Our CodeHow We Treat Each Other

Conducting Business With Integrity

Protecting Pure Storage

Code of Conduct 2024

Message from Charlie
Hello Pure Team,
Pure Storage is the only company that invests into your manager, Pure Storage Legal and Humandata storage and management as high technology

Resources, or through our hotline or web portal.

while our competitors treat it as a commodity.

We have zero tolerance for retaliation, so feelThis strategy will propel us to be not only the

comfortable and encouraged to speak up if you havetechnological leader, but the market shareconcerns or questions, as outlined in our Code.

leader in this $60B+ industry. Staying true to ourcompany culture and values is crucial for achieving
this goal. Pure Storage’s continued growth into
one of the most respected and admired brands
in technology will be a result of maintaining
our focus on our guiding principles: Integrity,
Honesty, Innovation and Respect for others.
At Pure Storage, conduct counts. Our Codeof Conduct should be your lodestar for how to
act when carrying out business on behalf ofPure Storage. Our code is a reference document
for you to familiarize yourself with and referto frequently. We are all held accountable foracting within these guidelines and upholding ourIntegrity is table stakes at Pure Storage andwe expect every Pure Storage employee toact with integrity both inside and outside thecompany. Lapses in integrity have no place here
and—to put it simply—will not be tolerated.
I expect each and every team member to upholdour values and commitments every day. Embracing
our principles and values ensures our collective
success as we build a world-class global company.
I look forward to working with you and continuing
to make Pure Storage a great place to work.
Thank you,standards. The Code also identifies additional
resources available to assist you in making ethicaldecisions, including raising questions or concerns

2Charlie Giancarlo, Chairman & CEO

Our CodeHow We Treat Each Other

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Code of Conduct 2024

Conduct Counts
01
02

Integrity in everything we do. If an action seems wrong, it iswrong. If something feels off to you, you must speak up. Check
with your manager, Pure Storage Legal, your Human Resources06

respect human rights and does not tolerate any form of forcedlabor in our supply chain. Likewise, we are committed to continually

Business Partner, Pure Storage Finance or other appropriate

reducing our environmental impact through the innovations inorganization listed in the Speak Up section of this Code.

our products, our operations, and throughout our supply chain.

Integrity means doing the right thing, and doing things right.
It means operating in the customer’s interest, in Pure Storage’s
interest, and in compliance with global laws and07

regulations–not in your own self interest.

03

Be a Global Citizen. Pure Storage has firm commitments toTreat others with respect. We encourage direct discussions on
business issues, even when that means respectful disagreement. The
diverse views and experiences of our highly talented global workforce

Respect Confidentiality and Privacy. Pure Storage
employees have obligations to protect any private data
entrusted to the Company and to protect the confidentialityof Pure Storage’s own information from disclosure.

08

Safeguard Our Information Security. Protecting
the Company also means strictly following our
information security policies and guidelines
whenever you are using Pure Storage systems.

provide Pure with the business advantage that can only come from a
broad comparison of ideas, and mutual respect is how we win together.

04
05
3

Win the right way. At Pure Storage, we are fierce competitors, but
we win our business the right way. We never engage in corrupt, anti-

09

competitive, self-dealing, or unfair trade practices of any kind.

Be honest and transparent in all financial matters. As an employeeof Pure Storage, you are accountable for accuracy and complete
honesty in any report that impacts Pure Storage financial reporting.

10

Prevent Waste and Protect the Company. Integrity
also means protecting our company assets, ensuring
their efficient use, and preventing waste.

When in doubt, Speak Up! Pure Storage employees are expected
to come forward with suspected violations of this Code using anyof the avenues described in the Speak Up section of this Code.

Our CodeHow We Treat Each Other

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Code of Conduct 2024

Protecting Pure Storage

Contents

Our Code4

How We Treat
Each Other

Why We Have a Code6

Our Code Applies to All

7Speak Up! Asking for Advice
and Raising Concerns

8• No Retaliation

8• What to expect when I report a Violation?

8

Integrity & Respect:
The Foundation of Our Culture

Conducting Businesswith Integrity
10

Discrimination, Harassment and Bullying 11
Commitment to Diversity,
Equity and Inclusion
Keeping Pure Storage a
Safe and Healthy Place

12

13

Protecting
Pure Storage

Compliance with Laws and Regulations

15

Avoiding and Disclosing
Conflicts of Interest

16

Bribery and Corruption

18• Compliance with Global Anti-Corruption Laws

18

• Meals Gifts and Entertainment

18• Special Considerations for
Government and State-Owned Customers

18

Accurate Records andFinancial Reporting

19

Respecting Human Rights

20

Compliance with Global Export
and Trade Rules

21

Environmental Stewardshipand Responsibility

22

No Insider Trading

23

Protecting Sensitive Data
and Respecting Privacy Rights

24

Physical Security and Useof Pure Storage Property

26• Expense Reporting26

IT Security and Acceptable Use

27

Protecting Pure Storage Intellectual
Property and Confidential Information

29• Respecting Intellectual Property Rights

29• Pure Storage Confidential Information30

Proper Handling of Media Requests
and Public Discussions

31

Waivers32

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Our CodeHow We Treat Each Other

Why WeHave a CodePure Storage Is Founded on
Integrity and Mutual Respect
We are steadfast in our commitment tolive out these principles through our corevalues—persistence, creativity, teamwork,ownership and customer-first. We are
passionate about maintaining the highest
standards of business conduct and ethics,
guided by this Code of Conduct. Our
Code reflects our business practices andbehavioral principles, and will help guideyou in preserving our reputation and values.
As Pure Storage continues to grow, weneed to evolve and improve in everything
we do. If you have suggestions for how we
can improve this Code of Conduct, please
send them to Legal@purestorage.com
or to any of the other resources listed
below in our “Speak Up!” section.

