Contents Sustainable Impact Footprint Integrity and human rights Supply chain responsibility Operations Products and solutions Appendix Items reported to global Integrity When appropriate, representatives from our Risk assessment and audits Third-party management Legal, Controllership, and Human Resources HP conducts regular internal assessments of and due diligence at HP team or other compliance teams (including dedicated Employee Relations corruption-related risks across 100% of our functions in 2021 investigators from Human Resources) conduct HP performs ongoing risk-based due diligence local investigations. Escalated allegations are global operations, including detailed reviews of of third parties that support our business, percentage of total investigated by a dedicated global Integrity the company’s global policies and processes including channel partners, sales intermediaries, Total number of reported items in 2021: 123 investigations team. HP’s investigation process applicable to all business units and global suppliers, and lobbyists. We communicate HP’s continues to evolve, with improved resources functions worldwide. We also use internal data anti-corruption standards and requirements to 2021 and technology to perform investigation-related and Transparency International’s Corruption 100% of these third parties through contractual functions in-house and to respond promptly Perceptions Index (CPI) to identify high-risk terms and conditions as well as our Partner Code Human resources 30% regions and assess risks related to our business. of Conduct and Supplier Code of Conduct. HP to concerns. Additionally, our global case Anti-corruption* 5% management tool enables us to identify emerging The public sector data analytics tools and requires all partners and suppliers, respectively, Misuse of assets 17% trends in ethics violations and to assess where processes we adopted in 2019 have enhanced to comply with our Partner and Supplier Codes additional controls may be needed. HP’s ability to monitor and mitigate potential risk of Conduct. Fraud 15% from its public sector business. These tools are Theft 5% subject to regular review and improvement to HP has implemented and maintains a robust risk- Brand protection/channel 7% Anti-corruption enhance the quantity and quality of available data. based legal and regulatory due diligence program to detect, mitigate, and prevent third-party anti- Conflicts of interest 8% We also periodically retain outside experts to corruption compliance risks and violations. Inaccurate records 11% Corruption disrupts fair competition, and is assess our anti-corruption policies and programs. at odds with HP values. We do not tolerate We benchmark our approach against peer We determine risk levels based primarily on Competition 2% corrupt behavior of any kind, including bribery companies to identify best practices in areas completion of our due diligence questionnaire Total 100% and kickbacks. including operational procedures, employee by the third party (every three years, for existing education, and supplier and partner training partners and suppliers) as well as the country- * Includes allegations of commercial bribery, kickbacks, and Our Anti-Corruption Policy and compliance and monitoring. level CPI. Based on these items, HP decides Global Business Amenities Policy violations, as well as alleged program require our employees, partners, corruption related to foreign public officials. and suppliers to follow all applicable national whether to conduct an additional due diligence laws and regulations, including the U.S. Foreign Complementing these assessments, HP conducts investigation. If we determine that the risk Investigating concerns Corrupt Practices Act and the UK Bribery Act. regular audits focused on potential corruption cannot be mitigated, we apply consequences to Although HP is not certified to an anti-corruption risks in our operations. These audits include end- the relevant third party by removing access to Suspected violations of Integrity at HP damage management system, all of our operational to-end review and testing of compliance policies specific benefits and/or terminating any contract trust in our company. We take all alleged violations sites and subsidiaries are required to follow and processes. with HP. seriously, ensure responses are timely, and take HP’s Anti-Corruption Policy and are subject disciplinary or remedial actions when appropriate, Potential corruption risks are reviewed using HP HP requires third parties to complete due including coaching, written warnings, and, in serious to HP’s compliance program and procedures transactional data and third-party corruption diligence on a predetermined basis. In general, cases, termination. Serious violations may impact (or a comparable subsidiary-level policy and assessments. The Anti-Corruption team may then all channel partners must complete this process an employee’s Total Rewards package (subject to compliance program). take various actions to appropriately minimize or before beginning a contractual relationship with local labor laws and where legally permissible). eliminate identified risk. This can include termination HP and then undergo a renewal process at least of partner contracts or special handling measures. 22 2021 HP Sustainable Impact Report www.hp.com/sustainableimpact