CODE OF

CONDUCT
AND ETHICS
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Infosys
CODE OF CONDUCT
Our Code of Conduct sets forth our core values, shared responsibilities, global
commitments, and promises. It provides general guidance about the Company’s
expectations, highlights situations that may require particular attention, and references
additional resources and channels of communication available to us. It is also the first
step for you to get clarity on any questions relating to ethical conduct.

Our Code, however, cannot possibly address every situation we face at work. Therefore,
the Code is by no means a substitute for our good judgment, upon which Infosys
depends. We must remember that each of us is responsible for our own actions and that
the ethical choice is always the best choice.

Please review the entire Code and refer to it whenever you have a question on ethical
conduct. If requested to, you shall confirm in writing that you have reviewed the Code,
and understand and agree to adhere to our core values, shared responsibilities, global
commitments, and promises.

This Code of Conduct is also available on our Company website at:

 Code of Conduct and Ethics

 Digitized Code of Conduct and Ethics

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THE CEO & MD Infosys stands for many things – a commitment We lead by example, always, and pursue
to delivering great client value, a space for excellence in all our fields. This is built into our
employees to be themselves, a sharp focus on vision, and this helps us make a difference – to
making a difference both within the industry ourselves and to everyone with whom we
and within the larger society – but most of all, interact.
we are known for our values. These values,
embodied in C-LIFE (Client Value, Leadership by All of this is captured in our Code of Conduct.
example, Integrity and Transparency, Fairness With a simple, easy-to-imbibe format, the Code
and Excellence) form the bedrock of our daily forms the guidelines by which we lead our lives
lives at the workplace. They are the foundation at work. It helps you take the right decisions,
on which we built our success over the years especially during challenging or ambiguous
and have held us in good stead from our times. More than anything, it’s important that
inception. we raise our concerns whenever we spot a
violation of the Code, as the responsibility of
It isn’t a simple task to lead a life, especially in an upholding the Code lies with us. If you notice
ever-changing and demanding environment something amiss, please do reach out to the
like ours, driven by values. But I have already Office of Integrity and Compliance, or use the
seen that Infoscions strive to uphold our values helpline/incident tracker, and we assure you
in all that they do. This is remarkable, and that we will look into it, all the while protecting
proves that the only way to follow values is to you against any form of retaliation.
truly live them. They are a part of our DNA, and
rightly so. Therefore, each one of us is Let us work together to live the Code, and find
responsible for the values, and for maintaining greater success within the strong framework
and enhancing the culture that they have built. that we have built over the years.
We act with integrity and transparency in all our
transactions and work with fairness to solve the
challenges faced by our stakeholders.

Regards,

SALIL S. PAREKH
Chief Executive Officer & Managing Director

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VALUES: C-LIFE
Our values are the principles we use to run the Company on a daily basis. They are so important that they are the source of our entire Code—a sort of ethical backbone. They are
clear and simple. Our values are the foundation of everything we do and they are encapsulated in the acronym C-LIFE.

CLIENT VALUE LEADERSHIP BY INTEGRITY & FAIRNESS EXCELLENCE

EXAMPLE TRANSPARENCY
To surpass client To set standards in our To be ethical, sincere and To be objective and To strive relentlessly,
expectations business and transactions open in all our transactions. transaction-oriented, constantly improve
consistently. and be an exemplar for and thereby earn ourselves, our teams, our
the industry and trust & respect. services and products to
ourselves. become the best

Our values are also influenced by the principle of trusteeship. As Infoscions, we are all trustees of the company’s legacy—its resources, assets and opportunities. As trustees, we
have an obligation to pass on a better, stronger Infosys than the one we received. By necessity this includes meeting or exceeding our commitments to stakeholders, developing
the full potential of our employees, and building Infosys’ reputation to make it the most respected company in the world.

But trusteeship at Infosys goes further than that; trusteeship also includes our corporate commitment to utilizing natural resources in a sustainable way and to improving the
communities in which we live and work. An early adopter of a robust CSR agenda, along with sustained economic performance, we believe in the importance of social stewardship.
We embrace responsibility for our company to create a positive impact in the communities in which we work and live. Our key programs are driven by the strong CSR platforms
we’ve built over the years. Trusteeship to the Infoscion means that we strive to create positive environmental, social and economic values in every aspect of our business.

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VALUES IN ACTION
What does it mean to act with integrity
and transparency?

Acting with integrity and transparency means that we should be ethical, sincere
and open in all our transactions. Personal accountability goes a long way in
showing our clients and our employees that they can rely on us. That is why, as
employees and leaders of Infosys, we keep our commitments and walk the talk.
We speak up when we are uncomfortable or uncertain, especially when it comes
to actions, conditions and behaviors that contradict our values and culture.

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VALUES IN ACTION
What does it mean to create client value?

Client value is a commitment to bring in ideas and recommendations that are in the
client’s best interests, thus discharging our professional responsibilities in a manner
that leads to long-term partnerships.

This means we should:

 Always consider our customers’ perspective. The art of creating value starts with
the ability to see our business through our client’s eyes.
 Consistently work to improve customer satisfaction. Soliciting honest feedback
through surveys on a regular basis allows us to keep our finger on the pulse of our
customers’ needs.
 Develop a memorable customer experience. Go the extra mile. Businesses with
unforgettable customer experiences are more likely to benefit from word-of-mouth
referrals and higher retention rates.

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VALUES IN ACTION
What does it mean to lead by example?

At Infosys, we strive to set standards in all our business dealings and to be an

exemplar for the industry and our fellow Infoscions. Each one of us can lead by
example in acting with integrity and transparency.

This means we should:

 Act with fairness and honesty in all our dealings—be objective and
transaction-oriented.
 Make sure that those whom we supervise and those to whom we report
understand and follow the Code, Company policies and applicable laws.
 Know what resources are available to help.
 Support employees who, in good faith, ask questions, raise concerns, or
cooperate with investigations.
 Raise any integrity concerns immediately. Problems caused by violations of the
Code, Company policies or applicable laws seldom get better with the passage
of time—they frequently get worse.

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VALUES IN ACTION
What does it mean to be fair?

Fairness in the workplace is about respecting the rights of all those who work
with us.

This means we should:

 Treat employees fairly, keeping differing skills, abilities and circumstances
in mind.
 As a manager, make our expectations and evaluation criteria known.
 At every stage, give employees an equal chance to be heard—whether it is
allowing them to share great ideas or to air grievances.
 Discourage politicking. Establish a reputation for discouraging this practice
and encouraging team members to communicate openly with each other
to solve issues.
 Give credit generously. Employees should be recognized for their ideas and
contributions.

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VALUES IN ACTION
What does it mean to be excellent?

‘Excellence’ can be defined as the quality of excelling, possessing good qualities

in high degree. It is about developing a winning mindset that says, “l want to be
great at what I do. I want my work and my personal life to be successful.”

