WIXLIB

INVESTIGATING ANDRESOLVING ISSUESNO RETALIATIONINTRODUCTION 13When necessary, Lenovo will investigate issues raisedby employees or others. All employees, contractors andconsultants are required to cooperate fully with investigationsand audits conducted by Lenovo or governmentalauthorities. This means providing information, Lenovoissued equipment such as computers or smartphones,documents and personal interviews. Failure to cooperate,including misleading, lying, destroying or altering documentsor records, or failing to respond promptly to requestsfor information by investigators or auditors is groundsfor disciplinary action up to and including terminationof employment. Lenovo may report misconduct to theappropriate authorities. Consult the ECO or the LegalDepartment before responding to non-routine requests foraudits, investigations or information from parties outsideof Lenovo.Lenovo does not tolerate retaliation against any employee,consultant or contractor for reporting an issue or raising aconcern he or she believes to be true, cooperating with aninvestigation or audit, or refusing to participate in activitiesthat violate the Code, laws or company policies. Thispolicy protects anyone who makes a report in good faith,even if he or she is found to be mistaken. Anyone whoengages in retaliation will be subject to disciplinary action,including termination of employment. If you believe you wereretaliated against, immediately report the matter to the ECO.» Q. What are some examples ofretaliation?A: Retaliation can take many forms including: Demotions Undesirable assignments Inappropriate performance ratings Termination of employment Verbal harassment Intimidation Threats» Q. I raised a compliance concernabout my manager to my localHR Partner. My manager has nowstarted raising issues with myperformance that he never raisedbefore. What should I do?A: Let HR or the ECO know about yourconcerns, even if you aren’t sure. Your concernwill be investigated and if you are being retaliatedagainst, action will be taken to protect you.

FAIR TREATMENTOUR EMPLOYEESWe believe in treating each other with respect and dignity. We judge allapplicants and employees by their qualifications, demonstrated skills andachievements without regard to race, color, religion, gender, gender identityor expression, national origin, ethnicity, sexual orientation, sex, age, disability,veteran status, marital status or any other characteristic protected by locallaw. When necessary, Lenovo will provide reasonable accommodations foremployees with disabilities or those with special religious requirements.All employees help to create a positive work environment by adhering tothese standards.DIVERSITYWe are proud to actively promote diversity in our workforce and theworkforces of those with whom we do business. We respect andvalue individuals for their diverse backgrounds, experiences, styles,approaches and ideas. We rely upon diversity to inspire innovationthat drives our business, enhance our competitive advantage andserve consumers across the world.COMMITMENT TODIVERSE BUSINESSRELATIONSHIPSPOLICYOUR EMPLOYEES 14

HARASSMENT-FREEWORKPLACELenovo will not tolerate discrimination or harassment of any individualwith whom we have a business, service or professional relationship.This includes discrimination or harassment based on race, color,religion, gender, gender identity or expression, national origin,ethnicity, sexual orientation, sex, age, disability, veteran status, maritalstatus or any other characteristic protected by local law. We do nottolerate unwelcome verbal or physical conduct of a sexual nature.When a co-worker’s conduct makes us uncomfortable, we speak out.If we experience or observe workplace harassment, we should reportthe incident to our manager, any other member of management,HR or the ECO. Lenovo takes harassment claims seriously and willinvestigate them thoroughly. Employees who engage in harassment,discrimination or inappropriate behavior are subject to disciplinaryaction, including termination of employment.COMMITMENT TODIVERSITY ANDNON-DISCRIMINATIONPOLICYOUR EMPLOYEES 15Harassment can be physical, verbal or visualconduct that creates an intimidating, offensive,abusive or hostile environment.Harassment can take many forms. Someexamples of harassing behaviors include: Unwanted requests for datesDisplaying or sharing offensive orpornographic pictures or imagesUnwanted touchingOffensive or inappropriate language,comments or jokesLenovo managers are required by Lenovoand in some cases, by local law, to report anyharassment as soon as they become aware of thesituation to Human Resources or to the ECO sothe issue can be appropriately investigated.

