Our Code of Conduct
Safeguarding TrustCONTENTS

A Message fromVincent Pilette

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

BUILDING TRUSTBY SAFEGUARDING
EACH OTHERTeam,
The mission of Gen is to create technology solutions that enablepeople to take full advantage of the digital world, safely, privately,
and confidently.
Today’s consumer expects and deserves a partner they can trust
to always do the right thing—a company that embraces strong
principles and ethics.
The Gen Code of Conduct guides how we operate as individuals
and as a team. With our values and standards as the framework,
the Code outlines the expectations we set for ourselves according
to our business practices and policies. The Code of Conduct also
helps us to be accountable to each other and to our customers.
A high standard of ethics and good governance is Gen’s greatest
strength as we advocate, innovate, communicate, and execute as ateam.

SAFEGUARDINGASSETS ANDSENSITIVE
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SAFEGUARDING
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Vincent PiletteCEO, Gen™
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Contents
Safeguarding with Integrity		

SAFEGUARDING
WITH INTEGRITYWe Keep Free of Conflicts of Interest

Our Purpose

Building Trust by Safeguarding
Each Other			11Our Mission

We Foster a Respectful Environment

We Keep Accurate Records and Accounts

Gen Values

We Promote Inclusion, Diversity, andEqual Opportunity

We Deal Fairly and Honestly

Trusting Through Transparency

3

5

Living Our Values

We Keep Our Workplaces Safe, Secure,and Healthy

We Prevent Insider Trading

We Do Business Globally the Right Way

Safeguarding Trust in Our
Communities			40Being Accountable

Safeguarding Assets andSensitive Information		

Special Responsibilities of People Leaders

We Protect Personal Data

We Are Committed to Environmental
Responsibility

Responsibilities of Business Partners
and Vendors

We Guard Our Valuable Information

We Contribute to Our Communities

Applicability

We Respect the Intellectual Property
of Others

We Protect Human Rights and Source
Responsibly

Waivers

We Protect Our Assets

We Carefully Participate in the Political
Process

Making Ethical Decisions

16

We Protect Our Reputation

Asking Questions, Raising Concerns
Confidentiality and Anonymity
What Happens When I Report an Issue?
Zero Tolerance for Retaliation
What Happens if Gen Is
Involved in a Lawsuit?
Consequences of Noncompliance

Empowering Marketplace
Trust				25Conclusion			46Resources			47TRUSTING
THROUGH
TRANSPARENCY

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SAFEGUARDING
TRUST IN OUR
COMMUNITIESWe Conduct Business Fairly and Honestly
We Prevent Bribery and Corruption
CONCLUSIONWe Give and Receive Gifts andEntertainment with Integrity

How to Use the CodeRESOURCES
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Safeguarding
withIntegrity

SAFEGUARDING
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At Gen, our Purpose and Mission define what we want to achieve,and our Values define who we are and how we’ll achieve them. To
make good on our Purpose, we rely on our Values to inform thedecisions we make and the actions we take.

Gen Values

Our Purpose

Powering Digital Freedom.
Our Mission

We create technology
solutions for people totake full advantage ofthe digital world, safely,
privately, and confidently– so together, we canbuild a better tomorrow.

PEOPLE: What we do

Customer Driven.
Community Minded.
We areadvocates forour customers
and are dedicated to making
their lives simpler and safer.
We are driven by the positive
impact we can have on all thecommunities in which we live
and work.

INNOVATION: How we think

Think Big. Be Bold.
We empower
and inspire one
another to thinkin new ways andto embrace change. We takecalculated risks and learn fast
to drive innovation across thebusiness.

CULTURE: How we behave

OPERATIONS: How we operate

Keep It Real. Make It
Happen.

Play to Win. Together.

We are authentic,
open, and treat
one anotherwith respect. We do what wesay and say what we do withintegrity.

We act with
passion, purpose,and energy to win
with customers
and in the marketplace. We
leverage the strength of ourglobal team, knowing we’remore powerful together.
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Trusting
Through
Transparency

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Safeguarding Trust is the theme of our Code of Conduct. The Codeconnects our values to specific daily behaviors. It is a tool to help us
all make decisions that benefit our business and protect us from risk.

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Living Our Values
A values-based culture is one where integrity thrives. It
allows us to delight our customers, celebrate the uniquecontributions of every employee, and grow the business.
It also reinforces our reputation as an ethical company,
one that has the trust of its members, markets, andcommunities.
Staying true to our values ensures we are aligned as ateam to deliver on our mission.

Being Accountable
We live our values when we:
1. Read the Code of Conduct.
2. Use it as our guide.
3. Ask for help when in doubt.
4. Apply our best judgment.
Every decision we make should safeguard trust—thetrust our customers have in their online security andthe trust our stakeholders have in our commitment todoing business the right way. We are responsible forbeing self-starters and holding ourselves to the highest
standards of ethical and professional behavior.

Special Responsibilities of People Leaders
At Gen, we expect every employee to demonstrate our values anduphold our Code. In addition, leaders must be active listeners and rolemodels who:
• Respect and value the diverse perspectives, backgrounds, andideas of all employees.
• Maintain a safe, positive, and ethical work environment.
• Behave and manage others in a way that honors Gen’s core values.
• Hire, promote, and delegate in a lawful and ethical manner.
• Understand key company policies and compliance procedures.
• Model integrity and transparency when handling challenging
situations.
• Provide training and resources.
• Identify and reduce ethics and compliance risks.
• Respond appropriately and promptly to colleagues seeking help.
• Maintain accountability among all employees.
• Prevent retaliation against employees who raise concerns or who
participate in investigations.
• Hold accountable any employee who raises a complaint in bad
faith.
• Manage situations that may involve conflicts of interest.

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Responsibilities of Business Partners and Vendors

Making Ethical Decisions

We partner with businesses that share our commitment totransparency and putting customers first. Our reputation
depends on our ability to protect the devices and identities ofour customers. We expect our business partners and vendors
to adhere to the standards in our Global Supplier Code of
Conduct and the Responsible Business Alliance Code of
Conduct.

We all use our judgment and values when faced with ethicalchoices. If you are faced with an ethical dilemma at work, it isoften best to reach out to your people leader. If reaching out toyour immediate leader is not an option, seek help from Ethics& Compliance or People & Culture. Using this model as a guide,
we can work together to determine the course of action bestaligned with our values.

Does This Code Apply to Me?
The Code applies to each of us at Gen. Compliance with theCode, as well as applicable laws, regulations, and company
policies, is mandatory for everyone, no matter our position or
location.
The Code applies to every director, officer, employee, intern,
and contractor of Gen, as well as third parties acting on behalfof the company.

Waivers
In rare cases, following the Code may cause significant
hardship. In those situations, you may request a waiver of theCode. Consult with the Global Head of Compliance or use theEthicsLine if you believe you need a waiver.

