Our Code of Ethics
How we make our world of work, work.
A Code based on values
Our purpose leads the way
We show up every day with our purpose leading the way, aligned to our core values, and we always do the right thing by keeping integrity, teamwork, and trust top of mind. This not only applies to ServiceNow’s employees and leaders, but our entire community including contingent workers, executive officers, and Board of Directors.
We recognize that decisions are not always clear-cut. That’s why our Code provides an overview of some of our specific policies, as well as the framework to help us navigate areas of uncertainty and apply our values to all situations.
Our values and behaviors come together as our Code of Ethics (our “Code”). And, the true function of our Code is to act as our cultural guiderails and provide tools and resources to help you do the right thing, time after time, no matter the circumstances.
Because, to make the world of work, work better for people, we must make our world of work the best that it can be.
Our values
- Stay hungry and humble
- Embrace diversity, create belonging
- Enjoy the journey
- Win as a team
- Innovate and execute
- Deliver customer success
Integrity
Doing the right thing means speaking up whenever something doesn’t seem right. Not all of the details are needed to raise a concern – just a good faith belief that misconduct or violations of our Code may be occurring. All concerns are taken seriously and investigated promptly and thoroughly, as appropriate.
We have several ways you can let us know when you see, hear, or feel something is wrong. Please raise concerns under the reporting methods you feel comfortable with below. If you feel more comfortable raising concerns anonymously, you can do so to the extent permitted by applicable law.
Contacts:
- Contact your manager, Global Talent, or Legal, Ethics & Compliance
- Email legal_compliance@servicenow.com
- Submit a concern online at www.servicenow.ethicspoint.com
- Call the Speak Up Line at (855) 869-7272 or the number listed for your country at www.servicenow.ethicspoint.com
- Contact a member of our executive team (“P4 member”)
- Contact the ServiceNow Board of Directors by sending a letter to our Santa Clara, CA, headquarters labeled “Attention: Board Audit Committee Chair”
No tolerance for retaliation
- Need to know more?
- Whistleblower and Complaint Policy (the Speak Up Policy)
Those within the ServiceNow community are expected to act with integrity and in the best interest of ServiceNow. That means avoiding situations where our personal interests conflict, or appear to conflict, with ServiceNow’s interests. And if a potential issue arises, your first instinct should be transparency.
Examples of potential conflicts of interest:
- Using ServiceNow business opportunities, confidential information, assets, or services to benefit another entity, individual, or yourself.
- Participating in outside employment or consulting activity without prior approval.
- Serving on a Board of Directors for a non-profit or for-profit organization or company, without prior approval.
- Hiring or supervising a family member or household member.
- Engaging in a romantic relationship with a subordinate employee.
- Accepting gifts, entertainment, or favors from a customer, potential customer, sales partner, competitor, vendor, or supplier in violation of our Conflict of Interest Policy.
- Need to know more?
- Conflict of Interest Policy
- Related Party Transactions Policy
We’re honest and respectful in every trade we make, and that starts with making sure we follow all applicable financial laws. We don’t trade Company securities if we’re in possession of material non-public information about the Company. It’s not only against our Code – it’s illegal, too.
Similarly, it’s illegal to “tip” or share material non-public information with others so they can trade based on such information.
Our Code for avoiding insider trading:
- Information is “material” if there is a substantial likelihood that a reasonable investor would consider it important when making an investment decision.
- Information is “non-public” until the Company broadly communicates it, and it has been absorbed by the investing public. We don’t trade in Company securities while in possession of material non-public information, disclose material non-public information, or give trading advice about the Company.
Contacts:
Reach out to the Insider Trading Team with questions.
- Need to know more?
- Insider Trading Policy
We do the right thing for ServiceNow, our customers, our partners, and the communities in which we operate – without exception. We demonstrate our commitment to this by complying with all applicable laws and regulations.
Our Code for legal compliance:
- We comply with all applicable anti-corruption, anti-money laundering, sanctions, anti-boycott, import and export laws, and regulations that govern who we can do business with, how we can do business, where we can do business, and the transfer of sensitive technologies.
- We are truthful and transparent when interacting with government officials and representatives, and we comply with all applicable lobbying laws.
- We are committed to respecting human rights, and upholding all applicable human rights laws, rules, and regulations, including those pertaining to child labor, modern slavery, and human trafficking.
- We are committed to adhering to all applicable labor laws, rules, and regulations, including those pertaining to minimum wages and working hours.
- We are committed to engaging in responsible and sustainable business practices.
Ethics and integrity come first at ServiceNow. If it comes down to losing business or gaining it unethically, the choice is clear – we would rather lose business and maintain our integrity.
Anti-corruption laws and Company policy prohibit us (and third-parties acting on our behalf) from offering, authorizing, or providing anything of value in order to obtain an improper business advantage or influence a government official.
