Teradata Corporation Code of Conduct

Participating In Industry Associations and Trade Shows

Industry associations, conferences and trade shows can be wonderful networking and business development opportunities, but they can also pose legal and ethical challenges. When attending these events, be careful to avoid even the appearance of improper collusion. If you become aware of any formal or informal discussion between competitors regarding anti-competitive topics at any of these events, you should excuse yourself and contact the Law Department.

Dealing Fairly with Customers

Teradata is known for its extraordinary customer dedication and service. To live up to this reputation, we must deal fairly with our customers.

Fair competition laws generally allow Teradata to choose the companies with which we conduct business. However, those decisions must be made independently and never in agreement or collusion with competitors.

As part of dealing fairly with customers and avoiding violating competition laws and fair trade practices laws, we never:

Make false, unfounded, or misleading statements about our competitors’ products or services, or make false or unfounded comparisons of their products and services with our products and services.

Make commitments or promises that you or Teradata do not intend to or are not able to keep.

Sell comparable goods on comparable terms at significantly different prices, during the same time periods, in the same volumes, and in the same geographies to customers who compete with one another. Significant pricing deviations for competing customers, which are not justified based on objective differences in products/services, timing, geography, terms, volumes, and the like, can constitute illegal, anti-competitive price discrimination.

If you have any questions about how to deal fairly with customers, seek guidance from the Law Department before you act.

Not Abusing Market Power

Fair competition laws also restrict companies from taking actions that discourage innovation and competition based on their market power. To avoid abusing market power, we should not:

Sell our goods and services at below-cost pricing with the intent of driving competitors out of the market.

Tie the purchase of certain goods and services to the required purchase of additional items.

Make reciprocal deals with customers where we commit to buy their products if they commit to buy ours, unless pre-approved by the Law Department.

Make exclusive dealing (exclusivity) arrangements, without prior approval from the Law Department.

Business Intelligence

Obtaining accurate information about our competitors’ activities is necessary and may even be part of your job. We obtain this information ethically and from legitimate sources. These include publicly available documents, analysts, publications, and the Internet.

We may not, however, gain a competitive advantage by obtaining information through illicit means. We may never steal confidential business information or trade secrets by any means—not through bribery, espionage, false pretenses, or other illegal or unethical behavior. This means, in part, you should not ask for or encourage others to share with you any information that would violate a confidentiality agreement they have with any other company. If someone sends you confidential information unsolicited, you should advise the Teradata Law Department immediately.

Teradata competes fairly and aggressively, but legally. If you are a former employee of a Teradata competitor, do not disclose or use any of your prior employer’s confidential information or trade secrets in connection with your Teradata job. Even if you are asked by one of your colleagues or managers to share such information, you must not.