CODE OF ETHICS We comply with all applicable laws and regulations. 14 We interact ethically with governments and their representatives. 15 We respect privacy and protect customer and employee data. 16 We prohibit and do not engage in insider trading or similar conduct. 18 We develop and use artificial intelligence (AI) responsibly. 19 We protect innovation and intellectual property rights. 21 We are responsible with gifts, meals, and entertainment. 22 We avoid improper payments. 23 We believe in and promote fair competition. 24 We safeguard our corporate resources. 25 We use our Code to help us make ethical decisions. 27 We prioritize learning and development. 28 We, as people leaders, foster an ethical culture. 31 We speak up by asking for advice and reporting concerns. 32 We select our partners and suppliers carefully. 33 We investigate reports of misconduct. 34 We are active bystanders and TAP in to stop unethical behavior. 37 We are committed to creating a culture of belonging. 38 We prioritize safe and secure workplaces. 39 We respect human rights throughout our business operations. 40 Bill McDermott, Chairman and Chief Executive Officer 1 Hossein Nowbar, President and Chief Legal Officer 2 Code of Ethics Table of Contents Bill Burtis, Chief Ethics & Compliance Officer 3 ServiceNow’s Code of Ethics 4 Administration, waivers, and amendments. 41 Policies and resources. 41 We communicate accurately and honestly. 7 We avoid conflicts of interest and handle corporate opportunities ethically. 8 We create and maintain accurate and complete books and records. 10 We do not allow retaliation. 11 Transparency Responsibility Understanding Supervision Teamwork — 1 —To report concerns or seek guidance, contact the Speak Up Line at www.servicenow.ethicspoint.com, call +1 (855) 869-7272 (country-specific numbers available online), or email SpeakUp@servicenow.com. CODE OF ETHICS We owe it to ourselves, our team, and our customers to always do right. There’s only one way to become the AI defining enterprise software company of the 21st century (AI DESCO21C).....that’s the RIGHT way. Bill McDermott Chairman and Chief Executive Officer OUR CODE TRANSPARENCY RESPONSIBILITY UNDERSTANDING SUPERVISION TEAMWORK — 2 —To report concerns or seek guidance, contact the Speak Up Line at www.servicenow.ethicspoint.com, call +1 (855) 869-7272 (country-specific numbers available online), or email SpeakUp@servicenow.com. CODE OF ETHICS Winning the right way isn’t just about results; it’s about how we achieve them. When we uphold ServiceNow’s values in every interaction, we strengthen the foundation of trust that allows us to serve our customers with elite-level execution. Hossein Nowbar President and Chief Legal Officer UNDERSTANDINGRESPONSIBILITYTRANSPARENCYOUR CODE SUPERVISION TEAMWORK To report concerns or seek guidance, contact the Speak Up Line at www.servicenow.ethicspoint.com, call +1 (855) 869-7272 (country-specific numbers available online), or email SpeakUp@servicenow.com. — 3 — CODE OF ETHICS To the ServiceNow Community, Our Code of Ethics reflects who we aspire to be and who we already are when we’re at our best. Every day, you make choices that define ServiceNow. Those choices, multiplied across our global team, create our culture. And our culture is our competitive advantage. Trust as Our Foundation ServiceNow was built on a vision: to transform how people work and make the world work better for everyone. As the AI defining enterprise software company of the 21st century, achieving that vision requires trust. Our customers trust us with their most critical operations. Our investors and partners trust us to operate with integrity. Our colleagues trust each other to do right even when it’s difficult. This Code exists to protect and strengthen that trust. Trust is most powerful when we act as active bystanders — when we Think, Act, and Prevent (TAP) by stepping in when something doesn’t feel right. Our Commitments to Each Other We will never ask you to compromise your integrity to achieve a business goal.