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Our CodeHow We Treat Each Other

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Our Code
Applies to All
Our Code Applies With Equal Force to
All Pure Storage Employees, Contractors,
Officers, and Board Members
We also require that our partners, suppliers, and vendors abideby these standards when working on behalf of Pure Storage.
Our requirements for partners and suppliers are further
outlined in our Partner and Supplier Codes of Conduct.
This Code—in addition to our policies and procedures—lays out
our key expectations and rules for ethical conduct. We also trustand expect you to apply common sense and act in accordancewith our core values at all times, even without explicit guidance.
Violations of these standards may result in disciplinary action,
which range from a warning to termination of employment and,in appropriate cases, legal action or referral to law enforcement.

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Our CodeHow We Treat Each Other

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Speak Up!
Asking for Advice and Raising Concerns

Code of Conduct 2024

No Retaliation
If something concerns you, we need to know. We have zerotolerance for retaliation or threats of retaliation of any kind

Employees who have questions about this Code or about whether certain conduct could be improper oragainst good faith reporters. If you believe you may be theunlawful should seek advice and clarification. Employees most often seek advice in the first instance fromsubject of retaliation, please let your Human Resources

their manager, but there are many alternative avenues available to employees, such as their Human Resources

Business Partner, Pure Storage Legal, or Pure Storage’s

Business Partner, Pure Storage Legal, Pure Storage Employee Relations, or any of the other resources listed

Employee Relations team know. Retaliation of any kind will

below or elsewhere in this Code. Pure Storage contractors may seek advice from their managers or use

not be tolerated and will result in termination of employment

Pure Storage’s Speak Up portal.

from Pure Storage or, for partners and suppliers, termination

Raising concerns about suspected or potential violations of this Code, Pure Storage policies, or the law
is critical to Pure Storage’s ability to identify problems early on and take corrective action. Pure Storage
employees and business partners are empowered and expected to report any suspected violations toPure Storage through any of the reporting avenues described in this Code. The reporting avenues described
below are also available to third parties with no relationship to Pure Storage who may become aware ofsuspected violations.
Pure Storage people managers have special obligations to foster a culture of integrity and encourage theirteams to report and discuss their concerns. People managers also have an obligation to immediately speak up
if they suspect, hear of, or see possible violations of this Code. This means if you are a people manager andone of your reports raises a concern to you, you should listen attentively, and then escalate their concerns toPure Storage Legal or Human Resources by reaching out to the contacts below.

of your business relationship with Pure Storage.

What to Expect When I Report a
Violation or a Suspected Violation?
Whichever avenue you choose to report your concerns,
you will be contacted within two business days regarding
next steps from either our Employee Relations or Legal
Compliance team. All concerns are thoroughly investigated,
but what the investigation looks like will depend on thespecific facts of the matter and the types of concerns raised.
Our investigators will work with you and make every effort
to keep the investigation as confidential as possible and

How To Speak Up! Report Concerns To:• Your manager or Human Resources Business Partner• Pure Storage Employee Relations• Pure Storage Legal: legal@purestorage.com

may not be able to share details of the resolution with you
to protect the privacy of other parties involved. For moredetailed explanations of the process and other resources• Pure Storage Chief Compliance Officer: complianceofficer@purestorage.com

about reporting, please review the Employee Relations• Speak Up Tool (web portal with options for anonymous reporting)

Investigations Process Overview and/or visit the• The Audit & Risk Committee of the Pure Storage Board of Directors: auditcommittee@purestorage.com

Employee Relations HUB Page.

• Pure Storage Internal Audit: ia@purestorage.com

8

as allowed by law. Depending on the facts of the case, weOur CodeHow We Treat Each OtherHow We Treat
Each Other

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Our CodeHow We Treat Each Other

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Protecting Pure Storage

Integrity &Respect
The Foundation of Our Culture
Integrity and respect are the cornerstone of how we operate
at Pure Storage. Whether you are on Pure Storage premises,
acting on behalf of Pure Storage with third parties (like ourcustomers, partners, vendors, etc.), or wearing the Pure Storage
logo to run your errands, you represent Pure Storage in all
you say and do. Pure’s reputation and success depend on you
and your ability to act ethically and respectfully at all times.
Pure Storage employees are expected to treat one anotherand our business partners and customers with respect andprofessional courtesy at all times. We have a dynamic andinnovative culture of creative, talented professionals who standout from the crowd, and we expect all of our employees tofoster this environment by bringing their ideas to the table andencouraging one another to innovate and succeed together.
Professional debate and discussion—including disagreement—of ideas and differing perspectives is paramount to the innovation
process. By contrast, bullying, discrimination, harassment(including, but not limited to, sexual harassment), and otherharmful conduct have no place at Pure Storage. Failure to meetcommon standards for respectful conduct can result in negative
employment consequences, including termination of employment.

RELEVANT LINKS
10•

Employee Relations HUB Page

Our CodeHow We Treat Each Other

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Protecting Pure Storage

Discrimination,
Harassment and Bullying
Pure Storage Is Committed to a
Culture of Integrity, Professionalism, and Respect
We expect all of our employees, and anyone we do business with, to actively foster an inclusive work environmentthat is free from harassment (including but not limited to, sexual harassment), discrimination, or bullying of any kind.
Respectful, professional conduct furthers our vision, promotes productivity, minimizes internal disputes, and bolsters
our already stellar culture.
As part of our commitment to diversity and inclusion, Pure Storage expects every employee and contractor to show

Any Type of Bullying
Is Prohibited
Examples of prohibited bullying include:• Screaming• Name calling• Stealing• Threatening, intimidating,or cruel behaviors• Deliberately humiliating a person• Retaliation or stealing work credit

respect for all co-workers, customers, partners, suppliers, vendors, and anyone else with whom we do business.

