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Code of Ethics

and Business Conduct

July 2015
Code of Ethics | 2

Code of Ethics
and Business Conduct

Dear Colleague,
At Amdocs, we pride ourselves on our commitment to uphold the highest professional and ethical standards at all times.
The trust and confidence of our customers, shareholders, suppliers and employees is one of our greatest assets. Our success
depends on maintaining our reputation for integrity in everything we do.
We pledge to maintain the highest ethical standards, not only out of our legal obligation, but because we believe that it is
the right thing to do. I t is imperative that we all conduct ourselves honestly, fairly and with integrity in our dealings with
customers, suppliers and co-workers.
P lease take the time to read our Code and use it in guiding your day-to-day behavior on the job. As a valued member of the
Amdocs team, you represent the company and are personally responsible for full adherence to these standards.

S incerely,
Eli Gelman
President and Chief Executive Officer
Amdocs Management L imited
Code of Ethics | 3

Table of Contents

Introduction ............................................................. 4 Anti-Bribery and Corruption................................... 15


> Why Amdocs Has a Code > Bribes or Kickbacks are Illegal
> What’s Your Responsibility? > What is the FCPA?
> Amdocs’ Ethics Hotline
> You Are in Charge of Your Decisions and Actions Gifts and Hospitality ............................................. 16
> We Look to Managers to Lead with Integrity > Is it OK to Give (or Receive) Gifts and
> Make Good Choices and Hospitality?
Protecting Amdocs Assets....................................... 17
Employment Principles ............................................ 8
> Honesty Always
> Respect for Amdocs’ Employees > Financial Assets – Be Accurate in Recordkeeping
> Celebrate Amdocs’ Diversity > Working with Independent Auditors
> Speak Out Against Discrimination > Information Assets
> Harassment: Recognize It, Report It. > Proprietary and Confidential Information
> Sexual Harassment > Nondisclosure Agreements
> Intellectual Property
Employee Health, Safety and Privacy ..................... 10 > Protect Customer, Prospective Customer and
> Health and Safety are Everyone’s Responsibility Supplier Information
> Know Amdocs’ Policy on Substance Abuse > Open Source Software
> Keep Amdocs Violence-Free > Physical Assets
> Technology Assets
> Protect Employee Privacy
> Communicating about Amdocs
Conflicts of Interest ................................................ 12 Respect for the Marketplace .................................. 24
> Respect for the Company > Good Corporate Citizens
> Avoid Conflicts of Interest > Amdocs is a Fair and Honest Competitor
> Conflicts of Interest Can Take Many Forms > Insider Trading
Code of Ethics | 4

Introduction

Amdocs’ Code Why Amdocs Has a Code What’s Your Responsibility?


applies to:
If you think of integrity as a destination, our company’s As a valued member of the Amdocs team, we rely on you to:
> Employees, Directors and Code of Ethics and Business Conduct is the map we use > Read the Code, be familiar with it and make sure you
Officers of Amdocs; to get there. It provides information to help us work fairly comply with it.
> Amdocs subsidiaries; and and honestly wherever we conduct business in the world, > Check the Code when you’re not sure of what to do.
> Other business entities and it outlines the steps we need to take for making ethical > Do the right thing and be alert to activities going on
controlled by Amdocs. decisions along the way. around you.
> Report any violations – or suspected violations – of the Code.
Amdocs’ Code helps us to stay on the right track, pointing
We want you to feel comfortable coming forward, without
us in the right direction when we’re not sure of what to do.
any apprehension.That’s why we strictly prohibit anyone
It also represents our shared commitment to the highest
Involved in a situation standards of integrity. By working for Amdocs, you are
from “getting back at” or retaliating against anyone
that just doesn’t feel agreeing to follow its Code.
who speaks up and reports any violation – or suspected
right? violation – of the Code. Amdocs will address and
investigate all claims of retaliation.
> Discuss it with your Senior
Leader. If you are not sure who If everyone is committed to doing the Amdocs’ Ethics Hotline
is the Senior Leader of your right thing, why do we need a Code? If you don’t feel comfortable in approaching your Senior
division, please contact your Leader, HR representative, or the Compliance Officer
Most people do not knowingly violate a law or policy.
HR Representative. (Amdocs’ General Counsel), you can contact the
Violations usually occur because you’re faced with a
> Contact the Compliance Officer. Amdocs’ Ethics Hotline anonymously. The Ethics Hotline
difficult choice, where the “right thing” is not clear. Our
> Access the Amdocs Ethics company’s Code doesn’t address every possible ethical offers you a confidential way to ask questions or share
Hotline. situation you might face on the job, but it’s designed to concerns about possible unethical or illegal behavior either
guide you through the gray areas and direct you to people by calling a toll-free number (as specified for each country)
who can help you. or online. The Ethics Hotline is operated by an independent,
third-party organization that provides reporting services
to companies like Amdocs around the world.
Code of Ethics | 5