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CAN WE DO IT?

Do the law and Gen policies permit it?
BUILDING TRUSTBY SAFEGUARDING
EACH OTHERYes

SHOULD WE DO IT?

Is it ethical and consistent with our values and Code?

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DO WE WANT TO DO IT?

Will it improve our culture, reputation, and/or businesswithout compromising our values?
Yes

PROCEED WITH CONFIDENCE!

If the answer to any of the questions is no, stop anddon’t pursue the action.

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If you are not sure about the answers to any of the questions,seek help from your people leader, Ethics & Compliance, orPeople & Culture.

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Asking Questions, Raising Concerns
At Gen, we win together when we’re open and authentic.
As part of the team, it is important you voice yourconcerns. We all must commit to doing our part tospeak up or seek help if we believe we have seensomething that violates our Code. Retaliation has noplace at Gen. We win together when we deal openly withissues that we need to address. Even if you are unsure
whether what you have witnessed is a violation, you
should still reach out to one of the following:• Your People Leader: Leaders at Gen are expected

to maintain an Open-Door Policy when it comes toyour questions and concerns, and to take action
as quickly as possible. Leaders are responsible for
escalating concerns to Ethics & Compliance—thisis not something you need to do yourself if you’ve
reported those concerns to leadership. If you
believe your people leader has not addressed asituation appropriately, seek help from one of thefollowing resources.

• Ethics & Compliance: You can also turn to Ethics& Compliance directly and confidentially. You canshare your concern verbally or in writing, and if you
feel it’s necessary, you can do it anonymously.
– Direct reporting may be especiallyappropriate if the suspected violation
involves financial, accounting, auditing,banking, or anti-bribery areas due toconfidentiality concerns.
– To report a concern, use our EthicsLine:• gen.ethicspoint.com• U.S./Canada: 1-866-833-3430(Global numbers available online)• Confidential, Global, Interpreters Available• 24 Hours A Day, 7 Days A Week,
Anonymous Option• People & Culture: People & Culture is always

an outlet for employee concerns and is also
responsible for escalating concerns to Ethics &Compliance.

For additional points of contact, see the Resources
section at the end of this Code.

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Confidentiality and Anonymity

What Happens When I Report an Issue?

Gen values open, real communication. We encourage
employees to express their concerns. If you see a
problem or a potential problem, speak up. It’s consistent
with our self-starter culture to tackle problems head on.

When you file a report of suspected misconduct, Gen
acts promptly to investigate. To help our investigations
run smoothly and ethically, all employees involved mustcooperate in the investigation and provide truthful andcomplete information.

We make every reasonable effort to protect the identityof those involved in reports and investigations. We do
not discipline employees who make reports in goodfaith, nor do we tolerate retaliation.
Reports can be made anonymously to the extent
permitted by laws and regulations. If you wish to remain
anonymous, you do not need to provide your name orother identifying information when submitting yourconcern through the EthicsLine.
Please provide as much detail as possible in your report
so we can fully investigate your concern. Informationsuch as location, individuals, transactions, events, anddates involved promotes a more efficient investigation.
The company may report activity that involves potential
criminal or illegal activities to the appropriate authorities.

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Zero Tolerance for Retaliation
At Gen, we seek to create an environment that fosters
trust, teamwork, and innovation. Everyone at Gen
should feel comfortable raising their concerns. To
create a safe work environment, we prohibit any form of
retaliation. We take reports of retaliation seriously. Wheninvestigations establish that retaliation has occurred,disciplinary action up to termination or legal action will
result.

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What Happens if Gen Is Involved in a
Lawsuit?

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If you receive a court-issued document or learn of any
pending or threatened legal proceedings relating to thecompany, contact the Litigation legal team right away.
Follow their guidance with respect to sharing and not
sharing information as well as preserving and supplying
relevant records.

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Consequences of Noncompliance
When we live our Code, we foster a culture where we
can innovate and grow. Failing to follow the Code or
to participate in investigations and lawsuits damages
that culture and holds us back. It mars our reputationand threatens our relationships with our stakeholders.
In some cases, a violation could also subject Gen
to civil and/or criminal penalties. And it can result inpersonal consequences for all of us, up to and including
termination of employment.

Misconduct that may result in disciplinary action
includes:• Violating our Code or asking others to do so.
• Failing to report a known or suspected violation of
our Code or company policies.

• Refusing to cooperate fully in an investigation orlegal proceeding.

• Intentionally providing false or incomplete

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information, or raising a concern in bad faith.

• Retaliating against another employee for reporting
concerns or participating in an investigation.

How to Use the CodeThe second section explains
Why Our Actions Matter bydescribing why the relevant
standard is important to ourbusiness and culture.

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Each topic in the Code is divided into three main sections.

The first section includes a Topicand Principle Statement thathighlights our approach to doing
business and fulfilling our values
in connection with the topic.

SAFEGUARDING
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The third section identifies How
We Safeguard Trust by listing
practical examples showing how
to put our values into action.

When appropriate, you may also find a Question and Answer section (Q&A) that teaches the principles through real-life scenarios.

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This structure is meant to guide you through the Code, outlining the reasoning of our standards and showing us how to enact
the Code in our daily lives. Our policies often go into more detail than our Code and relevant policies may be found under the
Additional Safeguards heading for each topic.
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CONTENTS

Building Trust
by Safeguarding
Each Other

SAFEGUARDING
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We Foster a
Respectful
Environment
We believe everyone has theright to be treated with dignity
and respect. We strive to create
supportive, harassment-free work
environments.

CONTENTS

Why Our Actions Matter
Every team member is an ambassador for Gen and is expected toembody our values and safeguard our brand and reputation. This includes
compliance with all company policies, both on and off the job, inside andoutside the office (including during business travel and external events),
and in all circumstances at which employees, business partners, and/or
customers are present.

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How We Safeguard Trust
We foster a respectful environment when we:• Speak up! If you see harassment or offensive behavior, say something.
• Think about our actions. Avoid saying or doing things that may offend

BUILDING TRUSTBY SAFEGUARDING
EACH OTHER

others.

• Always treat one another with dignity and respect.

Q
A

Mila is on my team. She and I met with our supervisor, Theo,
to raise a potential issue with a product we’re developing.
After Mila suggested we should delay production in orderto address the problem, Theo raised his voice in a way thatmade me uncomfortable. He was angry and belittled Mila’s
concerns. I’ve seen him get like this once or twice before,
but usually he’s a decent guy. Is this harassment?
Depending on the facts, this could be harassment, bullying,or just poor management. Regardless, Theo’s actions are notokay. We safeguard trust and serve our mission best when
we develop teams where everyone feels safe and supported.
Check with Mila to see how she feels and speak up to help
create a respectful work environment.

