Red Hat, Inc. Supplier Code of Conduct

1. Compliance with Laws & Regulations

Red Hat, Inc. suppliers shall comply with all laws, regulations and policies of the countries, states and localities in which they operate which are applicable to them and shall require their own suppliers to do the same. This includes, but is not limited to, Small Business rules and regulations, Affirmative Action and Equal Employment Opportunity rules and regulations, general labor and employment rules and regulations, and the rules regarding suspension and debarment of companies from doing business with the United States Government.

2. Gifts and Gratuities

No supplier or its representatives or employees shall offer to any Red Hat employee a kickback, favor, gratuity, gift, entertainment or anything of value to obtain favorable treatment from Red Hat. Red Hat employees and their immediate family are similarly prohibited from soliciting such items. As long as the gift is not intended to obtain favorable treatment for the supplier and does not create the appearance of a bribe, kickback, payoff or irregular type of payment, Red Hat employees are not prohibited from accepting gifts or entertainment if: (a) it does not exceed a value of more than $100, (b) public disclosure would not embarrass Red Hat, Inc., (c) acceptance is consistent with Red Hat, Inc's business practices and policies, and (d) it does not violate any applicable law. Red Hat, Inc. employees are prohibited from engaging in insider trading.

3. Conflicts of Interest

No supplier shall enter into a financial or any other relationship with a Red Hat, Inc. employee that creates a conflict of interest for Red Hat, Inc. Suppliers and/or their representatives shall not deal directly with any Red Hat employee whose spouse, domestic partner, other family member or relative holds a significant financial interest in the Supplier. All such conflicts must be disclosed, corrected or approved by Red Hat management.

4. Trade Practices

Suppliers shall not engage in collusive bidding, price fixing, price discrimination, or other unfair trade practices in violation of federal or state antitrust laws. Suppliers shall comply with all applicable trade control and export control laws, and should not directly or indirectly engage in or support any terrorist activity.

5. Labor Practices

Suppliers are expected to adopt fair labor practices and treat their workers in accordance with local laws and regulations in all of their operations worldwide, including but not limited to:

• Ensuring no forced, bonded or involuntary labor and ensuring that its overall terms of employment are voluntary.

• Compliance with local minimum working age laws and requirements, and not employing child labor.

• Providing wages and benefits that meet or exceed applicable legal requirements.

• Not requiring workers to work more than the maximum hours of daily labor set by local, applicable laws.

• Prohibiting physical abuse, harassment or the threat of either.

• Prohibiting legal discrimination in employment practices based on race, color, religion, gender, age, physical disability, national origin, sexual orientation, union membership or political affiliation.

• Respecting the rights of workers to organize in labor unions in accordance with local labor laws and established practices.

• Provide a safe and healthy working environment for their workers in accordance with applicable laws and regulations.

6. Compliance with Red Hat Contracts

Red Hat Suppliers will supply products and services that conform in all respects with the requirements of their contract with Red Hat, including in particular, all applicable quality requirements.

7. Record Keeping and Reporting

Suppliers shall honestly and accurately report all business information and comply with all applicable laws regarding their completion and accuracy. Suppliers are expected to create, retain and dispose of business records in full compliance with all applicable and legal regulatory requirements. Red Hat expects suppliers to protect its confidential information, which shall include but not be limited to, personal data, financial information or trade secrets when supplier has access to such information.

8. Compliance and Reporting of Violations

It is the responsibility of the Red Hat Supplier to ensure that its representatives understand and comply with this Supplier Code of Conduct. If you wish to report a questionable behavior or possible violation of the Supplier Code of Conduct anonymously, please contact the Red Hat, Inc. Corporate Grievance Hotline at 800-224-9902. Suppliers are expected to monitor their own compliance with this Supplier Code of Conduct. In addition to the other rights that Red Hat may have under its contract with Supplier, Red Hat may request the immediate removal of any Supplier representative who behaves in a manner that is unlawful or inconsistent with this Code or any Red Hat policy.