We encourage you to immediately report

All Pure Storage employees and contractors are expected to regularly complete anti-harassment and anti-

bullying incidents to a manager, your Human

discrimination training as a condition of employment or work engagement. Pure Storage absolutely prohibits

Resources Business Partner, Employee

harassment or discrimination on the basis of race, ethnicity, color, religion (including religious dress and grooming

Relations, or any of the other reporting

practices), sex, gender identity, gender expression, sexual orientation, national origin, ancestry, age, marital status,

resources identified in this Code.

military or veteran status, genetic information, or any physical or mental disability, whether actual or perceived, taking
protected leaves (e.g., maternity leave, parental leave, sick leave, disability leave, etc.), pregnancy, childbirth, orother related medical conditions. For more information please see our Zero Tolerance for Workplace Discrimination orHarassment Policy.
For more information, please see our Speak Up! Policy. Reports of harassment (including but not limited to, sexual
harassment), discrimination and retaliation will be promptly, effectively, thoroughly and objectively investigated.
Disciplinary action up to and including termination of employment will be taken on a case-by-case basis, as
appropriate and based on the outcome of any investigation. For more details, see “What to expect when I report a
RELEVANT LINKS

Violation or a Suspected Violation,” above on page 08.

11•

Speak Up Policy•

Zero Tolerance for Workplace
Discrimination or Harassment Policy•

Supplier Code of Conduct•

Partner Code of Conduct•

Equal Employment Opportunity

Our CodeHow We Treat Each Other

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Commitment toDiversity, Equity
and Inclusion

Pure Storage ERGs

Pure Storage Is a Company Driven
by Innovation and Creativity
We maintain our drive and vision by valuing unique perspectives andcelebrating our employees’ diverse backgrounds, cultures, experiences, andɿ Learn More

ɿ Learn More

ɿ Learn More

ɿ Learn More

ɿ Learn More

ɿ Learn Moreideas, and we create teams that foster relationships that are unconditionally
inclusive and bring out the best of our individuals. Pure Storage
employees, and especially people managers, are expected to support
diversity, equity, and inclusion in our global workforce and culture.
Our employee resource groups (ERGs) serve a critical role in advancing
inclusion at Pure Storage. ERGs build connections, a strong sense ofcommunity, and provide development opportunities for our employees. In
many ways, they are the fabric of our inclusive culture. All Pure Storage
employees are encouraged to join ERGs as community members and allies.

12Our CodeHow We Treat Each Other

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Code of Conduct 2024

Protecting Pure Storage

Keeping Pure Storage a
Safe and Healthy Place
Pure Storage Is Committed to aViolence-Free Work Environment
We do not tolerate violence or the threat of violence in our offices, other places of work, or in work-related
situations, including virtual meetings and Pure Storage events.

Remember That You Are a
Pure Storage Representative
The health and safety of our employees are paramount.
We trust our employees to exercise prudent judgment
when it comes to consuming alcohol. You represent
Pure Storage—whether in the office, at an after-hours
work activity, an offsite, or Pure Storage-sponsored
event. Never drink to the point of impairment,
inappropriate behavior, or in a way that endangers the

You may not bring any weapon—such as a gun, knife, taser, etc.—into any Pure Storage office, a customer

safety of yourself or others. Failure to meet our highor partner site, or any Pure-sponsored event. Actual violence, threats of violence, or carrying weapons instandards for the health and safety of our employees

connection with your work at Pure Storage can result in adverse employment action, including termination andcan result in negative employment consequences,referral to law enforcement. You must report any suspicious activity at any Pure Storage office to Pure Physicalincluding termination of employment.

Security & Safety immediately, by Slack, email, or in Santa Clara by calling 650-243-0349. In case of potential
violence or danger, immediately contact local law enforcement and then report it to your manager, Human
Resources Business Partner, Employee Relations, or Pure Storage Legal.

We also expect all employees to comply withapplicable federal, state and local laws regarding
drugs if engaged in Pure Storage business. You may
never engage in the unlawful manufacture, distribution,

For Immediate Threats to Health or Safety:
Contact local law enforcement and Pure Storage Physical Security & Safety at
physicalsecurityandsafety@purestorage.com, on Slack, or, in Santa Clara,by calling 650-243-0349.

dispensing, possession, sale, or use of a controlled
substance in the workplace. Failure to comply
can result in negative employment consequences,including termination of employment.

RELEVANT LINKS
13•

Environmental Health and Safety PolicyOur CodeHow We Treat Each Other

Conducting
Business
With Integrity

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Our CodeHow We Treat Each Other

Conducting Business With Integrity

Compliancewith Laws andRegulations
At Pure Storage, We Follow the Law
We are a global company and our success depends on operating
within legal requirements and cooperating with local, national,
and international authorities. As a Pure Storage employee, you
are required to understand the laws, rules, and regulations
applicable to Pure Storage generally and in particular toyour job responsibilities. This Code and many of our policies
provide detailed guidance on certain areas of the law, but yourviolation of any law in connection with your employment can
result in termination of employment and even referral to law
enforcement. If you have a question or need advice about legal
compliance, seek answers from your manager, Pure Storage
Legal, or reach out directly to legal@purestorage.com.

