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IntegrityWithoutCompromiseIntuits Codeof Conduct& Ethics
A message fromSasan GoodarziHello everyone.Integrity Without Compromise is a core value at Intuit and thefoundation for who we are and how we operate as a company.We believe in doing the right thing, even when no one’s watching—for our employees, customers and partners around the world.Change continues to happen all around us—both internally andexternally—with greater focus on integrated customer data,machine learning and artificial intelligence. These changes make itimperative that we do better in how we protect our information,our workplace and culture, and each other. This isn’t just aboutcompleting required training. This is about how we make decisionsand what we will and will not do. This means conducting ourselvesin a way that helps us earn and keep the trust of our employees,customers and partners. As we move at speed and accelerate thepace of our work, we ask every employee to embrace and live up toour value of integrity without compromise. It doesn’t matterwhether you’re a long-time senior leader or this is your first job outof college. Always do the right thing. Have the courage to speak upif you see something you disagree with. And no matter what, holdyourself and others accountable for acting with integrity every dayand in every thing we do. We all need to do our part in ensuringIntuit has a safe, ethical and inclusive work environment whereeveryone can make an impact, learn and grow, and feel connected.Thank you.Sasan GoodarziIntuit CEO1
INTUIT CODE OF CONDUCT & ETHICSIntuit is committed to fostering a safe,ethical and inclusive environment whereemployees can do the best work oftheir lives. We expect everyone at Intuitto act with integrity, follow the law andour policies, ask for help and re portconcerns. Because no document canever address every situation that maycome up, when our Code of Conduct& Ethics, our core values and policiesdon’t answer your question, ask for helpand use good judgment.Be open, honest and transparentin all you do for Intuit.2
INTUIT CODE OF CONDUCT & ETHICSOur ExpectationsAll employees and contingent workers must follow Intuit’s Codeof Conduct & Ethics and all government laws and regulations.If laws or regulations are not as strict as this Code of Conduct &Ethics and Intuit’s policies, follow this Code of Conduct & Ethicsand Intuit’s policies. You are accountable for your behavior atall times.If you are a people manager, we expect you to help your teamunderstand what it means to act with integrity and to report anyconcerns that are raised to you. Create an en vironment whereemployees and contingent workers feel comfortable askingquestions about what it means to do the right thing for Intuit andall our stakeholders (employees, customers, partners andshareholders). Encourage reporting through any channel andask your employees and contingent workers to be honest at alltimes. It is also your responsibility to respond to inappro priateand unethical behavior if you observe it.If you see something, you must say something and dosomething about it—even if it happens outside of yourimmediate team.3
INTUIT CODE OF CONDUCT & ETHICSWhere to go withquestions or for helpFor help with questions about this Code of Conduct & Ethicsor if you have questions about what the right thing to do isin a situation: Review our employee policies, which provide more detail andsupplement this Code of Conduct & Ethics, or the Code ofConduct & Ethics Frequently Asked Questions Talk to your manager or HR Connect Reach out to Intuit’s ethics team through Ask EthicsReport concerns to any of these resources: Your manager or higher-level leaders Your HR Business Partner Ask Ethics Your employer or the company that you are contracted with, ifyou are a contingent worker HR Connect The Intuit Integrity Line, which is an external, third-partyservice that supports anonymous reporting in most countries,24 hours a day, 365 days a yearIf you are asked to help with an investigation or asked a questionabout an ethics issue, we expect you to cooperate and givecomplete, accurate information.We do not retaliateIntuit does not tolerate retaliation or victimization against anyonewho raises an ethics question or concern in good faith. We wantemployees and contingent workers to raise concerns throughwhatever reporting channel they are most comfortable using.4Review Intuit’s equalemployment opportunity andprohibition of harassmentpolicies for more information.
