QUESTIONS
AND CONCERNS
               JULY 2020 • 5
        What Is The Code of
         Ethical Conduct?
THE CODE IS A S TATEME NT O F CO NCIS E PRINCIPL ES OF P ROP ER
  B USINESS CO NDUCT TO FO L LOW AND TURN IN T O AC T I ON.
                                                                  JULY 2020 •6
Asking Questions and Raising Concerns
Why Does EPAM Have A Code                Who Must Follow It?                     How Should I Use It?
of Ethical Conduct?                                                              READ IT - Understand EPAM’s
                                         EACH OF US - All employees, officers,
                                         and board members                       Code of Ethical Conduct
EDUCATION - Educates us about ethical,
lawful and professional conduct          OUR BUSINESS PARTNERS -                 USE IT - To guide your decisions
                                         Anyone we do business with
GUIDANCE - Guides us to live our                                                 RAIS E IT - Raise good faith questions and
                                         (contractors, suppliers, customers)
core values                                                                      concerns when needed
EXCELLENCE - Maintains EPAM’s                                                    COMPLY WITH IT - Take annual
reputation for excellence                                                        mandatory certification training on
                                                                                 Onboarding Portal
                                                                                                                       JULY 2020 • 7
Asking Questions and Raising Concerns
Where Do I Ask Questions Or Report Concerns?
EPAM encourages you to ask questions and report concerns about proper
conduct, so we can maintain our reputation and improve where needed.
TO ASK Q UE STIONS OR REPOR T CON C ERN S U N D E R O UR CO DE , E PA M O F F E RS M A N Y C H A N N E LS :
I N PERSON                                               E PA M’S E T H IC S LIN E
• Your manager                                           EPAM provides a confidential hotline to
•E
  PAM’s Compliance Sponsors and                         report concerns, which allows you to report
 Compliance Managers                                     anonymously if you prefer where law permits.
 (see https://info.epam.com/ethics.html)
                                                         Our EthicsLine allows you to report online
• HR                                                     through a dedicated web portal or by calling
• Legal                                                  the dedicated phone number for your region:
•E
  PAM Leadership
                                                         • Locate local phone numbers in
 (see http://investors.epam.com/investors/
                                                           "What Else" section on the page 44 or
 leadership-and-governance)
                                                           at ethics.epam.com
• E PAM’S Chief Compliance Officer
                                                         • EthicsLine Webpage — Submit a written
                                                           concern online at ethics.epam.com
                                                                                                              JULY 2020 • 8
Asking Questions and Raising Concerns
What will the company do in response?
WHEN YOU REPORT A CONCERN, EPAM WILL:                                                         P ROVI D I N G D ETA I L S A BOU T
• Promptly and carefully review your concern      • N ever tolerate retaliation because      REP ORT ED CON C ERN S
• Conduct a proper investigation                     someone raises good faith questions
•T
  reat your report and its investigations as
                                                     or concerns or participates in           Whether you identify
                                                     an investigation
 confidentially as it can, consistent with                                                    yourself or raise concerns
 relevant laws and EPAM’s need to conduct a       • Take appropriate corrective and/or
                                                     disciplinary action
                                                                                              anonymously, it helps
 fair, complete and compliant review
                                                                                              EPAM if you can provide
                                                                                              sufficient details, such as
                                                                                              relevant background, names,
Managers have expanded responsibility                                                         dates, places, people with
                                                                                              knowledge, and why the
IF YOU MANAGE EMPLOYEES, EPAM EXPECTS YOU WILL:
                                                                                              situation is cause for concern.
•S
  et the right tone and model best behavior      • R ecognize and reward ethical behavior
 for those you manage                             • S upport our investigation process
• W elcome questions and concerns, take them     • H elp EPAM implement necessary
  seriously, and escalate them when needed           remedial actions
                                                                                                                       JULY 2020 • 9