Introduction

To access the Ethics When you access the hotline, you will be able to talk to a concerns. B y speaking up, you are helping us uphold an
Hotline: specially trained representative who will document your honest and ethical Amdocs.
concern in detail and relay the information to Amdocs for
Click here to submit an Amdocs’ Code complements the company’s policies,
action.
anonymous and confidential procedures and employment agreements. If you encounter
report about any unethical Depending on the nature of your concern, the information an inconsistency or conflict, discuss it with your Senior
behavior, theft or fraud in the will be forwarded to either the Amdocs’ Human R esources Leader Human Resources representative, or contact the
workplace. or I nternal Audit departments for investigation. All Compliance Officer to determine the proper course of action.
Code violations and the results of any investigations are
reported to the Audit Committee of the Amdocs B oard of
You can find the Directors on at least a quarterly basis.
Amdocs Code of Ethics What if a local law where I work
and Business Conduct on: conflicts with the Code?
Tip: I f you report a concern, it’s a good idea to
keep all relevant documents ( including computer As a company operating in a global marketplace, we
> The Amdocs intranet homepage,
discs, tapes, hard drive and audiotapes) in case there is an experience a wide range of social customs, rules and
under Corporate Governance
investigation. regulations, cultures and laws. We have an obligation to
Policies, and
comply with all applicable laws wherever we operate. I f a
> Amdocs.com. local law conflicts with the Code, you should follow the law,
You Are in Charge of Your Decisions and
Actions but please advise the Compliance Officer of the conflict. If
you find, however, that a local business practice conflicts
Always act legally and ethically even if someone tells you with the Code, you should follow the Code. Not sure? Ask
to do otherwise. R emember, no one has the authority to for help.
cause you to violate the law or the Amdocs Code of E thics
and B usiness Conduct. I t’s important to know and follow the Code at all times. Anyone
who violates the Code will be subject to disciplinary action,
I f you suspect illegal or unethical activities, share your which may include termination and, in some cases, legal action.
Code of Ethics | 6

Introduction

What You Might Be We Look to Managers to Lead with Integrity > Be there for your employees.
Concerned About: Help them understand the Code. E ncourage them to
Managers have a special responsibility: come to you with any questions or concerns they may
> Retaliation. E veryone can
> Set a good example. have and guide them when they need it.
raise concerns about illegal or
S erve as a role model for your employees. Model ethical > Stand by the Code.
unethical behavior without fear
behavior on the job and work according to Amdocs’ I n your day-to-day business, make sure policies and
of retaliation. Amdocs doesn’t
values, policies and procedures. procedures you develop fit into the framework of the
tolerate retaliation against
employees who speak up. > Support the annual signing campaign. Code. Take action to report any Code violations.
> Reporting Concerns about B e sure members of your team receive a copy of our
Your Manager. Use the company’s Code of E thics and B usiness Conduct and
Amdocs E thics Hotline. I t’s a that every year they certify that they have received and
confidential way to share your understand its importance.
concerns.

What You Need to Do:


> R ead, understand and comply
with the Code.
> S hare your concerns if you see
or suspect violations of the
Code.
> Ask for help whenever you have
questions.
Code of Ethics | 7

Introduction

Make Good Choices > Would you feel comfortable if everyone knew you did it?
> Would it be viewed positively by your co-workers, your
Amdocs counts on you to use good judgment in your
company and companies Amdocs does business with?
decision-making. B ut if you are ever faced with a complex
ethical situation and the right course of action is unclear,
ask yourself the following questions: I f you are in doubt as to any of the above or if you feel
uncomfortable about a situation, discuss it with your Senior
> I s it legal? Leader or your Human Resources representative, or contact
> I s it in line with Amdocs’ Code and other company policies? the Compliance Officer for guidance.

? I s it legal? NO
YES
If in doubt I f you can’t answer
? I s it in line with Amdocs’ Code and other
discuss it with your company policies?
NO Yes to these
Senior Leadrer, your YES
questions
HR representative, Don’t do it
or contact the ? Would you feel comfortable if everyone NO
knew you did it?
Compliance Officer YES
for guidance.
Would it be viewed positively by your
? co-workers, your company and companies NO
Amdocs does business with?
YES

You can go ahead and do it


Code of Ethics | 8

Employment Principles

Respect for Amdocs’ Employees demotions, transfers, layoffs and terminations, and
disciplinary actions.
Amdocs’ employees are the company’s greatest asset. This
section of the Code includes policies that ensure that every These kinds of decisions are based solely on an individual’s
employee is treated with dignity and respect. performance, experience, training, work history and overall
job suitability.
Celebrate Amdocs’ Diversity
Amdocs is committed to providing employment
I think I may have been denied an off-
opportunities for all qualified candidates and does not
site training opportunity because of my
discriminate on the basis of race, color, religion, gender,
sexual orientation. What should I do?
sexual orientation, age, national origin, disability or All employment decisions must be made without regard
veteran status or any other status that is protected by law. to sexual orientation or any other status that is protected
by law. I f you feel you were treated unfairly, contact your
With thousands of employees serving customers in more Human R esources representative, the Compliance Officer
than 60 countries, Amdocs is proud of the diversity of or the Amdocs E thics Hotline.
cultures, experiences and talents we each represent.
Speak Out Against Discrimination Harassment: Recognize it, Report it.
Amdocs’ commitment to a diverse workforce is reflected As employees, we value and respect each other. We do not
in all its employment practices, including decisions about harass others based on their race, color, religion, gender,
recruiting and hiring, working conditions, appraisals, sexual orientation, age, national origin, disability or veteran
compensation and benefits, training, promotions and status or other status that is protected by law.
Code of Ethics | 9