This means we should:

MATCH LEARN FROM SPEAK WITH MAKE THE MOST TAKE BE WILLING TO BE BALANCED
BEHAVIOR WITH MISTAKES PURPOSE OF EVERY RESPONSIBILITY DO THINGS
VALUES MOMENT FOR ACTIONS DIFFERENTLY Balance is about
View failures as Think before we considering everything
Demonstrate our feedback that speak. Make sure Focus our attention Be responsible for Recognize what’s that’s meaningful and
positive personal provides us with your intention is on the present our thoughts, not working and be important to us when
values in all we do the information we positive and your moment. Keep a feelings, words and willing to change we make choices about
and say. Be sincere need to learn, grow words are sincere. positive attitude. actions. ‘Own’ the what you are doing how we spend our time
and real. and succeed. choices you make to achieve your and energy. When we
and the results that goal. find the right balance,
follow. we are happy, healthy,
satisfied and productive.

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THE The Code of Conduct expresses Infosys’

commitment to conducting business

CODE
ethically. It explains what it means to act
with integrity and transparency in
everything we do and in accordance with
our unique culture and values.
IS MORE THAN As members of the Infosys family, let us follow not only the letter of
the Code, but its intent and spirit as well. This means we should:

JUST WORDS ON  Understand the areas covered by the Code, Company policies and
procedures, and laws that apply to our job.
 Follow the legal requirements of all locations where we do

A PAGE—IT’S A
business.
 Conduct ourselves in ways that are consistent with the Code,
Company policies and procedures, and laws.

WAY OF LIFE
 Speak up if we have concerns or suspect violations of the Code,
Company policies and procedures, or laws.
 When requested, certify that we have reviewed, understand and
agree to follow the Code.
 Understand that following the Code is a mandatory part of our job.

FOR THE The Code cannot address every situation that may occur. We are
expected to exercise good judgment and ask questions when we

INFOSCION
need guidance or clarification. Many resources are available to assist
us. These include our managers, the Office of Integrity and
Compliance, Human Resources, Legal Department, the Helpline, and
other resources listed at the end of the Code. In addition to the Code,
we should also be aware of all Company policies and procedures
applicable to our work. You may refer to the Policy Portal which is a
repository of all our policies.

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WHAT ARE MY

RESPONSIBILITIES?
I Follow the Code I am the Example for my Team
Our Code applies equally to all Infosys directors, officers and employees globally, across Most often, a manager is the first person to be contacted about a concern in our
our subsidiaries. The Code also applies to our partners, suppliers, agents or others acting work environment. Managers have some specific responsibilities:
on the Company’s behalf. As employees, it is important that we know and follow the  Be a role model of ethical behavior.
Code as a guideline for decision-making that is paired with integrity.  Encourage your team to raise issues and speak up.
 Communicate a positive message about your commitment to ethics and
I Lead by Example compliance.
 Promote our values, the Code of Conduct and compliance with policies and the
law.
No matter what our role is, each one of us is expected to lead when it is a question of  Actively support ethics and compliance awareness and training programs.
ethics and be accountable for our actions. We act with responsibility and integrity in  Have open avenues for communication.
tune with our C-LIFE values.  Listen and respond fairly to employee concerns.
 Find satisfactory and complete resolutions to ethical issues.
 Escalate concerns when additional assistance is needed.

Infosys’ non-retaliation policy is an embodiment of our values and a cornerstone of our Code. If you observe violations of Infosys values and principles, you are encouraged
to report such incidents to the Helpline. Infosys will protect you and ensure that you are not retaliated against because of any report that you raise in good faith. Infosys
does not tolerate any form of retaliation (whether by a manager, co-worker or otherwise) against an individual because he or she made a good faith report of an integrity
concern. This protection also extends to anyone who assists with or cooperates in an investigation or report of an integrity concern or question. We support those who
support our values.

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SPEAK
UP
If you believe that you have been discriminated
against, harassed or have not been given equal
opportunities at work, you are encouraged to
submit a complaint to:
 Your manager
 Your skip-level manager
 Human Resources
 HEAR@infosys.com
 GRB@infosys.com, if you believe you
have been sexually harassed
 Helpline

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TABLE OF CONTENTS
A. RESPECTING EACH OTHER 17 D. COMMITTED TO OUR CUSTOMERS
AND OUR SUPPLIERS 38
An Equal Opportunity Workplace Free of
Discrimination or Harassment 17 Fair Dealings 38
A Safe Place to Work 18 Confidential Information of Clients
and Third Parties 39
B. ETHICS IN OUR BUSINESS ACTIVITIES 19 Free and Fair Competition 40
Industrial Espionage 42
Preventing Corruption 19
Governmental Relations 42
Gifts and Entertainment 22
Selecting Suppliers 42
Charitable Contributions 22
Transacting with Third Parties 23 E. RECORDS, DISCLOSURES AND AUDITS 43
Trading in Company Shares 24
Understanding Regulated Trade Restrictions 26 F. ADMINISTERING OUR CODE 47
Export Control and Import Regulations 26
Investigations 47
Anti-Boycott Laws 27
Amendments/Modifications to Our Code 47
Conflict of Interest 28
Acknowledgement 47
Political Activities 31
Waivers 47
Lobbying 31
Disciplinary Actions 48
Money Laundering and Terrorism Financing 32
Immigration 32
Form of Acknowledgment of Receipt of Code of
Conduct and Ethics 50
C. PROTECTING COMPANY ASSETS 33 INDEX 51
Company Confidential Information 34
Improper Opportunities 35
Company Intellectual Property 35
Providing Information to the Media 36
Physical Access Control 36
Use of Company Assets 37

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A RESPECTING EACH OTHER

An Equal Opportunity Workplace

Free of Discrimination or Harassment
At Infosys, we strive to provide a work environment free of discrimination and harassment. We are an equal opportunity employer and employment decisions are based on merit
and business needs. Our Human Rights Statement further illustrates our stand on this. Employees in the U.S. may also refer to our U.S. equal opportunity statement.

We are committed to following fair employment practices that provide equal opportunities to all employees. We do not discriminate or allow harassment on the basis of race,
color, religion, disability, gender, national origin, sexual orientation, gender identity, gender expression, age, genetic information, military status, or any other legally protected
status. At Infosys, we value diversity and believe that a diverse workplace builds a competitive advantage.

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An Equal Opportunity Workplace

Free of Discrimination or Harassment
To put these values in practice, all of us must ensure that decisions affecting employees are based on business factors only. For instance, decisions regarding hiring, promotion,
termination, transfer, leave of absence or compensation should only be based on relevant business factors.

We must also ensure that we never verbally or physically mistreat others or engage in offensive behavior, and we should not tolerate those who do. This includes harassing,
bullying, abusive or intimidating treatment, inappropriate language or gestures, disorderly conduct, violence and any other conduct that interferes with a co-worker’s ability to do
his or her job.

