Teradata Corporation Code of Conduct

accurately. If, after checking relevant Teradata policies, you are unsure whether a certain expense is a legitimate reimbursable/payable business expense or is permitted by our policies, you should ask your manager or other subject matter experts in the company before you act and before you submit a reimbursement/payment claim for it. Associates are accountable and will be subject to discipline for submitting false reports or claims for reimbursement/payment.

We must never book or process a transaction or payment, including recognizing orders and recognizing revenue, without the full and appropriate underlying documentation. Falsifying, forging, or back-dating books, records, orders, contracts, approvals, invoices, acceptances, or any documents that may be used in connection with revenue recognition or other proper accounting treatment is always wrong and will not be tolerated. Each of us must cooperate fully with financial controls personnel, revenue recognition assurance personnel, and internal and external auditors in their effort to verify the accuracy of the company’s books and records and compliance with accounting and legal requirements. Refusing to cooperate, offering misleading information, or affirmatively interfering with a review, audit, or investigation will result in discipline.

Properly maintaining corporate records after they are created also is very important. Teradata has adopted a Record Retention Policy (Corporate Finance & Accounting Policy (CFAP) 111) describing how to maintain records for required periods and destroy them when they are no longer needed. If you are unsure about what records you need to maintain and for how long, please review our Record Retention Policy and make certain you follow the record retention schedule for your area or for the types of documents with which you work.

Also keep in mind in the event of actual or threatened legal proceedings or government investigations, a Legal Hold might be placed on certain documents and

records. Teradata’s status in legal proceedings may be at risk if we do not secure or are unable to produce relevant documents and records. In these cases, you will be contacted by the Teradata Law Department. If a Legal Hold applies to you or documents or records held or controlled by you, you must retain all relevant records subject to the Legal Hold instructions.

Social Messaging, IT, and Network Systems

Social networking and the Internet are key business tools. The use of the Internet and social networks at work or using company technologies must be consistent with the Code, our core principles, and company policies. We may not use either Teradata information technologies (equipment, software, or networking resources) or a customer’s or business partner’s information technologies to gather or distribute offensive, sexually-suggestive, discriminatory, harassing, pornographic, unlawful or other inappropriate data or information, whether during or after work hours.

Email messages, text messages, instant messages, blog comments, twitter messages, social networking site communications, and voicemail messages produce an easily-forwarded, traceable, and recoverable record of communications. All messages made on or through Teradata IT systems, devices or networks, or that are Teradata-related should be composed with the same care you would take in composing a letter on the company’s letterhead.

You should assume that whatever you say in emails, instant messages, text messages, and other forms of social networking will be seen by others and could be the subject of external and internal investigations or subject to legally-required disclosures. A good rule of thumb to keep in mind and apply to the content of communications and documents using those resources or that refer to or involve Teradata is the “Newspaper Rule”: If your communication appeared on the front page of the newspaper for others to read without any other context, would it be perceived as consistent with Teradata’s core principles and Code of Conduct? If not, then don’t use it, send it, or post it.

Red Flags of Fraud

Red Flags of Fraud

The individual is in the office at odd hours for no apparent legitimate business purpose.

The individual is discreetly accessing/copying company records for no apparent legitimate business purpose or company records that are not related to their job responsibilities.

The individual’s lifestyle reflects that they are living beyond their means.

The individual lacks personal stability; the individual is experiencing an emotional trauma in home life or work life; the individual is facing undue/unreasonable family, company, community, financial, or lifestyle expectations.

The individual consistently tries to beat the system, compromise or manipulate processes, or exceed their authority.

An unnecessary intermediary/contractor is used; an unqualified or not-fully-vetted intermediary/contractor is used; an associate has an undisclosed personal relationship or arrangement with an intermediary or contractor.

Descriptions or dates on invoices, purchase orders or statements of work do not match the items/dates actually involved/delivered; invoices or purchase orders for one transaction-set are split into multiple invoices or purchase orders so as to avoid otherwise-required higher-level approvals.

Transferring of Teradata information/assets/data to personal email accounts without prior approval; use of personal email instead of Teradata email accounts.