Employment Principles

What You Might Be gender boundaries and involve people of the opposite sex
Concerned About: What is harassment? or the same sex.
Speaking Out on Behalf of Others. Harassment is when words or actions are used in a way that To ensure the protection of every employee, Amdocs has
You have a responsibility to act interferes with someone’s work or creates a work environment a sexual harassment policy that provides details about the
when you see or suspect a threat that is intimidating, hostile or offensive. Harassment can take kinds of behaviors that are considered to be harassment.
or risk to anyone at Amdocs. many forms including words, derogatory statements, signs, The policy also provides information on how to file a sexual
Notify your Senior Leader, your HR offensive jokes, cartoons, pictures, posters, e-mails, pranks, harassment complaint.
representative or the Compliance intimidation, physical contact or assault.
Officer or access the Amdocs B e sure you know, understand and follow Amdocs’ sexual
E thics Hotline. harassment policy. Details of the policy vary according
What if the person harassing me is my to local laws, but remember, Amdocs will discipline any
manager? I’m afraid that if I complain, employee who is found to be guilty of harassment. This
What You Need to Do: I’ll lose my job. may include dismissal.
You are a valued member of Amdocs and you have a right
> Treat others with dignity and to work without fear of intimidating, hostile or offensive
respect.
behavior from anyone, including your manager. I f you feel
> S upport and promote a
workplace that values all people, you are being harassed, contact your Human R esources Sexual harassment includes…
regardless of culture, background representative, the Compliance Officer or the Amdocs R equests for sexual favors, graphic verbal comments about
and life experience. E thics Hotline. a person’s body or sexually degrading descriptions of a
> I f you know or suspect that person. S exual harassment also includes the display of
others are being harassed or Sexual Harassment sexually suggestive objects or pictures at work or anything
discriminated against, report it that creates an uncomfortable environment that prevents
immediately. Any form of sexual harassment, including unwelcome
someone from focusing on his or her job.
> K now Amdocs S exual sexual advances of either a physical or verbal nature, is
Harassment Policy. strictly prohibited. S exual harassment can cross age and
Code of Ethics | 10

Employee Health, Safety and Privacy

Health and Safety is Everyone’s Responsibility


Ensure a safe Amdocs Be aware that…
Amdocs aims to provide a safe workplace for all
> Comply with all health and You may be required to undergo drug testing as a
employees and visitors. The company counts on you to
safety rules. condition of employment. I f you are charged with a
follow all health and safety rules and notify your Senior
> R eport any unsafe conditions, drug-related crime – or, in fact, any crime – while on
Leader immediately of an accident, injury or illness
accidents or injuries. Amdocs business, you must report the incident to your
you may experience on the job.
> Do not use or abuse alcohol Senior Leader immediately.
or drugs on Amdocs’ property Know Amdocs’ Policy on Substance Abuse
or when working on Amdocs
business. You may not use, possess, purchase, manufacture, sell or
> R eport any threatening distribute illegal drugs or controlled substances while on Protect Employee Privacy
behavior or weapons in the Amdocs property or when working on Amdocs business.
Our company works to balance its employees’ need for
workplace. Alcohol or other substances that can affect your job
privacy with the need to gather essential information.
performance or good judgment are also prohibited.
Personal information about Amdocs employees - gathered
Keep Amdocs Violence-Free for business, legal and contractual reasons, such as your
home address and phone number, salary information,
Threats or violence of any kind ( including physical benefits information - is kept strictly confidential and
violence, intimidation, harassment or coercion) are not shared only with those who have a legal right or a
tolerated at Amdocs. Weapons are also prohibited while legitimate business need to know.
working on Amdocs business, whether you are working on-
site, off-site or traveling on behalf of Amdocs. I f you have access to personal information about co-
workers you must take every precaution to ensure it is not
misused or improperly disclosed.
Code of Ethics | 11

Employee Health, Safety and Privacy

What You Might Be Amdocs respects the privacy of your personal information
Concerned About: and the workspace you use as an Amdocs employee. Tip: “ Company property” includes, for example,
> Sharing Private Information B e aware, however, that if the company suspects an desks, cupboards, computers, telephones, mail, voicemail,
about Employees. I f you are employee of illegal behavior, it has the authority to search e-mail and I nternet access.
ever unsure about what kind and monitor company property without notification
of employee data is considered in advance. Amdocs also reserves the right to search
private, ask. employee property, such as briefcases, bags and private
vehicles on Amdocs’ premises.

