GLOBAL SUPPLIER CODE OF CONDUCTAugust 18, 2020
Gigamon conducts its business ethically, respectfully, and with integrity, and we fully expect our Suppliers todo the same. The Global Supplier Code of Conduct applies to all suppliers of Gigamon products or services,
including but not limited to, staffing agencies, contractors, licensors, component suppliers and any
subcontracted party performing work on behalf of Gigamon (“Suppliers”). As a Gigamon Supplier, we expect
you to abide by all the applicable laws and regulations that apply to wherever you do business. In short,Gigamon acts ethically in all business dealings and holds our Suppliers to the same ethical standards that wehold ourselves to.
1Workplace Integrity
Here at Gigamon, we are committed to diversity and treating our employees with respect anddignity. Suppliers must comply with all employment and safety laws, uphold the human rights of all
employees, and strive to build a diverse and inclusive workplace.
A. Anti-Discrimination
Suppliers should only make employment-related decisions based on an individual’s skills andaptitude and never on characteristics that may include: Race, Color, Religion, Nationality, Gender,Age, Medical Condition or Disability, Pregnancy, Marital Status, Political Affiliation, SexualOrientation, Military Status, or any other basis protected by law. We strongly encourage ourSuppliers to embrace diversity into their own business processes.
Hiring and employment decisions, including those relating to compensation, benefits, promotion,training and development, discipline, and termination must be based solely on the worker’s skill,ability, experience and performance.
B. Harassment
Solid teamwork also requires people to treat each other with dignity and respect. Harassment orbullying in the workplace should not be allowed or tolerated by the Suppliers. Suppliers are expected
to maintain an employment environment that is free from physical, psychological, and verbal
harassment, or other abusive conduct.
Suppliers are expected to respect the rights of workers to associate freely and communicate openly
with management regarding working conditions without fear of harassment, intimidation, penalty,
interference or reprisal. Suppliers are also expected to recognize and respect any rights of workers toexercise lawful rights of free association, including joining or not joining any association of theirchoosing.

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C. Health, Safety, and Human Rights
We expect our Suppliers to provide and maintain a safe and healthy work environment for theirworkers that complies with all applicable health and safety laws and regulations. Supplier shall takeproactive measures to prevent any workplace hazards.
D. Wage and Benefits
Suppliers must pay workers at least the minimum compensation required by local law and provide alllegally mandated benefits. In addition to payment for regular hours of work, workers must be paidfor overtime at such premium rate as is legally required or, in those countries where such laws donot exist, at least equal to their regular hourly payment rate. Deduction from wages as a disciplinary
measure should not be permitted.
E. Child Labor
Gigamon does not tolerate any form of child labor in our supply chain. We expect our Suppliers toprevent child labor in their operations and encourage our Suppliers to participate in industry efforts
aimed at the elimination of such practices wherever they exist in the supply chain. No individuals
shall be hired under 15 years of age, or 14 years of age where local law allows, or under the legal
minimum age defined by the International Labour Organization (ILO) or applicable local laws.
Workers under the age of 18 shall not perform work that is likely to jeopardize their health or safety.
F. Forced Labor and Human Trafficking
Gigamon requires that all labor in its supply chain be voluntary and that workers are allowed
freedom of movement. All forms of forced labor and human trafficking are prohibited including but
not limited to any form of prison, slave, bonded or forced indentured labor.
2Anti-Corruption
No matter where you conduct business for Gigamon, all Suppliers must abide by anti-corruption
laws, including but not limited to the U.S. Foreign Corrupt Practices Act (“FCPA”) and the UK Bribery
Act. You must not tolerate, permit, or engage in any form of corruption, extortion, or bribery. This istrue whether you are working with government officials or individuals in the private sector.
Suppliers are expected to exert reasonable due diligence to prevent and detect corruption in allbusiness arrangements, including partnerships, joint ventures, and the hiring of intermediaries suchas agents or consultants.
A. Bribery
Bribery is offering or giving something of value in order to improperly influence the recipient’sactions. Bribery is illegal everywhere we do business, and the consequences for offering or accepting
a bribe are severe. You may never offer, authorize, give, promise, or accept any form of a bribe,
extortion payment, improper payment, gift, or benefit while working on Gigamon’s behalf.

