CODE OF BUSINESS CONDUCT TRAINING

CONNECTING TO THE CODE

CEO INTRODUCTION

I am very pleased to introduce CSC's Code of Business Conduct training and to share with you—on behalf of
the Board and our global leadership team—how important integrity, values and culture are to CSC's success.
At CSC, we see clearly that a strong reputation for integrity is a fundamental enabler of trust and success. I
believe in a strong culture of performance with integrity—one in which our methods matter as much as our
results. This type of culture drives employee engagement, sets a single standard for how we operate as a
team, and rewards our clients, partners and investors for choosing CSC and trusting us to deliver on our
commitments.
Now, when it comes to creating and sustaining a strong culture of integrity, each of us at CSC has an
important role to play. Our Board of Directors and my senior leadership team are committed to a performance
agenda in which ethics, compliance, and CLEAR values are absolutely integral to our results. As such, you
should expect that all of our decisions and actions uphold the highest ethical standard marked by honesty,
transparency, fairness and the right tone. That's my pledge to you.
As an employee, it is equally important that you do your part to support our culture by leading with integrity,
making responsible decisions, living our CLEAR values, and operating by the ethics and compliance standards
in our Code of Business Conduct.
Our Code serves us in several practical ways. First, it reminds us of CSC's CLEAR values, which focus us on
what matters most to CSC. Second, it sets lasting expectations of the ethics and compliance commitment we
make to each other and our company, to our clients and shareholders, and to the communities in which we
work and live. Third, it reinforces our steadfast commitment to an open and honest culture in which you can
ask questions or report concerns or misconduct without fear of retaliation or hostility for having done so in good
faith.
In this training, you will learn about our code in detail and the many channels that are available if you need
help or advice, or wish to report ethical concerns.
Finally, on behalf of the Board and our global leadership team, thank you very much for all you do each day to
live by our values and the principles of our Code of Business Conduct. Thank you for your pride in CSC and for
your efforts to perform with integrity.
I now invite you to begin our Code of Business Conduct training.

Mike Lawrie
President and CEO

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INTRODUCTION
Welcome to the CSC Code of Business Conduct training course.

Our Code of Business Conduct

 Sets an expectation for integrity in our workplace
 Offers practical guidance for ethical business conduct

The Code covers a wide range of topics, policies and compliance areas. It cannot cover everything and is not a
substitute for using good judgment. Each of us is individually responsible to understand and abide by the
laws, policies and guidelines that relate to our jobs.

Our Values Are CLEAR

Our Code finds its basis in the core corporate values that unite our global CSC community.

These CLEAR values are intended to:

 Provide unifying clarity and purpose
 Align behaviors and decisions
 Describe what really matters most to CSC—including ethics and integrity

CLEAR stands for:

Client Focused
Leadership
Execution Excellence
Aspiration
Results

Our CLEAR Values

Client Focused: Our success derives from a deep understanding of our clients, to whom all of CSC is
committed to deliver exceptional service and value.
Leadership: We lead from the front, displaying our integrity and using facts to support our straight talk. We
create an environment for positive change built on collaboration and trust.
Execution Excellence: We insist on excellence in all we do for clients and ourselves, striving always for
recognition among the leaders in our industry.
Aspiration: We aspire individually and collectively to be more tomorrow than we are today.
Results: We accept individual responsibility for our commitments and expect to be accountable for results.

Course Objectives
This course will teach you about the contents of our Code. This course is designed to bring our Code to life
and to stimulate your thinking about its principles. It will help you to do your job, make choices and perform
with integrity in clear focus.

Upon completion of this course, you will be able to:

 Describe CSC's expectations for ethical business conduct
 Identify ethical dilemmas that could occur in your work environment
 Use the Code as a guide for making ethical decisions
 Identify resources for asking a question or reporting suspected or known violations of the Code,
Company policy or the law

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At the conclusion of this course, you will acknowledge that you have read the Code and completed your
training. Note: Your answers to “Ethics Challenge” questions throughout this course will not be tracked or
scored; however, your completion of the full course will be recorded for compliance.

