01
Code of Ethics and Business Conduct 02
A Message from Our Most Senior Leaders 03
Our Core Values 05
Our Code 06
Your Role 07
Speak Up 09
02
Code Rules 11
Antitrust and Competition Laws 12
Global Anti-Corruption and Bribery Laws 14
No Improper Payments 14
Gifts, Meals, and Entertainment 16
Business Courtesies You May Extend 17
Business Courtesies You May Receive 18
Engaging Government and Public Sector Employees and Officials 19
Government Contracting 19
Government Procurement Integrity 20
Organizational Conflict of Interest (OCI) 21
Post-Government Employment Restrictions 21
Lobbying of Government Officials 22
Political Contributions 22
Personal Political Activity 23
Influencing Others 24
Trade Compliance Laws and Regulations 25
No Economic Boycotts 27
Securities and Insider Trading 28
Intellectual Property 30
Protecting Confidential Information 31
Security Policies and Practices 32
Privacy Policies 32
Social Media 33
0
Conflicts of Interest 34
Gathering Information About Our Competitors or Other Third Parties 36
Contracting 37
Spending and Signing Authority 37
Use of Oracle Resources 38
Financial Integrity 39
Public Disclosures 40
Records Retention 41
Charitable Donations 42
Corporate Social Responsibility 43
03
Oracle's Relationships 44
Oracle and Our Employees 45
Immigration Laws 45
Diversity 46
Harassment 47
Safety and Security 48
Environment, Health, and Safety 48
Taxation 48
Oracle and Our Customers 49
Oracle and Our Partners 50
Oracle and Our Suppliers 51
06
Resources 58