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Code of Conduct 2024

Our CodeHow We Treat Each Other

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Avoiding and Disclosing
Conflicts of Interest

Romantic Relationships
Between Co-Workers
We recognize that romantic relationships

Pure Storage Employees Are Expected to Act at All
Times in the Best Interest of the Company

can sometimes happen in the workplace.

Any kind of self-dealing is strictly prohibited. This means you must avoid influences that conflict with the interests of

employee should reach out to their Human

Pure Storage or any relationship that might deprive Pure Storage of your undivided loyalty in the Company’s businessdealings. Not every conflict can be avoided, so transparency should be your guiding value. Undisclosed conflicts ofinterest can have serious adverse repercussions for your employment at Pure Storage, including termination from
employment. Conflicts of interest can arise in many different situations, but the most common are described below:

Side Businesses
Our employees are creative, talented, and dynamic individuals with many talents. Whether it is a side business or apassion project, having a second source of employment or an ownership stake in a small business that you work on
with your own resources and on your own time may be acceptable depending on the time commitment, nature of thework, who your customers are, and other factors. All requests to participate in a side business must be reviewed andapproved by Pure Storage Legal (legal@purestorage.com) and your manager. Please note that working for a competitor
will always be forbidden and that with a few rare exceptions, you are also generally prohibited from working for or inconnection with a customer, vendor, supplier, or partner.

Romantic or Family Relationships
Having a close romantic or family relationship with another Pure Storage employee or with owners or employees ofPure Storage vendors, partners, or customers may be a conflict of interest. For example, if you have a parent, romantic
partner, spouse, sibling, or child who also works at Pure Storage or is applying for employment at Pure Storage,
you must notify Pure Storage Legal immediately to discuss the potential conflict and make sure that appropriate
safeguards are in place. Likewise, if you have a close family member who works at a Pure Storage partner or a
Pure Storage vendor, especially if that family member is an owner or controller of that company, you must disclose that
relationship to Pure Storage Legal (legal@purestorage.com). If you are concerned about a family relationship conflict,
you should err on the side of disclosure.

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Code of Conduct 2024

Employees who find themselves in a romantic
relationship with another Pure Storage
Resources Business Partner or the Employee
Relations team to disclose the relationshipand discuss any potential conflicts of interest.
Romantic relationships between a manager anda subordinate or between an employee andanother employee who has responsibility for
determining the success of another employee,such as a business partner in anotherfunction, can create unnecessary risk anduncomfortable work environments. Dependingon the circumstances, intra-office relationships
may require changes to work arrangements,
including reporting structure, organizationalchanges, or separation from employment.

Our CodeHow We Treat Each Other

Conducting Business With Integrity

Protecting Pure Storage

Board and Advisory Roles
Serving on boards, especially for non-profits, or in advisory roles can be excellent ways to build on yourexpertise, become a thought leader, and deepen your professional network. Such roles are generally
acceptable, but must be cleared by Pure Storage Legal. If you are asked to join a board or take an advisory
position of any kind, please reach out to Pure Storage Legal (legal@purestorage.com) immediately to discuss.
Please also be aware that there are special rules regarding when you can identify yourself as a Pure Storage
employee as part of your service, and see the section below regarding Media and Public disclosures.
If you think that you may have a conflict of interest with Pure Storage or are considering entering into a
relationship or side venture that you think has the potential to be a conflict, you must immediately disclosethat interest to Pure Storage­—ideally before entering into the relationship—and seek guidance fromPure Storage Legal on whether it will impact your employment at Pure Storage. Once you have disclosed the

Evaluating a Potential
Conflict of Interest
Factors that should be considered
are, among others:• Any potential adverse or beneficial impact
on our business, or relationships with acustomer, vendor or other business partnerof Pure Storage• The nature of Pure confidential information

potential conflict to your manager and your Human Resources Business Partner, you will need to complete

to which the employee has accessa written request for your potential conflict to be reviewed and cleared by Pure Storage Legal by emailing• The extent to which it would result in

legal@purestorage.com. You should keep in mind that with proper safeguards, many conflicts of interest can bedirect or indirect benefit to the employee

disclosed and cleared by Pure Storage, but some cannot. If a potential conflict of interest cannot be cleared,or a customer, vendor or business partner

you would need to either end the conflicting relationship or terminate your employment with Pure Storage.

of Pure Storage

Receiving Gifts and Hospitalities From Third Parties Can Be A Conflict of Interest, Too
Accepting gifts and hospitalities from third-parties, such as vendors or partners, can create an actual or
potential conflict of interest. Receiving nominal branded swag-type gifts (t-shirts, mugs, etc.) from is generally
acceptable, but accepting more lavish gifts can create the appearance of impropriety and is generally• The impact on the performance,
responsibilities or morale of the employee
or others at Pure Storage• Whether it would enhance or support a

prohibited. In particular, Pure Storage employees are prohibited from accepting gifts of travel, including flights,

competitor’s position; and the extent toaccommodations, and other perks from vendors without prior approval of Pure Storage’s Chief Legal Officer.

which it would appear improper to an

You should consult the section below on giving gifts (Page 18) for further details. If you have been offered a gift

outside observer

or hospitality that you have questions about, please reach out to legal@purestorage.com before accepting.

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Code of Conduct 2024

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Protecting Pure Storage

Bribery and Corruption
Pure Storage Conducts All of Its Global Business With Integrity

Zero Tolerance for
All Business Partners
Pure Storage’s zero tolerance for corruption

This means we do not pay bribes, kickbacks, or engage in any type of corrupt activity or scheme. Engaging in corrupt

applies with equal force to all of our businessconduct of any kind in connection with Pure Storage business is grounds for termination of employment and referral topartners, as explained in our Partner Codelaw enforcement authorities.

of Conduct and Supplier Code of Conduct.