Employee and Manager Responsibilities

The Code applies equally to all employees. Each of us is expected to:
 Know the Code
 Follow its directions
 Refer to it when a problem or question arises

Each of us is expected to set the right example and to be accountable for our actions. Managers have
additional responsibilities. You play an important role in ethical leadership. You often serve as the first
resource employees turn to, either for guidance or to resolve ethical dilemmas and compliance issues. Let's
remember that managers should:
 Always model ethical behavior and communicate a positive message about their commitment to ethics
and compliance.
 Promote our CLEAR values, the Code and compliance with policies and the law.
 Actively support ethics and compliance awareness and training engagements.
 Encourage employees to speak up by voicing concerns and reporting issues.
 Commit to open communication and listen and respond fairly to employee concerns.
 Seek satisfactory and complete resolution to ethical issues.
 Escalate concerns when additional assistance is needed.

RESPECTING EACH OTHER IN THE WORKPLACE

Diversity is a valuable asset to our Company. CSC is committed to finding and leveraging the strength in our
differing backgrounds and perspectives. This commitment starts with making employment decisions that are
based on each individual's personal qualifications. We do not discriminate on the basis of:

Race, color, religion, national origin, citizenship, marital status, sex, sexual orientation or gender identity, age,
genetic information, disability, or veteran status

Our Code also reminds us of our commitment to an open, honest and respectful work environment, free
from harassing behavior.

Harassment
Any form of unwelcome conduct toward another person that creates an intimidating, hostile or offensive work
environment.

Harassment includes:
 Verbal harassment
 Physical harassment
 Visual harassment
 Sexual harassment

You should immediately report to Human Resources any incident of harassment or discrimination that you
personally experience or observe.

Ethics Challenge
Can you identify harassing conduct? In this activity, select the response that signals the best approach for
each situation: Go Ahead or Stop Now

1) Mario tells his fellow staff member Felicia, "Great job on that presentation."
Go Ahead Stop Now

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 2) Traveling for a conference, Justin and his manager Carly work late in the hotel restaurant on their
presentation for the next day. When the restaurant closes, she suggests moving up to her room to
continue working.
Go Ahead Stop Now

3) Owen jokes with his colleague, who is in his 60's, "This work is not easy, old-timer. I hope you can
keep up."
Go Ahead Stop Now

4) Sue often tells racially themed jokes that she hears on the radio while driving to work.
Go Ahead Stop Now

5) Bill compliments a female coworker by saying, "I like your dress. It is a nice color."
Go Ahead Stop Now

6) Julien holds the door open for Alicia whose hands are full.
Go Ahead Stop Now

7) During a day of religious observance that requires fasting, Jenny is pressured by her coworkers to
participate by bringing food and eating at an office party.
Go Ahead Stop Now

Answer Key:
1) Go Ahead 2) Stop Now 3) Stop Now 4) Stop Now 5) Go Ahead 6) Go Ahead
7) Stop Now

Workplace Safety
Safety in the workplace is another important issue for our Company. CSC is committed to providing a safe
workplace for all employees. It is essential that you:
 Carefully follow all safety rules and regulations
 Report any accidents or unsafe conditions that you might see to Human Resources or to a facilities
manager

To work effectively, we must not be impaired by alcohol or illegal drugs.CSC has a zero tolerance policy with
regard to substance abuse. No one is allowed to use, possess or be under the influence of illegal drugs or
alcohol when working on company time or property. No one at our Company may engage in or tolerate any
form of violence.

This includes any direct or indirect threat or intimidation, whether physical, verbal, written or electronic. If you
know of any threats or acts of workplace violence, immediately report them. If you or someone else is in
immediate danger, contact the local authorities immediately.

Ethics Challenge
You share a workspace with a coworker and smell alcohol on the coworker after she returns from lunch. What
should you do?
A Do not take any action since the coworker is staying quiet and is not disruptive
B Report the observation to your manager
C Confront the coworker and ask if she was drinking

B is correct. You have the responsibility to uphold CSC's policy at all times by reporting the matter to your
manager.

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PROTECTING COMPANY ASSETS
We are all responsible for using Company assets appropriately and to protect them from loss, theft, waste
and misuse.

Physical assets include:

 Facilities
 Vehicles
 Furniture
 Equipment
 Electronic devices, such as computers, telephones, mobile phones, copiers and printers
These assets should only be used for legitimate business purposes and never for personal gain or
prohibited conduct.

Electronic Resources
CSC gives us access to various electronic assets to do our work. These systems are provided for business
use.

We must always:
 Use our Company's equipment and data responsibly
 Avoid questionable websites and suspicious files
 Comply with our policies and applicable laws
 Report all concerns or abuses

Unacceptable uses include:

 Storing or transmitting data in violation of the law
 Using resources to transmit harassing content
 Accessing questionable Internet sites
 Exposing confidential or proprietary information
 Downloading or using unauthorized software or applications

Some minimal personal use is permitted. Never let personal use interfere with your job duties. You should
not expect privacy, as CSC may monitor computers and communications systems.

