with clients, prospects, partners, and one another, we are making a statement about our company’s

character. Simply put, Cognizant’s global reputation is in our hands. Staying true to our values of integrity,

ethical behavior, and lawfulness is critically important.

As ingrained and powerful as our culture of integrity is, our reputation can be damaged with just one small

lapse. So we must stay ever vigilant to maintaining our culture of ethics and compliance. Our Code of

Living by a clear set of values, ethics, and standards is what earns and sustains the trust of clients, which

in turn creates a competitive advantage, contributes to our growth, and strengthens our brand.

Let’s all work together to ensure that acting with integrity remains core to our culture.

a leader in our industry. One way we distinguish ourselves in the market is by maintaining the highest

standards of integrity. Our reputation and our success depend on it— but it’s more than that. Whether

at work, in a development center, on-site with our clients, in our corporate office, or in our everyday lives,

integrity is core to who we are.

We created our Code of Ethics (“Code”) to help you ensure that everything you do at Cognizant is in

accordance with our standards of integrity. The principles of this Code, and the related Ethics and

Compliance Program are approved by and have the full support of Cognizant’s Board of Directors. The

Board of Directors and management is responsible for overseeing the Ethics and Compliance Program

and compliance with this Code.

depend on our commitment to perform

with the highest level of integrity.

ethically includes respecting privacy,

protecting information, and

safeguarding assets.

All associates are responsible for upholding our

culture of integrity. It is not only the right thing to

do, but also an integral part of our commitment

to excellence and our dedication to being a

responsible corporate citizen.

• Look for and address developments in your

• Report any suspected violations of our Code,

• Cooperate fully in Cognizant investigations

Code. However, a failure to promptly

disclose a conflict is always a violation.

In fact, many conflicts can be cleared

or easily resolved once reported.

Disclosing and seeking approval for

any activity that may give rise to a

potential conflict allows the company

to document its approval and any

agreed upon controls to mitigate

the impact of that conflict on the

and is not allowed. We never conduct business

based on our personal relationships or any personal

or financial stake we may have in the outcome of a

decision. Similarly, we never use our connection to

Cognizant for personal gain of any kind. Potential

conflicts could arise through:

• Outside Employment & Board Memberships

• Financial Investments and Arrangements

• Close Personal Relationships

• Government Roles

interest, or something that others could reasonably

perceive as a conflict of interest, you must report

it to your manager or Cognizant’s Chief Ethics &

Compliance Officer as set forth in our Conflicts of

Interest Policy.

If you are a member of the executive committee, an

executive officer or Board Member, you must report

any such situation in writing to Cognizant’s General

Counsel who will then discuss with the Chair of the

Audit Committee of the Board of Directors, as needed.

Unless you are authorized in writing by the Head of Investor Relations or the Head of External

Communications, do not communicate with any member of the media or investment community on

behalf of Cognizant, clients, competitors or our industry.

Cognizant, we may from time to time learn of material nonpublic information about Cognizant or

another company (such as a current or potential customer, partner or M&A target). We have an

obligation to ensure that we and our affiliated persons, such as family members, do not trade on

such material nonpublic information or provide (“tip”) or allow access to such information to others

records and that our accounts accurately reflect transactions. This is a prerequisite to preparing

accurate financial statements for external stakeholders. Cognizant also has zero tolerance for

submitting false or inaccurate claims to its clients or third parties with whom it interacts, including

any government entities. Always ensure you record and categorize all costs — including timesheets,

travel & expense reports and other billable expenses — to the appropriate accounts and clients and

carefully review all documentation to ensure its accuracy.

with those who need to know. Prior to transmitting Cognizant sensitive financial data to a third party,

editor), direct those queries to the Corporate

Communications team. Never disclose

company information, including emails,

and always be mindful of the potential to

accidentally share internal confidential

information that you have been exposed to.

Consider this, you could be in a WhatsApp

group right now that includes third parties

such as press or competitors. If you were

to discuss imminent personnel changes

• Associate Privacy Notice

• Intellectual Property Policy

• Acceptable Use Policy

• Record Retention Policy

• Be sure to protect our company and client information and assets.

• Communicate professionally and appropriately.

• Could it be against the law?

• Could it cause harm to Cognizant’s brand, reputation, financial performance or

• How would the decision look to other Cognizant associates or to someone outside of Cognizant?

• Am I willing to be held accountable for this decision?

• Is this in line with Cognizant’s Code?

Nothing in our Code should be misunderstood to prevent you from reporting a violation of law to a

government agency, or from cooperating in a government investigation. If you have any questions about

government investigations, please direct them to the Legal Department.

of such requests, and reports such requests and dispositions to the company’s Audit Committee.

Any executive officer or Board Member who seeks an exception to any of the Code provisions should

contact the company’s General Counsel. Any waiver of the Code for executive officers or Board Members

or any change to this Code that applies to them may be made only by the Board of Directors of the

company, and may be disclosed as required by law or stock market regulation.

Cognizant associates have a responsibility to report suspected

violations of this Code. Cognizant is committed to ensuring that an

subject to disciplinary action, up to and including termination, as permitted by local laws. If you know or

suspect that you or someone you know has been retaliated against, you should contact our Chief Ethics &

Compliance Officer or the Ethics & Compliance Helpline immediately.

For more information about our prohibition on retaliation for reporting, please see our Whistleblower and

Non-Retaliation Policy.

• There will be no retaliation for making a report,

even if no violation is found.

• Associates must fully cooperate with

investigations of ethics or compliance issues.

To make a report by telephone, please dial the number specific to your

country and follow the prompts:

The Cognizant Ethics & Compliance Helpline is serviced by a third-party provider that is available by phone or online 24 hours a day, 7 days a week. Reports of suspected

violations or concerns may be made anonymously, where local laws allow. However, you are encouraged to identify yourself when making a report, so that additional

information can be obtained if needed. Whenever possible and permitted by law, your identity will be kept strictly confidential. The Ethics & Compliance Helpline also

features a Question Manager, where an associate may seek advice.