Compliance with Global Anti-Corruption Laws

Under U.S. and international anti-bribery laws,
Pure Storage can be held responsible for thePure Storage is a global company and we comply with all applicable national, state, local, and international anti-

bad acts of its partners and vendors if theycorruption laws, including the United States Foreign Corrupt Practices Act and the United Kingdom Bribery Act, andare made in connection with Pure Storage

local anti-corruption laws where we do business.

Meals, Gifts, and Entertainment
Gifts and hospitalities are a business custom and tradition in many places around the world where Pure Storage does
business, but as a Pure Storage employee you must be mindful that gifts, meals, and entertainment can easily create
an appearance of impropriety. All gifts, meals, entertainment, and travel given by Pure Storage to a third-party mustcomply with our detailed Travel & Expense Guidelines. Under these Guidelines, most gifts and many other categoriesof spend require pre-approval by Pure Legal, Pure Finance, and your VP and build in sufficient time to obtain suchapprovals. You should reach out to legal@purestorage.com if you have particular questions or concerns.

Special Considerations for Government and State-Owned Customers
When you interact with public sector customers, you must be especially cautious to avoid even the appearance ofbusiness. If you as a Pure Storage employee
suspect or are concerned that a third-party may
be engaging in corrupt conduct on behalf ofPure Storage or in connection with Pure Storage
business, you must speak up immediately
by reaching out to legal@purestorage.com
or our Speak Up hotline. Similarly, if you
suspect or believe that a business partnerof Pure Storage may be engaging in corrupt
or unethical conduct, please reach out tolegal@purestorage.com immediately.

impropriety. Gifts and meals that could be acceptable or even typical in the private sector can be illegal or create theappearance of impropriety in the public sector. You should consult Pure Storage’s Anti-Bribery and Anti-Corruption
Policy closely before offering any gifts or meals to public sector employees, keeping in mind that most public sector
gifting requires pre-approval by Pure Storage Legal (via a PERC ticket). You are responsible for learning and strictly
following special laws and rules around gifting and hospitality for government employees, remembering that thesecan include employees of government-owned enterprises, even where those enterprises compete in the private
market, and that many public sector employees are not allowed to accept gifts or meals or any kind. If you havequestions about the rules that apply in your region or to your customers, please reach out to your manager orlegal@purestorage.com at any time to discuss.

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RELEVANT LINKS•

Anti-Bribery and Anti-Corruption Policy•

Travel & Expense Guidelines

Our CodeHow We Treat Each Other

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Accurate Records andFinancial Reporting

Cooperation For All
Pure Storage Employees
All employees must cooperate fully with
Pure Storage Finance and Legal, as well as

Pure Storage’s Backbone Is Accuracy

our independent public accountants, respond

Our corporate and financial books and records serve as the foundation for managing our business and meeting

to their questions with candor and provide

our obligations to customers, suppliers, creditors, employees and others with whom we do business, andthem with complete and accurate information

we rely upon these records to produce accurate and complete reports for our management, stockholders,to help ensure that our books and records,

creditors, and governmental agencies, including the U.S. Securities and Exchange Commission (the “SEC”).

as well as our reports filed with the SEC, areThis means that it is critically important that all of our records and accounts accurately, completely,
and fairly reflect, in reasonable detail, our assets, liabilities, revenues, costs, and expenses, as well
as all transactions and changes in assets and liabilities. Making false or misleading entries is strictly
prohibited, and can result in termination from employment and referral to law enforcement.

We require that:• No entry be made in our books and records thathides or disguises the nature of any transaction

These rules apply to all official
Pure Storage books and records,
including but not limited to:or of any of our liabilities or mis-classifies any• Financial statements and public filings;

transactions as to accounts or accounting periods;• Travel bookings and Expense reports• Transactions be supported byappropriate documentation;• The terms of sales and other commercial transactions
be reflected accurately in the documentation for thosetransactions and all such documentation be provided
and reflected accurately in our books and records;• Employees carry out, support, and comply
with our system of internal controls; and• No cash, credits or other assets be maintained for any
purpose in any unrecorded or “off-the-books” fund.

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Code of Conduct 2024

Protecting Pure Storage(see more below on Page 26;

accurate and complete. For employees involvedin Pure Storage sales, this includes timely andaccurate completion of your quarterly sales
certification. Failure to fully cooperate withsuch inquiries or to complete your quarterly
sales certification in a timely manner can resultin disciplinary action, including termination.

Additional Reporting Resources
You may also report issues or• Purchase Requisitions and Purchase Orders;concerns directly to our Internal Audit team• Credit Notes;

at ia@purestorage.com or the Audit and• Import/Export documentation;• Sales certification;

Risk Committee of our Board of Directors byemail to: auditcommittee@purestorage.com.

• Tax filings and documentations;• Invoices and sales orders; and• Product testing and performance metrics.

RELEVANT LINKS•

Travel & Expense Guidelines•

Guidance on Purchase
Requisitions and Procurement•

Pure Finance Intranet Page

Our CodeHow We Treat Each Other

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Protecting Pure Storage

Respecting
Human Rights
Pure Storage Is Committed to
Respecting Human Rights and Fair Labor
Standards in Our Own Business andThroughout Our Global Supply Chain
Pure Storage strictly forbids any forced labor, slavery, childlabor, unsafe working conditions, conflict minerals, or humantrafficking anywhere in its supply chain or in connection withany Pure Storage business in any way. This rule applies toall Pure Storage employees and contractors anywhere in
our global workforce and to all Pure Storage Suppliers.
In addition to Pure Storage’s own Supplier Code of Conduct,
Pure Storage is a member of the Responsible Business Alliancesand Pure Storage requires all of our employees, contractors,
partners, and suppliers to practice the principles embodied
in the Responsible Business Alliance (RBA) Code of Conduct,
which prohibits the use of forced labor, indentured labor, or
involuntary/child labor and human trafficking and requires
compliance with global labor standards and applicable laws
(worker health and safety, the environment, business ethics).
Pure Storage employees, contractors, partners, andsuppliers are expected to raise any concerns about laboror human rights abuses immediately via the company’s
Speak Up hotline or to legal@purestorage.com.