Ethics Challenge
Jacques manages a virtual team and wants to increase the peer-to-peer interaction by using video
conferencing. His budget is limited and will not allow him to use a paid service. Jacques uses free video
software from the Internet on his home computer to communicate with family, and he thinks this service would
also be helpful for his team. He plans to have his team use the free software to meet for staff meetings and
share project strategies. Jacques believes the visual interaction will help his team produce exciting results for
the client.

Do Jacques' actions cause any risk for the company?

A No, he is creating a better team environment by using video conferencing
B No, he is saving money for the company by using free software
C Yes, he is using non-approved, unsecured software
D No, his efforts will be rewarded if his management and the client like the results

Answer C is the best choice. Jacques was considering free video conferencing software that does not operate
on a secure network, which could expose sensitive or confidential information to unauthorized individuals.
Jacques should contact his IT team to determine other low cost solutions that are available to him and his
team.

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Social Media
Social media has an important and valuable business purpose, to engage with our clients and business
partners. The use of social media should always be approached with responsibility, care and restraint. Our
Code reminds us of simple guidelines to follow when using social media for business purposes.

You should:
 Treat social media business communications with the same professionalism as any business
communication
 Only provide valuable and accurate information
 Never reveal confidential or proprietary information about CSC, our clients, or other partners
 Not attempt to speak for CSC on any issue unless you have received approval to do so
 Not engage in speculation, rumor or confrontation
 Not be anonymous and always identify yourself

If you interact with coworkers through social networking sites, always treat them with respect. The rules for
respectful communication with coworkers still apply. You should:
 Not mix sensitive work information into your personal social media use
 Protect our reputation and confidential information
 Only post as a private citizen and not on behalf of CSC
 Not discuss Company business or non-public information

Ethics Challenge
Rachel keeps a personal blog outside of work and shares her thoughts, opinions and ideas. After a long week
at work, she wrote an entry about her job. "A tough week at CSC. Long hours and so many projects. My
manager asks me to be available on the weekends, but I have a life, too! Hopefully, after the IR2 Corp win is
announced, the pace will slow down."

What did Rachel do wrong?

A Nothing; she was writing on her own personal blog outside of work hours
B Nothing; she didn't identify her manager by name
C She should not have identified herself as a CSC employee and relayed non-public information
D She should not post on her own personal blog

Answer C is the right choice. Rachel can post on her personal blog on her own time, but she should not reveal
non-public information about a contract win. She must be cautious when mentioning CSC and its business on
her personal blog. Information that is widely published without proper authorization can have serious
consequences.

Confidential Information and Intellectual Property

We must safeguard the confidential and proprietary information of CSC and our clients.

Confidential information
Information that is not public and if disclosed, might harm our Company or our clients.

Examples include:
 Client and pricing information
 Bid proposals
 Sales projections and forecasts
 Lists of legal actions
 Project activities
 Corporate strategies

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If you have access to CSC confidential information, you are obligated to protect it. Never disclose this
information to anyone outside the Company or even to coworkers unless they are authorized and need it for
business purposes. Do not handle or discuss confidential information in places where it may be seen or
overheard. Your obligation to protect confidential information does not end when you leave CSC.

Do not disclose
 CSC's confidential information to a future employer
 Confidential information from another company to CSC

Also protect the confidential information that belongs to clients and other third parties. Never disclose it
without first obtaining the necessary authorization. Please notify the Ethics and Compliance Office about
unauthorized disclosures. We must also protect intellectual property.

Intellectual property includes:

 Copyrights
 Patents
 Trademarks and service marks
 Trade secrets
 Design rights
 Logos and brands
 Know-how

Any works, inventions or developments belong to CSC. We should make sure they have legal protections.

Ethics Challenge
Which of the following is NOT an example of confidential company information?
A Customer names and addresses
B CSC Annual Report
C Data from employee personnel files
D A copy of the Company's strategic plan

B is correct.The CSC Annual Report is public information and therefore does not need to be kept confidential.

Protecting Private Employee Information

You provide certain personal information to our Company as part of your employment. Employees who
handle such personal information must protect employee privacy. We must collect process and transfer
private employee information carefully according to CSC policy and privacy laws. Personal information about
an employee should never be shared with others unless there is a specific business need. If you have
questions, please contact Human Resources or the Ethics and Compliance Office.