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We Foster a
Respectful
Environment
Continued

CONTENTS

What does harassment look like?

• It can be what we say or write to one another in person or

via company or personal channels, including Teams, email, or
social media. This includes slurs, jokes, or stereotypes basedon but not limited to race, ethnicity, sexual orientation, gender,
disability, age, or medical condition, and the use of threatening,harsh, or abusive language.

SAFEGUARDING
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TRUSTING
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• It can be about what we display, such as what others may

consider pornographic or sexually suggestive photos ormaterials or potentially offensive slogans, posters, or bumper
stickers.

When it comes to harassment, the question isn’t what we mean or
intend by our words or actions, but how others might perceive orreact to them.

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ADDITIONAL SAFEGUARDS
Global Workforce Inclusion Policies

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We Promote
Inclusion,
Diversity,and Equal
Opportunity
We make better and faster
decisions and are at our creative
best when we are inclusive, anddraw on diverse talents andperspectives.

CONTENTS

Why Our Actions Matter
Being accountable to each other means valuing our people for thevariety of talents, ideas, backgrounds, and perspectives they bring. Our
unique talent sets help us play to win more creatively and innovate more
effectively.

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How We Safeguard Trust
We promote inclusion and diversity when we:• Build our teams with diversity in mind.
• Are transparent and share information with the entire team.
• Seek out different points of view to create innovative solutions.
• Listen to the ideas of others with courtesy and respect.
• Speak out if we feel our views or those of others are not being heard,or are being disrespected.

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ADDITIONAL SAFEGUARDS
Global Workforce Inclusion Policies

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We Keep Our
Workplaces Safe,
Secure, andHealthy
We are committed to keeping
ourselves and each other safe,
secure, and healthy. We takeaction to keep our visitors andcommunities safe from harm.

CONTENTS

Why Our Actions Matter
We are at our best in a safe and comfortable environment. When we’reconfident, we can focus on our mission and produce our best ideas.

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How We Safeguard Trust
We keep our workplaces safe, secure, and healthy when we:• Report unhealthy conditions, such as workplace hazards, broken

or missing equipment, or the presence of weapons, which are notallowed on company property.

• Do not make audio, photo, or video recordings of others at workwithout their notice and consent.

• Refrain from reporting to work under the influence of alcohol, drugs,
or any other substance that could impair our ability to do our job or
jeopardize the safety of others.

• Are prepared for a crisis event and call law enforcement in the case of
danger.

• Know what to do in case of injury or other workplace emergency.
• Report any threats of violence we experience or witness (including
outside of work and on social media).

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ADDITIONAL SAFEGUARDS
Workplace Office Conduct, Rules, & Regulations
Inappropriate Possessions in the Workplace
Substance-Free Environment Policy
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Safeguarding
Assets andSensitive
Information

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We Protect
Personal Data
To drive Cyber Safety forward, we
keep Personal Data protected.
At Gen, any information about
customers, employees, or partners
that relates to an identifiable
person is Personal Data. We handle
Personal Data with awareness andcare.

CONTENTS

Why Our Actions Matter
Our customers and employees deserve to know how we use Personal
Data. We want all of our stakeholders to feel protected and confident when
we collect, store, and use their Personal Data. Handling Personal Datacorrectly wins customer trust, but it’s also the right thing to do.

How We Safeguard Trust
We lock down personal data when we:• Collect and use Personal Data only to meet business or legal needs,

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and only collect the minimum information needed.

• Take steps to properly secure, update, and dispose of Personal Data.
• Share Personal Data inside or outside of our company only for the

purpose it was collected, and only in line with our internal and external
privacy policies and statements.

• Speak up about misuses of Personal Data, even accidental ones, bycontacting the Privacy Team.

• Follow all privacy and data protection laws that apply to us.
• Transfer Personal Data outside the European Economic Area in line

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with our Binding Corporate Rules.

QA

I work in customer support. I gather and store informationthat could identify individual customers. A colleague
who works in research asked if I could share data about
customers to contact them about joining a focus group. Can
I share this information with him?
No. Customers have the right to understand how the data wecollect about them is being used. Unless customers agree tohaving their data used for such a purpose, we should not do it.
We must ensure we uphold our Privacy Policy and the law.

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ADDITIONAL SAFEGUARDS
Global Privacy Policy | Binding Corporate Rules
Global Data Governance Policy and Records Management Schedule
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RESOURCESWe Guard
Our Valuable
Information
Gen’s intellectual property andconfidential information are at theheart of what we offer customers.
As a team, we must protect thesefrom misuse.

CONTENTS

Why Our Actions Matter
Our depth of leadership and fresh perspective give us an edge indeveloping new products and services. We use everything we’ve learned
over the years to attract new customers. Guarding what we know and how
we use that knowledge is key to our success.

How We Safeguard Trust
We guard our valuable information when we:• Share sensitive data only with employees and approved vendors who

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need access for specific work needs.

• Secure documents, data, and devices physically and use appropriate
document labels.

• Encrypt and password-protect our documents, data, and devices.
• Are aware of our surroundings when we work with or discussconfidential data.

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Internal documents visible via an unsecured Wi-Fi network.

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addresses to conduct business.

EMPOWERING
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TRUST• Ensure that we are not making Highly Confidential, Confidential, or• Allow only those who are authorized to access our facilities.
• Report possible data breaches so that they may be addressed quickly.
• Use only Gen-approved messaging systems and Gen domain email

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We Guard
Our Valuable
Information
Continued

CONTENTSSAFEGUARDING
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How Do We Classify Data?
At Gen, we classify data in one of the following ways.
Classification

HighlyConfidential

Confidential

Internal

PublicSensitivity

Very High

Moderate toHigh

Low toModerateLow

We own our responsibility to protect all data, but some types of
information are more sensitive than others. Unauthorized disclosureof Highly Confidential or Confidential information could havedirect or indirect negative consequences for our company and ourcustomers. Getting data right is an important way that we advocate
for our customers.

QA

I’m working with a vendor on our online subscription
platform. I need to share specific information about our
pricing with this third party. My company emails keep
getting filtered to the vendor’s spam folder. May I use mypersonal email account to share the necessary files?
No. We need to use approved, secure methods for sharing
such information. A personal email account does not meet
our security standards and is not acceptable. Because
sensitive information is in play, you should first confirm thata nondisclosure agreement is in place with this particularvendor. It’s also our responsibility to make sure that all ourvendors safeguard information carefully.

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We Guard
Our Valuable
Information
Continued

CONTENTS

What Is Highly Confidential or Confidential?
Highly Confidential and Confidential are the two most restrictiveclassifications within our company. Data in these categories
includes anything that the public doesn’t or shouldn’t know, such as:• Trade secrets and other intellectual property, such as source

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code and technical information.

