TIBCO Service Provider Code of Business Conduct and Ethics Policy

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to you that the misuse of sensitive information is contrary to TIBCO policy and U.S.
securities laws.
4.2. Prohibition Against Short Selling of Company Stock
No Service Provider may, directly or indirectly, sell any equity security, including
derivatives, of the TIBCO if he or she (i) does not own the security sold, or (ii) if he or she
owns the security, does not deliver it against such sale (a "short sale against the box")
within twenty (20) days thereafter, or does not within five (5) days after such sale deposit
it in the mails or other usual channels of transportation. No Service Provider may engage
in short sales. A short sale, as defined in this Policy, means any transaction whereby one
may benefit from a decline in TIBCO's stock price. While Service Providers who are not
executive officers or directors are not prohibited by law from engaging in short sales of
Company's securities, TIBCO has adopted as its policy that employees and Service
Providers, similarly, may not engage in such short sales .
5. Communications with Analysts
It is very important to TIBCO that all communications with analysts comply with applicable
laws and that they are consistent and in accordance with executive level management.
Therefore, the only employees authorized to discuss TIBCO matters with analysts are the
TIBCO CEO, CFO, Senior EVP, Worldwide Marketing and the VP, Investor Relations
(together “Spokespersons”). In the event a Service Provider is contacted by an analyst,
Service Provider must refer the analyst to a Spokesperson.
6. Equal Opportunity, Non-Discrimination and Anti-
Harassment
As a private employer subject to the United States Equal Opportunity Employment
Commission and other employment laws as applicable, TIBCO is committed to providing
a work environment that is free of discrimination and harassment and practices equal
opportunity with respect to all activities concerning its employees. In keeping with this
commitment, Service Provider is required to prohibit harassment of any kind (verbal,
physical, visual or sexual) or discrimination, including harassment or discrimination on the
basis of race, religious creed, color, national origin, ancestry, physical disability, and
mental disability, medical condition including genetic characteristics, marital status, sex,
age, sexual orientation, veteran status, or any other characteristics protected by law in
accordance with TIBCO policies.
Under no circumstance shall Service Provider retaliate against any of its employees for
reporting any incidents of harassment or perceived harassment, discrimination or for
participating in any investigation of incidents of discrimination or harassment or perceived
harassment.
Disclaimer: The Policy is subject to change at TIBCO’s discretion without notice at anytime. ©2008 TIBCO Software Inc. All
Rights Reserved.
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