Ethics Challenge
Neil plans to promote Uma to a senior manager role in a department that is undergoing significant change, and
the position is expected to be demanding for the first year. Neil submits the promotion request to Rebecca in
Human Resources who recalls meeting Uma at a non-work related social event where they discussed their
families and Uma's three young children.

Although Uma has an excellent record of performance, Rebecca is concerned that she may not be able to
dedicate enough time to this position without having a conflict with her family obligations. This new information
concerns Neil because he needs a dedicated individual to take on this role.

What are the correct actions to take in this situation? Select all that apply:
A Rebecca should not reveal Uma's personal information.
B Neil should report Rebecca's actions to the Ethics and Compliance Office.

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 C Neil should not promote Uma into the new high-stress position to avoid causing conflicts with her
family responsibilities.
D Neil should not use Uma's personal information to make an employment-related decision.

A, B, and D are correct. CSC bases employment decisions on an individual's qualifications. These three
actions are required for maintaining the confidentiality of employee personal data. It is wrong to use an
employee's personal information without proper authorization and a valid business reason, even if your motive
is intended to protect the employee.

Speaking to the Media

We must protect our confidential information from being revealed to the press or to other third parties
SEC regulations require CSC to disclose all significant company information to all investors at the same time.
Designated communications personnel speak to the media or financial analysts who may be seeking
information from our Company. Direct calls from the media, a financial analyst or an investor to Investor
Relations or Corporate Communications.

Accurate Books and Records

We take seriously our responsibility to accurately record financial transactions. Our Company is committed
to preparing full, fair, accurate, timely and understandable records and disclosures.
All employees are responsible for keeping accurate and complete timekeeping records and expense reports.

Follow CSC's Employee Timekeeping policy when recording your time worked on each project.
These records must be accurate and honest so that pay is accurately calculated and clients correctly billed.
We must also follow our internal procedures when preparing and submitting expense reports.
These reports should be accurate and timely and must include all required receipts and other
documentation.

By following these procedures and our internal controls, we preserve the trust our clients have in us. Always
strive for accuracy and completeness in our client billing. If you have any questions, please contact your
manager, Human Resources or the Ethics and Compliance Office.

Ethics Challenge
Your manager is responsible for financial reports and is directing you to make an entry that you believe to be
inaccurate and misleading. What should you do?
A Make the entry as directed by your manager since she is the one responsible
B Listen to your manager, but then make the entry the way you think appropriate when she's not looking
C Explain your position to your manager; escalate your concern if she refuses to listen

C is correct. It is important that we speak openly and honestly about potential issues and differing
perspectives, especially with respect to bookkeeping entries. Everyone is responsible for accurate financial
reporting. Never knowingly contribute to misleading financial statements. Always escalate or report suspected
financial reporting and policy violations.

Ethics Challenge
Liam is working with a new client account. He worked 50 hours in a week to familiarize himself with the project.
After submitting his weekly time entry, he received an email from his manager asking him to change his entry
to 40 hours in an effort to keep the client billing to standard regular hours.
His manager also indicated that any hours above the limit should not be recorded because he has not yet had
time to set up a separate overhead account. Liam is confused by this direction because he thought CSC policy
required employees to record all work hours.

What should Liam do?

A Follow his manager's direction despite his concerns that it may be in conflict with policy
B Ask a colleague what to do

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 C Confirm the direction with the client
D Explain his concern to his manager, and escalate the concern to another member of management,
Human Resources or the Ethics and Compliance Office if his manager sets the concern aside

D is the best choice. Employees must always record all hours worked to the proper work authorization codes.
It is important that we take compliance concerns to our managers whenever possible. If the direction seems
inconsistent with policy or the manager fails to act, then alerting another resource about the situation is
appropriate. A decision to escalate a matter will help the company preserve a strong ethical commitment to
maintaining accurate books and records.

Record Retention and Disposal

We must comply with all legal and regulatory requirements related to our business records.

Examples of business records include:

 Contracts
 Business correspondence (including email)
 Employee and payroll records
 Financial, tax and audit records
 Expense reports
 Time reports
 Billing data
 Health and safety information
 Voicemail

Our Records and Information Management policy contains guidelines on:

 Which business records we should keep
 How long we must keep them
 How and when they should be destroyed

You should always follow CSC policy for retention and destruction of business records. If a record is needed
for an audit, investigation, or legal matter, you will be notified by the Legal Department of a legal hold.