The Company’s Anti-Discrimination and Anti-Harassment Policy applies to all persons involved in the operations of the Company and prohibits harassment by any employee of
the Company towards other employees as well as outside vendors and customers. If you have any questions relating to what constitutes discrimination or harassment, or any
other questions or concerns pertaining to discrimination or harassment, please refer to the Policy on Prevention and Redressal of Harassment at Infosys or any of the location-
specific procedures found on your local policy page on the Company intranet. If you wish to report a concern, you may reach out to us using any of the relevant channels noted in
the “Speak Up” section on the previous page, or simply call the Helpline listed throughout this Code of Conduct.

A Safe Place to Work

To work effectively, all of us need a healthy and safe work environment. All forms of substance abuse as well as the use or distribution of drugs and alcohol while at work is
prohibited. Unless required as part of your role (for instance for security personnel where deemed necessary), possession and/or use of weapons/firearms or ammunition while on
business of the Company is prohibited. All of us should be safe at our place of work. Should you observe any unsafe situations at work, please reach out to the Helpline. Please also
take the time to familiarize yourselves with emergency procedures and the safety manuals applicable to your location.

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B ETHICS IN OUR BUSINESS ACTIVITIES

Infosys enjoys a hard-won reputation for honesty, integrity and fair dealing. Without question, this reputation for integrity is an invaluable part of our success. There are certain
regulations that Infosys is subject to and we should ensure that we comply both in letter and in spirit with these as is applicable.

Preventing Corruption
The United States Senate in 1977 stated “Corporate bribery is bad business. In our free market system it is basic that the sale of products should take place on the basis of price,
quality, and service. Corporate bribery is fundamentally destructive of this basic tenet.”

Corruption diverts public resources from priorities such as health, education, and infrastructure and impedes economic growth. Corruption undermines public accountability and
the rule of law. Corruption is anti-competitive, increases costs of doing business globally and introduces significant uncertainty into business. Bribery thus raises the risks of doing
business, putting a company’s bottom line and reputation in jeopardy. Companies that pay bribes to win business ultimately undermine their own long-term interests and the
best interests of their investors.

As a global company, apart from the Prevention of Corruption Act, 1988 (India), Infosys is subject to all relevant anti-corruption laws, including the U.S. Foreign Corrupt Practices
Act (FCPA) (as if it were a U.S. incorporated company) and the Bribery Act 2010 (U.K.). These prohibit bribery of government officials and commercial partners.

Government Officials
Particular care must be taken when interacting with government officials. Government Official includes officer or employee of any agency, department or instrument of any
government or anyone acting on their behalf. This includes (but is not limited to) officer or employees of a political party, employees or members of military services, civil
services or judicial systems, candidates for political or public office, members of a ruling or royal families and employees of businesses controlled by the government, public
international organizations etc. Family members of Government Officials are also considered as Government officials.

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Prevention Corruption
We should never offer, directly or indirectly, any form of gift, entertainment or anything of value to any government official or commercial partners including customers or their
representatives to:
 Obtain or retain business;
 Influence business decisions; or
 Secure an unfair advantage
This includes bribes, kickbacks and facilitation payments.

What is a bribe? What is a kickback? What is a facilitation payment?

A bribe is anything of value that may be seen as an A kickback is a form of corruption that involves two Certain countries may have a practice of ‘facilitation
attempt to influence an action or a decision in order parties agreeing that a portion of their sales or profits payments’, which are payments to government
to obtain or retain business or acquire an improper will be kicked back (given back) to the purchasing officials to expedite or ensure routine actions, such as
advantage. This could include money, gifts, favors, party in exchange for making the deal. issuing visas, work permits, licenses etc.
use of company resources, entertainment or other
items of value.

Infoscions don’t do any of these, nor do we allow third parties acting on our behalf, such as vendors, agents, customers, consultants, alliance partners, suppliers and contractors to
make any such payments.

Also remember that while managing these relationships, we must be on the watch for any actions relating to bribery, kickbacks, improper payments or other corrupting
influences. We can and will be held responsible for the conduct of our third parties if they violate the law while working on our behalf.

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QUESTION
One of the Company’s vendors always sends me a large gift
basket of fruit and chocolate during the holiday season. Can I
accept this?

Anything of value?
RESPONSE
What does that mean? If the holiday gift baskets is of low value and you receive them
infrequently, it is unlikely that you would feel obligated or
Cash payments, gifts, entertainment, excessive business influenced by them. If that is the case, you can continue to
promotional activities, covering or reimbursing expenses, accept them. However, you are encouraged to share the gift
investment opportunities, shares, securities, loans or baskets with other employees in your department. For more
contractual rights, promise of future employment, information on permissible value, please refer to Anti-Bribery
payments under consulting agreements, subcontracts, and Anti-Corruption Policy of the Company.
stock options, and similar items of value.

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Gifts and Entertainment Charitable Contributions

In connection with certain holidays and other occasions, it is customary in many Infosys believes that charitable contributions and donations are an integral part of
parts of the world to give gifts of nominal value to customers, government officials its corporate social responsibility. Typical areas for granting support are education
and other parties who have a business relationship with the Company. However, we and research, social welfare, disaster relief and other similar social causes.
should be careful that while doing so, we do not violate any regulations, Company
policy or do anything that is contrary to our C-LIFE values. Before making a charitable contribution on behalf of Infosys, we should keep in
mind the following:
When we offer a gift to a customer, a government official or any third party, we  The recipient is a registered, tax-paying, recognized organization.
should keep the following in mind:  The contributions are permissible under applicable local laws.
 Contributions are made without demand or expectation of business return.
 It is not done to obtain or retain business, influence busine  Beneficiaries of such contributions should not be related to the directors or
 ss decision or gain an improper advantage in business. executive officers of Infosys.
 It is lawful under the laws of the country where the gift is being given and  Contributions shall not be made in cash or to the private account of an
permitted under the policies of the client.
individual.
 It constitutes a bona fide promotion or goodwill expenditure.
 Any amounts contributed or donations made towards charitable causes shall be
 It is not in the form of cash.
fairly and accurately reflected in Infosys’ books of accounts.
 The gift is of nominal value (on an individual and aggregate basis).
 Contribution shall be in compliance with Anti-Bribery and Anti-Corruption
 The gift is accurately recorded in the Company’s books and records.
Policy.
 You must comply with our Anti-Bribery and Anti-Corruption Policy.

Accepting Gifts: Acceptance of gifts is not encouraged. Please refer to the We have a strict diligence process for charitable contributions. Reach out to the
Anti-Bribery and Anti-Corruption Policy. Office of Integrity & Compliance by writing to OIC@infosys.com to understand the
diligence we need to follow.
Reach out to OIC@infosys.com in case of any query.