INTUIT CODE OF CONDUCT & ETHICSTable of ContentsWe foster a safe, ethical and inclusive environment.We value diversity and inclusion 7We expect employees to help prevent harassment 7The safety and security of our workforce comes first 8We avoid actual or potential conflicts of interest 8We follow the law and our policies.We prohibit insider trading, including trading by family and otherhousehold members 12We follow all antitrust and competition laws 13We comply with international trade laws 14We do not allow or support money laundering orterrorist financing 14We do not allow bribery or corruption 15We comply with laws related to political contributions, lobbying,and government contracts 16We protect customer and employee privacy, confidentialinformation and property 17We respect intellectual property and copyright laws 18We act with integrity.We speak honestly, transparently and respectfully in publiccommunications 20We always act with integrity in financial reporting and accountingpractices 215
We foster a safe,ethical and inclusiveenvironment.6
INTUIT CODE OF CONDUCT & ETHICSWe value diversityand inclusionAt Intuit, diversity and inclusion are part of our culture and who weare as a company. We believe that innovation thrives in anenvironment that includes a diverse range of people, perspectivesReview Intuit’s equalemployment opportunity policyfor more information.and experiences.Intuit provides equal employment opportunities for all genders,ethnicities and other protected categories. All employees mustfollow our equal employment opportunity (non-discrimination)policies. We also provide employees with resources to ask for andreceive reasonable workplace accommodations for disabilitiesand religious beliefs.Always share different perspectives and points of view in acourteous and respectful way. Remember that not everyone mayshare your point of view.We expectemployees to helpprevent harassmentWe expect all of our employees to act professionally, to use goodjudgment and to treat each other with respect. We prohibitunwelcome and unwanted sexual or other related inappropriateconduct that could create an intimidating, hostile or offensive workenvironment for employees. We also prohibit such conduct whenit is based on other protected characteristics like race andethnicity, national origin, age, disability sexual orientation andgender identity.7Review Intuit’s prohibitionof harassment policy formore information.
INTUIT CODE OF CONDUCT & ETHICSThe safety and securityof our workforcecomes firstNever put your own safety or the safety of others at risk. Intuit doesnot tolerate violence or threats of violence. In addition, if you areengaging in company business or are attending a company eventwhere alcohol is served, we expect you to always drink responsiblyor choose not to consume alcohol.We avoid actualor potential conflictsof interestWe never want anyone at Intuit to be in a situation where they mightput, or appear to put, personal financial interests or anothercompany’s interests over Intuit’s interests. To avoid conflicts, do not: Participate in a decision on behalf of Intuit that could leadto or appear to provide a financial or other personal benefitto you, your family, close friends or someone you are in apersonal relationship with. Use Intuit confidential information or intellectual propertyfor your personal benefit or the benefit of another person orcompany. Take business opportunities that you learn about in your workwithout first disclosing those opportunities to Intuit. Accept a speaking fee or honorarium for events that arepart of your work. You may decline or ask to have the fee orhonorarium donated to a charity.8Review Intuit’s workplaceviolence and drug and alcoholpolicies for more information.
INTUIT CODE OF CONDUCT & ETHICSYou must also disclose the following situations to Ask Ethics forreview and approval because they may create a conflict of interest: Joining the board of directors or an advisory board of a forprofit company or, if you are new to Intuit, continuing on anyfor-profit boards. Working for, holding a position with, serving as an advisor for,or receiving any financial reward from another company: (a)with whom Intuit has a current or anticipated relationship, (b)which competes with Intuit’s current or reasonably anticipatedfuture business strategy or (c) that is developing technologythat potentially overlaps with Intuit’s current or reasonablyanticipated use of similar technology. Making any investments that might influence or appear toinfluence decisions you may make on Intuit’s behalf, includinginvestments in a company with whom Intuit has a currentor anticipated relationship or which competes with Intuit’scurrent or reasonably anticipated future business strategy.This restriction excludes ownership of stocks, bonds or othersecurities of companies listed on a public securities exchange,if the amount of the interest is less than 1% of the value of theclass of such securities. It also excludes investments in mutualfunds, venture capital or similar funds that invest in a broadcross-section of companies and industries that may includeIntuit competitors, partners or vendors, as long as you areonly a passive investor.9If you are involved in any othersituation that could present aperceived or actual conflict ofinterest, contact Ask Ethicsfor guidance.