• Personal Data about our employees or customers.
• Financial information, such as pricing and sales records.
• New product and marketing plans.
• Third-party information subject to a nondisclosure agreement.
• Customer and business partner lists.
• Research ideas and information.
• Information about acquisitions and spinoffs.
Our Internal data is primarily internal or proprietary information not
meant for public knowledge or disclosure. Our organizational charts,
policies, and standards are Internal data.
See additional examples in our Information Classification and
Handling Standard.

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ADDITIONAL SAFEGUARDS
Information Security Policy and Standards
Information Classification and Handling Standard

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We Respect
the Intellectual
Property of
OthersWe respect and safeguard
the intellectual property andcommercial rights of others.

CONTENTS

Why Our Actions Matter
We are aware of the business value of our own ideas. We know the effort
we put into creating and guarding these assets. We must respect others’
intellectual property as we do our own. Failing to do so is wrong and may
create financial and legal liability for Gen.

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

How We Safeguard TrustWe respect and protect the intellectual property of others when we:• Never infringe on the copyrights, patents, trademarks, or otherintangible property belonging to another person or company.

• Do not use competitive or confidential information learned from otherjobs while working at Gen.

BUILDING TRUSTBY SAFEGUARDING
EACH OTHER• Use all third-party assets, including software, music, videos, and textbased content, according to their specific license terms.

• Use software only for which we have a license for business use, evenon employee-owned personal devices.

SAFEGUARDINGASSETS ANDSENSITIVE
INFORMATIONEMPOWERING
MARKETPLACE
TRUST

SAFEGUARDING
TRUST IN OUR
COMMUNITIESCONCLUSIONRESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 21

We Protect
Our Assets
We take care of our assets because
we know they help us promote
Cyber Safety for our customers andcreate value for our shareholders.

CONTENTS

Why Our Actions Matter
Our assets are the product of our game-changing expertise and our hard
work. They represent our future. Our path to sustainable growth requiresthat we protect and use them wisely. We are all responsible for making
sure we protect our assets from loss, damage, waste, and improper use.

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

Types of Assets• Physical assets include buildings, supplies, furnishings, andcompany-issued laptops and phones.

• Information assets include all data contained in our files and on

BUILDING TRUSTBY SAFEGUARDING
EACH OTHER

our servers.

• Intangible assets include our reputation, ideas, inventions,

intellectual property, designs, copyrights, trademarks, patents,
and trade secrets. These assets help us drive innovation.

• Financial assets include money and anything that canbe converted to money, such as stocks, bonds, loans,and deposits.

SAFEGUARDINGASSETS ANDSENSITIVE
INFORMATIONEMPOWERING
MARKETPLACE
TRUST

SAFEGUARDING
TRUST IN OUR
COMMUNITIESCONCLUSIONRESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 22

We Protect
Our Assets
Continued

CONTENTS

How We Safeguard Trust
We protect Gen’s assets when we:• Safeguard them from damage, abuse, waste, loss, or theft.
• Employ good judgment in using information and communications
systems.

• Handle company funds honestly, responsibly, and in accordance with

Gen policies, including all finance policies and the Travel and Expense
Policy.

• Report any abuse or misuse of company assets.
• Report theft or loss of assets to Global Security.
• Work with respect and care when using company-owned equipment
at home or in any remote location.

• Return Gen equipment from remote work locations in good condition.
• Limit use of company-owned property for personal use.
• Never allow unauthorized individuals—including friends and family—to
use our Gen assets.

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

BUILDING TRUSTBY SAFEGUARDING
EACH OTHERSAFEGUARDINGASSETS ANDSENSITIVE
INFORMATIONEMPOWERING
MARKETPLACE
TRUST

SAFEGUARDING
TRUST IN OUR
COMMUNITIESADDITIONAL SAFEGUARDSCONCLUSION

Travel and Expense Policy
Information Security Policy and Standards
Copyright Usage Policy
Intellectual Property Policy
Trademark Usage Policy

RESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 23

We Protect Our
Reputation
At Gen, we speak with one
voice. This is true whether we’recommunicating with the media,
financial analysts, investors, or thegeneral public.

CONTENTS

Why Our Actions Matter
Our customers, investors, and communities deserve the most accurate
and clear information we can offer. We safeguard trust when we present
our company in a positive light while always being truthful. We havedesignated specially trained colleagues to speak on behalf of Gen. When
we direct media inquiries to those best prepared to deal with them, weprevent misinformation or errors from being released to the public.

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

How We Safeguard Trust
We protect our reputation when we:• Reply to external inquires for information about our company by

BUILDING TRUSTBY SAFEGUARDING
EACH OTHER• Refrain from divulging Highly Confidential, Confidential, or Internal

SAFEGUARDINGASSETS ANDSENSITIVE
INFORMATION

saying we are not authorized to speak on behalf of the company. Refer
such inquiries to Public Relations, Investor Relations, or Government
Affairs.
information about Gen, our customers, or our business partners andvendors.

• Use inclusive language and do not say anything that is discriminatoryor that would constitute a threat, bullying, or harassment.

• Be careful not to create any impression that we are speaking on behalfof the company in any personal communications such as blogs, user
forums, chat rooms, social media posts, or bulletin boards.

EMPOWERING
MARKETPLACE
TRUST

SAFEGUARDING
TRUST IN OUR
COMMUNITIESCONCLUSION

ADDITIONAL SAFEGUARDS
Social Media Policy
Insider Trading Policy

RESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 24

CONTENTS

Empowering
Marketplace
Trust

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

BUILDING TRUSTBY SAFEGUARDING
EACH OTHERSAFEGUARDINGASSETS ANDSENSITIVE
INFORMATIONEMPOWERING
MARKETPLACE
TRUST

SAFEGUARDING
TRUST IN OUR
COMMUNITIESCONCLUSIONRESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 25

We Conduct
Business Fairlyand Honestly
We play to win but we nevercompromise our honesty. We
succeed on the strength of theideas and technology that bringvalue to customers. We’re scrappy,
we play fair, and we think on our
feet.

CONTENTS

Why Our Actions Matter
We welcome strong competition because it keeps us on top of our game.
Customers searching for Cyber Safety come to Gen—and stay with us—
because they trust us. Innovating for their success is what ensures ourown success—it protects our reputation and competitive advantage.

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

How We Safeguard Trust
We play fair and honest when we:• Never discuss pricing, bidding processes, or dividing markets withcompetitors.

• Avoid making false claims or negative comments about competitors’
products.

• Ensure our own product claims are accurate and current.
• Never use illegal or questionable actions to obtain competitive
information.

• Avoid using our market strength in any way that might unfairly harm

BUILDING TRUSTBY SAFEGUARDING
EACH OTHERSAFEGUARDINGASSETS ANDSENSITIVE
INFORMATION

competition.

• Always behave professionally during negotiations, treating everyone
with respect.

