Our Code of Ethics

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.

We embrace diversity, inclusion, and belonging as a business imperative. It’s a cultural value and a shared commitment across our global leadership team. Diverse, inclusive teams where everyone belongs are more creative, more innovative, and more successful. Research proves it. And we believe it.

We’re committed to racial justice and equity for all, and want to always be learning, growing, and understanding how to be allies. We extend that to our customers and partners and do our part to lead the charge for sustainable, positive change.

Our Code for embracing diversity and creating belonging:

• We’re committed to providing equal employment opportunities and pay equity to all qualified candidates.
• We strictly prohibit discrimination, harassment, or retaliation against any individual on the basis of any legally protected characteristic recognized by applicable national, state, or local law including race, color, religion, sex, sexual orientation, gender identity, national origin, age, disability, or veteran status.

Our business relies on the trust of our investors and the public, so we must maintain complete and accurate books and records at all times. We must ensure our financial reports, public filings, and public statements meet legal requirements and accounting standards. And that our business records fairly and accurately reflect our activities.

Our Code for maintaining accurate books and records:

• We accurately record and report financial transactions in compliance with all applicable laws, regulations, accounting practices, and ServiceNow policies.
• Our written contracts fully and accurately reflect all deal terms.
• We don’t enter into side agreements or off-the-books transactions.
• We retain and dispose of all documents and materials in compliance with our legal obligations and our Record Retention Policy.

We’re trusted with the responsibility of giving modest gifts, meals, and entertainment in accordance with all applicable laws, our policies, and the recipient’s own internal policies.

Our Code for giving and receiving gifts:

• When we give or receive a gift or hospitality, it must be reasonable, appropriate, and tied to a legitimate business purpose.
• Gifts or hospitality to government personnel must also comply with applicable anti-corruption laws, and the recipient’s rules and policies.
• We can’t use personal funds to do something that can’t be done with ServiceNow funds.
• We can’t use a third-party, including our channel partners and consultants, to do something that can’t be done with ServiceNow funds.
• We can accept modest gifts and hospitality from third-parties, but never ask for them.

Refer to the U.S. Public Sector Gifts & Gratuities Policy for specific restrictions applicable to interactions with U.S. government employees and U.S. government contractor employees.

Keeping our customers’, employees’, partners’, and service providers’ information safe and secure is a priority for ServiceNow. We are committed to privacy in our own products, our data practices, and in the third-party products we use. We maintain a comprehensive data privacy program and follow all applicable privacy and data protection laws and regulations. We process personal data in compliance with our privacy and security documentation. We all must follow the obligations outlined in these documents without exception.

Our Code for protecting customer and employee data:

• Handle all personal data in accordance with our privacy and security policies, procedures, and standards.
• Treat all personal data we have access to as confidential information.
• Access only the personal data necessary to fulfill the business purpose.
• Ensure that appropriate data protection terms are in place with any third-party before disclosing personal data of our stakeholders.

Innovation isn’t just a buzzword at ServiceNow. It’s one of the core values that drives everything we do, and it’s essential to our commitment to continued growth and customer focus. So, it’s crucial that we protect and respect our innovation every day.

It’s equally crucial that when we’re handling the ideas, information, or intellectual property of others, that we protect and respect it as well. This is critical for maintaining trust with our customers, our partners, and the communities in which we operate.

Our Code for protecting our innovation:

• We use best practices to safeguard confidential ServiceNow information or intellectual property – and we do not disclose it to others – even after leaving ServiceNow.
• We also protect ServiceNow’s innovation in our copyrights, trademarks, and patents – and ensure they are being used appropriately.
• We don’t use confidential information or intellectual property of other companies without proper authorization.
• We don’t use copyrighted materials – including graphics, videos, and music – without a license.