INTUIT CODE OF CONDUCT & ETHICSAs a general rule, membership on boards of nonprofitorganizations or industry associations do not create a conflict ofinterest. However, always disclose nonprofit memberships to yourmanager. If you and your manager believe there is a potentialconflict between Intuit’s interests and the nonprofit, contactAsk Ethics.Gifts and entertainment: You and your family members may notaccept gifts or participate in any entertainment if they appear tointerfere with your ability to make objective business decisions.Gifts and entertainment must be: Given openly and directly, without an expectation of anythingin return Unsolicited Not in the form of cash or a cash equivalent (for example,a gift or cash card) Less than Intuit’s commercial gift and entertainment limits Not a regular occurrence Not accepted as part of or during a business negotiation and In compliance with all laws and the policies of both the giverand the recipient.10If you are involved in any othersituation that could present aperceived or actual conflict ofinterest, contact Ask Ethicsfor guidance.
We followthe law andour policies.11
INTUIT CODE OF CONDUCT & ETHICSWe prohibit insidertrading, includingtrading by family andother householdmembersTrading in Intuit’s stock—or the stock of vendors or partners—basedon material nonpublic information violates U.S. and other countries’laws and Intuit policy. “Material nonpublic information” meansinformation not publicly announced by Intuit that a reasonableinvestor would consider important in deciding whether to buy orsell shares of stock. You cannot trade outside any trading windowsset by Intuit management either by personally making trades orby arranging to have trades made by others on your behalf. Thismeans that when the window is closed, you cannot purchase or sellany Intuit stock in public markets, and you cannot sell Intuit sharesacquired through the Employee Stock Purchase Plan (ESPP), thevesting of RSUs or the exercise of stock options. (Acquiring sharesthrough the ESPP, stock option exercises, or RSU vesting are notprohibited when the window is closed, but you cannot sell any ofthose shares.) And even if we are in an open trading window, youcannot trade if you have material, nonpublic information.12Review Intuit’s insider tradingpolicy for more information.If you have questions aboutthe materiality of specific typesof information, talk with yourmanager or consult withAsk Ethics.
INTUIT CODE OF CONDUCT & ETHICSWe follow all antitrustand competition lawsWe promote a free and open marketplace for the products andservices we sell and the goods, services and talent we acquire.Never take action that could unreasonably restrain trade in afree marketplace. For example, never agree with an actual orprospective competitor to: Raise, fix or set the price to be charged or paid for a productor service. Divide markets, territories or customers or limit dealings. Forexample, Intuit would not agree with a competitor to not sellin a certain region. Set uniform terms of sales, warranties or contract provisions. Pre-determine the winning bid or limit competition with otherpotential bidders.When interacting with competitors: Always act in an independent manner. Do not obtain or share commercially sensitive informationwith competitors (for example, information about pricing,contract terms or profit margins). Do not share sensitive information about your formeremployer or ask an employee for information about a formeremployer if that former employer is a competitor. Always obtain market information from legitimate sources,such as publications, public studies, articles or newspapers.Finally, never make statements in emails, texts, social media,presentations or anywhere else that wrongly suggest we have fewcompetitors, that we want to harm our competitors or that we wantto improperly exploit our success.13
INTUIT CODE OF CONDUCT & ETHICSWe comply withinternational trade lawsWe follow all laws, rules and regulations about importing andexporting products and services and restrictions on trade orinteractions with certain countries, individuals or entities. If youhave questions on international trade, contact Ask Ethicsfor guidance.We do not allowor support moneylaundering orterrorist financingMoney laundering involves hiding financial assets acquired throughillegal activity or using legitimate funds to support criminal activity.Terrorist financing includes financing terrorists, terrorist acts andterrorist organizations and may involve both legal and illegalproceeds from legitimate or illegitimate sources. We do not allowor support money laundering or terrorist financing.14
INTUIT CODE OF CONDUCT & ETHICSWe do not allow briberyor corruptionBribery is never allowed. A bribe is a payment, gift or an offer toprovide anything of value, including meals, entertainment andtravel, to improperly influence someone in their official or profess ional capacity or to induce someone to use their influenceimproperly. Never encourage anyone to act illegally to help Intuit.It is not just unlawful for Intuit or our subsidiaries to directly offer abribe. It is also unlawful for our partners or agents to offer a bribe.Intuit requires strict compliance with the U.S. Foreign CorruptPractices Act (FCPA), as well as similar laws in other countries.Anyone who intends to provide a gift, hospitality, payment orentertainment of any value to a government official must firstreview and comply with Intuit policy and, where required, submitrequests to Ask Ethics for prior approval. Remember that under theFCPA, “government officials” can include not only officials andemployees of the government or government agencies, but alsoemployees of government-owned or controlled corporations orentities, candidates for political office and members of politicalparties, as well as anyone acting with or on behalf of any of thesepersons, including family members.15Review Intuit’s anti-corruptionpolicy for more information.