What You Need to Do:


> K now and abide by Amdocs
policies regarding drugs and
alcohol.
> R eport any unsafe conditions,
violent acts or threats.
> P rotect personal data from
unauthorized access, misuse or
improper disclosure.
Code of Ethics | 12

Think you may have a Respect for the Company Amdocs counts on you to make fair, objective decisions
conflict of interest? based on good business practices and not let personal
E ach of us has a responsibility to watch over our co- interests, associations or investments interfere—or appear
> Talk to your manager. workers, our company and our reputation. Policies in to interfere—with Amdocs’ interests.
> Document the facts in writing. this section of the Code will help you understand how
> S ubmit the information to the to protect Amdocs’ interests and use Amdocs’ resources What’s the best way to avoid a conflict of interest?
Compliance Officer. wisely. Be open and honest about your actions on and off the
job. Inform your Senior Leader about any outside activities
Avoid Conflicts of Interest or relationships (with customers, suppliers, competitors,
Amdocs respects your right to conduct activities and friends or family) that could influence your job
pursue interests outside of work. But a “conflict of responsibilities or the decisions you make at Amdocs.
interest” can occur whenever those activities or interests Together, you and your Senior Leader will document the
begin to interfere with your job responsibilities or affect facts in writing and submit them to the Compliance Officer
the way you make decisions as an Amdocs employee. for review, who will then provide you with advice on how
Conflicts of interest can happen to proceed.
when you...
Conflicts of Interest Can Take Many Forms
> Have a financial interest in an Amdocs competitor,
customer, supplier or vendor; Being aware of possible conflicts of interest can help you
> Take on a second job; avoid them. Make sure you’re familiar with the following
> Hire ( or work with) family or friends at Amdocs; situations which can present potential conflicts of interest:
> Take advantage of a business opportunity that rightfully Improper Investments
belongs to Amdocs; or
> S erve on the board of another company. Ask yourself: Do I or does any member of my immediate
family own or have a “financial interest” in an Amdocs’
competitor, customer or vendor?
Code of Ethics | 13

As an Amdocs employee, you and your If I invest in a mutual fund—is that


immediate family are prohibited from considered a “financial interest?”
owning or having a financial interest in one of our
company’s competitors, customers or vendors. No, an investment in a mutual fund is called an indirect
A “financial interest” is anything other than: investment and not considered a conflict of interest as
long as the fund is not managed or controlled by you, a
> L ess than 1% ownership of a public company member of your immediate family or a business that one
> L ess than 5% ownership of a private company of you owns.
> L ess than 20% of your annual Amdocs base salary.

“Immediate family” includes… A Second Job


Your spouse or partner and anyone living in your household,
I f you have a job in addition to your employment with
parents, brothers, sisters, children and children’s spouses as
Amdocs, you must request approval from your Senior Leader
well as your spouse’s parents, brothers, sisters, children and
and the Group President of Human Resources. As an Amdocs
children’s spouses.
employee, you may not work for any of our competitors,
customers, suppliers, vendors or companies that do (or want
My brother-in-law has a financial interest
to do) business with us.
in a company that just recently became an
Amdocs vendor. Could this be a conflict of interest? Working with a Friend or Family Member
It depends. If your brother-in-law is financially dependent
on you, then it may represent a conflict of interest. If your Advise your Senior Leader about any personal relationships
brother-in-law is not financially dependent on you, this you share with people at work. Depending on your individual
may not represent a conflict of interest.The best approach? job responsibilities and the areas in which you each work,
Notify your Senior Leader, in writing, to avoid even the your Senior Leader can take the proper steps to make sure
appearance of a conflict of interest and determine the that there are no conflict of interest situations you two might
best approach. experience on the job.
Code of Ethics | 14

Is it okay for my neighbor to apply for a As an employee of Amdocs, you may sit in meetings with
What You Need to Do: job opening in the department I manage? customers or suppliers or read Amdocs company
> I f you think you might have documents and learn about opportunities to invest in
There is nothing to stop your neighbor from working for Amdocs’ customers, competitors or suppliers. You may
a conflict of interest, act you, but think about it carefully. E ven if you try to be
promptly. Notify your Senior not take advantage of this information for personal gain.
objective in your business dealings, the very fact that you
Leader, your Human Resources share a personal relationship can suggest the appearance Before participating in any business
representative or the of a conflict of interest. Before proceeding, discuss the venture or investing in any project…
Compliance Officer. situation with your Senior Leader. Get the written approval of the Group President of Human
Resources. If you are an officer at Amdocs, you must
What about family and friends who work obtain prior written approval from Amdocs’ Chief
for Amdocs’ competitors, customers, Executive Officer before proceeding.
suppliers, vendors?
Serving on the Board of Another Company
S ometimes, family members or friends may work for
Amdocs competitors or for companies that do ( or want to You may serve on the board of a community or nonprofit
do) business with our company. These kinds of situations organization as long as it does not interfere with your
can affect your ability to make objective decisions on work. However, if you wish to serve on the B oard of
behalf of Amdocs, so you must let your Senior Leader Directors of another company, you must first obtain
know about them in order to avoid a conflict of interest. approval from the Compliance Officer.