EMPOWERING
MARKETPLACE
TRUST

SAFEGUARDING
TRUST IN OUR
COMMUNITIESCONCLUSIONRESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 26

We Conduct
Business Fairlyand Honestly
Continued

CONTENTSQ
A

I was at a conference with several employees fromcompetitors. During a side discussion, someone started
talking about his company’s pricing. I didn’t want to be rude,
but I knew we weren’t supposed to discuss that topic. I
interrupted him and told him to change the subject. Did I do
the right thing?
Yes. Discussing pricing, or other competitive information,with competitors is against antitrust laws. It’s important totake an active role in preventing this sort of behavior. Sitting
and listening without saying anything would not have beenenough. In addition to interrupting the competitor, you should
leave the conversation, document the incident, and let Ethics &Compliance know.

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

BUILDING TRUSTBY SAFEGUARDING
EACH OTHERSAFEGUARDINGASSETS ANDSENSITIVE
INFORMATIONEMPOWERING
MARKETPLACE
TRUST

SAFEGUARDING
TRUST IN OUR
COMMUNITIESCONCLUSION

ADDITIONAL SAFEGUARDS
Global Supplier Code of Conduct
Partner Code of Business Conduct
Global Procurement Policy
Global Antitrust and Competition Policy

RESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 27

We Prevent
Bribery andCorruption
We do not bribe. We are open,
honest, and direct. At Gen, we win
and retain business due to thestrength of what we offer.

CONTENTS

Why Our Actions Matter
Doing business the right way leads to better innovation and more powerfulproducts. When we fight corruption, our business is stronger, more resilient
to risk, and more sustainable. Conversely, corruption harms communities,
puts our company at risk, and can result in substantial fines and prisontime.

How We Safeguard Trust

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

We prevent bribery and other forms of corruption by:• Never offering or accepting anything of value in exchange for abusiness advantage.

• Keeping accurate and complete financial records.
• Complying with corruption laws around the world, including the U.S.
Foreign Corrupt Practices Act (FCPA) and the U.K. Bribery Act.

• Never using a third party to make improper payments.
• Following Gen policies related to giving and receiving gifts, hospitality,

BUILDING TRUSTBY SAFEGUARDING
EACH OTHERSAFEGUARDINGASSETS ANDSENSITIVE
INFORMATION

and entertainment. (see Gifts and Entertainment.)• Doing business only with partners and vendors who commit tooperating with integrity at all times.

EMPOWERING
MARKETPLACE
TRUST

SAFEGUARDING
TRUST IN OUR
COMMUNITIESCONCLUSIONRESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 28

We Prevent
Bribery andCorruption
Continued

CONTENTS

Improper Incentives• A bribe is anything of value offered to gain an improper

SAFEGUARDING
WITH INTEGRITY

business advantage. The amount of the bribe does not matter. A
bribe is wrong, even if it is not actually paid.

• A kickback is a form of bribe usually paid out of margin on atransaction and offered in return for favorable treatment.

• Facilitation, or “grease” payments are low-value payments

made to advance routine government actions. These actions
include visa processing, clearing customs, or securing policeand fire protection, for example.

TRUSTING
THROUGH
TRANSPARENCY

BUILDING TRUSTBY SAFEGUARDING
EACH OTHERSAFEGUARDINGASSETS ANDSENSITIVE
INFORMATIONEMPOWERING
MARKETPLACE
TRUST

SAFEGUARDING
TRUST IN OUR
COMMUNITIESCONCLUSION

ADDITIONAL SAFEGUARDS
Global Anti-Bribery and Corruption Policy

RESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 29

We Give andReceive Gifts andEntertainment
with Integrity
We are always looking for ways
to build and strengthen business
relationships. However, we are
first and foremost an advocate forour customers and will never offer
or accept gifts meant to influencebusiness decisions.

CONTENTS

Why Our Actions Matter
Strong personal and professional relationships are key to fulfilling our
mission. Exchanging modest gifts or hospitality can build goodwill andstrengthen those relationships. We must ensure, however, that suchcourtesies don’t affect our ability to make fair decisions. When we arecareful when giving and receiving gifts, we make the decisions that are
best for our customers and our reputation.

How We Safeguard TrustWe act with integrity by making sure any gifts or entertainment we give or
receive:• Are customary in nature as a business gift.
• Are not cash or cash equivalents (i.e., no Visa gift cards).
• Are under the value limits set by Gen polices.
• Are infrequent.
• Don’t have the appearance of or attempt to influence decision-making.
• Don’t create a sense of needing to return a favor.
• Are permitted by law.
• Don’t violate the business partner’s or vendor’s gift policy.

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

BUILDING TRUSTBY SAFEGUARDING
EACH OTHERSAFEGUARDINGASSETS ANDSENSITIVE
INFORMATIONEMPOWERING
MARKETPLACE
TRUST

Government Employees
Special rules apply to the giving of courtesies to government
officials. What might be fine for a commercial business partner
might pose a problem for a government official. It isn’t always
obvious who a government employee is, especially in countries
with many state- or government-owned enterprises. Given therisks to our business if we do not follow the rules, it is importantto seek guidance ahead of time from Ethics & Compliance for any
questions around gifts, hospitality, or entertainment for potential
government officials.

SAFEGUARDING
TRUST IN OUR
COMMUNITIESCONCLUSIONRESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 30

We Give andReceive Gifts andEntertainment
with Integrity
Continued

CONTENTS

The 20-40-250 RuleFirst, ask yourself who you’re working with, which determines theappropriate threshold for gifts, hospitality, and entertainment (“GHE”).

SAFEGUARDING
WITH INTEGRITY

US PUBLICSECTOR

INTERNATIONAL
PUBLIC SECTORCOMMERCIALSECTOR$250

TRUSTING
THROUGH
TRANSPARENCY

For the US public
sector, the GHE
threshold is $20
per person.

For the international
public sector, theGHE threshold is$40 per person.

And for thecommercial sector,
the GHE thresholdis $250 per person.

BUILDING TRUSTBY SAFEGUARDING
EACH OTHER

$20

Q
A

$40

I have a contact with a business partner who provides
support for the phones in our office. We’ve worked
together for a couple years now. The last time we met inperson to discuss a new contract, he noticed the screen
on my personal cell phone was cracked. A week later, I
got a package with a brand new phone in it at my office.
It had a note from him thanking me for the continued
business. Can I keep the phone?
No. Even if you think such a gift won’t affect your ability
to be fair in future business decisions, others may not see
it that way. This gift is above the limit of what we allow in
our Global Anti-Bribery and Corruption Policy, which sets
the thresholds and provides additional guidance.