INTUIT CODE OF CONDUCT & ETHICSWe comply with lawsrelated to politicalcontributions, lobbying,and governmentcontractsInteracting with governments is complex. In addition to lawsgoverning gifts and hospitality to government officials, there aremany laws restricting political contributions. Intuit CorporateAffairs must review and approve all political contributions madeon behalf of the company. You may send suggestions for politicalcontributions, inside or outside the United States, to Ask Ethics.If you make personal political contributions, make sure you neverlink your contribution to, or represent that it is from, Intuit. Personalpolitical contributions will not be reimbursed by the company.You may not attempt to influence politicians or public officials onparticular laws or issues on Intuit’s behalf, or appear to representIntuit in political lobbying activities unless you are asked to do soby Corporate Affairs. If you meet with a politician/policy influenceron personal time, you may mention Intuit, your role, publicinformation, and our values. However, you may not discuss Intuitpolicy positions unless briefed in advance by Corporate Affairs. Ifsomeone wants to talk about a policy issue and Intuit, gather theirinformation and tell them our Corporate Affairs team will follow up.Then refer that request to Ask Ethics.Contracts with government agencies are subject to additionalrules and regulations. They also require additional coordination toensure there is no conflict of interest.16Before setting up any contractwith the government, contactAsk Ethics to work with ourLegal and Corporate Affairsteams to ensure we fullyunderstand and can commit tothe special government rulesand regulations.
INTUIT CODE OF CONDUCT & ETHICSWe protect customerand employee privacy,confidential informationand propertyIntuit has a commitment to employees, customers, partners andshareholders to act as a responsible steward of data and personalinformation.To help us meet that commitment, you must: Follow all corporate privacy policies, security policies andsupporting standards. Act responsibly when collecting, using and protecting (and,when required, deleting) personal data and information thatemployees, customers or other third parties give to Intuit.This information includes names, emails, home addresses,national identification numbers, benefits information andfinancial information. Make sure Intuit has a contract or nondisclosure agreementin place with any third parties before sharing confidentialinformation or trade secrets. Treat confidential information from third parties with thesame care that you treat Intuit’s confidential information andtrade secrets.17Review Intuit’s privacy policyfor more information.
INTUIT CODE OF CONDUCT & ETHICSWe respectintellectual propertyand copyright lawsWe only use copyrighted materials with appropriate rights andlicenses. You must confirm that Intuit has the right to internally usecopyrighted music, images, news and content or other intellectualproperty that belongs to a third party before using it. Do not makecopies, share, lend, resell or transfer software to other employees,contingent workers or to anyone outside of Intuit unless allowed bythe software license agreement.18
We actwith integrity.19
INTUIT CODE OF CONDUCT & ETHICSWe speak honestly,transparently andrespectfully in publiccommunicationsAny external communications by Intuit employees or using Intuit’sname can impact Intuit’s brand and the trust that current andfuture employees, partners, shareholders have in the company. Itis therefore important that we communicate in the right way andstay coordinated with external messages, always striving to givefull, fair, accurate, timely and understandable disclosures in publiccommunications.We have designated spokespeople authorized to publiclydiscuss our strategy, financial information and other significantcorporate events. Refer all inquiries from the media, socialchannels, stockholders, industry, Wall Street or other financialanalysts to Corporate Communications or Investor R
Integrity Without Compromise is a core value at Intuit and the . service that supports anonymous reporting in most countries, 24 hours a day, 365 days a year . If you and your manager believe there is a potential conflict between
