Cognizant's Core Values and Standards of Business Conduct

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C O R E VA L U E S A N D S TA N D A R D SGifts and GratuitiesWhy it is ImportantTo maintain trust in our business relationships, we must avoid giving or receiving gifts that influence, are intendedto influence, or appear to influence business decisions except in accordance with standard business practices. Whenwe accept or give such gifts, particularly when they exceed local social and/or business customs, it can underminecustomer relationships, hurt our reputation and put the Company in legal jeopardy.Our CommitmentAs Cognizant Associates, we must only give gifts in compliance with applicable law that are nominal in amount andnot given in consideration or expectation of any action or favor by the recipient.We must immediately return any gift that is not nominal in value and report its receipt to our manager. If immediatereturn of the gift is not practical, we should give the gift to the Company for charitable disposition or such otherdisposition that the Company believes appropriate.We must not:nnnnnnAccept or permit any member of our immediate family to accept any gifts, gratuities or other favors from anycustomer, supplier or other person doing or seeking to do business with the Company, other than items ofnominal value or items that do not exceed local social and/or business customs.Give gifts outside of standard business practices in hopes of influencing a business decision.Give Company funds or assets for gifts, gratuities or other favors to government officials.Bribes and KickbacksBribes and kickbacks are criminal acts, strictly prohibited by law. As Cognizant Associates we must never offer,give, solicit or receive any form of bribe or kickback anywhere in the world.Business EntertainmentCommon sense and moderation should prevail in business entertainment engaged in on behalf of the Company.Cognizant Associates should only provide or accept business entertainment to or from someone doing businesswith the Company if the entertainment is modest and intended to serve legitimate business goals.International Considerations in the Receipt of GiftsLaws and customs of some countries permit gifts and courtesies beyond those considered customary in the U.S.Refusing such gifts or courtesies might be considered offensive in that country. If, as Cognizant Associates, wefind ourselves in a situation where it is difficult or inadvisable to refuse a gift or courtesy, we must disclosereceipt of the gift to our manager immediately. He or she will assist in handling the matter.Examples of Appropriate and Inappropriate BehaviorDon Follow Company guidelines for accepting gifts orentertainmentn Accept a gift if refusing the gift will insult or embarrassthe giver, and then give it to the Company forcharitable or other disposition if it exceeds thelimits in the table belowDo Notn Agree to frequent client requests for meetingsinvolving extravagant entertainmentn Accept a family outing in a tourist resort as a giftfrom a prospective vendor29
C O R E VA L U E S A N D S TA N D A R D SGuidelines for Determining the Acceptability of Gifts andEntertainmentGifts and entertainment generally fall into three categories:nnnThose that are usually acceptable and that you may approve yourself.Those that are never acceptable.Those that may be acceptable but require prior approval.Usually acceptableSome gifts and entertainment are sufficiently modest that they do not require prior approval. The following areusually acceptable without prior approval:nnnMeals: modest occasional meals with someone with whom we do business.Entertainment: occasional attendance at ordinary sports, theatre and other cultural events.Gifts: gifts of nominal value (see tables below), such as pens, calendars or small promotional items.Always unacceptableOther types of gifts and entertainment are simply wrong. These are never permissible, and no one can approvethem. These are:n Any gift or entertainment that would be illegal (anything offered to a government official in breach of localor international bribery laws).n Gifts or entertainment involving parties engaged in a tender or competitive bidding process, except inaccordance with standard business practices.n Any gift of cash.n Any gift or entertainment that is a “quid pro quo” (offered for something in return).n Any entertainment that is indecent, sexually oriented, does not comply with Cognizant’s commitment tomutual respect or that otherwise might adversely affect Cognizant’s reputation.n A gift or entertainment that you pay for personally to avoid having to report or seek approval for it.May be acceptable with prior approvalIf the gift or entertainment you are considering does not fit into the other categories, it may or may not bepermissible. You must get approval from a manager (with a designation of Manager or above) for the following:nnnnGifts and entertainment valued at more than the amounts in the first column on the next page.Meals that cost more than $150 (or equivalent) per person.Special events such as a World Cup game or major golf tournament.Client or vendor paid non-business travel or overnight accommodation, as this normally raises the personalbenefit to material levels.For gifts and entertainment that exceed the limits in the right-hand columns on the next page, you must notifyone of the following: Chief Executive Officer, Chief Financial Officer, General Counsel or Director – Compliance.30
Page 1 and 2: Cognizant’s Core Values andStanda
Page 3: | Introduction
Page 6 and 7: C O R E VA L U E S A N D S TA N D A
Page 10 and 11: | The Standards
Page 20: C O R E VA L U E S A N D S TA N D A
Page 46 and 47: | Index

Cognizant's Core Values and Standards of Business Conduct

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