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Transacting with Third Parties

We try, to the extent reasonably practicable, to directly interact with government officials. However, if third party is
required to interface with government authorities on behalf of Infosys, we should verify the credentials and reputation
of such a third party prior to any engagement with them and ensure that a formal contract is executed, including
appropriate provisions requiring the third party to comply with applicable anti-corruption and local laws.
Engagement of third party shall be in line with legal requirements, internal processes & guidelines. A copy of the
Supplier Code of Conduct must be provided to such third party.

Keep in mind that the Company and individual directors, officers or employees may be liable for a payment made by a
third party agent, if the Company makes a payment or transfers other value to that third party agent knowing that it
will be given to a government official.

We ensure that the fee, commission or other remuneration paid to intermediaries or third party agents is reasonable,
bona fide and commensurate with the functions and services performed. We should keep track of such expenses so
that they are fairly and accurately reflected in Infosys’ books of accounts.

Red Flags While Transacting with Third Parties

 Background check reveals a flawed background or reputation. QUESTION

 Transaction involves a country known for corrupt payments. Refer to Transparency International’s list for this I have some shares of Infosys as part of my
(www.transparency.org). portfolio. I need to sell them as I am in need of
 Agent suggested by a government official. money. How do I proceed?
 Agent objects to anti-corruption compliance requirements.
 Agent has a personal or business relationship with a government official.
 Unusual contract terms or payment arrangements such as payment in cash, payment in another country’s
currency or payment to a financial institution outside the country where the contract is performed. RESPONSE
 Requests that identity of the agent be kept confidential.
 Commission exceeds the ‘going rate’ or must be paid in cash. Read the Company’s Insider Trading Policy. You
 Indication that ‘facilitation payments are required’ to ‘get the business moving’. should follow the pre-clearance procedures for
 Request false invoices or any other type of false documentation. trading and trade only when the trading window
 Payment in a third country or in another party’s name. is open.

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Trading in Company Shares

Infosys is a publicly listed company. This means that the securities (which includes
Shares and American Depository Receipts) of Infosys may be traded by the public.
The price of our securities may fluctuate on the basis of publicly available
information about the Company’s activities.

Unpublished Price Sensitive Information (“UPSI, also known as material non-

public information”) is information about a company that (i) is not in the public
domain, and (ii) that an investor would find useful to decide whether to trade in
the Company’s securities. This could include information about financial results,
dividends, change in capital structure, mergers, de-mergers, acquisition, delisting,
disposal and expansion of business or changes in key managerial personnel. The
list of UPSI is not exhaustive. If someone is aware of any UPSI of the Company and
uses such information to buy or sell the Company’s securities before such
information is made public, they may be subject to penalties under insider
trading laws.

How is this relevant to me?

In the course of our everyday work, as an employee, a consultant or a vendor, we
may have access to UPSI. Under applicable securities laws, it is unlawful for a
person who has such information to trade in the securities of the Company or to
disclose such information to others who may trade. This activity is commonly
referred to as ‘insider trading’. Insider trading may lead to imprisonment, fines
and insider traders may even be subject to private lawsuits.

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Trading in Company Shares

So, what does this mean?
 Take care that we do not disclose UPSI to anyone outside the Company, including family and friends.
 Ensure that we do not trade in the securities of Infosys or any company involved with Infosys while you have
UPSI. Additionally, the Company imposes a trading blackout period each quarter, during such period designated
persons as per Infosys Internal Code of Conduct of Prohibition of Insider Trading are not to trade in Company
securities.

For more details, read the Company’s Insider Trading Policy. All questions regarding the Company’s Insider Trading
Policy should be directed to InsiderTrading@infosys.com.

Prohibition Against Short Selling of Company Securities

No Company director, officer, employee or third party agent may, directly or indirectly, sell any equity security,
including derivatives, of the Company if he or she (1) does not own the security sold, or (2) if he or she owns the
security, does not deliver it against such sale (a “short sale”) within the applicable settlement cycle.

QUESTION RESPONSE
My spouse is starting a company. To fulfil From the facts, it does not appear that your
regulatory requirements, I need to be appointed spouse’s start-up is in the same business as
as a director on the company. I will also be a Infosys. Remember that you may not use
majority shareholder in the company which is in Infosys time, property, or other resources to
the business of online food delivery. Is there a help your spouse. Good luck!
problem if I do this?

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Understanding Regulated Trade Restrictions

Export Control and Import Regulations
Many countries maintain controls on where items or data may be exported to – these are called ‘export controls’.
Under these laws, an ‘export’ occurs when a product, service, software, technical knowledge is transferred to
another country or to any foreign citizen or representative of another country, regardless of where that person is
located. Exports can also occur when a foreign citizen is given access to controlled information or software
through a network, visual inspection, or telephone conversation. Infoscions may be exposed to export controlled
items or data while developing software, working with clients, or reselling third party products.

Some of the strictest export controls are maintained by the United States. For example, U.S. export regulations
apply both to exports from the U.S. and to exports from other countries, when those products contain U.S.- origin
components or technology. Other countries, including in Europe, also have strict export control regulations.

What do you need to do?

 Early on in any customer engagement, you should carefully consider the obligations of the Company and the
Export Control
customer with respect to export controls.
 While you should familiarize yourself with Infosys’ export control policies, understand that the export rules are
Regulations
complex, and enlist the assistance of the Office of Integrity & Compliance at an early stage by writing to Even if duplicated and packaged abroad,
OIC@infosys.com. software created in the United States may
be subject to these regulations. In some
Infosys is engaged in import of software and other intangible assets. Several laws and legal requirements are circumstances, an oral presentation
applicable on imports. You should ensure to comply with all import laws, regulations and requirements when containing technical data made to foreign
transferring goods and controlled software across borders. nationals in the United States may
constitute a controlled export.

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Understanding Regulated
Trade Restrictions
Anti-Boycott Laws
In the course of our work, we may receive requests for Infosys to boycott certain
countries, companies or other entities. Boycott activity can take the form of
refusals to do business with certain groups or requests for information about
boycotted entities. We should not cooperate with any boycott that is not initiated
by the U.S. or Indian governments. This may be considered as an illegal foreign
boycott. Be alert to these situations, as these requests may be contained as part of
larger documents such as master service agreements, invoices or statements of
work. Please contact the Office of Integrity and Compliance at OIC@infosys.com if
you have questions.

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QUESTION
I work in a country where the laws are different from those in the
country where I am based. Does the Code cover both locations?

RESPONSE
Conflict of Interest Infosys respects the letter and the spirit of the laws and customs
of every place where we do business. The Code is intended to be
What does conflict of interest mean? broad enough to cover everyone worldwide, but laws vary from
place to place. What may be lawful in one place may be unlawful
in another. Employees must always perform their jobs in
When the interests or benefits of one person conflict with the interests or benefits of the
compliance with applicable laws, policies and procedures. If you
Company, a conflict of interest is said to occur. We must avoid situations involving actual or
are concerned about a possible conflict involving our Code,
potential conflict of interest so that even the slightest doubt about our integrity is not raised.
Company policies and procedures, and any local laws or customs
contact any of the resources listed at the end of the Code.
Conflicts of interest also occur when we or our family members receive improper personal
benefits, or preferential treatment as a result of our position, or the position of a family
member, in the Company. Remember that such situations might impact our judgment or
responsibilities towards our Company and our shareholders and customers.