HEALTH, SAFETY &SECURITY OF EMPLOYEESALCOHOL &SUBSTANCE ABUSEWe are committed to providing a safe and healthy workenvironment and preventing accidents. We must observe thesafety and health rules and practices that apply to our job andprotect ourselves and our coworkers, including immediatelyreporting accidents, injuries and unsafe conditions.Lenovo expects employees to report to work able to perform theirduties and free from the influence of alcohol, illegal drugs or theabuse of prescribed or over-the-counter drugs. Using, possessing,buying, or selling illegal drugs or abusing controlled substanceswhile on the job, on Lenovo premises, operating Lenovo property(including company vehicles) or engaging in Lenovo businessis prohibited and is grounds for disciplinary action, includingtermination of employment. Check the policies that apply to yourlocation for additional guidance.A safe and secure work environment also means a workplace freefrom violence. With the exception of Lenovo security personnel andlaw enforcement, Lenovo prohibits the possession, concealment oruse of any firearm or other weapon on Lenovo premises (includingparking lots and other outside spaces) or in any location outsidethe home when conducting Lenovo business. Report any violence,intimidation or threats of violence as soon as possible to LenovoSecurity or the Legal Department.RESPONSIBILITY FOREMPLOYEE HEALTHAND SAFETY POLICYWORKPLACEVIOLENCEPOLICYOUR EMPLOYEES 16

OUR INVESTORSCONFLICTS OF INTERESTWe should avoid situations that may involve a conflict, or evenan appearance of a conflict, between our personal interests andLenovo’s legitimate business interests. Immediately disclose anysituation that may be or could appear to be, a conflict of interestto your manager and the ECO or Legal Department and removeyourself from any related decisionmaking process.When faced with a potential conflict of interest, ask yourself: Does this benefit (or could it be perceived to benefit)me, my family or another business, in conflict withLenovo’s legitimate business interests?Would this activity, if publicized, harm my reputation, my abilityto do my job or embarrass Lenovo?THE FOLLOWING ARE SOME EXAMPLESCONFLICTSOF INTERESTPOLICYOUR INVESTORS 17

EXAMPLES OF CONFLICTS OF INTEREST: OUR INVESTORS 18Having an employment, contracting or consulting relationshipwith a Lenovo competitor, supplier or customerHolding a substantial financial interest in a Lenovo competitor,supplier or customerPerforming non-Lenovo work or soliciting non-Lenovo businesswhile working on Lenovo timeUsing Lenovo assets, including equipment, telephones, materialsor proprietary information for unauthorized personal use oroutside workAccepting any cash, gifts, entertainment or benefits that havemore than a nominal value from any competitor, supplier orcustomer of LenovoUsing opportunities discovered through Lenovo employment forpersonal gain at the expense of LenovoHiring, managing or supervising a relative or romantic partnerAwarding Lenovo business to a relative’s business

OUTSIDEEMPLOYMENT» Q. I took a second job working asan independent contractor fora company that sells variousproducts. Before taking the job, Ireceived approval from my Lenovomanager. I recently learned that thecompany will start manufacturingcomponents which may be sold toLenovo or to its competitors. Do Ineed to disclose this to my Lenovomanager as well?A: Yes. Even though you did the right thing initiallyby obtaining approval for the outside employment,the circumstances have changed and nowpresent a potential conflict of interest. You shouldconsult your manager or the ECO.OUR INVESTORS 19Any outside business activity must be strictly separate fromemployment at Lenovo, not compete with Lenovo’s interests, andshould not harm your job performance at Lenovo. We must followlocal Lenovo policies on taking outside employment or participating inoutside business ventures. We may not work for or receive paymentfor services from any third party who interacts with Lenovo, includingLenovo’s suppliers, customers, competitors or regulators without priorwritten approval from management. We may not use Lenovo assetsfor any outside business activity without prior written approval frommanagement.BOARDMEMBERSHIPSServing on a board of directors or similar body for an outsidebusiness, organization (including trade industry associations andstandard-setting boards) or government agency, can also createa conflict of interest and requires advance review by the ECO andapproval from Lenovo’s management at the level of Vice Presidentor higher. Serving as a director of a publicly traded company orany company that is a supplier to or customer of Lenovo requiresthe approval of the CEO and General Counsel of Lenovo. Lenovoencourages our employees to be active in their communities and,where appropriate, assume leadership positions in community ornon-profit organizations, provided this service does not create aconflict between their duties to Lenovo and their duties to the outsideorganization.

