TIBCO Anti-Bribery Policy

TIBCO Software Inc. is committed to ensuring that its employees, agents, consultants and representatives understand and comply with the requirements of the United States Foreign Corrupt Practices Act (the “FCPA”), the United Kingdom’s Bribery Act of 2010 (the “UK Act”), and with all laws wherever TIBCO conducts business (collectively, “Applicable Law”). TIBCO policy prohibits employees and other persons acting on behalf of TIBCO from giving or receiving bribes in connection with or in order to further TIBCO’s business interests. The term “bribe” includes, but is not limited to, the giving or receiving of improper: monetary payments, contract awards, business advantages, gifts, reimbursements, personal favors or any other thing of value. It does not matter that an individual did not personally benefit from the bribe; facilitating a bribe for any reason is prohibited. Put simply, TIBCO expressly prohibits all forms of bribery by its officers, employees, agents, partners and any other representatives. In addition to violating Company policy, the giving or receiving of bribes is usually illegal, and may subject the Company to substantial fines, the loss of privileges such as importing and exporting, and other penalties such as debarment from government procurement. Allegations of bribery can also result in embarrassment and damage to the Company’s reputation. Under Applicable Law, bribery may also subject an employee to individual monetary liability and criminal prosecution, including imprisonment.