Legal Hold
Requirement that you must maintain or turn over the specific records and not destroy them. For more
information, contact the Global Information Management Department.

Ethics Challenge
You have been notified by your manager that CSC may become involved in a legal action related to an issue
that you had maintained in certain case files. The Legal Department has not yet issued a legal hold.

What should you do?

A Go ahead and shred the documents since there hasn't been confirmation that the legal action will
occur
B Discard or otherwise dispose of the documents according to CSC's records retention schedule and the
Records and Information Management Policy
C Save the documents indefinitely
D Contact the Legal Department or the Global Information Management Department about how to
handle the records

D is correct. Always seek guidance on the correct action, especially with respect to a possible legal hold or an
anticipated investigation, audit or legal matter.

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CONFLICTS OF INTEREST
We each have a responsibility to protect the interests of CSC. We should avoid situations that give rise to a
conflict of interest, or even the appearance of a conflict of interest.

Conflict of Interest
Situation that arises when our personal interests interfere with our ability to make sound business decisions on
behalf of the Company.

Examples include:
 Taking outside employment that might conflict with your job at CSC
 Hiring, supervising or reporting to family members or friends
 Having a significant financial interest in competitor companies or in companies that are seeking to do
business with CSC
 Serving on outside boards of directors and associations
 Speaking at industry engagements

It is essential that we act with integrity and transparency in all personal dealings. If you think you may have a
conflict of interest, talk to your manager, Human Resources or the Ethics and Compliance Office.

Ethics Challenge
Your former employer – a CSC competitor – asks you to work for them on the weekends as a consultant.

Would accepting create a conflict of interest?

A Yes, because you would be working for a CSC competitor
B No, because the work will be done on your own time
C Yes, because you accepted secondary employment

A is correct. Working for a customer, supplier and especially a competitor of CSC is a conflict of interest. As a
CSC employee, you are obligated to refuse this opportunity.

Gifts and Entertainment

Giving and receiving favors or gifts and the offer of entertainment or other hospitality are a normal part of
doing business. Gifts and entertainment can lead to conflicts of interest if the frequency or value:
 Creates or implies a business obligation
 Improperly influences the recipient's objective business judgment

In general, CSC employees should not accept gifts or entertainment from people with whom we do business.
Some gifts or entertainment may be acceptable provided:
 They are modest and appropriate to the business relationship
 They are infrequent and unsolicited
 They are not cash or cash equivalents
 CSC is not participating in a public tender or commercial bid process at the time of the exchange
 Personal funds of CSC employees are not used to pay for them

You should never give or accept:

 Anything that could be viewed as influencing your or the recipient's decisions
 Entertainment that could embarrass CSC
 Anything illegal or which violates CSC's or the recipient's internal policies

If you are unsure, consult with the Ethics and Compliance Office.

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Ethics Challenge
Can you identify when it is acceptable to give or receive a gift or entertainment? For each of the following
situations, select the proper response:

STOP NOW
USE CAUTION
GO AHEAD

1) You consider giving one of your clients a gift card to express your appreciation for helping you to meet
your sales target.
Stop Now Use Caution Go Ahead

2) A business partner invites you to join him on a weekend trip that includes tickets to a championship
sports game and three nights in a hotel.
Stop Now Use Caution Go Ahead

3) It is the holiday season, and you consider sending a $15 box of candy to each of your clients. You
haven't given your clients anything else this year.
Stop Now Use Caution Go Ahead

4) You give a coffee mug with the CSC logo on it to a new client.
Stop Now Use Caution Go Ahead

5) A consultant gives you an expensive watch after completing a project to thank you for hiring him.
Stop Now Use Caution Go Ahead

6) One of your clients is in town, and your manager suggests that you take him to dinner at a reasonably
priced restaurant.
Stop Now Use Caution Go Ahead

Answer Key:
1) Stop Now - Giving or receiving a cash or cash equivalent gift is never acceptable. Moreover, a gift
should not be given if it could even appear that the gift may be intended to influence a business
decision.
2) Stop Now - This entertainment is excessive and could be considered a business inducement. You
should report this offer to your manager.
3) Go Ahead - It is generally okay to give tangible, non-cash items of nominal value that either have a
true business purpose or are intended to celebrate a special occasion, such as a holiday season.
4) Go Ahead - It is generally allowable to provide small gifts of token value that foster business
relationships but do not improperly influence decisions.
5) Stop Now - You should not accept any gift that is of more than token value and which could be
interpreted as an informal agreement to continue business. You must advise your manager or the
Ethics and Compliance Office if such a gift is offered to you.
6) Go Ahead - You may offer this invitation because the entertainment is modest, fosters your business
relationship and has been approved by your manager.