As an Amdocs employee, you may not


Taking Advantage of a Potential Business serve on the board of:
Opportunity > Amdocs’ competitors,
You are not permitted to invest in an outside business > Amdocs’ suppliers,
opportunity in which Amdocs has an interest without > Amdocs’ customers, or
> Other business associates.
the prior written approval of the Group President of
Human Resources.
Code of Ethics | 15

Anti-Bribery and Corruption

Bribes and Kickbacks are Illegal Executives of one of our company’s customers
What you need to do:
Never give or accept bribes. As a company that is expect us to pay special fees to do business in
> Never give or accept bribes. committed to fair and honest business practices and to the country where I operate. What should I do?
> Know and comply with the Amdocs the highest standards and promotion of good practices Special payments made directly, or indirectly, to a customer,
procedure on ‘Appointment and and promotion of good practices in prevention of bribery even if considered okay under local custom, could violate
Operating Agents in the Group’ prior and corruption, we trust you to never offer payment or the U.S. FCPA or other laws or regulations. Before making
to engaging any agent, consultant, accept payment from an Amdocs’ customer or supplier in any kind of payment to a customer, contact the Compliance
partner, reseller, subcontractor or any exchange for gaining or keeping business. In all Amdocs’ Officer for approval.
representative otherwise acting on transactions, our company must make sure that business is
behalf of Amdocs won strictly on the products and services we offer.
Amdocs may be liable for the conduct of
To help you understand the rules, Amdocs has an Anti- third parties
Bribery and Corruption Procedure. The FCPA and similar laws and regulations also
extend to the conduct of third party agents, sub-
contractors and other representatives or business
What you might be What is the FCPA? partners.
The U.S Foreign Corrupt Practices Act (FCPA) and simillar
Concerned about: laws and regulations such as the UK Bribery Act make it a We must be sensitive to potential abuses and careful to
> Violating the U.S. FCPA. crime to offer payment or a promise of payment, or to offer avoid situations involving third parties which might lead
Never pay, promise to pay, give, or or give anything of value to government officials in exchange to a violation of the FCPA, the UK Bribery Act and/or
promise to give anything of value to a for business. any other local law or regulation.
government official in exchange for
business
A “government official” includes…
The employee of any government-owned or controlled entity or
any public international organization, political party, party
official or candidate for public office.
Code of Ethics | 16

Gifts and Entertainment - Payments and Contributions

Is it OK to Give or Receive Gifts and Involving Government Officials:


What you need to do:
Entertainment? Stricter Rules Apply
> Know and comply with Amdocs’ Giving or receiving something of value can be considered No gifts, gratuities, favors, entertainment or travel expenses
Gifts and Hospitality Policy. bribery, compromise our objectivity, create the appearance may be offered or paid to any government official or to any
Remember the rules are stricter for of a conflict of interest and harm the reputation of our employee of a government-owned company, unless you have
interactions with government officials. company. To help you understand the rules, Amdocs has a obtained written approval from the Compliance Officer in
Gifts and Hospitality Policy. You may only exchange gifts, advance. Conducting business with government officials and
and gratuities and other favors as described in this policy. employees of government- owned companies is not the same
Make sure you know and understand the policy and that you as conducting business with other companies. Special rules
always consult and submit the Gift and Hospitality Online apply, such as the FCPA or other anti-corruption laws,
form before giving – or receiving – any Gift or Hospitality. to make sure that there are no improper attempts to
influence business.

Keep in mind..... After months of waiting, we finally closed


the deal we’d been working on. Is it okay
“Anything of value,” under the FCPA or other anti-bribery to take the employee of the government-
legislation can include tangible and intangible items owned customer - who approved the
such as: preferential treatment, discounts, a promise of
request - out to lunch to thank him for
future employment, charitable contributions, payment
for travel expenses or entertainment. his help?
No, you can’t offer lunch—or anything of value—to
a government official, unless you have received prior
approval under the Gifts and Hospitality Policy.
Code of Ethics | 17

Protecting Amdocs Assets


Make sure Amdocs’ E ach of us has a responsibility to protect Amdocs’ assets What are some examples of “fraud and
books, records and from damage, loss, fraud, misuse and theft. Amdocs dishonest acts”?
accounts: assets are the means for us to successfully carry out our
> Forgery of checks or business records
> Are clear, truthful, complete company’s business every day. Amdocs’ assets include:
> Lying on your timesheet or expense report
and accurate. > Financial Assets: cash assets, bank accounts and credit > Dishonest accounting practices
> Follow Amdocs policies, standing > S tealing company property
procedures and controls. > Information Assets: confidential information, > I dentity theft
> Comply with all applicable proprietary information and intellectual property > E mbezzlement
laws, regulations and > Physical Assets: our company’s facilities and equipment
standards. > Technology Assets: computer hardware, software and
> Accurately reflect the true R emember, if you are charged with any crime, you must
information systems
nature of the transactions report the incident to your Senior Leader immediately.
they represent. B y safeguarding these assets, we help safeguard our
Financial Assets – Be Accurate in
company’s competitive advantage in the marketplace.
Recordkeeping
Honesty Always You are responsible for ensuring the honesty, completeness
Did You Know? and accuracy of all company records, books, information
Fraud and dishonest acts are not tolerated at Amdocs,
F inancial statements must con- whether they occur while you’re employed at Amdocs or and accounts, including expense reports, time sheets,
form to U.S . generally accepted occurred before you accepted a job with us. To preserve an payments and other business transactions. Accurate and
accounting principles ( GAAP ) . honest and ethical workplace, we promptly investigate all complete recordkeeping is essential to the successful
Do your part to ensure that all suspected acts of fraud. operation of our company and its ability to meet its legal
entries that should be made are and regulatory obligations.
made, that they are honest and
accurate and that they include the
proper supporting documentation.
Code of Ethics | 18

