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Applicability of This CodeEmployeesThe Oracle Code applies to all personnelemployed by or engaged to provideservices to Oracle, including, but notlimited to, Oracle’s employees, officers,temporary employees, workers(including agency workers), casual staff,and independent contractors (for easeof reference throughout this Code,“employees”).Oracle Senior Officers andNon Employee Members of the OracleCorporation Board of DirectorsOracle’s senior officers (Chief ExecutiveOfficer, President(s), Chief OperatingOfficer, Chief Financial Officer, ChiefAccounting Officer, General Counsel,each Executive Vice President, and eachSenior Vice President) are subject to boththis Code and Oracle’s SupplementalConflict of Interest Policy for SeniorOfficers, which among other thingscontains certain supplemental proceduralmeasures designed to identify andaddress potential conflicts of interestinvolving senior officers. Non employeedirectors are also subject to this Code intheir capacity as members of the OracleCorporation Board of Directors (the“Oracle Board”), except that they aresubject to the conflict of interest provi sions of Oracle’s Corporate GovernanceGuidelines in lieu of the conflict ofinterest provisions contained in thisCode. The Supplemental Conflict ofInterest Policy for Senior Officers and theCorporate Governance Guidelines are2posted on the Corporate Governancesection of Oracle’s Investor RelationsWeb site. Senior officers and membersof the Oracle Board who have questionsregarding this Code or other relevantpolicies should contact Oracle’s GeneralCounsel.Any waiver of this Code for any execu tive officer of Oracle Corporation ormember of the Oracle Board must beapproved by the Oracle Board. Suchwaivers, and the reasons for suchwaivers, shall be promptly disclosedto Oracle’s stockholders.CommunicationCOMPLIANCEOracle employees share informationeffectively with each other. We balancethe need to share information alongsidethe need for confidentiality regardingcertain information.Compliance with Laws,Regulations, and OraclePoliciesInnovationOracle employees seek innovative andcreative approaches to problem solving.Customer SatisfactionOracle employees consistently treatcustomer satisfaction as a top priority.A Summary of Oracle ValuesQualityCertain core values comprise the foun dation of our company. The followingare essential to Oracle‘s business:Oracle employees make excellenceand quality a part of day to day workprocesses and seek continuousimprovement in all that they do.IntegrityFairnessOracle employees demonstrate honestyand sound ethical behavior in all busi ness transactions and personal integrityin all dealings with others.Oracle employees commit to dealingfairly with customers, suppliers, part ners, and one another.Mutual RespectOracle employees consistently treatindividuals with respect and dignity.We must each operate within the boundsof all laws, regulations, and internalpolicies applicable to Oracle‘s business,wherever we conduct it. Where locallaws are less restrictive than this Code,you must comply with the Code, even ifyour conduct would otherwise be legal.On the other hand, if local laws aremore restrictive than the Code, you mustalways, at a minimum, comply withthose laws.Oracle expects its employees to: Act ethically and with integrity in allbusiness dealings; Comply with the law, this Code, Oraclepolicies, and Oracle business practices; Report known or potential violationsusing available reporting channels;Compliance Cooperate with complianceinvestigations; andOracle employees comply with all laws,regulations, and Oracle policies thatgovern Oracle‘s business and employees‘actions on behalf of the company. Complete all mandatory complianceeducation courses and otherCompliance and Ethics Programrequirements in a timely manner.EthicsFurther, Oracle expects its managers to:Oracle employees observe the standardsthat have been established by Oracle andact ethically in their approach to businessdecisions. Promote and support ethical behaviorand business practices that complywith this Code;TeamworkOracle employees work together as ateam for the collective interests ofOracle. Ensure that employees who report tothem directly or indirectly understandwhere and how to report violations ofthis Code; Ensure that employees who report tothem directly or indirectly complete allmandatory compliance educationcourses and other Compliance andEthics Program requirements in atimely manner; Maintain an “open door” policy withregard to employee questions,including those of business conductand ethics, and ensure availability ofcompliance and ethics resources andsupport, such as printed materialsand relevant contact information; Encourage employees to challengeand report questionable conduct; and Encourage open, honest, andconfidential dialogue withoutretaliation.From time to time, we may revise thisCode. If and when this happens, Oraclewill notify you. You will then be responsi ble for becoming familiar with suchrevisions. For the most current version,always refer to the online Code, locatedon the Compliance and Ethics ProgramWeb site. If you have questions on howto interpret or comply with this Code,Oracle policies, or applicable law,contact the Oracle Compliance andEthics Program or Oracle LegalDepartment. Act as a leadership model for thisCode;3