FAMILY MEMBERS &CLOSE PERSONALRELATIONSHIPSIf our family members, romantic partners or people with whom weare in close personal relationships are or may become involved inbusiness activity related to Lenovo, including acting as a Lenovosupplier, customer or vendor, we should immediately disclose thenature of the relationship to management and HR and must removeourselves from any related decision-making process. If we superviseor are in a position to exercise influence over any aspect of theperformance, compensation or advancement of a family member,romantic partner or someone with whom we have a close personalrelationship, we must report this relationship to a Human ResourcesVice President at Lenovo.INAPPROPRIATERELATIONSHIPSPOLICYOUR INVESTORS 20» Q. My brother’s wife runs a companythat provides cleaning services.Can I be involved in hiring hercompany to work for Lenovo?A: No. It creates a conflict of interest betweenyour desire to help your brother’s wife and yourobjectivity in selecting the best company. Youshould disclose your relationship and removeyourself from the selection process. The cleaningcompany may then compete for Lenovo’sbusiness with other qualified vendors.

» Q. I would like to make a smallinvestment in Dell stock.Any problems?A: No. Small investments in public companiesthat compete with Lenovo are fine as long asyou are not basing your decision on confidentialinformation learned through your position atLenovo. If you have questions about whether yourinvestment could cause a conflict, contact theECO for guidance.» Q. I’d like to make an investment in myfriend’s company that competeswith Lenovo. The investment willgive me 25% of the equity in thebusiness and the ability to influencehow the business operates. Anyproblems with this?A: Yes, there is a problem. This businesscompetes with Lenovo and your investment in itis likely to cause, or appear to cause, you to actin ways that support your friend’s company, whichwould be harmful to Lenovo’s interests.OUR INVESTORS 21PERSONAL INVESTMENTSOur personal financial investments must not influence, or appearto influence, our independent judgment on behalf of Lenovo. Whendetermining whether a personal investment creates a conflict ofinterest, consider the relationship between the business of theoutside company, Lenovo’s business and what you do at Lenovo.Consider whether the company has a business relationshipwith Lenovo that you can influence and the extent to which thecompany competes with Lenovo.If there is any doubt about how an investment might be perceived,disclose it as soon as possible to your manager, the ECO or theLegal Department for guidance.We are also prohibited from directly or indirectly buying, orotherwise acquiring rights to any property or materials, whenwe know that Lenovo may be interested in pursuing suchan opportunity.

CONNECTEDTRANSACTIONS PROCESSWe must comply with Lenovo’s Worldwide ConnectedTransactions Process. Before contracting or transacting withany external entity or individual (including vendors, suppliers orcustomers) we must check to determine if the individual or entityis included on Lenovo’s List of Connected Persons. If an entity orindividual is on the list, you must immediately report the transactionto Lenovo’s Company Secretary Office before committing orentering into the contract or agreement.LENOVO WORLDWIDECONNECTED TRANSACTIONSPROCESSOUR INVESTORS 22

ACCURACY OFBUSINESS RECORDSInvestors count on Lenovo to provide shareholders with accurate,timely and understandable information about the company’sfinancial condition. We rely on every employee to ensure that allbooks, records and accounts conform both to required accountingprinciples and to Lenovo’s system of internal controls. We mustnever conceal or falsify any Lenovo business records.All business records and communications should be clear, truthfuland accurate. Our communications must avoid exaggeration,guesswork and insulting remarks or characterizations of peopleand companies. We should not include judgments about the law orany potential legal liability in our communications unless we havebeen authorized to do so by the Legal Department.Business records must be retained and destroyed according toLenovo’s record retention policy unless directed differently by theLegal Department.Contact your manager, Internal Audit, the ECO, or the LegalDepartment or make a confidential report through the LenovoLine,immediately, if you suspect that: Any Lenovo book, record or account has been falsified orimproperly altered or destroyed orImproper or illegal action has been taken related toaccounting or financial reportingOUR INVESTORS 23» Q. You tried hard to close a big salebefore the end of the quarter.Unfortunately, the customer was onvacation and did not accept or signthe contract until after the quarterhad ended. Your manager wantsyour team to meet its numbers andasked you to date the paperworkback to last quarter. Should youdo this?A: Definitely not. It is improper to record falsesales or false dates. Dates, costs and revenuesmust be recorded accurately in the proper timeperiod. If a sale is not yet final, it should not berecorded as final.Did you know?Business records include financial books,records, accounts, receipts, expense reports,texts, emails, notes, time cards and quality,safety and personnel records. They may eveninclude your posts on social media.