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RELEVANT LINKS•

Supplier Code of Conduct•

Statement Against Human Trafficking•

Conflict Minerals Statement•

ESG ReportOur CodeHow We Treat Each Other

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Protecting Pure Storage

Compliance with
Global Export
and Trade Rules
Pure Storage Is a Global Company
and We Deliver Products, Spare Parts,
and Services to Customers in Many
Countries Around the WorldWe are committed to complying with all applicable export laws andregulations—including trade sanctions—in all countries where we
operate and conduct business, and especially to all global export
laws and policies that seek to control nuclear proliferation, missile
technology, and/or biological weapons.
Trade and export regulations are complex and often of a technicalnature. If you have questions about the compliance of a particulartransaction or more general questions about how export laws apply to
Pure Storage and the countries where we do business, we encourage
you to reach out directly to our Legal Export and Trade and Traffic
teams by emailing export@purestorage.com.
Keep in mind that violations of trade and export laws can result inserious consequences for the Company and you as an individual,
including significant fines and jail time. Employees may also be subject
to disciplinary action up to and including termination. If you areconcerned about a potential violation of export or trade laws, you are
obligated to speak up immediately at the resources listed in this Code.

RELEVANT LINKS
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Pure Storage Export Policy Statement

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Protecting Pure Storage

Environmental
Stewardship andResponsibility
Reducing Environmental Impact andLowering Carbon Emissions Is Part of theCore Innovation of Pure Storage Products
Our products drive out direct carbon usage by up to 85%
when compared to our flash competitors, shrink overall
data center footprints for our customers, and reduce
product replacements and associated e-waste.
Our environmental stewardship also includes improving
the sustainability of our operations. The most significant
impacts in this area are related to our offices, data
centers, and our global supply chain. We are committed
to continually increasing our impact on the global effort
to fight climate change and reduce carbon emissions.

RELEVANT LINKS

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Environmental Health and Safety Policy•

ESG Report•

Pure Storage Insider Trading PolicyOur CodeHow We Treat Each Other

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Code of Conduct 2024

Protecting Pure Storage

No Insider
Trading
As a Pure Storage Employee, Director,or Contractor, You Are Required to
Abide by Federal Insider Trading and All
Other Laws That Protect Our Investors
If you gain access to confidential (or “inside” or “non-public”)
information about Pure Storage business (or aboutcompanies with whom we do business) in the courseof your employment, you are not permitted to use or
share that information for stock trading or for any otherpurpose except to conduct Pure Storage business.
This includes sharing that information with third-parties(“tipping”) who then engage in stock transactions. Pure Storage
employees are also required to abide by periodic “blackout”
periods that may impact your ability to sell or buy Pure Storage
stock during certain windows of time. It is your responsibility
to understand these obligations and be aware of when thecompany’s trading window is open or closed. Please refer toPure Storage Insider Trading Policy for more information.

RELEVANT LINKS

23•

Environmental Health and Safety Policy•

ESG Report•

Pure Storage Insider Trading PolicyOur CodeHow We Treat Each Other

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Protecting Pure Storage

Protecting Sensitive
Data and Respecting
Privacy Rights
Safeguarding the Personal Data Provided to Us byPure Storage’s Customers, Employees, Partners, andOthers Is Critical to Building and Maintaining Trust
Pure Storage is committed to complying with all applicable data protection laws and has internaland external policies on collecting, processing, and protecting data.
We expect every Pure Storage employee to take a shared ownership in our commitment to data privacy.
All Pure Storage employees are required to regularly complete data privacy training, and Pure Storage
has a Privacy Council consisting of key stakeholders from each major business unit that meets quarterly
to address privacy needs and risks facing the Company.
As a Pure Storage employee, you must not disclose Pure Storage data outside of the Company or tounauthorized parties within the Company. If you know or suspect that any personal, confidential, orother sensitive information held by Pure Storage, or on our behalf by a third-party, has been improperly
disclosed, breached, stolen, or leaked (even inadvertently), you must contact Pure Storage Legal’s
Privacy team immediately by reaching out to privacyatpure@purestorage.com.

Personal Data
Personal data is broadly defined to include any data that could make an individual person identifiable.
Emails (including business emails), names, and addresses, are all personally identifiable information that

RELEVANT LINKS

is subject to protection from disclosure under the various privacy laws governing the regions in which
Pure Storage does business.

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External Privacy Statement•

Pure Data Retention and
Destruction Standard•

Document Retention and Destruction
Schedule and Guidelines•

Privacy@Pure Intranet Page

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Code of Conduct 2024

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Physical Security
and Use ofPure Storage Property
As a Pure Storage Employee, You Must Protect
Our Assets and Ensure Their Efficient Use
Theft, carelessness, and waste have a direct impact on our profitability. Pure Storage
assets, such as office supplies, computer equipment, services, facilities, and buildings,
are expected to be used only for legitimate business purposes, although incidental
personal use may be permissible. Food and beverages provided by Pure Storage
are intended as a benefit during hours of service to Pure Storage.
You may not use our corporate name, any brand name or trademark owned or associatedwith Pure Storage or any letterhead stationery for any personal purpose. If you are notsure if a certain use of Pure Storage assets is allowed, contact your manager.

