TIBCO Service Provider Code of Business Conduct and Ethics Policy

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Document Service Providers worldwide are required to comply with the U.S. Foreign Corrupt Practices Act and all applicable local anti-bribery laws and shall not participate in, or provide information that could be construed to further, any economic or other type of boycott not sanctioned by the United States government and applicable local laws. Laws in most countries outside of the United States also prohibit or restrict government officials or employees of government agencies from receiving payments, entertainment, or gifts for the purpose of winning or keeping business. No contract or agreement may be made with any business in which a government official or employee holds a significant interest, without the prior written approval of TIBCO General Counsel. 11. Antitrust and Competition Many countries have laws and regulations, usually referred to as antitrust or competition laws, that prohibit unlawful restraint of trade and generally, prohibit agreements or actions that unreasonably restrain trade, are deceptive or misleading or unreasonably reduce competition with no beneficial effect to consumers. These laws are designed to protect consumers and competitors against unfair business practices and to promote and protect healthy competition. TIBCO Service Providers are required to strictly adhere to all such laws and regulations. 12. Export Controls/Anti-Boycott Legislation A number of countries maintain controls on the destinations to which products or software may be exported. Some of the strictest export controls are maintained by the United States against countries that the U.S. government considers unfriendly or as supporting international terrorism. The U.S. regulations are complex and apply both to exports from the United States and to exports of products from other countries, when those products contain components or technology of U.S. origin. Software created in the United States is subject to these regulations even if duplicated and packaged abroad. In some circumstances, an oral presentation containing technical data made to foreign nationals in the United States may constitute a controlled export. TIBCO Service Providers are required to strictly adhere to all applicable export controls. 13. Lobbying Service Providers worldwide whose work requires lobbying communication with any member or employee of a legislative body or with any government official or employee in the formulation of legislation must have prior written approval of such activity from TIBCO’s General Counsel. Activity covered by this policy includes meetings with legislators or members of their staffs or with senior executive branch officials. Preparation, research, and other background activities that are done in support of lobbying communication are also covered by this policy even if the communication ultimately is not made. Disclaimer: The Policy is subject to change at TIBCO’s discretion without notice at anytime. ©2008 TIBCO Software Inc. All Rights Reserved. 6
14. Government Contracts Document It is TIBCO's policy that Service Providers comply fully with all applicable laws and regulations that apply to government contracting. Service Provider’s providing services under government contracts must strictly adhere to all terms and conditions of such contracts and all local, state, federal, foreign or other applicable government laws and regulations which apply to such contracts. Service Providers are required to disclose if they have been declared ineligible for United States federal contracts because they have violated Executive Order 11246; Section 503 of the Rehabilitation Act of 1973, as amended 29 U.S.C. Sec. 793 ("Section 503"); and/or the affirmative action provisions of the Vietnam Era Veterans' Readjustment Assistance Act of 1974, as amended, 38 U.S.C. Sec. 4212 ("Section 4212"). 15. Supplier Diversity TIBCO welcomes supplier diversity in its Service Providers in order to create the greatest opportunity for development of the most innovative, highest quality and most costeffective business solutions for TIBCO. Diversity Classifications: Small Business Concern, Small Disadvantaged Business, Woman-Owned Small Business, Veteran-Owned Small Business, Disabled Veteran- Owned Small Business, HUBZone Small Business Concern, Minority Business Enterprise, Woman Business Enterprise and Historically Black College/University or Minority Educational Institution. For additional information about diversity classifications, visit the websites at U.S. Small Business Administration (http://www.sba.gov/), the National Minority Supplier Development Council (http://www.nmsdcus.org/) , the Women’s Business Enterprise National Council (http://www.wbenc.org/Default.aspx), or Supplier Diversity Europe (http://www.supplierdiversityeurope.eu/forum/). 16. Industrial Espionage It is TIBCO’s policy to lawfully compete in the marketplace. This commitment to fairness includes respecting the rights of our competitors and abiding by all applicable laws in the course of competing. TIBCO expects its competitors to respect TIBCO’s rights to compete lawfully in the marketplace, and TIBCO must respect the right of a competitor equally. Service Providers may not steal or unlawfully use the information, material, products, intellectual property, or proprietary or confidential information of anyone including suppliers, customers, business partners or competitors of TIBCO. Disclaimer: The Policy is subject to change at TIBCO’s discretion without notice at anytime. ©2008 TIBCO Software Inc. All Rights Reserved. 7
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TIBCO Service Provider Code of Business Conduct and Ethics Policy

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