Where to Go for Help Oversees internal complianceinvestigations;The Oracle Complianceand Ethics Program Promotes consistency in theapplication of disciplinary action;The Oracle Compliance and EthicsProgram, with the support of Oracle’sExecutive Management and Board ofDirectors, aims to ensure that all Oracleemployees, business partners, andsuppliers adhere to high ethicalbusiness standards. Provides quarterly updates to theFinance and Audit Committee ofOracle‘s Board of Directors regardinginvestigations and disciplinary actiontaken; andWith general oversight from the GeneralCounsel, the Compliance and EthicsProgram is led globally by the ChiefCompliance & Ethics Officer. RegionalCompliance & Ethics Officers manageday to day operations of the Complianceand Ethics Program, including Code ofConduct investigations, and apply theCompliance and Ethics Program’sinitiatives at the regional level.A major objective of the Complianceand Ethics Program is the enforcementof the Oracle Code of Ethics andBusiness Conduct and related policies.We work closely with other lines ofbusiness and outside advisors, asappropriate.The Oracle Compliance and EthicsProgram: Provides support to help employeescomply with the Oracle Code of Ethicsand Business Conduct; Seeks to prevent and detect unlawfulor unethical business conduct; Manages the administration ofmandatory compliance educationtraining courses;4 Provides the entire Board of Directorswith a full briefing on the Complianceand Ethics Program at a minimumannually.Please visit the Oracle Compliance andEthics Program Web site, which canbe found through the Oracle LegalDepartment Web site, to becomefamiliar with our policies, trainingrequirements, and periodic updates.We count on each of you to set the righttone and lead by example.Reporting Code ViolationsOracle fully commits to maintaining highstandards of ethical and professionalconduct for the company and itsemployees. To do so, we providemultiple resources for reporting,investigating, and resolving allegationsof employee misconduct as well asfor determining and enforcing relateddisciplinary action. Report any conductthat you reasonably believe may be aviolation of this Code and other activitiesthat could affect Oracle’s or its employ ees’ compliance with legal and ethicalobligations. If at any time you have evena suspicion that Oracle’s obligationsrelating to financial integrity, auditingand accounting, insider trading,anti corruption policies, or politicalcontributions have been compromised,you are expected to immediatelyreport it.Oracle will not tolerate retaliation againstany employee who reports a concernin good faith or cooperates with acompliance investigation even whenallegations are found to beunsubstantiated.You have multiple options for reportingallegations of misconduct. Depending onthe circumstances, these include: Your manager; Human Resources; Your Regional Compliance & EthicsOfficer; The Chief Compliance & Ethics Officer; Your employee representative (whereapplicable); The Oracle Compliance and EthicsHelpline: and The Oracle Compliance and EthicsIncident Reporting Web site.Regional Compliance & Ethics Officersand other Compliance and EthicsProgram contacts are listed on theOracle Compliance and Ethics ProgramWeb site.Q: My manager asked me to dosomething that I think violates this Code.Should I do it anyway?A: No. First, make sure that yourmanager knows you are concerned andthat there is not a misunderstanding.If that doesn‘t resolve the problem, youshould seek advice from your next levelmanager or your Regional Compliance& Ethics Officer. The wrong answer isto do nothing or to simply follow yourmanager‘s request. Disciplinary actionwill be taken against any employeewho is found to have participated in,condoned, or concealed an actual orpotential violation of the Code, even ifhe or she did not directly initiate it.The Oracle Compliance and EthicsHelpline and Incident ReportingWeb siteIf you feel uncomfortable reporting a con cern to your manager, Human Resources,or a member of the Compliance andEthics Program, or if you feel that yourconcern has not been addressed prop erly, you also may report allegationsanytime via telephone, using the OracleCompliance and Ethics Helpline, oronline, through the Oracle Complianceand Ethics Incident Reporting Web site.Both the Helpline and the IncidentReporting Web site are confidentialresources available to all Oracle employ ees worldwide to raise concerns or seekguidance regarding issues of ethics andbusiness conduct and violations of ourCode. The Oracle Compliance and EthicsIncident Reporting Web site is accessiblethrough the Compliance and EthicsProgram Web site.To submit a telephone report, dial theHelpline at 800 679 7417. To submit areport regarding a facility or employeebased in the European Union, dial the EUHelpline at 866 455 1215. When callingeither number, callers from outsidethe United States should first dial theircountry’s access