Global Supplier Code of Conduct | 2B. Kickback
A kickback is the return of a sum paid as a reward for fostering a business arrangement. Accepting oroffering a kickback violates this Supplier Code.
C. Fair Competition
Suppliers must not fix prices or rig bids with their competitors. They must not exchange current,
recent, or future pricing information with competitors. Suppliers must refrain from participating in acartel.
D. Gifts
Suppliers are expected to compete on the merits of their products and services. The exchange ofbusiness courtesies may not be used to gain an unfair competitive advantage. In any business
relationship, Suppliers must ensure that the offering or receipt of any gift or business courtesy ispermitted by law and regulation, and that these exchanges do not violate the rules and standards ofthe recipient’s organization and are consistent with reasonable marketplace customs and practices.
As a general rule, Suppliers should not offer any gift other than token gifts (for example, modest
company-branded items) or any entertainment or meal to any Gigamon employee other thanmodest meals, or anything that could reasonably be expected to create a sense of obligation, or thatis given with the intent to influence a business decision. In addition, Suppliers should never offer
anything of any value to Gigamon employees during a period in which a Request for Proposal (RFPs)
or other vendor-selection process is ongoing.
3Conflicts of Interest
Suppliers are expected to avoid all conflicts of interest or situations giving the appearance of apotential conflict of interest. Suppliers are expected to provide notification to all affected parties inthe event that an actual or potential conflict of interest arises. This includes a conflict between theinterests of Gigamon and personal interests or those of close relatives, friends or associates.

4Financial Integrity
Suppliers will accurately and completely record all business information and comply with allapplicable laws regarding accounting and other business records. Suppliers must not engage in false
and/or misleading accounting practices and all records, regardless of format, made or received as
evidence of a business transaction must fully and accurately represent the transaction or event being
documented.
Our business relationships are governed by contracts and obligations negotiated by all parties
involved. Suppliers should be familiar with and comply with the requirements of any agreements inplace. Please note that any contractual obligations with Gigamon also apply to the vendors andsubcontractors who work with you on the services that you provide to Gigamon.

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Trust
Gigamon protects your confidential information, and in return, we trust Suppliers to protect ourconfidential information as well. Suppliers shall not use or disclose confidential information ofGlobal Supplier Code of Conduct | 3

Gigamon except in performance of the Supplier’s services to Gigamon. Suppliers shall protect all
Gigamon confidential information to the same degree as they protect their own confidential
information, but in no case less than with a reasonable degree of care. Information should not be
used for any purpose (e.g. advertisement, publicity, and the like) other than the business purpose forwhich it was provided, unless there is express written authorization from Gigamon.
A. Intellectual Property
Suppliers must comply with all the applicable laws and contractual obligations governing intellectual
property rights, including with regard to Gigamon’s inventions, whether trade secrets, patents,copyrights, or trademarks. You may not use or disclose any of such intellectual property rights except
in service of obligations to Gigamon and in conformance with your contractual obligations. Gigamon
expects you to respect intellectual property rights of Gigamon and other companies. You may not
obtain, distribute, or use unlicensed software or information without proper authorization.
B. Information Security
Suppliers must protect the confidential and proprietary information of Gigamon and others,including personal information, from unauthorized access, destruction, use, modification anddisclosure, through appropriate physical and electronic security procedures. Suppliers must comply
with applicable data privacy laws.
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Environment
Suppliers are expected to follow all applicable environmental laws, regulations, and standards,
including but not limited to, requirements for chemical and waste management and disposal,recycling, industrial wastewater treatment and discharge, air emissions controls, environmental
permits, and environmental reporting. Suppliers must comply with all requirements regarding
conflict minerals, exercise proper due diligence, and provide evidence that they are in compliancewhen requested.

7Import and Export
Gigamon complies with all U.S. and non-U.S. trade laws and regulations that apply to our businessand expects our Suppliers to do the same. Suppliers must have and follow an export control programthat complies with U.S. and all other applicable export and import laws and regulations that may
apply to goods, technology, hardware, software, intellectual property, and technical information.

8Reporting
The Global Supplier Code of Conduct serves as a guide to ethical Supplier conduct. In the event thatexpectations of this Code are not met, the business relationship may be reviewed and terminated.
We encourage you to report anyone, whether an employee of Gigamon or a Supplier, if you suspectthey are not meeting the standards in this Supplier Code. Please send any such concerns toethics@gigamon.com so that we may investigate and address the issue.

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