Subject: Region/Country: Global

Effective Date: January 1, 2017

Receipt of Employment Related Gifts Policy
Supersedes:
Dated:

Scope

Conduent Business Services, LLC and its subsidiaries provide this policy as a guide for employees. This policy applies
to all employees of Conduent Business Services, LLC and its subsidiaries who are based in the Region/Country
identified above and any reference hereafter to Conduent is a reference to Conduent Business Services, LLC and its
subsidiaries.

Summary

Establishes the practices governing the restrictions on the receipt of gifts and gratuities, entertainment and
honorariums by employees that arise as a result of their employment relationship.

Definitions

Immediate Family - includes spouse, minor children or any other relative or person sharing the same home with the
employee including common law or live-in arrangements.

Policy

I. Gifts and Gratuities

A. No employee or member of his/her immediate family may accept from any person who has business
dealings with Conduent gifts or gratuities, (including favors, special considerations, discounts and the
like) that go beyond common courtesies usually associated with accepted business practice.

No employee may accept cash or cash equivalents (gift certificates, etc.), regardless of the amount,
from any such person.

B. Employees must advise their manager of the receipt of any gift or other gratuity, regardless of value.

C. Gifts or gratuities with a value greater than $100 USD or equivalent in local currency should be
returned to the sender with a note explaining that acceptance is contrary to Company policy.

II. Entertainment

A. No employee or member of his/her immediate family may accept, from any person having business
dealings with Conduent, entertainment that goes beyond common courtesies usually associated with
accepted business practice.

B. Employees may accept invitations to lunch, dinner, or other social events (ball game, concert, etc.) as
an expression of normal business courtesy, provided that they are not intended to induce special
consideration, advantage, or have a total face value over $100 USD or equivalent in local currency.
Employees should always seek approval from his/her manager regarding participation.

Conduent Internal Use Only

CONDUENT GLOBAL ETHICS HELPLINE www.conduent.com/ethicshelpline or 844-330-0221
Conduent Ethics and Compliance Program Internet Site: www.conduent.com/ethics Page 1 of 2
 Subject: Region/Country: Global
Effective Date: January 1, 2017
Receipt of Employment Related Gifts Policy
Supersedes:
Dated:

C. Employees who are invited on trips, outings or seminars that require overnight travel must seek the
prior approval of the designated sector leader within their group.

Those sector leaders having approval authority should be so designated in writing.

III. Honorariums

Honorariums in amounts greater than $100 USD or equivalent in local currency cannot be accepted by
employees for services related to their Conduent position or duties. If greater amounts are offered, it is suggested
that the giver be asked to send the honorarium directly to a recognized charity of the employee's choosing in the
name of the giver.

IV. Establishment of Stricter Standards For Gifts, Entertainment, Etc.

The aforementioned standards are considered to be minimum requirements. Stricter standards, where required
by law or deemed appropriate by management, may be necessary for organizations or specific employee job
classifications, e.g., Global Purchasing.

V. Gifts Between Employees

Employees in a subordinate/supervisory relationship are not to exchange favors or gifts that could or appear to
give rise to an obligation. Company funds shall not be used to purchase gifts or services for employees except as
authorized under formal employee recognition programs or as prizes awarded for a contest or promotional activity
having defined eligibility criteria.

VI. Questions Concerning Standard Practices

Employees are encouraged to discuss questions concerning any aspect of these practices with their manager
prior to undertaking any course of action.

Exceptions

Within the boundaries of each policy there may be ‘allowable’ exceptions, and where this is the case the policy owner
(e.g. Global Leader, Compensation for the Compensation Policy) will oversee and grant the exception subject to
approval of the Chief Human Resource Officer.

Without the necessary approvals, no exceptions may be made to the existing HR policy nor granted to specific
individuals. Any other exception would be classified as unauthorized and would be considered a policy violation.
Where a policy exception is made without the appropriate approvals disciplinary action, up to and including termination
may be taken against the employee(s) who authorized the exception.

Conduent Internal Use Only

CONDUENT GLOBAL ETHICS HELPLINE www.conduent.com/ethicshelpline or 844-330-0221
Conduent Ethics and Compliance Program Internet Site: www.conduent.com/ethics Page 2 of 2