Protecting Amdocs Assets


As a public company, Amdocs is required to file periodic of our company’s Code but may also be a violation of the law.
Did You Know? reports and issue certain public communications. I f your If you have any questions about an auditor’s request, contact
I f you are responsible for job requires you to prepare or maintain these reports your Senior Leader or the Head of Corporate Finance
.
controlling funds or records, or relay these communications, make sure any company
including cash, checks, money information provided, including financial results and My manager asked me to hold an invoice
orders, credit cards or electronic financial condition, is full, fair, accurate, timely and for posting until the next quarter—is that
media, make sure Amdocs is understandable. okay?
getting what it is paying for and R emember, feel free to come forward and report any No, all expenses should be reported and recorded in the
that amounts are appropriate and accounting or auditing concerns. Amdocs doesn’t tolerate period in which they are spent. I f you believe that goods or
valid. If you have any questions on retaliation against anyone who speaks up about unethical services are not being accounted for in the proper period,
the appropriate use of Amdocs or illegal behavior. Discuss your concerns with: document and report it. Contact your Human R esources
funds, contact your Senior Leader. representative, the Compliance Officer or the Amdocs
> Your Senior Leader E thics Hotline.
> Your HR representative
> The Compliance Officer or
> The Amdocs E thics Hotline Information Assets
Amdocs information assets are among our company’s
Working with Independent Auditors most valuable assets and must be handled with care.
We insist on the same standard of honesty and accuracy Information assets include Amdocs’ confidential
when working with independent auditors (certified public information, proprietary information and intellectual
accountants who are not employees of Amdocs) . B eing property ( I P ) .
dishonest, coercing, manipulating, fraudulently influencing
or misleading auditors in any way is not only a violation
Code of Ethics | 19

Protecting Amdocs Assets

Proprietary and Confidential Information Use proprietary and confidential information only as
Did You Know? needed to do your job and never share it with people who
Amdocs proprietary information is any information do not have a need for it, even within Amdocs.
Your responsibility to protect Amdocs owns. I t includes things like the processes our
confidential information applies company creates, strategies it develops, specifications I f you leave your job at Amdocs, you must return all
to work you did before coming it designs, sales lists it generates, systems it develops, proprietary and confidential information.
to Amdocs and to any work you personnel information, information related to current
will do after you leave Amdocs. Nondisclosure Agreements
or future products and services, confidential market
I f you have any pre- or post- search, sales and marketing plans, earnings or financial Never share confidential information outside Amdocs
employment restrictions, such data, organization information and many other types of without your manager’s approval and without a
as confidentiality agreements, information. nondisclosure agreement in place. L imit the amount of
Amdocs requires you to abide by
confidential information shared to the minimum necessary
them. All proprietary information about Amdocs is confidential
to address the business need. When dealing with suppliers,
information and should be handled and protected in the
vendors, or other third parties, use extreme care from
same way.
improper disclosure. Original copies of nondisclosure
Disclosing confidential information of Amdocs can agreements should be kept with the L egal Department
seriously damage our company and put current—and
future—business opportunities at risk. I t can also expose What are some examples of
you and Amdocs to legal penalties. For any questions “confidential” information?
on confidential information, contact your Senior Leader or S uch information includes employment and personnel
the Compliance Officer
. information ( such as health, salary or performance
Confidential information includes also information you information), product specifications, designs and pricing,
may be exposed to as part of your job, whether about business strategies, technical information and data,
Amdocs or about its customers, suppliers or other third customer lists, trade secrets, government classified
parties. I t can be verbal, written or electronic information. information, marketing plans and nonpublic financial
information.
Code of Ethics | 20

Protecting Amdocs Assets


You have an obligation to protect Amdocs’ confidential > DON’T
Where can I learn information: R emove it from Amdocs’ premises, unless explicit
more about Information authorization has been given.
Security? > DO
Use it only as necessary to do your job and never for > DON’T
Amdocs has a detailed your own personal benefit. Allow inadvertent disclosure. Never Discuss Amdocs’
I nformation S ecurity Policy. > DO confidential information or nonpublic information about
S hare it only with those Amdocs employees who need Amdocs in public places where others can hear, such as
access to it in order to do their jobs. in elevators, planes, trains and restaurants, as well as in
> DO social networks or blogs.
Notify your Senior Leader if you receive confidential
information that you should not have received. What if an ex-colleague of mine asks me
> DO for some documentation on key processes
S ecure information properly, by protecting papers and we worked on? Can I forward it to them?
documents from view, safeguarding your password and
blocking electronic access on computers, P DAs, phones No, all documentation is Amdocs property and should not
or other mobile devices. be shared with your ex-colleague. I f you are in any doubt,
> DO contact your Senior Leader.
Act according to Amdocs’ published information
security procedures, relevant to your field of work.
> DON’T
Discuss it with anyone outside of Amdocs ( including
family and friends) or internally, except as required to
do your job.
Code of Ethics | 21

Protecting Amdocs Assets

Intellectual Property to see it or use it. B usiness associates trust us to maintain