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Conflict of Interest
When could I be faced with a ‘conflict of interest’ issue?
Some examples include:

OUTSIDE EMPLOYMENT WORKING WITH FAMILY AND FRIENDS OUTSIDE DIRECTORSHIPS

If you take part in any activity that enhances or To avoid conflicts of interest and any appearance of It is a conflict of interest for employees or directors to serve as a
supports a competitor’s position or accept favoritism, ensure that you do not work directly for, director, partner, sole proprietor or any other equivalent
simultaneous employment with any other supervise or make employment decisions about a Family position of any company, firm or business entity, as the case
company or business entity, it is considered outside Member or Relative. This includes positions or assignments may be that competes with the Company or have a line of
employment and a conflict of interest. This includes within the same department and the employment of such business similar to that of Infosys. With prior approval of the
performing services as an employee, agent or individuals in positions that have a financial or other Office of Integrity and Compliance, employees may serve on the
contractor for a customer, supplier or any other dependence or influence (e.g., an auditing or control boards or governing body of two other business entities,
entity that has a business relationship with the relationship, or a supervisor/subordinate relationship). provided such entities do not compete with Infosys. In case any
Company while working at Infosys. clarification is required, please reach out to the Office of
Please reach out to your manager and unit HR manager if Integrity and Compliance.
RELATED PARTY TRANSACTIONS you have any questions about this. The Human Resources
Department is responsible for determining whether an OUTSIDE INVESTMENTS
You should also avoid conducting Company acknowledged relationship is covered by the policy.
business with a Family Member or Relative, or with You should not have a financial interest, including through a
a business in which a Family Member or Relative is relative, in any organization if that interest would give or appear
associated in any significant role. Family Member or RELATIONSHIPS AT WORK
to give you a conflict of interest with the Company. You should
Relative include spouse, siblings, children, parents, Personal or romantic involvement with a competitor, be particularly sensitive to financial interests in competitors,
grandparents, grandchildren, aunts, uncles, nieces, supplier, or another employee of the Company might affect suppliers, customers, distributors and strategic partners.
nephews, cousins, step relationships, and in-laws. your ability to exercise good judgment on behalf of the Questions in this regard should be directed to OIC@infosys.com.
Company. This could lead to conflict of interest. Personal
Material transactions, particularly those involving relationships and romantic liaisons between employees
the Company’s directors or executive officers, must who are in a manager-employee reporting structure may LOANS
be reviewed and approved in writing in advance by lead to team management challenges and reduced morale. Loans and guarantees to employees by the Company could
the Company’s Audit Committee. As a listed entity, Such relationships must be disclosed to the manager constitute improper personal benefits depending on the facts
the Company is subject to certain legal obligations immediately, who may take appropriate corrective action. and circumstances. Loans by the Company to, or guarantees by
to report such material related party transactions to
the Company of obligations of, any director or executive officer
regulators and it is important that all such
or their family members are prohibited by law.
transactions be fully disclosed, conducted at arm’s
length and with no preferential treatment.

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Conflict of Interest
When faced with such issues, ask yourself:
 Would this create or appear to create an unfair incentive for me or my
friends and family?
 Am I putting Infosys at risk of violating laws or agreements with our
customers?
 Would this look bad if it was brought up in social media?
 Would this distract me from doing my job?

What should I do if I have any questions?

 All such situations must be disclosed by reaching out to OIC@infosys.com.
Remember, having a conflict of interest is a violation of this Code.
 Additionally, you must also update any changes to your disclosures to
OIC@infosys.com.

Since the situations for other conflicts of interest are wide and many, it would be
impractical to attempt to list all possible situations. If a proposed transaction or
situation raises any questions or doubts, you should raise it to OIC@infosys.com.

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Political Activities
Infosys reserves the right to communicate its position on important issues to the
elected representatives and other government officials. Infosys’ funds or assets
must not be used as contribution for political campaigns or political practices
under any circumstances without the prior written approval of the Board. For
obtaining such approvals, please reach out to OIC@infosys.com. We do not seek
reimbursement for political contributions or use Infosys resources for personal
political activities. We also do not indicate in any manner that we represent our
Company’s opinion about a candidate for office or any political cause or decision
of any government.

Lobbying
If our work includes meetings with government, elected officials, all of which might
be construed as ‘lobbying’, we must be aware that such activities are regulated. We
should not claim to represent our Company at such meetings unless we are
specifically designated by the Company to do so. As in all other spheres of our
activity, any meetings of this sort should be carried out with high integrity, in line
with our C-LIFE values.

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Money Laundering and

Terrorism Financing
Money Laundering occurs when someone directly or indirectly gets involved in any
process or activity connected with the proceeds of crime including its concealment,
possession, acquisition or use and projecting or claiming it as untainted property.
Terrorism financing occurs when money or other resources are made available to
commit criminal acts of terrorism or to support terrorist organizations. In case you
notice any such activity, please report it using the helpline details.

Immigration
At Infosys, employees are required to travel across the globe from time to time to
support defined business requirements. During such travel, you are expected to
ensure compliance with applicable requirements both under immigration laws
as well as company policies. In case any clarification is required, please reach out
to Global Immigration helpdesk at GI_Helpdesk2@infosys.com.

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C PROTECTING
COMPANY ASSETS

Company Confidential Information

For the Company, its confidential information is a valuable asset and every director,
employee and agent of the Company must protect it. Confidential information includes all
non-public information. It also includes personal information (regardless of its source) that
we obtain in the course of business. We must take care that all confidential information is
used for Company business purposes only and in case of personal information, in
addition, it must be processed on instructions from the Company in accordance with laid
out policies, procedures and guidelines and as per applicable privacy laws and
regulations.

Upon joining Infosys, all employees sign a Confidentiality and Nondisclosure Agreement
which details their confidentiality obligations to the Company. As employees, we have
access to significant amounts of company information that may not be available to the
public, and we should preserve the confidentiality of information obtained in the
Company’s service. Information of a confidential, private and sensitive nature must be
used responsibly and controlled and protected to prevent its prohibited, arbitrary or
careless disclosure.

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Company Confidential Information

Unless the Company has provided its specific consent, which should preferably be in writing, or there is a legal or professional right or duty to disclose, we are prohibited from
disclosing confidential Company information. Confidential or proprietary information about clients, our organization, or other parties, which has been gained through employment
or affiliation with Infosys, may not be used for personal advantage or for the benefit of third parties.