CONDUCTING BUSINESS ETHICALLY

CSC does business globally, and we must follow all applicable laws and regulations that apply to us. Our
Code reminds us:
 We never bribe anyone to obtain or retain business or to secure any other improper advantage.
 We do not allow any of our business partners, associates or any other parties to give or take bribes for
us.

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FCPA and Anti-Bribery Laws
We comply with all laws that prohibit bribery and kickbacks, such as the U.S. Foreign Corrupt Practices Act
(FCPA). The FCPA makes it illegal to give or offer anything of value to a foreign government official or a
member of the individual's family in order to obtain or retain business. We also comply with the UK Bribery
Act. Under UK law, it is illegal to bribe:
 Government officials
 Anyone in the course of doing business

Government Official
Employees of any government, political candidates and party officials, members of royal families, employees of
businesses that are owned or controlled by a government and employees of international organizations. A
corrupt payment or bribe can include:

 Money in any form including cash currency, checks, money orders or other negotiable instruments or
securities
 Gifts
 Favors
 In-kind use of company resources
 Entertainment
 Other items or services of value

In some locations around the world, facilitating or "grease" payments customarily are permitted.
CSC forbids such payments. Violations of anticorruption laws carry severe penalties. If you have any
questions, contact our Ethics and Compliance Office or the Legal Department.

Ethics Challenge
Pieter is managing a project for CSC and needs to obtain a permit quickly to transact business with a company
in Asia. The government official says the permit will take 90 days to receive — unless Pieter pays $250 USD
cash for him to personally expedite the transaction. The official assures Pieter that this is the custom.

What course of action should Pieter take?

A Contact the Ethics and Compliance Office to report the request for the expediting payment
B Pay the money and record it as several meals in his expense report
C Pay the money, document the payment properly and then notify the appropriate company
resources

A is the best choice. Payments to expedite routine government action, also known as facilitating payments, are
not allowed under CSC policy. Immediately contact the Ethics and Compliance Office if you receive a request
for such a payment.

Government Clients
We treat all of our clients with respect and deliver high-quality services to everyone. There are special laws,
rules and regulations we must obey when our client is a government. We must always be aware of our
obligations under government contracts and required accounting and billing practices. There are significant
penalties for not following the law. As a leading provider of services to governments, CSC must follow these
rules. When working on a government contract, you must maintain accurate and detailed records. The
government may conduct periodic audits. You must:
 Always allocate work hours to the correct contract
 Never use government time or equipment for any purpose other than the contracted activities

We must also be cautious in our relationships with government officials. You must:
 Be familiar with anti-corruption statutes
 Not provide gifts or entertainment without following our policies and procedures
 Even a small gift or a simple lunch may violate the law
 Exercise caution before offering anything of value to a government employee

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  Do not discuss employment opportunities with government personnel
 Seek guidance from the Legal Department or the Ethics and Compliance Office

Trade Restrictions and Anti-Boycott

Our work involves the deployment and use of sophisticated technology. We take great care to ensure that
when we use or transfer such technology, we do so legally. Strict laws and regulations limit the transfer of
certain products and technologies to certain individuals, organizations and nations.
We must:
 Verify the eligibility of both the location and the recipient before exporting any product, technology or
other information.
 Ensure that we have properly obtained all required licenses and permits and paid all fees and duties
for each transfer.

Sanctions and embargoes put in place by the United States restrict us from investing in or trading goods,
technology and services with certain countries. We must comply with these sanctions when we are
conducting business internationally.

Boycott
A refusal to have dealings with a person, company or organization to express disapproval or to force
acceptance of certain terms and conditions.

U.S. anti-boycott laws prohibit cooperating with international boycotts that are not sanctioned by the U.S.
government. We must be especially cautious about any boycott request. Be aware of red flags that might
signify our Company is being used by a third party as a channel for illegal funds or money laundering.
These red flags include:
 The lack of a physical address
 A complicated or suspicious business history
 Reluctance by a third party to provide information, particularly about the source of the funds

If you have questions or concerns, contact the Ethics and Compliance Office.

