Pegasystems Inc. Chief Compliance Officer, Confidential 1 Main Street Cambridge, MA 02142 Phone: 844-320-0006 Email: PegaCompliance@pega.com Compliance with antitrust and competition laws worldwide is essential. These laws generally prohibit “trade restrictions”, which refer to anti-competitive behaviour involving competitors, customers or suppliers in the market. These laws are complex. Certain types of anti-competitive behavior, such as restrictive agreements with competitors or agreements on minimum resale prices or price levels (e.g., discounts) for goods and services, are illegal under the antitrust laws of the United States and many other countries. We are committed to being vigilant in order to avoid even the appearance of illegal anti-competitive behaviour. It is expected that we will all commit to responsibly embodying these basic principles and the specific guidelines of this Code. We want our team to support each other and hold each other accountable for these principles. We do not tolerate any deviation from our Code. Contact your People Talent Advisor, the human resources team, or a senior company executive for advice if you don`t know how to comply with this code. At Pega, we are committed to extremely high ethical and legal standards of conduct. We strive to foster a culture where employees can work at the highest level, where they are empowered to make good ethical decisions and never have to compromise their personal integrity or the integrity of our company. We have adopted this Code of Conduct (the “Code”) in line with our Pega values and successes, which highlight the expectations we have of each other, the commitment we share with our customers and, most importantly, the role each of us plays in creating our culture, and emphasize the ethical and legal standards we expect from all Pega employees in their relationships.
with Pega. Colleagues, customers, partners, suppliers and other key stakeholders. This Code applies to all our interactions in various areas of our common professional life, including those of our officers, full-time and part-time employees, interns, anyone hired as independent consultants and members of the board of directors of Pega and its subsidiaries worldwide. We care about our own reputation as well as that of Pega. We are therefore committed to bringing any violation or alleged violation of this Code by any person to the attention of our responsible or chief compliance officer. If we have information about suspected improper accounting or auditing matters, we agree to bring such information to the attention of our Compliance Officer or any of the others listed on our “Procedures for Complaints or Concerns Relating to Accounting, Internal Audit, Audit and Other Matters” website on Pega`s public website. www.pega.com/about/company/leadership/governance/reporting-accountability-concerns are indicated. As with all topics, there is always an additional way to anonymously report such suspicious activity through this compliance hotline.
Pega believes in diversity and supports the freedom of our employees to exercise their right to personal political contributions within the limits of the law. Pega will not solicit or ask us to make or offset political contributions, and we will not attempt to obtain or facilitate such refunds. We pledge not to make any political contribution pending favourable treatment of the State at home and abroad. Our product information, business plans, trade secrets and other proprietary data are valuable assets. It is important that we protect this information and all the data we learn by doing business with our customers, suppliers and partners. Each employee is required to respect confidentiality agreements. We cannot comment on legal issues or disclose proprietary information, always remembering that the Internet is accessible to everyone. If we become aware of confidential information in the course of our business relationships, we will protect it as such and will ensure that it is not disclosed or disclosed, even after leaving Pega. We are a publicly traded company.
We understand and undertake never to trade or recommend securities of Pega or other companies with which we do business if we have important and non-public information about Pega or such other companies. Buying or selling a security in possession of important non-public information about the issuer of the security constitutes insider trading and is illegal. Non-public material information may include, for example, information about profits, significant profits or losses resulting from transactions, the conclusion or termination of a material contract, announcements of important products or major personnel changes. Securities laws and this Code prohibit insider trading, as well as the disclosure of important, non-public information to anyone who may use it to buy or sell securities, sometimes referred to as “tips.” When in doubt, it should be assumed that the information we receive as part of our obligations to Pega is material and not public. Due to the importance of legal requirements regarding the disclosure of certain information to our investors, we must ensure that any information about our business, financial condition or results of operations that is made available to the public is accurate and consistent. Therefore, as employees of Pega, we undertake not to discuss Pega`s internal matters with anyone outside of Pega unless it is clearly necessary in the performance of our duties. This prohibition applies in particular to requests concerning Pega from the media, securities analysts and investors. All responses to these requests can only be made by authorized persons. Only our CEOs, CFOs and Marketing Directors (and the people they specifically designate) are authorized to discuss information about Pega with the media, securities analysts and investors.
We understand and agree that if we receive requests from these sources, we will immediately refer them to one of these authorized spokespersons. Laws and customs vary around the world, but in carrying out our work, we must always maintain the integrity of Pega. When doing business in other countries, it is imperative that we be sensitive to foreign legal requirements and understand that the laws of one jurisdiction may apply to activities in another jurisdiction. For example, the U.S. government and the governments of other countries use economic sanctions and trade embargoes to promote various foreign policy and national security objectives. As employees of Pega, we comply with all laws, including export laws and regulations, as well as economic sanctions or trade embargoes, adopted by the United States or any other country whose laws are binding on Pega. On May 9, 2022, a jury awarded Appian more than $2 billion for the misappropriation of trade secrets by Pegasystems (Pega). On May 10, Pega responded to the decision with this 8K filing with the SEC. The verdict, by all calculations, is enormous. Since the decision, several law firms have announced legal action on behalf of Pega shareholders. Pega is challenging both the judgment and the amount of the award decisively and will take legal action. Based on interactions with Forrester customers, this judgment affects purchasing behavior.
Forrester isn`t able to weigh how this will play out in court, but there are still important considerations: Implementing a business process in a separate case type also allows you to reuse the case type as needed. For example, claims for auto and property insurance may include a claim for bodily injury. By implementing personal injury claims as a separate type of case, you can use the type of assault case for damage to motor vehicles and property. As Pega employees, we ARE Pega before all customers, partners and colleagues, which is why we are committed to always behaving appropriately and minimizing our alcohol consumption, if at all. We care about our own reputation as well as Pega`s reputation, and therefore we are committed to not doing business or representing Pega under the influence of alcohol and/or illegal drugs or intoxicants, including the inappropriate use of legal medications. This includes all business events, including after-work engagements or dinners with colleagues, clients or partners. “Usually, when the behavior is outrageous, jurors pay less attention to technical details,” Rowe said. “The case focuses on theft, and everyone neglects the technical part of whether everything was a trade secret and how much it was worth.” We seek business from government agencies solely on the basis of superior price, performance, reliability, delivery and customer service.