Business Ethics & Compliance

The Helpline is managed by Navex Global, a leading provider of customized helpline services, and is staffed 24 hours a day, 365 days a year. While primarily intended for current Western Digital employees, the helpline may be used by other interested parties, including vendors, customers and former employees.

To make a report via telephone, please use the following telephone numbers by country. Concerns are always confidential.

• Mainland China: 4008810209
  
• India: 000-800-100-1705
  
• Israel: 180-931-7189
  
• Japan: 0066-33-830444 (Softbank); or 00-539-111 (KDDI); or 0034-811-001 (NTT)
  
• Malaysia: 1-800-81-6497
  
• Philippines: Dial 105-11 or 1010-5511-00 (PLDT), then dial 855-216-6129 at the prompt
  
• Thailand: 001-800-11-0027437
  
• United States: 1-877-548-6716
  

All other countries/regions: Dial your country’s AT&T Direct Access Code from this list, then dial 877-548-6716 at the prompt. To make a report via the web, access the web-based Ethics Helpline reporting system at: www.EthicsHelplineWDC.com.

Employees are encouraged to report suspected instances of ethical misconduct within Western Digital, including:

• Trading on inside information or providing illegal tips
• Workplace harassment or discrimination
  
• Illegal gifts or bribes to or from government officials, vendors or customers
  
• Fraud, embezzlement or theft
  
• Questionable accounting or auditing matters
  
• Conflict mineral sourcing
  

The Ethics Helpline is intended to provide employees with another avenue for reporting suspected misconduct. Employees may use the Helpline if they believe that a problem cannot be addressed through their supervisors or the human resources staff, and employees may remain completely anonymous when they communicate with the Helpline’s operators. Western Digital will not allow any retaliation against an employee who contacts the Helpline and reports suspected misconduct in good faith.

Western Digital Corporation’s Global Code of Conduct provides information about the minimum standards of integrity that Western Digital Corporation expects all of its employees worldwide (including those of WDC’s subsidiaries) to follow and takes into account varying practices due to cultural differences in international locations. The standards set forth in the Global Code of Conduct are supported by more detailed Company policies and procedures, which are issued in various geographic regions to supplement or implement those standards. These policies and procedures provide clear, specific directions concerning many of the business practices and behaviors discussed in the Code.

A copy of the Global Code of Conduct in the appropriate language is given, or is available online, to all employees of Western Digital Corporation (including employees of domestic and foreign subsidiaries). In addition, new employees are given a copy of the Code of Conduct on their first day of employment. All employees are informed that they are expected to comply with the provisions of the Code of Conduct and that failure to do so is regarded as misconduct that can result in disciplinary action.

Each year, senior members of management and several hundred key designated employees worldwide are required to complete an online disclosure certification confirming that they have complied with the provisions of the Global Code of Conduct. This certification process is required by the Audit Committee and is managed by the Corporation’s General Counsel.

Western Digital’s Ethics & Compliance team conducts regular risk assessments, including both enterprise-wide risk assessments and subject-specific risk assessments in areas such as anti-corruption and privacy. Privacy risk assessments consider, among other things, Western Digital’s use of technology and its practices around user, partner, and employee data.

Western Digital Corporation believes it is essential that its employees and business partners comply with global anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and the anti-bribery laws of the countries in which the Company operates.

Western Digital prohibits any of its or its subsidiaries’ employees, consultants, agents or representatives from corruptly seeking to obtain or retain business by offering, paying or offering to pay money or provide other things of value to foreign or commercial officials for the purposes of:

• Influencing any act or decision of such official in his/her official capacity, or
  
• Inducing such official to do or omit to do any act in violation of his/her official duty, or
  
• Inducing such official to use his/her influence with a foreign government or instrumentality thereof to affect or influence a governmental act or decision, or
  
• Securing an improper advantage
  

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.