Did You Know? the privacy of their information and records and to use
Amdocs’ intellectual property is one of our company’s them only for legitimate and permitted business purposes.
S ecurity procedures, product most valuable assets. I ntellectual P roperty includes,
development information, Amdocs employees, including others acting on its behalf,
but is not limited to, patents, trademarks, trade names, are responsible for understanding and complying with
locations of physical plant copyrights, proprietary routines, computer programs,
facilities, financial information— our customers’ applicable procedures, including those
documentation, trade secrets, systems, methodology, which are more restrictive than our own. Failure to do
this kind of information is highly know-how, marketing and other commercial and business
valued by individuals who wish to so may result in legal liability and damage relations with
information, techniques, specifications and plans. customers, suppliers and others.
harm our company or take unfair
advantage of our company’s Our intellectual property helps us remain competitive. I t is
success. I f someone requests any our most confidential asset and should be treated as such. Disclosing confidential information about
sensitive information and they are Amdocs’ customers, suppliers or other
R emember, just as Amdocs expects others to respect the third parties can:
not authorized to see it, contact
legal rights our company has in its intellectual property,
your Senior Leader immediately. > Harm our company’s business relationships,
our company has a responsibility to respect the brands,
designs, software and legally protected intellectual > Cause current projects to be cancelled,
property of other companies. Never copy, borrow, publish > P ut future opportunities at risk,
or use other companies’ intellectual property without > E ndanger the job security of all Amdocs employees, and
proper authorization. > Expose you and Amdocs to significant risk with the SEC
and other legal bodies.
Protect Customer, Prospective Customer and Don’t take chances. Do your part to keep information
Supplier Information confidential.
I f you work with information belonging to Amdocs’
customers, suppliers or other third parties —including Is it okay to use the office copier to make a
written, voice and electronic communications—you have few copies of my daughter’s school paper?
a duty to protect it from others who are not authorized Yes, limited personal use such as this is allowed.
Code of Ethics | 22

Protecting Amdocs Assets

What You Might Be Protecting Amdocs Customers’ Information is Occasional, personal use of internet and e-mail access
Concerned About: Critical and voicemail, is permitted but make sure you do so in
moderation.
Not Recognizing Confidential Keep information on Amdocs’ customers’ customers
Information. I f you are ever To protect Amdocs’ technology assets:
confidential too. Due to the nature of Amdocs’ business,
unsure about what information many of us have access to the personal and private > DO
is considered confidential or information of millions of Amdocs’ customers’ subscribers. Use extreme caution when opening e-mail attachments
how it should be handled, This information is not only considered highly confidential, from unknown or suspicious senders.
contact your Senior Leader. but is also protected by numerous laws and regulations. > DO
B e aware that sharing this data can result in serious Use only software that is legally licensed to Amdocs.
consequences both for you and for Amdocs. > DO
Contact the systems administrator before installing data
Open Source Software or software not provided by Amdocs.
Open source software is software for which normally > DO
the source code is available free of charge under a free P rotect and do not share your individually assigned
software or open source license. Just because open source passwords and personal I Ds.
software is downloadable without charge does not mean > DON’T
we can use it without restrictions. Open source software Use of someone else’s password, which you may have
licenses often impose obligations that could have serious learned by chance or while performing your duties.
implications if violated. B efore downloading, using or > DON’T
modifying any open source software, whether for internal Download files from unknown or suspicious sources.
use or for use as part of a product development, you must > DON’T
review Amdocs’ F OS S Policy and obtain the approvals of Send e-mails that contain offensive, harassing, illegal or
the L egal Department and others mentioned in that policy. otherwise inappropriate content.
Code of Ethics | 23

Protecting Amdocs Assets


Direct connection (within Amdocs’ premises) to the Communicating About Amdocs
What You Need to Do: Amdocs’ network using a non-Amdocs P C is strictly
forbidden. R emote connection to the Amdocs’ network, Don’t speak on behalf of Amdocs unless you’re authorized
> P rotect all Amdocs’ assets –
financial, information, physical from any location which is not within Amdocs’ premises, to do so. I f you are contacted by a member of the media,
and technology. using a non-Amdocs P C, shall be made through web based financial analysts, stockholders, government entities or
> Keep all confidential services only. For further details please refer to Amdocs law enforcement for information about Amdocs, please
information safe and comply R emote Connection using Non Amdocs E quipment refer them to the contacts below:
with non disclosure obligations.
> Do your part to ensure Amdocs’ P rocedure.
books, records and accounts
Contacted by: Refer them to:
are clear, complete, truthful and R epresentative of the media Public Relations
accurate. Tip: Make sure any portable storage devices, or other outside group Manager
> E nsure the privacy of Amdocs’ systems, data and magnetic media are used only
Financial analysts and Head of Investor
customers’ and suppliers’ in compliance with customer contracts and, where used
information. stockholders Relations
in the office or at home for the storage of Amdocs data,
> I f you see or suspect any are physically and logically secured and used for Amdocs Government entities and Compliance Officer
violations of computer security law enforcement
business only.
measures, report your concerns
> Don’t speak on behalf
of Amdocs unless you’re
authorized to do so. Be aware that any information you
create, send, receive, download or store
on Amdocs’ systems belongs to the company.
Amdocs reserves the right to review and monitor its use at
any time without notifying you and to the extent permitted
by law. I f you see or suspect any violations of computer
security measures, report your concerns to your Senior Leader.
Code of Ethics | 24