Expense Reporting
Pure Storage employees should apply the principles of integrity, transparency, and accuracy
when expensing charges to the Company. You should take care when spending Company funds
to closely follow Pure Storage’s Travel & Expense Guidelines. Failure to report your expenses inan accurate, complete, and timely manner harms the Company and may result in your expense
reports being rejected. People managers have a further responsibility to carefully review andmonitor the expenses of their teams. People managers who approve expenses of their reports
without thorough review are failing to meet an important baseline performance expectation andmay be subject to discipline. Dishonesty, fraud, or abuse of your expense account can resultin discipline, including termination from employment and even referral to law enforcement.

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Code of Conduct 2024

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Protecting Pure Storage

IT Security andAcceptable Use
Pure Storage Operates With the Highest
Standard of Information Security
Pure Storage employees, contingent workers, and business
partners are expected to do their part to prevent unauthorizedaccess to Pure Storage systems and to protect the devices andinformation entrusted to them. This means that Pure Storage
employees and contingent workers must familiarize themselveswith our Information Security Policy and Acceptable Use Standard,
being mindful that these standards and policies are updated atleast annually.

RELEVANT LINKS

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Information Security Policy•

Acceptable Use Standard•

Investigations Safeguards Standard•

Expanded Security Region(ESR) Equipment Standard

Our CodeHow We Treat Each Other

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Protecting Pure Storage

In addition to following all relevant information security policies
and internal controls, Pure Storage employees must:• Safeguard passwords and any information or hardware that is assigned to them;• Not use Pure Storage systems to commit an illegal act or to access or transmit content thatis sexually explicit, harassing, offensive, or otherwise unlawful or objectionable;• Connect to Pure Storage networks only with approved systems and devices;• Not remove or alter any installed security or management mechanisms;• Not introduce any vulnerability or malicious code (e.g., backdoor, virus,
trojan, or exploit) into any Pure Storage system or product;• Not access the internal computer system or other resource of another entity without express
written authorization from the entity responsible for operating that resource (aka hacking).

Precautions for Overseas
Travel With Pure Storage
Devices and Equipment
Pure Storage employees should be awarethat when traveling abroad on Pure Storage
business, you must consult the Expanded
Security Region (ESR) Equipment Standard
and country list to see whether, based on yourdestination, you are required to obtain and use
special loaner device(s), such as laptops, fromthe IT Help Desk during your travels. In general,• Fully cooperate during a security incident investigation by providing all relevant and accurate

Pure Storage employees are prohibited frominformation in a timely manner, granting necessary access to systems under investigation,

taking their Pure Storage devices or loanersand following any other required measures to contain and resolve the incident.
• Complete all assigned security awareness training.
Because electronic and computing devices are necessary for the performance of many job duties as well as many
personal tasks, it is easy to forget that these devices, and the data within, are the sole property of Pure Storage and must
be used only in accordance with Pure Storage policies. If you use a personal device, such as a mobile phone, to access
Pure Storage systems, the information continues to belong solely to Pure Storage. Pure Storage does not actively monitor
its employees’ systems use, but we reserve the right to do so in accordance with our Investigations Safeguards Standard.

Concerned About A Security Issue:
If you believe someone may have gained unauthorized access to Pure Storage systems or that
Pure Storage confidential information may have been exposed to unauthorized parties, you havean obligation as a Pure Storage employee to speak up immediately, either through our Speak Up
hotline or infosec@purestorage.com or report the issue via PERC.

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into Extended Security Region countries on
personal travel. Exceptions to this rule will
require executive approval.

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Protecting Pure Storage
Intellectual Property andConfidential Information
Pure Storage Respects the Intellectual Property
Rights of Others and Expects the Same in Return
With our employees, intellectual property (e.g., patent, trademark, copyright and trade secret) is
one of our greatest assets, and it is up to every employee to help protect it. If you’re developing a
product or services or collateral that uses content, like third-party media, that does not belong toPure Storage, you must check with Pure Storage Legal first.

Respecting Intellectual Property Rights
We expect employees to respect all laws related to patents, trademarks, trade secrets,
copyrights, rights of publicity, and other intellectual property and use the Company’s intellectual
property in accordance with our policies or guidelines. This means when you join Pure Storageas a new employee, you must not bring any property or proprietary or confidential information ofyour prior employer, including documents like emails, slide decks, and spreadsheets with you or
install them on Pure Storage systems, including your assigned laptop or mobile device. Likewise,
when you leave Pure Storage, you are forbidden from taking any information with you or fromproviding Pure Storage proprietary or confidential information of any kind to your new employer.

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Our CodeHow We Treat Each Other

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Proprietary Information
Acquiring proprietary information through improper means, possessing trade secret information that was improperly
obtained, or inducing improper disclosure of confidential information from past or present employees of othercompanies is prohibited, even if motivated by an intention to advance Pure Storage interests. If you somehow obtain
information that may constitute a trade secret or other confidential information of another business, or if you have any
questions about the legality of the information gathering, consult with Pure Storage Legal.