number and, whenprompted, enter the appropriate Helplinetelephone number. You may find yourcountry‘s access code athttp://www.usa.att.com/traveler/index.jsp.The Helpline is toll free for all employeesand is available 24 hours a day, sevendays a week. The Helpline providesinterpreters for callers who want tocommunicate in languages other thanEnglish, and the Incident Reporting Website is available in multiple languages.The Helpline does not record or tracecalls, and the Incident Reporting Website does not use any identity trackingtechnology.You may remain anonymous wherepermitted by local law, whether you callthe Helpline or use the Incident ReportingWeb site. Certain jurisdictions limit topicsthat may be reported anonymouslythrough the Helpline or IncidentReporting Web site. Oracle’s processesincorporate any local limitations, and theHelpline and Incident Reporting Web sitealert employees from affected countriesif special reporting rules apply to them.When you report incidents through theHelpline, an operator will ask questionsto better detail your concerns and thenwill document the call. Web site reportsare forwarded directly to Oracle withoutreview or modification. In either case,you will receive a report number, whichyou can use later to add details or tocheck the status of your report.5

The Helpline is operated by a third partyservice provider in the United States,and reports to the Helpline and IncidentReporting Web site are provided to theOracle Compliance and Ethics Programfor investigation and processing. Allreports are handled in accordance withOracle’s Internal Privacy Policy, which isavailable on the Oracle Legal DepartmentWeb site.Business PracticesAntitrust and Competition LawsTypically, the countries in which Oracleoperates have laws and regulationsthat prohibit unlawful restraint of trade,usually referred to as antitrust orcompetition laws. These laws aredesigned to protect consumers andcompetitors against unfair businesspractices and to promote and protecthealthy competition. Oracle commitsrigorously to observing applicableantitrust or competition laws of allcountries or organizations.Q: At a trade association meeting, youoverhear an informal group of Oraclecompetitors discussing future productpricing. May you join the conversationto gain some excellent competitiveintelligence?A: No. Oracle is only interested incompeting honestly and fairly.6You must avoid all discussions and theexchange of information with competi tors involving topics such as pricing,supplier or customer relationships, ormarket allocation, because they are, infact, illegal. Disassociate yourself fromany such discussions immediately andreport the incident to the Oracle LegalDepartment.Antitrust or competition laws vary fromcountry to country but, generally, suchlaws prohibit agreements or actions thatreduce competition without benefitingconsumers. Among those activitiesgenerally found to violate antitrust orcompetition laws are agreements andunderstandings among competitors to: Fix or control prices; Structure or orchestrate bids todirect a contract to a certaincompetitor or reseller (bid rigging); Boycott specified suppliers orcustomers; Divide or allocate markets orcustomers; or Limit the production or saleof products or product lines foranti competitive purposes.Agreements of the type listed above areagainst public policy and are againstOracle policy. Employees must neverengage in discussions of such matterswith representatives of other companies.You should report to the Oracle LegalDepartment any instance in which othercompanies initiate such discussions.Contracts or other arrangements thatinvolve exclusive dealing, tie in sales,price discrimination, and other terms ofsale may be unlawful under applicableantitrust or competition laws. You shouldnot enter into such arrangementswithout the approval of the Oracle LegalDepartment.Oracle strives to ensure that its globalpractices comply with United Statesantitrust laws. In addition to local laws,antitrust laws of the United States mayapply to our international businessoperations and transactions. Thisincludes imports to and exports fromthe United States.Unfair methods of competition anddeceptive practices are also prohibited.Examples of these include: Making false or misleadingrepresentations about Oracle‘sproducts; Falsely disparaging a competitor orits products; Making product claims without facts tosubstantiate them; and Using another company‘s trademarksin a way that confuses the customer asto the source of a product.Because of the complexity of antitrustand competition laws, seek advice fromthe Oracle Legal Department on anyrelated question.No Improper PaymentsYou are prohibited from receiving,offering, promising, authorizing, direct ing, or making any bribes, kickbacks, orpayments of money or anything of valueto improperly obtain business or anyother advantage for Oracle or yourself.The above prohibition applies whethersuch payments go to: Government or public internationalorganization employees or officials;Q: An Oracle partner offers me apercentage of the partner’s margin inexchange for encouraging a majorcustomer to purchase the