Our Information Security Policy sets out the expectations on each of us to safeguard confidential information of Infosys and our third parties with the assurance of security,
availability, integrity and confidentiality. The Acceptable Usage Policy provides the purposes for which Infosys IT resources may be legitimately used and our cybersecurity
responsibilities. These policies, together provide employees with the mandatory directive of safeguarding Infosys and client information.

Our Infosys Privacy Policy sets out the expectations on each of us to process personal information belonging to our employees, clients, agents, consultants, suppliers, and
contractors in a manner so as to ensure compliance with all applicable privacy laws and regulations, including processing through cross border data transfer between group
entities. Unless authorized and contractually agreed, we are committed to protect the confidentiality of such personal information while processing such personal information,
implement adequate technical and organizational measures and employees are made aware of and required to comply with mandated processes under Privacy Policy for
responsible use, disclosure, storage, retaining or any other processing of such personal information.

Any incident involving personal data/information (actual or suspected) should be brought to the attention of Data Privacy Office by raising an AHD to DPO or via email at
privacy@infosys.com.

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Improper Opportunities
When we receive information as part of our job, we should not trade with it for our personal
benefit. Neither should we pass on the information to our friends and family members or
indirectly compete with the Company. Information obtained as part of our job should not be
taken advantage of even after we leave the organization.

Company Intellectual Property

The intellectual property (IP) of the Company must be protected as a vital business asset. Our
IP portfolio includes copyrights, patents, trademarks, service marks, trade secrets, design
rights, logos, brands and know-how. We must use our IP focusing on protecting these assets.
It is important to ensure that to the extent permitted by law, the rights to all IP created using
the Company’s time and expense that which are within the scope of our duties are assigned
to and are the property of the Company. We should promptly disclose any works, inventions
or developments we create to obtain legal protection over them. Please contact the IP Cell at
iphelp@infosys.com if you have any questions.

Speaking to the Media

Any inappropriate or inaccurate response, even a simple ‘NO’ or disclaimer of information, may
result in adverse publicity and could otherwise gravely affect the Company’s legal position.

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Providing Information to the Media

To protect our confidential information from misuse and to ensure that only accurate
information about the Company is disclosed, we have designated our Corporate
Communications team to handle exchanges with the media. Additionally, our Chief
Executive Officer, Chief Operating Officer, Chief Financial Officer and Investor Relations
Department are the official Company spokespeople for financial matters. All inquiries
or calls from the press and financial analysts should be referred to the Corporate
Communications team. We must not post or discuss information concerning the
Company’s services or business on the Internet unless we are authorized to do so.
Neither must we create a perception that we are speaking or posting on behalf of the
Company. Remember that your online posts will be available for a long time, so think
carefully prior to posting any information that could affect our Company.

For more information, you may read Infosys Code on Fair Disclosures
and Investor Relations which establishes who in the Company may
communicate information.

Physical Access Control

Infosys has developed procedures covering physical access
control to ensure privacy of communications, maintenance of
the security of the Company communication equipment, and
safeguard Company assets from theft, misuse and
destruction. We are responsible for complying with the
security policies in your location. You must not defeat or
cause to defeat the purpose for which the access control was
implemented. For more details please read the Company’s
Information Security Policy.

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Use of Company Assets

The use of Infosys assets for individual profit or any unlawful, unauthorized personal or unethical purpose is prohibited.
Our information technology, intellectual property (e.g., copyrights, patents, and trademarks), facilities, equipment,
machines, software, and cash may be used for business purposes only, including responsible and accurate expense
reimbursement, and in accordance with applicable policies.

Other assets (e.g., computers, printers, and copiers) may be used for minor and incidental personal purposes provided
such use is kept to a minimum, and does not create any significant incremental costs, interfere with work duties, or violate
any laws or Infosys policies. The use of any Infosys resources for personal political activities is prohibited.

Computer hardware, software, data, and facilities are valuable resources that need protection from potential destruction,
theft, or misuse. These resources may also include confidential client or Infosys information that requires safeguarding. It
QUESTION is your responsibility to prevent unauthorized access through the use of ID badges, passwords, or other security codes,
I recently started working at Infosys. I previously and physical security measures (such as using computer cable locks, not leaving computers unattended in cars, and other
worked for a competitor and just realized I may be normal precautions).
involved in developing technology for Infosys that
is very similar to what I developed for my prior Copyrighted materials (e.g., books, music, software, and magazines) should not be reproduced, distributed, or altered
employer. Should I inform my manager? without permission of the copyright owner or an authorized agent. Software used in connection with the business of
Infosys should be properly licensed and used only in accordance with that license. Using unlicensed software could
constitute copyright infringement and may be grounds for disciplinary action. For more information, please read the
RESPONSE Company’s policies on use of Company assets.

Yes, immediately inform your supervisor that there

may be a conflict with your obligations to a prior
employer, but take care not to disclose any Expense Claims
confidential information belonging to the prior
employer in doing so. You should follow any Each supervisor, manager, and individual employee has an obligation to each other and to the Company to comply with
obligation to your prior employer not to disclose Infosys business expenses and reimbursement policies and practices. All business-related expense claims must be
or use their confidential technical information. authorized by your manager before being incurred. Personal expenses will not be reimbursed by the Company.
Infosys expects you to honor your confidentiality
obligations to your prior employer. When in doubt
about the scope of obligations to a prior employer
contact our IP Cell.

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D COMMITTED TO OUR
CUSTOMERS AND
OUR SUPPLIERS
To many people, you are the only “Infosys” that they will ever meet—as such you are
a brand ambassador and a representative of the Company. For instance, if our job
involves working with current or potential Company customers/suppliers, we must
act in a manner that is representative of our C-LIFE values. The goodwill our Company
enjoys is one of our most important assets, and we must preserve and enhance our
reputation through our actions.

Fair Dealings
We must deal fairly with the Company’s customers, suppliers, partners, service
providers, competitors and anyone else with whom we interact while at work. We
should not take unfair advantage of anyone through manipulation, concealment,
abuse of privileged information, misrepresentation of facts or any other unfair dealing
practice.

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Confidential Information of Clients and Third Parties

The Confidentiality and Nondisclosure Agreement we sign when we join the Company details our confidentiality obligations to the Company and its clients. We have access to
significant amounts of client information that may not be available to the public, and we are required to preserve the confidentiality of information obtained in client service.
Information of a confidential, private and sensitive nature must be used responsibly and controlled and protected to prevent its prohibited, arbitrary or careless disclosure. Unless
the client has provided its specific consent, which should preferably be in writing, or there is a legal or professional right or duty to process or disclose, we are prohibited from
processing or disclosing confidential client information.

Confidential or proprietary information including personal information about clients, our organization, or other parties, which has been gained through employment or affiliation
with Infosys, may not be used for personal advantage or for the benefit of third parties. We are committed to protect the confidentiality of processing such personal information by
implementing adequate technical and organizational measures, and all employees, agents, consultants, suppliers, contractors, are made aware of their responsibility to use, or
process personal information, unless authorized by law and/or contractually agreed.