Pure Storage Confidential Information

What’s Confidential?
Confidential information includes non-public
information that might be of use to competitors
or harmful to Pure Storage or its customers if
disclosed, such as business plans, technicalstrategies, financial information, information
related to Pure Storage products, data andAs an employee of Pure Storage, you may learn of information about Pure Storage that is confidential and proprietary.

results, inventions, works of authorship, trade

You also may learn of information before it is released to the general public. We expect that you keep the Company’s

secrets, software, patents, patent applications,information confidential, as unauthorized use or disclosure of Pure Storage’s intellectual property or other confidential

licenses, suppliers, manufacturers, customers,

information can lead to their loss to competitors or serious loss of value. In addition, there may be times when you

market data, personnel data, personallylearn confidential information about other companies before that information has been made available to the public.

identifiable information pertaining to our

You must treat this information in the same way you treat Pure Storage confidential and proprietary information. Thereemployees, customers or other individuals

may even be times when you must treat as confidential the fact that we have an interest in, or are involved with,(including, for example, names, addresses,

another company. We expect you to keep confidential and proprietary information confidential unless and until that

telephone numbers and social security

information is released to the public through approved channels.

numbers), and similar types of information

You must refrain from discussing confidential or proprietary information with outsiders and even with other employeesof Pure Storage, unless those fellow employees have a legitimate need to know the information in order to performtheir job duties. Unauthorized use or distribution of this information could be illegal and result in civil liability and/or
criminal penalties.
You should also take care not to inadvertently disclose confidential information. Devices and materials that containconfidential information should be stored securely. Unauthorized posting or discussion of confidential information
concerning our business, information or prospects on the Internet is prohibited. Be cautious when discussing sensitive
information in public places like elevators, airports, restaurants and “quasi-public” areas in and around our place ofbusiness. All Pure Storage emails, voicemails, and other communications are presumed confidential and should not be
forwarded or otherwise disseminated outside of Pure Storage except where required for legitimate business purposes
and only with appropriate confidentiality markings.

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Code of Conduct 2024

provided to us by our customers, suppliers
and partners. This information may beprotected by patent, trademark, copyrightand trade secret laws.

Our CodeHow We Treat Each Other

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Code of Conduct 2024

Protecting Pure Storage

Proper Handling ofMedia Requests andPublic Discussions
Pure Storage Employees Are Not Authorized to
Speak on Behalf of the Company to the MediaThis includes speaking with reporters “off the record” or for background or under any terms of confidentiality or

Our Guidelines require,among other things:• Identify yourself honestly and clearly andstate your affiliation to Pure Storage;• Take care to make sure the information
you post is truthful, accurate, andprecise (particularly when using
metrics and statistical information);• Ensure the information you provide issecrecy regardless of whether the employee is contacted in a formal or personal capacity. Before you speak to thecomplete and not restate or alter the

media about Pure Storage, you must seek approval from our Chief Legal Officer and/or VP of Global Communications.

language of information in a way thatIf part of your role at Pure Storage involves contributing to public-facing social media content, such as blogs, wikis,social networks, virtual worlds, or any other kind of social media content, you must familiarize yourself with and follow
our Social Media Guidelines.

would contribute to misunderstandings;• Give proper credit and attribution when
you re-post or cite others’ ideas;• Protect confidential company information,

Many Pure Storage employees also choose to engage in various social media platforms in a personal capacity on their

including trade secrets and cybersecurity,

own time. You should be mindful when using social media that your activities and statements should be consistentand do not post publicly anythingwith the standards described in this Code of Conduct. If you endorse products or services, make political statements,that should be kept confidential;

or endorsements online in an account that identifies you as a Pure Storage employee, you should clearly state that you
are expressing your own personal opinion and not the opinions of Pure Storage.
You should also be aware that there are special rules for disclosure of Company financial information. Pure Storage
discloses material financial information to the public only through specifically designated channels to avoid• Exercise prudent judgment and makesure that any content you post is inline with our core values of honesty,
integrity, and respect for others;

inappropriate publicity and to ensure that all those with an interest in Pure Storage will have equal access to• If you must respond to competitive

information. All inquiries or calls from financial and industry analysts should be referred to Investor Relations

claims or statements, be fact-(IR@purestorage.com) or to Pure Storage’s Chief Legal Officer.

based in your commentary.

RELEVANT LINKS

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Social Media Guidelines•

Trademark Usage Guidelines

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Code of Conduct 2024

Waivers
Any waiver of this Code for executive officers (including, where required by applicable laws, our principal executive
officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions)or directors may be authorized only by our Board of Directors or, to the extent permitted by the rules of any
exchange on which Pure Storage may list its shares and our Corporate Governance Guidelines, a committeeof the Board and will be disclosed to stockholders as required by applicable laws, rules and regulations.

Quick Resources and Links•

Acceptable Use Standard•

Partner Code of Conduct•

Anti-Bribery and Anti-Corruption Policy•

Privacy@Pure Intranet Page•

Conflict Minerals Statement•

Pure Data Retention and Destruction Standard•

Document Retention and Destruction
Schedule and Guidelines•

Pure Finance Intranet Page•

Pure Storage Export Policy Statement•

Employee Relations HUB Page•

Pure Storage Insider Trading Policy•

Environmental Health and Safety Policy•

Social Media Guidelines•

Equal Employment Opportunity•

Speak Up Policy•

ESG Report•Statement Against Human Trafficking•

Expanded Security Region (ESR) Equipment Standard•

Supplier Code of Conduct•

External Privacy Statement•

Trademark Usage Guidelines•

Guidance on Purchase Requisitions and Procurement•

Travel & Expense Guidelines•

Information Security Policy••

Investigations Safeguards Standard

Zero Tolerance for Workplace
Discrimination or Harassment Policypurestorage.com

800.379.PURE©2024 Pure Storage, Inc. All rights reserved. Pure Storage, the P logo mark, FlashArray, FlashBlade, Pure1, and Evergreen are trademarks
or registered trademarks of Pure Storage, Inc. All other names may be trademarks of their respective owners.

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