partner’sservices and products. Can I acceptsuch a payment?A: No. This is a kickback, which isprohibited by Oracle’s Code of Conductand Anti Corruption Policy. Boththe Code of Conduct and Oracle’sAnti Corruption Policy apply to dealingswith both public and private entities. Political parties or candidates forpolitical office;No Economic Boycotts Business entities partially or whollyowned by government interests;Oracle does not participate in anyeconomic boycott not sanctioned by theUnited States government. Oracle andits employees are prohibited fromdiscriminating against or refusing to dobusiness with a country that is the objectof an unsanctioned boycott, nationals ofthe boycotted country, or “blacklisted”companies. Privately held commercial companies; Oracle employees; or Any other third party.Oracle strictly prohibits giving money oranything of value directly or indirectlyto a government official for the purposeof corruptly influencing a foreign govern ment. This prohibition includes corruptlygiving money or anything of value toany third party where there is reason tobelieve that it will be passed on to agovernment employee or official. Referto the “Dealing with Government”section for more information regardinggovernment entities.For more information, refer to Oracle’sAnti Corruption Policy, located on theCompliance and Ethics Program Website.Additionally, Oracle and its employeesmay not furnish information concerningOracle’s, or any other person’s, businessrelationships with a boycotted countryor blacklisted company. If requested tosupply any information, take any action,or refrain from taking any action tofurther or support a boycott of a country,immediately contact the Oracle LegalDepartment. For further information onidentifying and handling boycottrequests, please refer to Oracle’s ForeignEconomic Boycott Policy, which is7

available on the Oracle Compliance andEthics Program Web site. This policy isintended to ensure that we comply withforeign economic boycott laws of theUnited States. Address questions orrequests for information regarding theForeign Economic Boycott Policy orantiboycott laws to the Oracle LegalDepartment.Q: Oracle received an order from acompany in a country that has imposeda government sponsored economicboycott not sanctioned by the U.S.government. The customer's purchaseorder states that the supplier (in thiscase Oracle) agrees not to conductbusiness with a blacklisted company orcountry. May the order be accepted?A: No. Accepting this order may subjectOracle to criminal and tax sanctions.It is Oracle‘s policy to comply withantiboycott provisions of U.S. law.The division receiving this requestshould immediately seek Oracle LegalDepartment and Oracle Corporate TaxDepartment advice on how to proceed.Export LawsUnited States Export Control Lawsgovern all exports of commodities andtechnical data from the United States,including: Physical items; Items that are hand carried as samplesor demonstration units in luggage;8 Electronic or physical distribution ofsoftware and source code; and Written, electronic, or oral disclosureof technical data to a foreign visitor orH1 B Visa worker.Failure to comply with U.S. exportcontrol laws could result in the loss orrestriction of Oracle‘s export privileges,which, in turn, could damage or evendestroy a significant portion of ourbusiness. Violation of these laws mayalso result in fines and imprisonment forindividual employees and their manage ment chain. You are responsible forunderstanding how the export controllaws apply to your job and for conform ing to these laws.Q: I understand that there arerestrictions on the export of certainstrategic goods and technical dataunless an appropriate export license isobtained. Are there any such restrictionson disclosing technical information toforeign nationals visiting Oracle in theU.S.? After all, the information isn’treally crossing any border.A: Yes. Any oral or written disclosure oftechnical data to a foreign visitor mustcomply with the same export controlrestrictions that apply to the physicalexport of such data.You may not ship Oracle software,documentation, source code, technicaldata, nor technology without processingthe order and shipment throughauthorized Oracle order entry,distribution, and support processesand/or through authorized Oraclesubsidiary channels.Compliance with export control laws isessential to our continued ability to dobusiness in the international marketplace.United States and foreign governmentsmaintain strict rules regarding themethodology for goods exchangedacross their borders. Local export lawsmay also apply to shipments to or fromthe country in which you operate. Falseor misleading statements made onexport documentation could jeopardizeOracle‘s global operations and lead toaudits and fines, which would damageour ab

of all laws, regulations, and internal policies applicable to Oracle's business, wherever we conduct it. Where local laws are less restrictive than this Code, you must comply with the Code, even if your conduct would otherwise be legal. On the other hand, if local laws are more restrictive than the Code, you must always, at a minimum, comply with