SAFEGUARDINGASSETS ANDSENSITIVE
INFORMATIONEMPOWERING
MARKETPLACE
TRUST

SAFEGUARDING
TRUST IN OUR
COMMUNITIESCONCLUSION

ADDITIONAL SAFEGUARDS
Global Anti-Bribery and Corruption Policy

RESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 31

We Keep Freeof Conflicts ofInterest
We put Gen’s goals and customer
interests before personal gain. Doingso safeguards trust by keeping us
laser focused on protecting andenabling our consumers’ digital lives.

CONTENTS

Why Our Actions Matter
We all have lives outside of Gen. But blazing the Cyber Safety trail requires
us to make the decisions that best serve our customers and company.
When we keep free of conflicts of interest, we can strive and innovate
without divided loyalty. Even the appearance of a conflict of interest canleave others thinking we aren’t acting cohesively as a team.

How We Safeguard Trust

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

We avoid conflicts of interest when we:• Are alert for situations where our personal activities or relationships
could get in the way of our objectivity.

• Speak up to a people leader or People & Culture or use the EthicsLine

when we believe there may be a conflict between our personal interestand the interests of the Company.

BUILDING TRUSTBY SAFEGUARDING
EACH OTHER• Disclose—in advance—all potential conflicts of interest via EthicsLine

SAFEGUARDINGASSETS ANDSENSITIVE
INFORMATION

What Is A Conflict of Interest?

EMPOWERING
MARKETPLACE
TRUST

for review.

A conflict of interest exists when our personal interests, activities, orinvestments clash with our responsibilities for Gen. Many potential
conflicts can be avoided. Use the EthicsLine when in doubt about
how to handle a specific situation.

SAFEGUARDING
TRUST IN OUR
COMMUNITIESCONCLUSIONRESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 32

CONTENTS

Potential conflicts of interest that require pre-disclosure to
Ethics & Compliance via EthicsLine include:
Employing Relatives and Friends. We avoid employing relatives and friends: (1) in the same department, unless they
are reporting to different first-line people leaders; (2) where one is managing the other or in a position to influence thecareer of the other; or (3) where one employee is in a position considered “sensitive” or “confidential.”
Relationships with Colleagues. Romantic relationships between colleagues may require changes to be made to work
arrangements, depending on the employees’ roles within the company. Disclose such relationships promptly to Ethics& Compliance.
Financial Interests in Other Businesses. We ensure that personal and family investments do not get in the way of ourdecisions on behalf of Gen. We avoid personal or family financial interests in a Gen customer, channel partner, vendor,
other business partner, or competitor. These financial interests include investment, ownership, or creditor interests,
which could improperly influence our judgment, have the potential to cause the appearance of divided loyalty, or might
result in personal benefit because of our roles at Gen.
Personal Benefit or Gain from Business. We do not take personal advantage of business opportunities that we
discover in the course of our work. They belong to the company. Additionally, receiving personal benefits from others
because of our status as an employee may lead to divided loyalties. We do not accept any personal benefit otherthan our compensation from Gen in connection with any transaction involving Gen, or our status as employees. This
includes situations where we may do business directly or indirectly with family members or friends.
Outside Employment. We each give our best effort every day to make sure that outside jobs or other activities,
including outside directorships, don’t hinder our work for Gen. We do not let outside employment and other activities
influence our judgment, decisions, or actions with respect to our roles at the company, interfere with our work at
Gen, or cause us to misuse company information or assets. This holds true regardless of whether we may be called
an “employee,” “consultant,” “contractor,” “owner,” “investor,” or “volunteer.” Working for or serving on the board of acompetitor is never allowed.

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

BUILDING TRUSTBY SAFEGUARDING
EACH OTHERSAFEGUARDINGASSETS ANDSENSITIVE
INFORMATIONEMPOWERING
MARKETPLACE
TRUST

SAFEGUARDING
TRUST IN OUR
COMMUNITIESCONCLUSION

ADDITIONAL SAFEGUARDS
Employment of Relatives Policy
Conflicts of Interest Policy

RESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 33

We Prevent
Insider Trading
At Gen, we have access to sensitive
information. We never use or shareprivate information about ourcompany or any other for the purposeof buying or selling securities.

CONTENTS

Why Our Actions MatterIn the course of our jobs, we may have access to information that is notknown to the public. Whether such information belongs to us, or to anotherentity, we’re careful to protect it. We value our reputation as a company
that can be relied on to guard the information entrusted to us. This applies
to material, nonpublic information about Gen, our customers, and business
partners.
Insider trading occurs when someone uses or shares “inside information”
for personal gain or to avoid a loss. It is a serious crime, punishable bylarge fines and imprisonment.

How We Safeguard Trust

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

BUILDING TRUSTBY SAFEGUARDING
EACH OTHER

We help prevent insider trading when we:• Do not buy or sell shares in Gen or any other publicly traded company,
when we have inside information about Gen or the company inquestion.

• Avoid buying or selling shares until the key inside information is
published and investors have had a chance to gauge it.

• Avoid sharing inside information with anyone outside Gen, including
relatives or friends.

• Share inside information with fellow employees only on a need-to-

SAFEGUARDINGASSETS ANDSENSITIVE
INFORMATIONEMPOWERING
MARKETPLACE
TRUST

know basis.

• Take care to protect inside information from accidental disclosure.
• Do not tip, the act of directly or indirectly passing along inside
information.

SAFEGUARDING
TRUST IN OUR
COMMUNITIESCONCLUSIONRESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 34

We Prevent
Insider Trading
Continued

CONTENTS

What Is Inside Information?
Inside information is anything known to us, but not yet released tothe public, which might inform an investor’s decision to buy or sellshares. Examples include:• New business relationships• New product launches• Company financial results• The results of significant litigation• Prospective mergers and acquisitions

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

BUILDING TRUSTBY SAFEGUARDING
EACH OTHERSAFEGUARDINGASSETS ANDSENSITIVE
INFORMATIONEMPOWERING
MARKETPLACE
TRUST

SAFEGUARDING
TRUST IN OUR
COMMUNITIESCONCLUSION

ADDITIONAL SAFEGUARDS
Insider Trading Policy

RESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 35

We KeepAccurate
Records andAccounts
We keep complete and accurate
records to help us make goodbusiness decisions. They allow
us to provide honest and up-todate information to investors andgovernment agencies.

CONTENTS

Why Our Actions Matter
Complete and accurate financial statements and business records help us
to make the best decisions and plans. We win together when we maintainproper records to run Gen successfully and lawfully. We are a publiccompany and are required to disclose full information about our business
when asked.

How We Safeguard Trust

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

We maintain the integrity of our books and records when we:• Comply with accepted accounting principles, internal controls, andlaws.

• Maintain honest, careful books, expense reports, and receipts of our

BUILDING TRUSTBY SAFEGUARDING
EACH OTHER

financial transactions.

• Record all assets, liabilities, revenues, expenses, and business
transactions accurately.