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Free and Fair Competition

At Infosys, we believe that a free and fair market benefits all of us and ensures that our clients receive the best quality products and services at the best prices. Most countries we
operate in have laws to encourage and protect free and fair market competition by regulating anti-competitive conduct, including unfair acts by market leaders. These laws regulate
our relationships with our customers, competitors, distributors and resellers.

What do we need to know? What is regulated?

How do we comply?
 Anti-trust laws generally address the following areas: Unfair pricing practices
(such as price discrimination, price fixing), secret rebates, entry barriers
through exclusive dealerships or distributorships which are questionable,
restrictions on carrying competing products and other practices. If you come
across any such questionable practices in the course of your work, for
instance, while bidding for services, please contact the Helpline.
 You should not engage in any commercially motivated understanding
(written or oral, expressed or implied) to undermine the fair market
competition.
 You should not knowingly make false or misleading statements regarding
our competitors or the products and services of our competitors, customers
or suppliers.
 Collusion among competitors is illegal. Our communications with
competitors should always avoid subjects such as prices or other terms and
conditions of sale, customers and suppliers. You should not enter into an
agreement or understanding, written or oral, express or implied, with any
competitor on these subjects.

For more information, please refer Anti-Trust Policy.

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QUESTION
My department is in the process of choosing a vendor. One of my employees recommended a company owned
by his sister. I have heard good things about this company from other sources. Can I consider this company
even though one of my employees is related to the owner?

RESPONSE
This employee can compete for the work, but the employee who is related to the owner cannot be involved in
decisions about choosing the vendor. Nor can the employee be involved in managing the vendor, if chosen.
Your employee should also understand that he cannot provide any confidential Infosys information or other
advantage to his sister that would help her company be selected. Also, you should consult your manager about
any actual or apparent conflicts of interest under the circumstances, particularly where family members are
involved.

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Industrial Espionage
Our commitment to fairness includes respecting the rights of our competitors and abiding by all applicable laws. As a lawful competitor and to help ensure the integrity of the
competitive marketplace, we must respect our competitors. Take care that we do not appropriate or unlawfully use the information, material, products, intellectual property, or
proprietary or confidential information of anyone including suppliers, customers, business partners or competitors.

Governmental Relations
While all our clients are treated with respect, we should be especially careful while dealing with government clients. There are significant penalties in many countries, including
debarment and monetary penalties for organizations that fail to follow the law while working for government clients. The principles set out in Section B of this Code of Conduct
‘Ethics in Our Business Activities” and Anti-Bribery and Anti-Corruption Policy of the Company must be strictly followed by all who interact with government officials especially with
respect to gifts and entertainment. We should not attempt to influence government employees in any manner other than what is agreed in our contractual arrangement with the
government. Employment opportunities for former government officials must not be discussed without first seeking guidance and approval of the Office of Integrity and
Compliance. Similarly, we should not initiate discussions for any contract with any business in which a government official or employee holds a significant interest, without the prior
approval of the Office of Integrity and Compliance. Reach out to OIC@infosys.com for approvals.

Selecting Suppliers
The Company’s suppliers make significant contributions to our success. We strive to create an environment where our suppliers are confident that they will be treated with respect.
We select our significant suppliers or enter into significant supplier agreements though a competitive bid process where possible. For more information, read our Supplier Code of
Conduct.

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E RECORDS, DISCLOSURES AND AUDITS

Maintaining Accurate Records

The integrity of our financial transactions and records is critical to the operation of our business.
Our shareholders’ trust is based on their confidence in the accurate recording of our financial
transactions. Additionally, as a listed company, we are bound by certain standards for accurate
financial reporting and we are required to have appropriate internal controls and procedures. If you
have responsibility for or any involvement in financial reporting or accounting, you should have an
appropriate understanding of, and you should seek in good faith to adhere to, relevant accounting
and financial reporting principles, standards, laws, rules and regulations and the company’s
financial and accounting policies, controls and procedures.

If you are a senior officer, you should seek to ensure that the internal controls and procedures in
your business area are in place, understood and followed.

Additionally you should take every precaution, whether you are otherwise required to be familiar
with finance or accounting matters or not, to ensure that every business record or report with
which you deal is honestly filled in, accurate, complete and reliable. For more information, refer to
the Policies on Reimbursement of Official Expenses. Additional policies may be applicable, based
on your location.

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Ensuring Accurate Public

Disclosures
Infosys is committed to provide full, fair, accurate, timely and clear disclosures in reports
and documents that we file with, or submit to our regulators and in our other public
communications. To enable this, we must ensure that we comply with our disclosure
controls and procedures, and our internal control over financial reporting.

Auditors
Our outside auditors have a duty to review our records in a fair and accurate manner.

We must cooperate with them in good faith and in accordance with law. We must never
mislead them in any manner regarding financial records, processes, controls or
procedures or other matters which they may enquire about.

Interacting with Regulators

We must fully and truthfully cooperate with any examination or request for information
from a regulator or law enforcement agency. Any contact with law enforcement
agencies or regulators must be coordinated through the Legal Department.

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Records on Legal Hold

In certain circumstances, such as litigation or government investigations, you may be informed by the Legal Department that a legal hold is placed on records for which you are
responsible. A legal hold prevents the destruction of documents which may be required for such investigations. We must all comply with instructions of the Legal Department if a
legal hold is placed.

Unless released in writing by the Legal Department, a legal hold remains effective. If you have any questions about a legal hold, contact the person who has sent you the notice of
legal hold.

Record Retention
All Company records shall be maintained in accordance with our Document Retention and Archival Policy.

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Do Not

Enter information in the Establish any undisclosed or Enter into any transaction or
Company’s records that hides the unrecorded fund, account, asset or agreement that could affect the
true nature of any financial or non- liability for any improper purpose. accurate and timely recording of
financial transaction or result. revenues or expenses.

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F ADMINISTERING OUR CODE

The Office of Integrity and Compliance is responsible for administering the Code and reports to the General Counsel and the Audit Committee of the Company.

Investigations Acknowledgement
We have put in place a process to review and investigate all potential legal or Code Employees and our Board of Directors are required to acknowledge that they have
violations. Investigations will be conducted in confidence and will be respectful and fair. read and understood the Code. Our Independent directors may be required to
If an allegation is substantiated by an investigation, the appropriate management team acknowledge acceptance of the Code for Independent Directors as well. You must
will review the findings and determine the final outcome. Should you report a potential remember that under no circumstances does your failure to read our Code, sign an
violation in good faith, you are assured of all support by the Company. This support is acknowledgement or certify online exempt you from your obligation to comply
extended to any person who is assisting in any investigation or process with respect to with our Code.
such a violation as well. You can report any potential violation in good faith without ever
worrying, for instance if it will affect you professionally. Any such retaliation may be
immediately reported to the Helpline. If you are the subject of an external investigation,
you should immediately report this to your manager unless it is prohibited by law.
Waivers
Any waiver of our Code requires the prior written approval of the Office of Integrity
Amendments/Modifications and Compliance or, in certain circumstances, the Board of Directors or a committee
thereof. Waivers will be promptly disclosed as required by applicable law.

to Our Code
Our Company’s Board is responsible for approving and issuing the Code. The Code was
first effective on April 10, 2003, with revisions through July 12, 2019 and October 13,
2021. Our Code is reviewed annually to determine whether revisions may be required
due to changes in the law or regulations, or changes in our business or the business
environment. The Board of Directors must approve any changes to our Code.