ServiceNow can be held accountable for the actions of third-parties acting on our behalf, including our channel partners, vendors, and consultants. That’s why we make it clear to our third-parties that ServiceNow requires full compliance with all applicable anti-corruption laws. We Speak Up if we have concerns about a third-party’s conduct or our own conduct.
Our Code for payments:
- We never offer or pay bribes or kickbacks to anyone. We don’t allow our partners to do it either.
- Gifts or hospitality we offer to a government official or customer must be modest, appropriate, directly tied to a legitimate business purpose, and in compliance with applicable laws.
- We never offer or provide cash, gift cards, or travel stipends to a government official or employee of a state-owned enterprise (such as a public hospital or university).
- We do not make charitable or political contributions in exchange for an improper business advantage or in connection with any official governmental decision.
- We do not make hiring decisions to improperly benefit a customer or government official.
- We hold ourselves to the same standards – we do not request or accept kickbacks or bribes.
U.S. Public Sector Guidance
There are specific laws and regulations that apply to interactions with U.S. government employees and U.S. government contractor employees. For more information specific to those interactions, please refer to the U.S. Public Sector Gifts & Gratuities Policy.
If the contemplated gift or payment relates to a U.S. government official, employee, or contractor, reach out to the U.S. Public Sector Compliance Team for guidance prior to engaging.
Contacts:
Unless you are certain that a proposed payment or fee is permissible under the Anti-Corruption Policy and applicable law, reach out to our Anti-Bribery and Anti-Corruption Team before proceeding.
As market leaders, we want to be known for always leading the right way – with products, services, and solutions that deliver value to our customers — not through unethical practices. When we compete, we do it fairly, in ways that build trust with our customers and each other. We compete in compliance with our policies and procedures. We comply with the antitrust and competition laws of all countries in which we do business.
Our Code for competing fairly:
- We do not enter into formal or informal agreements to limit competition, including agreements to fix prices, allocate customers or geographic territories, or reduce the quality of our products.
- We do not discuss prices, discounts, incentives, demographic divisions, customers, research, and development plans, strategic initiatives, or other non-public competitively sensitive information with our competitors.
- We do not discuss our bidding plans with our competitors, or otherwise compromise competitive bidding processes, or assist others in doing so.
- We do not set or discuss the price that our sales partners offer to customers.
- We do not use any illegal or unethical means to seek or acquire information about other companies, competitors, or customers.
Customer success as a leading digital transformation company can’t exist without trust and fair competition.
Kevin Haverty
Chief Revenue Officer
Applicability
Our Code applies to everyone in the ServiceNow community, from executive officers to contingent workers, and members of our Board of Directors. All are responsible for upholding the standards set forth in our Code, ServiceNow policies, and applicable laws.
Oversight
Our Board of Directors established the standards in our Code and, directly or through its committees, oversees its compliance. Our General Counsel is responsible for ensuring adherence to our Code and, while serving in this capacity, reports directly to the Board of Directors and its committees.
Violations
Violations of our Code, other ServiceNow policies, or applicable laws can result in disciplinary action, up to and including termination of employment.
Waivers and Amendments
Waivers of provisions of our Code may be made only by our General Counsel, or, with respect to directors, executive officers, and senior financial officers, by the Board of Directors or the appropriate Board Committee. In addition, any amendments to our Code must be approved by the Board of Directors. When required, any waiver or amendment will be reported as required by federal securities laws and applicable stock exchange rules.
Our Code for upholding our commitments:
- Review and understand our Code.
- If you don’t understand something about our Code, our policies, or certain laws, ask.
- Speak Up if you see or hear about potential violations of our Code, ServiceNow policies, or applicable laws.
- Be truthful and cooperate fully in internal investigations.
- Complete all required training to show you understand the principles set forth in our Code, ServiceNow policies, and applicable laws.
Teamwork
Everyone at ServiceNow is responsible for upholding the culture and values that are outlined in our Code. When each of us accepts that responsibility and commits to leading by example, our team is as strong as it can be.
With that in mind, you should pay attention to how decisions are made, wins are celebrated, losses are handled, consensus is reached, and debate is fostered. Our success largely depends on all of us embracing that accountability and leading by example in every action.
Our Code for leading by example:
- Listen to your team, take their concerns seriously, and escalate concerns when you feel you need additional support.
- Talk with teams about acting with integrity and doing the right thing. Make it known that at ServiceNow, we all must align to our policies and all applicable laws.
- Emphasize that while reaching our goals and executing on our priorities matter, how we achieve them is equally important.
- Listen. Good leadership allows for two-way dialogue. Ask questions and check in regularly, particularly about the challenges your team is facing.