» Q. Does Lenovo’s Insider TradingPolicy apply to buying or sellingstock in other companies?A: Yes. For example, let’s say you learn duringdiscussions about a new hardware purchasethat a customer plans a major expansion. If youpurchase stock in the customer’s company,share this information with a friend or tell thefriend to buy stock in the company, it could beinsider trading.INSIDER INFORMATION& SECURITIES TRADINGIn the course of our employment with Lenovo, we may learn nonpublic information (also called “inside information”) about Lenovo orother companies, including our customers, suppliers or businesspartners. In some cases, if this confidential information becamepublic, it could affect the price of Lenovo’s or another company’sstock. The use or sharing of such non-public information aboutLenovo or another company for your or another’s benefit is called“insider trading.”All Lenovo employees are prohibited from engaging in insidertrading, even if you will not financially benefit from the informationbeing shared. Engaging in insider trading can hurt Lenovo andLenovo’s shareholders and may also subject you to civil andcriminal penalties.CONTINUOUSDISCLOSURE POLICYPRACTICAL GUIDANCEON THE OPERATIONOF THE CONTINUOUSDISCLOSURE POLICYTRADING INSECURITIES POLICYOUR INVESTORS 24

AUTHORITY TO MAKELENOVO COMMITMENTSLenovo’s management system, contracting processes anddelegations of authority are designed to provide the appropriatecontrols needed for Lenovo to run our business effectively, complywith laws and protect Lenovo from waste, fraud and abuse.We must keep to the limits of our authority to act on behalf ofLenovo and must not take any action to exceed or avoid thoselimits. These delegations of authority set out the rules for whichorganizations and line management have authority to approvepricing and certain other contract terms and conditions.You are not allowed to make oral or written business commitmentsoutside of these processes, such as side deals. In addition, allcommitments must be visible to Lenovo Accounting to ensure theaccuracy of Lenovo’s books and records.DELEGATION OFAUTHORITYPOLICYOUR INVESTORS 25» Q. Can I split purchase orders in orderto avoid delegation of authoritylimits or speed up the approvalprocess if I’m just trying to help theCompany operate faster?A: No. We must accurately record each of ourbusiness transactions. No Lenovo entry should bemade to conceal or disguise the true nature of atransaction regardless of your reasoning.

PROTECTINGCOMPANY ASSETSWe have a responsibility to protect any Lenovo asset entrustedto us from loss, damage, misuse or theft. Examples of companyassets include: Physical assets like our products, facilities, equipment,computers and communications systemsFinancial assets such as funds, credit cards or bank accountsLenovo’s intellectual property including our trademarks,copyrights and patentsLenovo proprietary information such as trade secrets, “knowhow,” prototypes, internal and external communications,digital information, hard copy documents, oral discussions andinteractions via social media channelsCustomer, consumer, supplier and employee personalinformationLenovo’s physical and information security policies protectour assets from theft, loss, damage or misuse. If there is theft, loss,damage or misuse of company assets, we are responsiblefor immediately reporting the occurrence to

OUR INVESTORS 17. Conflicts of Interest 17 Outside Employment 19 Board Memberships 19 . Anti-Corruption Laws & Bribery 36 Government Customers 37 Product & Quality Service 38 Representations Regarding Lenovo Products 38 . Teamwork with Integrity & Trust.