For years, Western Digital has operated under a GCOC that informs all employees of their legal and ethical obligations to the Company, its employees, customers, competitors and suppliers, taking into account varying practices due to cultural differences throughout the world. The standards set forth in the GCOC are supported by more detailed Company policies and procedures, which supplement or implement those standards. These policies and procedures provide clear, specific directions concerning many of the business practices and expectations discussed in the Code.

A copy of the GCOC in the local languages is provided, in hard copy and/or online, to all of our employees. All employees are informed that they are expected to comply with the GCOC and that failure to do so can result in discipline.

Each year, training on the GCOC is provided in English and local languages.  In addition, senior members of management and several hundred other key designated employees worldwide are required to complete an online questionnaire certifying that they have complied with the provisions of the GCOC. This certification process is required by the Audit Committee and is managed by the Chief Compliance Officer.

A copy of the Global Code of Conduct can be accessed by clicking here.

Western Digital’s Board of Directors has also adopted a Code of Business Ethics, the goals of which are to:

• Promote honest and ethical conduct, including the ethical handling of conflicts of interest;
• Promote full, fair, accurate, timely and understandable disclosure in Company reports;
• Promote compliance with applicable laws and governmental rules and regulations;
• Promote prompt internal reporting of violations of this Code;
• Ensure the protection of the Company’s legitimate business interests, including corporate opportunities, assets and confidential information; and
• Deter wrongdoing.

The Code of Business Ethics provides a framework for ethical business conduct and is not intended to establish rules governing every possible instance that could arise. The Code of Business Ethics sets forth general legal and ethical principles.  Directors, officers and employees must use good judgment and common sense in applying them, and in deciding when to seek guidance from others as to the appropriate course of conduct.

A copy of the Code of Business Ethics can be accessed by clicking here.

As part of its commitment to maintaining the highest standards of workplace integrity, Western Digital maintains a toll-free Ethics Helpline. The Helpline is managed by a third party provider, and is staffed 24 hours a day, 365 days a year. While primarily intended for current Western Digital employees, the helpline is available to third parties, including business partners and former employees.

Employees may report suspected instances of ethical misconduct within Western Digital, including but not limited to:

• Trading on inside information or providing illegal tips
• Workplace harassment or discrimination
• Illegal gifts or bribes
• Fraud, embezzlement or theft
• Questionable accounting or auditing matters

The Ethics Helpline is intended to provide employees with another avenue for reporting suspected misconduct. Employees may use the Helpline to report a concern or ask a question at any time. Western Digital prohibits retaliation against an employee who report suspected misconduct in good faith.

The Ethics Helpline can be accessed here.

Western Digital believes it is essential that its employees and business partners comply with applicable global anti-corruption laws.

Western Digital prohibits any of its or its subsidiaries’ employees, consultants, agents or representatives from paying or receiving bribes, and from authorizing the same. 

Western Digital has published a comprehensive policy relating to Anti-Corruption, which is published on the Company’s internal website. In addition, compliance with the provisions of global anti-corruption laws is discussed in both the Company’s Global Code of Conduct and Employee Handbook.