We keep accurate records.

We apply our Code of Conduct and policies consistently.

We prohibit retaliation against those raising concerns in good faith.

We do the right thing—always.

Using the Code to Make Ethical Decisions

Our Code of Conduct sets the standards for how we conduct Teradata business. However, our Code and policies are only guides to ethical conduct. They cannot cover every possible situation or every question a Teradata person might face. If you are unsure about what is the right thing to do, you should ask. Start with your manager, and then contact appropriate Teradata subject matter experts. Ethics compel us to get an answer before we act if we are uncertain if something is right.

On unique occasions, it may be appropriate to waive or alter a provision of our Code or a policy for a unique situation. This might be the case if doing one thing would be a violation, but doing another thing—or nothing at all—would also be a violation, or where legal requirements changed after the provision was written. If you encounter circumstances where you think such an ethical dilemma or contradiction has arisen, you should raise the issue with your manager immediately, and the manager should raise it with other appropriate responsible Teradata resources. If either of you is uncertain as to whom a question should be directed, you should raise it to the Teradata Ethics & Compliance Office. The important thing is to obtain direction before you act if you face such a dilemma or uncertainty.

Except for permitted deviations expressly provided for in our policies, all Code of Conduct and policy waivers require the advance written approval of the Teradata Law Department. Only the Audit Committee of the Teradata Board of Directors may waive compliance with our Code by Teradata executive officers or Board members, and only in the most unique situations, and only in compliance with proper disclosure and transparency requirements. We hold everyone from the top down to the same standards of conduct.

And we hold company executives and Board members to even higher standards and expectations.

Seeking Guidance and Reporting Violations

Violations of our Code are serious and can cause great harm to our business relationships and reputation. If you have a question or concern, or become aware of conduct you think may be a violation of our Code, our policies, or the law, then you have a duty to speak up. Reporting your concerns in good faith—meaning you are giving a sincere and complete account of a possible issue—helps Teradata avoid or solve problems in the workplace before they escalate.

If you suspect a legal or ethical violation, bring it to the attention of one of the following:

Your manager

A higher-level manager

Your Teradata human resources representative

The Teradata Ethics & Compliance Office by e-mail at E&C@teradata.com

The Teradata Ethics Helpline, which can be reached online at www.integrity-helpline.com/tdhelp.jsp or by telephone at 1-866-455-0993. The Teradata Ethics Helpline telephone number is printed on most Teradata associate identification badges—so it is readily available to you at all times. The Teradata Ethics Helpline allows for anonymous reporting, where permitted by law.

Any member of the Teradata Law Department

A member of the Teradata subject matter expert team for the area at issue (for example, Corporate Security for suspected theft issues, or Internal Audit for suspected financial irregularities).

While you may choose to report anonymously, it may be difficult to follow up with specific details of your concern. In some countries, local laws may require you to identify yourself. The Ethics & Compliance Office or the Ethics Helpline will let you know if either of these apply to your report. We encourage you to identify yourself when contacting these resources so Teradata can thoroughly investigate the issue. If you do give your name or come forward in person, Teradata will take