• Follow all recordkeeping procedures and guidelines.
• Never set up or maintain secret cash funds or other assets or
liabilities.

• Promptly submit accurate records to internal and external auditors.
• Seek help from the Litigation legal team when unsure about how to

SAFEGUARDINGASSETS ANDSENSITIVE
INFORMATIONEMPOWERING
MARKETPLACE
TRUST

handle records.

SAFEGUARDING
TRUST IN OUR
COMMUNITIESCONCLUSION

ADDITIONAL SAFEGUARDS
Global Data Governance Policy and Records Management Schedule
RESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 36

We Deal Fairlyand Honestly
We speak with honesty when
showing the value Gen brings to ourcustomers. We never make false
statements about what we offer orabout our competitors in marketingor sales activities. We also partnerwith businesses that share our highethical standards and ensure the bestvalue for Gen.

CONTENTS

Why Our Actions Matter
We play to win by being open and real about what we do. Failing to doso undercuts our ambition to become a trusted partner to protect andenable our consumers’ digital lives. It also exposes us to fines, penalties,
and lawsuits. By working with ethical business partners and vendors whoshare our commitment to transparency, we can advance and protect ourbusiness.

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

How We Safeguard TrustWe deal fairly and honestly when we:• Have all marketing language reviewed by the Marketing Legal team,including language provided by third parties.

• Do not misrepresent what our products and services do.
• Do not make inaccurate or disparaging claims about competitors.
• Do not infringe on copyrights, logos, or other intellectual property.
• Ensure our advertisements and contracts comply with all laws and

BUILDING TRUSTBY SAFEGUARDING
EACH OTHERSAFEGUARDINGASSETS ANDSENSITIVE
INFORMATION

regulations.

• Treat all business partners and vendors fairly and with integrity.
• Choose business partners who share our values and meet our needs
and who agree to market and sell our products with integrity.

EMPOWERING
MARKETPLACE
TRUST• Avoid inappropriate gifts, which may compromise the selection of thebest partners for Gen.

• Seek to understand issues when they arise and work together to findsolutions that work for everyone.

SAFEGUARDING
TRUST IN OUR
COMMUNITIES• Ensure all business partners and vendors are committed to ethicalbusiness practices and compliance with the law.

CONCLUSIONRESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 37

We Deal Fairlyand Honestly
Continued

CONTENTS

Q
AQ
A

ADDITIONAL SAFEGUARDS
Unfair, Deceptive, or Abusive Acts or Practices Policy
Global Signature Authority Policy
Global Financial Approval Authority Policy
Global Procurement Policy
Partner Code of Business Conduct
Social Media Policy
Marketing and Sales Policy

I’m a customer support representative. On a call, acustomer is asking if I can guarantee that his personal
computer using one of our Cyber Safety solutions isprotected from hackers. Can I tell him that it is?
No. While we’re an industry leader in Cyber Safety, nosolution is without some vulnerability. We should not
attempt to overstate or misrepresent what our products
do. We speak with honesty and transparency withcustomers about our own products and those of ourcompetitors. Refer to our Unfair, Deceptive, or Abusive
Acts or Practices Policy for more.
I work with our advertising group. I just had a greatslogan for a new product. Can I start using the languagein email blasts I write?
It depends. Legal needs to review all external marketing
language in advance to ensure that the slogan accurately
describes the product. We take this measure to be fairto our customers and to comply with the Federal Trade
Commission (FTC) and similar regulatory bodies. Gen
benefits when consumers are protected and markets
are fair, because we believe that we can distinguish our
products and services based on their merits.

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

BUILDING TRUSTBY SAFEGUARDING
EACH OTHERSAFEGUARDINGASSETS ANDSENSITIVE
INFORMATIONEMPOWERING
MARKETPLACE
TRUST

SAFEGUARDING
TRUST IN OUR
COMMUNITIESContracting Practices
When we follow best practices to contract third parties, we protect
Gen’s interests. We minimize risk to our customers, employees, andshareholders. Only authorized employees can enter into contracts thatmeet specific standards outlined in our policies. Side agreements ofany kind are prohibited.

CONCLUSIONRESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 38

We Do Business
Globally the
Right WayWe follow all global rules and lawsthat apply to our business.

CONTENTS

Why Our Actions Matter
As a global business, our decisions and actions must follow the regulations
that apply to us around the world. When we follow these laws, we upholdfair markets and support a safe and fair world. We also avoid penalties andfines.

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

How We Safeguard Trust
We do business globally the right way when we:• Follow import and export laws.
• Don’t agree to any contractual clauses that obligate a party to boycott
any country, which are illegal in the United States.

• Don’t bribe or pay facilitation payments. (See We Prevent Bribery and

BUILDING TRUSTBY SAFEGUARDING
EACH OTHER

Corruption.)• Compete fairly. (See We Conduct Business Fairly and Honestly.)

SAFEGUARDINGASSETS ANDSENSITIVE
INFORMATIONEMPOWERING
MARKETPLACE
TRUST

SAFEGUARDING
TRUST IN OUR
COMMUNITIESCONCLUSION

ADDITIONAL SAFEGUARDS
Global Trade Compliance Policy
Global Procurement Policy
Global Antitrust and Competition Policy
Global Anti-Bribery and Corruption Policy

RESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 39

CONTENTS

Safeguarding
Trust in Our
Communities

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

BUILDING TRUSTBY SAFEGUARDING
EACH OTHERSAFEGUARDINGASSETS ANDSENSITIVE
INFORMATIONEMPOWERING
MARKETPLACE
TRUST

SAFEGUARDING
TRUST IN OUR
COMMUNITIESCONCLUSIONRESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 40

We AreCommitted toEnvironmental
Responsibility
We strive to lead in environmental
responsibility. We apply the sametactics to lowering our environmental
impact that we use to advance Cyber
Safety.

CONTENTS

Why Our Actions Matter
We know that our business has an impact on the environment. We seek tominimize this impact in various ways ranging from reducing water usage,
carbon emissions, and waste to developing environmental initiatives. We
safeguard trust when we take care of the environment where we operate.

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

How We Safeguard Trust
We commit to environmental responsibility when we:• Consider and propose ways to reduce waste and recycle goods.
• Participate in company initiatives related to environmental action.
• Take small, practical steps every day to cut emissions and reduce ouruse of water, fuel, and electricity.

• Follow all applicable environmental laws and company policies.

BUILDING TRUSTBY SAFEGUARDING
EACH OTHERSAFEGUARDINGASSETS ANDSENSITIVE
INFORMATIONEMPOWERING
MARKETPLACE
TRUST

SAFEGUARDING
TRUST IN OUR
COMMUNITIESCONCLUSION

ADDITIONAL SAFEGUARDS
Global Supplier Code of Conduct

RESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 41

We Contributeto OurCommunities
We are committed to supporting thecommunities where we live and work.
This commitment extends to thecountries where we operate.