Insider Trading
The illegal act of buying or selling securities based on material, non-public information. We may gain access to
significant or material information about our Company or other organizations. When other investors are not
privy to this information, it is unlawful for us to use it for investment decisions. Information is non-public if it
has not yet been released to the general public.
Examples of material, non-public information include:
 Financial results or information regarding future earnings or losses
 Impending bankruptcy or liquidity problems
 A major change in management
 A significant acquisition or divestiture
 The gain or loss of a significant client or contract
 Significant new discoveries or developments
 An impending dividend or an offering, sale or repurchase of securities

If you possess material, non-public information about CSC or any company:

 Do not buy or sell securities in those companies
 Do not tip or provide material, non-public information to others

Violations of insider trading laws carry severe penalties. Seek guidance from the Legal Department or the
Ethics and Compliance Office. You should immediately report violations to the Ethics and Compliance Office.

Fair Dealing and Competition

CSC is committed to fair and ethical business practices. You should never:
 Make misleading statements about our product and service offerings
 Disparage our competitors' products

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Always strive to deal fairly and honestly with our business partners and to fulfill our service agreements.
Behaving ethically and with integrity is the right thing to do and is good for business. CSC always competes
vigorously, but fairly in the marketplace. We make sure to follow all applicable antitrust and fair competition
laws. The basic requirement of antitrust laws is that each company makes its business decisions
independently. Agreements to achieve an unfair business advantage violate these laws

You should never:

 Fix prices
 Rig bids
 Allocate territories or markets
 Agree with competitors or suppliers not to deal with certain companies

Be careful any time you communicate with a competitor. Avoid any conversation that could even appear to
violate antitrust laws.

You must immediately:

 Stop the conversation
 Contact the Legal Department or the Ethics and Compliance Office

Ethics Challenge
Noor and Jariah were former colleagues for many years at a different company. Now working for competitors,
Noor and Jariah see each other at a social function during a trade show. Jariah casually mentions that his
company is considering a price increase for services. He then quietly asks Noor about CSC's pricing and
whether she thinks the company would consider raising prices by the same amount.

What should Noor do?

A End the conversation immediately, and contact the Ethics and Compliance Office
B Make a joke to show she does not take Jariah's suggestion seriously
C Refuse to have any further interaction with Jariah whatsoever
D Make the pricing agreement with Jariah because he's trustworthy, and no one else would know

A is correct. It is important to avoid even the appearance of collaborating with competitors in activities that
violate antitrust statutes, including by discussing prices, bids, specific markets or clients. Immediately stopping
the conversation and informing the Ethics and Compliance Office about what happened is the best way to
minimize the risks this situation poses.

SEEKING GUIDANCE AND REPORTING CONCERNS

Integrity starts with a commitment to ask questions, raise concerns and engage in an open dialogue. That is
why we all must speak up when we have a question or a concern about a situation that affects our Company.
CSC has an Open Door policy that encourages everyone to speak freely and report concerns. You should
speak up if you:
 Are directed by your supervisor or your manager to do something inconsistent with CSC's Code
 Are confused or worried by something you've seen or heard or when you need advice
 Don't understand a policy, a law or a regulatory compliance obligation
 Know or suspect an instance of fraud, corruption or abuse
 Are faced with an ethical dilemma and are reluctant to proceed or are unsure of the consequences of
an action you're considering
 Feel concerns you've previously raised have been mishandled or set aside
 Know or suspect any violation of the Code has occurred

If you have a question or want to make a report, you should first contact your manager. You may also
contact:
 Your department or function head
 Your local Human Resources manager or an HR representative at a higher level

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  CSC's Ethics and Compliance Office (ethics@csc.com)
 CSC OpenLine (www.cscopenline.ethicspoint.com)

No Retaliation
When you report a concern, each issue is handled or investigated promptly, consistently and appropriately.
We will maintain your confidentiality to the extent permitted by law. When the investigation is completed,
CSC will take any necessary corrective actions. CSC will neither discipline nor permit direct or indirect
retaliation against employees who speak up. Our Company has zero tolerance for threats or acts of
retaliation.

Good faith
 Does not mean you have to have definite proof that a violation has occurred
 Means that you honestly believe your report to be true

If you believe you are being retaliated against for reporting a concern, immediately contact Human Resources
or the Ethics and Compliance Office.
Ethics Challenge
Pascal is suspicious that Lyna may have made an improper payment to a competitor to receive the
competitor's confidential information.