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Disciplinary Actions
If you violate our Code, the Company will take appropriate
disciplinary action.

The matters covered in this Code are of the utmost importance to the Company, its shareholders and
its business partners, and are essential to the Company’s ability to conduct its business in accordance
with its stated values. We expect all of our directors, officers, employees and third party agents to
adhere to these rules in carrying out their duties for the Company.

We take violations of this Code, Company policies and applicable laws seriously. Where appropriate,
the Company takes prompt corrective action, up to and including termination of employment. We
strive for consistency and fairness in discipline for Code violations. Discipline may include a verbal or
written warning; suspension with or without pay; loss or reduction of bonus or stock options; or, for
the most serious offenses or repeated misconduct, termination of employment.

Any disciplinary action depends on the nature, severity, and frequency of the violation. It may vary
depending upon local law. Please understand that those who violate the laws or regulations
mentioned in the Code could expose themselves and the Company to substantial civil damages and
criminal penalties.

Corrective action may be taken if you:

 Violate the Code, Company policies and procedures, or applicable laws.
 Direct others to violate the Code, Company policies and procedures, or applicable laws.
 Are aware of a violation or potential violation, and fail to report it.
 Fail to effectively monitor the actions of people you manage.
 Do not cooperate in a Company audit or investigation.
 Fail to participate in required training.
 Retaliate against someone for reporting a concern in good faith or for participating in an
investigation of such a report.
 Disclose information learned during an internal investigation.

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Confidential
Toll-free 24/7 UP
Report your concerns to your manager, Human
Resources manager, or the Helpline.
Use the helpline to report:
 Inaccuracy of financial records
The helpline numbers are :  Accounting and auditing irregularities
 U.S. Toll Free #: 1-800-236-6618  Bribery, corruption or illegal payments
 U.K. Toll Free #: 0-808-189-1043  Criminal conduct and violations of law
 India Toll Free #: 000-800-100-4380  Discrimination and harassment
 You can also report at http://oic.infosys.com  Conflicts of interest
 Local helpline numbers are available at
http://oic.infosys.com

You can also write to whistleblower@infosys.com, or to the Chief Compliance Officer at

complianceoffice@infosys.com.

If you have concerns about reaching out to the Chief Compliance Officer, your report
may be made to the Audit Committee of Infosys at Audit.Committee@infosys.com.

For more details, read the Company’s Whistleblower Policy available on the Infosys
intranet and on the Infosys website at:
https://www.infosys.com/investors/corporate-governance/documents/whistleblower-
policy.pdf. Retaliation is against our values
If you have concerns relating to your fellow employees’ behavior, you can also reach out All such reports may be made without fear of reprisal and with the assurance that
to HEAR@infosys.com. the Company is behind you. Threats, retribution or retaliation against any person
who has in good faith reported a violation or a suspected violation of law, this
Grievances relating to sexual harassment may be raised by writing to GRB@infosys.com. Code or other Company policies, or against any person who is assisting in any
investigation or process with respect to such a violation, is prohibited.

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Form of Acknowledgment of Receipt of Code of Conduct and Ethics

I have received and read the Company’s Code of Conduct and Ethics. I understand the standards and policies contained in the Company Code of Conduct and Ethics and understand
that there may be additional policies or laws specific to my job and/or the location of my posting. I further agree to follow the values of the Company in all that I do and comply with
the Company Code of Conduct and Ethics.

If I have questions concerning the meaning or application of the Company Code of Conduct and Ethics, any Company policies, or the legal and regulatory requirements applicable to
my job, I know I can consult my manager, the Office of Integrity & Compliance, the Human Resources Department or the Legal Department, knowing that my questions or reports to
these sources will be maintained in confidence.

Employee Name Signature

Employee No. Date

Please sign and return this form to the Human Resources Department.

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INDEX
Anti-competitive 19, 40 Facilitation Payment 19, 20, 23 Non Retaliation 14
Anti-corruption 19, 21, 22, 23, 24, 42 Family and Friends 25, 29 Outside Directorships 29
Books and Records 22 Financial Records 44, 49 Outside Employment 29
Boycott 27 Gifts and Entertainment 16, 22, 42 Political Activities 16, 31, 37
Bribery 19, 20, 21, 22, 42, 49 Government Officials 19, 20, 22, 23, 24, 31, 42 Record Retention 45
Business Partners 42, 48 Harassment 16, 17, 18, 49 Related Party 29
Cash 21, 22, 23, 37 Insider Trading 23, 24, 25 Reporting 29, 43, 44, 48
Company Assets 16, 33, 36, 37 Intellectual Property 16, 35, 37, 42 Retaliation 5, 14, 47, 49
Company Records 45 Internet 36 Safe Work 18
Confidential Information 16, 33, 34, 36, 37, 39, 42 Intimidation 18 Environment 5, 6, 14, 17, 18, 42, 47
Confidentiality 33, 34, 37, 39 Inventions 35 Security 18, 25, 34, 36, 37
Conflicts of Interest 28, 29, 30, 41, 49 Investigations 9, 14, 16, 45, 47, 48, 49 Sexual Harassment 49
Copyrights 35, 37 Investments 21, 29 Social Media 30
Corruption 16, 19, 20 Invoices 23, 27 Subsidiaries 14
Data 26, 34, 37 Kickbacks 19, 20 Suppliers 14, 16, 20, 29, 34, 38, 39, 40, 42
Discrimination 16, 17, 18, 49 Legal Hold 45 Third Parties 16, 20, 23, 24, 34, 39
Diversity 17 Loans 21, 29 Trademarks 35, 37
Emails 34 Manager 10, 13, 14, 15, 29, 37, 41, 47, 49 Violence 18
Export Controls 26 Media Inquiries 35, 36

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INDEX OF POLICIES
 Anti-Bribery and Anti-Corruption Policy  Policy on Reimbursement of Official Expenses in India

 Acceptable Usage Policy  Privacy Policy

 Corporate Policy Statement on Investor Relations  Reimbursement of Official Expenses outside India

 Document Retention and Archival Policy  Supplier Code of Conduct

 Human Rights Statement  U.S. Equal Opportunity Statement

 Information Security Policy  Whistleblower Policy

 Insider Trading Policy  Digitized Code of Conduct and Ethics

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www.infosys.com
http://oic.infosys.com

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