CONTENTS

Why Our Actions Matter
At Gen we invest strategically to contribute to the communities where
we live and work. We amplify our impact and accelerate progress bypartnering with high-impact nonprofit organizations and leveraging
employee expertise. Our philanthropic focus areas are aligned to ourbusiness priorities and include STEM (Science, Technology, Engineering,
Mathematics) education, emphasizing computer science and cybersecurity skills, diversity, online safety, and environmental responsibility.

How We Safeguard Trust
We contribute to our communities when we:• Volunteer and participate in charitable activities.
• Obtain approval before donating company funds or making
contributions in Gen’s name.

• Ensure that outside activities do not interfere with our job
performance or create a conflict of interest.

• Never pressure others to contribute to charitable organizations orother community activities.

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

BUILDING TRUSTBY SAFEGUARDING
EACH OTHERSAFEGUARDINGASSETS ANDSENSITIVE
INFORMATIONEMPOWERING
MARKETPLACE
TRUST

SAFEGUARDING
TRUST IN OUR
COMMUNITIESCONCLUSION

ADDITIONAL SAFEGUARDS
Charitable Donations Policy
Solicitation of Goods and Services Policy

RESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 42

We Protect
Human Rights
and Source
Responsibly
Gen respects human, cultural, andlegal rights. We are dedicated to fairtreatment. We expect our business
partners to share this commitment.

CONTENTS

Why Our Actions Matter
Gen supports the dignity and equality of all human beings. We believe thathuman trafficking, slavery, child labor, and unsafe and unfair work practices
have no place in our global society. We make sure we safeguard humanrights every step of the way.

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

How We Safeguard Trust
We protect human rights and source responsibly when we:• Provide proper working conditions, hours, and compensation to all
Gen employees.

• Work only with business partners who are committed to fair labor andsustainable sourcing practices.

• Never use child or prison labor.
• Uphold our commitments as a signatory of the UN Global Compact
Ten Principles and Sustainable Development Goals.

• Alert People & Culture or use the EthicsLine if we suspect human

BUILDING TRUSTBY SAFEGUARDING
EACH OTHERSAFEGUARDINGASSETS ANDSENSITIVE
INFORMATION

rights violations.

EMPOWERING
MARKETPLACE
TRUST

SAFEGUARDING
TRUST IN OUR
COMMUNITIESCONCLUSION

ADDITIONAL SAFEGUARDS
Global Supplier Code of Conduct
Human Rights Policy

RESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 43

We Carefully
Participate in the
Political Process
Active participation in the politicalprocess can have a positive impact on
our lives. As a company, we engage
constructively with governments in
the regions where we operate.

CONTENTS

Why Our Actions Matter
We feel that an open, robust political process makes a fairer, more efficient,and more productive society. While we support every employee’s right toan active political life, it is important to keep our work separate. We don’t
want to create the impression that Gen supports our personal causes.

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

How We Safeguard TrustWe carefully participate in the political process when we:• Make it clear that our political views and actions are our own and not
those of the company.

• Make political contributions on behalf of Gen only with advanceapproval.

BUILDING TRUSTBY SAFEGUARDING
EACH OTHER• Follow the rules on public disclosure and all reporting requirements
related to lobbying on behalf of Gen.

• Seek help to comply with all relevant laws regarding corporate politicalcontributions wherever we do business.

SAFEGUARDINGASSETS ANDSENSITIVE
INFORMATION• Approach public policy in a bipartisan manner and work to educate all
those with an interest in issues that impact our company.

EMPOWERING
MARKETPLACE
TRUST

SAFEGUARDING
TRUST IN OUR
COMMUNITIESCONCLUSIONRESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 44

We Carefully
Participate in the
Political Process
Continued

CONTENTS

Participating in the Development of Public Policy
We engage in public policy debates worldwide. Our aim is to promote
policy that supports our long-term mission to protect consumers,
innovate, and ensure the unimpeded flow of the world’s information.
We promote ideas that can deal with the complexities of consumer
cyber safety and to ensure that we can compete on a level playing
field across the global marketplace.
We follow all laws related to political contributions and make suchcontributions only with approval from Government Affairs andEthics & Compliance. We further uphold our commitment to open
communication by disclosing all our contributions on our public
website.

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

BUILDING TRUSTBY SAFEGUARDING
EACH OTHERSAFEGUARDINGASSETS ANDSENSITIVE
INFORMATIONEMPOWERING
MARKETPLACE
TRUST

SAFEGUARDING
TRUST IN OUR
COMMUNITIESCONCLUSION

ADDITIONAL SAFEGUARDS
Global Political Contributions Policy

RESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 45

CONTENTS

Conclusion
At Gen, we are known for our technical know-how and spirited drive toadvance the cause of Cyber Safety. But it’s our commitment to safeguarding trust and doing business the right way that sets us apart.
When we live our Code—when we pair a scrappy, can-do attitude with acommitment to transparency, accountability, and putting our customers
first—we set ourselves up for long-term success. When we ground ourdecisions in our values and follow the principles of our Code, we safeguard
trust for all the people who depend on us day in and day out.

SAFEGUARDING
WITH INTEGRITY

TRUSTING
THROUGH
TRANSPARENCY

BUILDING TRUSTBY SAFEGUARDING
EACH OTHER

Each of us has the power to do what is right and enact change, both in theworld and within our company. Go do it.

SAFEGUARDINGASSETS ANDSENSITIVE
INFORMATIONEMPOWERING
MARKETPLACE
TRUST

SAFEGUARDING
TRUST IN OUR
COMMUNITIESCONCLUSIONRESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 46

CONTENTS

Resources

SAFEGUARDING
WITH INTEGRITYGEN POLICY REPOSITORY
Ethics & Compliance
To report a concern, use our EthicsLine:• gen.ethicspoint.com• U.S./Canada: 1-866-833-3430(Global numbers available online)• Confidential, Global, Interpreters
Available• 24 Hours A Day, 7 Days A Week,
Anonymous Option

People & Culture• Submit a ticket via our Employees HR

Gen Legal& Payroll Portal.

Public Relations

Manager or Business Partner directly.

Investor Relations

People & Culture team.

Government Affairs• Contact your People & Culture• Reach out to any member of the

Global Cyber Security
Global Security
Operations Center

TRUSTING
THROUGH
TRANSPARENCY

BUILDING TRUSTBY SAFEGUARDING
EACH OTHERSAFEGUARDINGASSETS ANDSENSITIVE
INFORMATIONEMPOWERING
MARKETPLACE
TRUST

SAFEGUARDING
TRUST IN OUR
COMMUNITIESCONCLUSIONRESOURCES
Copyright © Gen Digital Inc. All rights reserved. | 47

Code of Conduct

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