What should Pascal do?

A Nothing; he does not have proof and the situation does not directly involve him
B Pascal should report his suspicions that a violation of the Code or the law has occurred
C Confront Lyna with his suspicions
D Seek the opinion of an uninvolved coworker to confirm if his suspicions are valid

B is correct. Pascal should not ignore the situation if he honestly believes corrupt payments are being made. If
he knows about or suspects any incidents of misconduct or ethical violations, it is his duty as an ethical leader
to report it.

Conclusion
Our Code and our CLEAR values will
 Help guide you in making ethical decisions
 Keep our company an ethical, honest, inclusive and transparent place to work

The ethical choice is always the best choice. And when we make the ethical choice, we personally commit to
strengthening CSC's culture of integrity. Stay connected to ethics and get the information you need about
CSC's business conduct policies by joining the Ethics and Compliance group on C3.

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ACKNOWLEDGMENT AND CONFIRMATION
“I affirm that I have completed the Code of Business Conduct training course, and I acknowledge that I have
read and agree to comply with CSC's Code of Business Conduct, the company's policies and any laws and
regulations that apply to my job. I understand that any questions I have about the Code of Business Conduct
should be directed to my manager or to CSC's Ethics and Compliance Office. I understand further that multiple
resources are available for me to report a concern or seek advice.”

CSC’s Code of Business Conduct can be found online at:

http://www.csc.com/governance/ds/88549-code_of_business_conduct. Please contact your manager if you
need help locating the Code.

Name (please print) ______________________________________________________

CSC Shortname _________________________________________________________

Employee Number _______________________________________________________

Signed _________________________________________________________________

Date ___________________________________________________________________

Please submit this signed page to your manager, Human Resources representative, or other business
unit designee.*

Congratulations! You have now completed the course.

*North American Public Sector Employees:

If you complete a paper copy of this briefing, ask your manager to identify the person to whom you should
submit your briefing Acknowledgement Form. You must submit the Acknowledgement Form in order to receive
credit for completing the training. For additional information and answers to frequently asked questions,
contact your Training Process Group (TPG) representative or visit: https://c3.csc.com/docs/DOC-87680.

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JOB AIDS

Ethics and Compliance Office

 Email: ethics@csc.com Connect on C3: https://c3.csc.com/groups/ethics

CSC OpenLine (www.cscopenline.ethicspoint.com)

CSC Code of Business Conduct

(http://assets1.csc.com/governance/downloads/EthicsStandards.pdf)

CSC Policies on Conduct

 Management Policies: https://domino.csc.com/clu1/Resource/mps.nsf
 Human Resources Policies: https://domino.csc.com/clu2/resource/handbook.nsf

CSC Clear Values

 Connect on C3: https://c3.csc.com/groups/csc-values

Timekeeping and Expense Reporting Handbook (U.S.)

(http://www.csc.com/assets/secure/css_us/downloads/timekeeping_and_expense_reporting.pdf)

Global Information Management Department

 Connect on C3: https://c3.csc.com/groups/csc-global-information-management-gim
 Email: gim@csc.com

IT Security
 Global Network Security on C3: https://c3.csc.com/groups/global-network-security
 Security Awareness on C3: https://c3.csc.com/groups/security-awareness
 Email: ciso@csc.com

Security Incident Response Control Center (SIRCC)

Email: sircc@csc.com
Sametime (Group Name): CSC SIRCC Information Office
Phone: +61 2 9034 3430, Toll Free: +800 2722 7227 (It may be necessary to dial your country code before the toll free
number. For example, to dial U.S., 011 800 2722 7227)
Australia: 1300 368 739
United States (non AT&T carriers): 1010 288 011 800 2722 7227

Global Trade Controls Department

 Connect on C3: https://c3.csc.com/groups/global-trade-controls
 Email: GlobalTradeControls@csc.com

U.S. Foreign Corrupt Practices Act (FCPA) (http://www.fcpa.us/)

UK Bribery Act (http://www.justice.gov.uk/legislation/bribery)

Accounting Guidance
Contact the Technical Accounting Guidance team for inquiries on technical accounting issues and advice on proper
application of United States Generally Accepted Accounting Principles (US GAAP) in recording transactions
 Email: AccountingGuidance@csc.com, Telephone: +1 703.645.2666

Corporate Media Relations

Contact Joel Shadle (jshadle@csc.com), Telephone: +1 703.645.2660

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