Respect for the Marketplace

Fair competition Amdocs is committed to conducting its business fairly, B y following good business practices, we maintain the
means we… honestly and in accordance with the highest ethical respect of Amdocs customers and Amdocs competitors
principles. Amdocs provides you with the information and ensure future Amdocs business. I f you have questions
> Never interfere in contracts
you need to do your job with integrity and expects you to about fair competition practices, contact your Senior Leader.
between a prospective customer
observe ethical business practices everywhere Amdocs
and an Amdocs competitor
operates in the world.
> Don’t engage in industrial
espionage or offer bribes Good Corporate Citizens What is “industrial espionage?”
> Don’t say disrespectful or S omeone who is involved in industrial espionage is
untruthful things about Amdocs’ Amdocs recognizes that our company has a responsibility using illegal means to try to obtain information about a
competitors’ products or services to respect individuals, the environment and the global company’s plans, products, clients or trade secrets.
> Never take unfair advantage of community in developing its corporate strategies. Amdocs’
anyone through manipulation, Corporate R esponsibility R eport describes our company’s
concealment, abuse of privileged commitment and the steps it is taking to measure
information or misrepresentation our company’s economic, environmental and social
of facts. performance. Do your part to support these initiatives.
Amdocs is a Fair and Honest Competitor
Our company competes against other companies based
only on the merits of our products and services and
our ability to support our clients. We depend on you to
be truthful in all customer interactions and accurately
represent Amdocs’ product and service quality, features
and availability.
Code of Ethics | 25

Respect for the Marketplace

Insider Trading What happens if someone trades on


Did You Know?
Never Trade on Inside Information Inside Information?
Passing on I nside I nformation to
any other person is generally illegal. As an employee of Amdocs, you may not use inside Think about all of the sensitive information about our
information for personal gain or “ tip” others about the company and other companies that you see and work with
What You Might Be information. “ I nside I nformation” – which is also referred every day. I f someone uses this information or shares it
Concerned About: to as “ material non-public information” is any information with individuals outside the company to buy or sell stock,
Violating Insider Trading Laws. about Amdocs, its customers, suppliers or other companies it could potentially affect the market value of those stocks.
I f you are ever unsure about what that is not known to the public, but if known, could
information is considered “ inside influence someone to buy, sell or hold stock in a company. Amdocs has a detailed I nsider Trading Policy to help you
information” or how it should be No inside information should be considered “ public” until determine what’s appropriate and what’s not. I f you have
handled, contact your Senior Leader. a formal external announcement is made either through a any questions about Inside Information, talk to your Senior
press release or through a document filed with the SEC.
Leader or your Human Resources representative. If you
What is the U.S. Securities and believe someone may have improperly shared Inside
What You Need to Do: Exchange Commission (SEC)? information with others, contact the Chief Financial Officer.
> K now Amdocs’ I nsider Trading
Policy The S E C is a U.S . government agency that is responsible
for enforcing U.S . federal securities laws. I have information about the release
> B e familiar with Amdocs’ of a new mobile technology by one
Corporate R esponsibility R eport of Amdocs’ vendors that has not yet been
> Compete fairly and honestly for What kinds of information may be
considered Inside Information? announced. Is it okay to buy stock in that
business—always be truthful
and accurate.
company?
“ I nside I nformation” includes information about new
> R eport any suspected acts of products or services, financial information (such as No, this would violate the law and our policies because
fraud or dishonesty. pricing, budgets and revenues) , earnings, proposed the trading would be on the basis of inside information.
> Never buy or sell stock ( or tip mergers or acquisitions, the gain or loss of a major I n addition, it may also present a conflict of interest as
off others to do so) based on customer or supplier, organizational changes, anticipated Amdocs prohibits employees from investing in an Amdocs
“ inside information.” layoffs, and any other material non public information. vendor under many circumstances.
Code of Ethics | 26

Code of Ethics
and Business Conduct

Asking Questions and Voicing Concerns


Questions or concerns about Amdocs’ Code of E thics and
B usiness Conduct may be brought to:
> Your Senior Leader
> Your Human R esources representative
> The Compliance Officer
> The Amdocs E thics Hotline

Waivers of the Amdocs’ Code


R emember, you can feel comfortable coming forward.
Any employee, other than an executive officer, requesting an exception to
Amdocs strictly prohibits retaliation against anyone who the Code must first contact his or her Senior Leader. If the Senior Leader
speaks up to protect our company. agrees that an exception is appropriate, then the approval of the Group President
of Human Resources and the Compliance Officer must be obtained. Group
President of Human Resources is responsible for maintaining a complete record
of all exception requests and the handling of those requests.
Any executive officer or director who seeks an exception to the Code must
first contact the Compliance Officer . Waivers may only be granted by the
B oard of Directors and must be disclosed as required by law or regulation.

This Code is Not an Employment Agreement between


Amdocs and Any of its Employees
Your rights as an employee and Amdocs rights as an employer are
governed by the laws of the country of employment, the work rules at your
location and your individual written employment contract, if any. To the
extent that the terms of your employment are more specific than those
contained in this Code, the more specific terms shall govern.This Code shall
not modify the term of employment of any employee of Amdocs, including,
but not limited to, any employee employed at-will.

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