Waivers and Amendments
We acknowledge that the Code won’t cover every situation or circumstance. Any waivers of the Code for executive officers or directors must be approved by the Dynatrace Board of
Directors, or, if permitted, the Audit Committee of the Board of Directors. If such a waiver is provided, we will promptly disclose it publicly if required by law or stock exchange rules.
Any waiver of the Code for other employees or officers may be made by the Chief Legal Officer, the Dynatrace Board of Directors, or, if permitted, the Audit Committee of the Board of
Directors.
Dynatrace reserves the right to amend, modify, suspend, or revoke this Code and any and all policies, procedures and programs in whole or in part, at any time, with or without notice,consistent with applicable law. Any amendments to the Code must be approved by the Board of Directors. We will promptly disclose amendments publicly if required by law or stock
exchange rules.

Page 41...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Company

Our Communities

Resources

Other Notices
This Code does not alter or modify the terms and conditions of your employment relationship, whether at will or governed by a written contract. The Code does not constitute an
employment contract or an assurance of continued employment with Dynatrace.
Dynatrace reserves the right to interpret this Code and these policies in its sole discretion as it deems appropriate.
Dynatrace supports our employees’ rights to speak publicly about matters of public concern or to engage in certain activities related to the terms and conditions of their employment.
The Code will be administered in compliance with applicable laws, rules, and regulations; thus, it should not be viewed as limiting your ability to: (i) file a charge or complaint about
potential violations of law with a governmental agency or commission, such as the U.S. Equal Employment Opportunity Commission, the U.S. National Labor Relations Board or the
U.S. SEC; (ii) participate or testify truthfully in any governmental investigation or proceeding; (iii) exercise any rights applicable to you under the U.S. National Labor Relations Act,
including assisting co-workers with or discussing any employment issue for the purpose of mutual aid or protection; (iv) share compensation information concerning you or others (so longas you are not sharing information about other Dynatracers that you obtain because your job responsibilities require or allow access to such information); or (v) discuss or disclose
information about unlawful acts in the workplace, such as harassment or discrimination or any other conduct that you have reason to believe is unlawful. Any communications anddisclosures related to these matters must be consistent with applicable law and the information disclosed must not have been obtained through a communication that was subject tothe attorney-client privilege or a similar legal privilege (unless disclosure of that information would otherwise be permitted consistent with such privilege or applicable law).
Dynatrace will not limit any right you may have to receive an award pursuant to the whistleblower provisions of any applicable law or regulation for providing information to the SEC or
any other government agency. Any provisions of any agreement between Dynatrace and any current or former employee that is inconsistent with the above language or that may limit
or interfere with the ability of any person to receive an award under the whistleblower provisions of applicable law will not be enforced by Dynatrace.
The Code is published electronically. The version of this Code that is posted at www.dynatrace.com and on Dynatrace’s SharePoint is the most up-to-date document and supersedes
any previous versions should there be any conflict or discrepancy.
@ 2024 Dynatrace, Inc. All rights reserved. Dynatrace and the Dynatrace logo are registered trademarks of Dynatrace LLC in the United States and other countries.
This Code was updated in August 2024.

Page 42...

Speaking Up?

Q&A

Dynatrace Code of Business Conduct & Ethics

Introduction

Our People

Our Company

Our Communities

Resources

Policy and Reference Links
AI - Responsible Use Policy
Anti-Corruption Policy
Corporate Communications Policies and Procedures
Data Protection Policy
Export Compliance Policy
Global Travel and Expense Policy
Human Rights Policy
Information Security Policy
Insider Trading Policy
IT - Acceptable Use Policy
Social Media Policy
Speak Up Portal
Supplier Code of Conduct
Whistleblower Complaint Handling Policy

Page 43

Dynatrace Code of Business Conduct & Ethics

08.09.24 _GEB_COC_cb/ao