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Non-public, inside information about ANSYS must not be communicated without a legitimate business reason and express prior authorization by the Chief Financial Officer or the General Counsel of the Company. ANSYS strictly prohibits the unlawful manufacture, distribution, dispensation, possession or use of a controlled substance in the workplace. Accordingly, persons who make reports anonymously should endeavor to provide as much detail as is reasonably necessary to permit the Company to look into, investigate and evaluate the matter s set forth in the anonymous report. When transmitting information using ANSYS computer resources, we must always be mindful of the following: This list can change frequently due to world events and changes in U.

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I encourage you to look to this document for guidance to align your choices with our Company values, including contacting me at compliance ansys. Equal Opportunity It is the policy of ANSYS to hire well-qualified people to perform the many tasks necessary to provide high-quality products and services to our customers.

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ANSYS employees are responsible for protecting their assigned laptops from damage, loss and theft when they take their laptops from the office for use at home or while traveling. All of us must be vigilant in safeguarding our user IDs and passwords.

Receiving gifts, entertainment or other gratuities from people with it-l541 ANSYS does business is generally not it-dl541 because doing so may imply an obligation on the part it-wl41 the Company and, therefore, potentially pose a conflict of interest.

Prior to being executed by the Company, all contracts must be reviewed and approved by authorized Company management in accordance with the Contract Administration and Signature Authority Policy, the Signature Authority and Financial Approval Checklist and the Purchasing Procedures. Approved payments to public officials should be treated no differently. When you raise concerns, we have the opportunity to remediate issues before they become more serious.

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Employees are required not to disclose or distribute such confidential and proprietary information, except when disclosure is authorized by the Company or required by law or other regulations, and shall use such ut-wl541 solely for legitimate Company purposes.

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Price fixing involves any agreement among competitors that tends to raise, lower or stabilize prices or rig bids. While there may not be a legal it-wk541 compliance concern, you are making a recommendation on behalf of ANSYS.

Special care should be taken, however, to note that trade associations are essentially meetings with competitors, therefore, ANSYS employees should: Remember that, through these core values and the other standards of conduct set forth in this Code, the Company provides general guidance for resolving a variety of legal and ethical questions for employees, officers and directors.

Accordingly, persons ut-wl541 make reports anonymously should endeavor to provide as much detail as is reasonably necessary to permit the Company to look into, investigate and evaluate the matter s set forth in the anonymous report.

These values help us not only comply with regulatory, legal and ethical standards, they help ANSYS be and remain a great place to work. If you are aware of a workplace violence incident or a potential threat, you must immediately report such conduct or statement, either to your supervisor or manager, the Human Resources Department or the Legal Department, or to the ANSYS Ethics Line.

An investigation related to misconduct by someone on my team has just concluded.

Agents and Representatives The payment of anything of value to influence a public official may be illegal even if someone else makes the payment. Likewise, we must act diligently with respect to agents, representatives and others working on behalf of ANSYS in regards to their compliance with all anti-corruption laws. We are in the mids to f contract negotiations. ANSYS intends to provide equal employment opportunity to all types of jobs and at all levels of the workforce.

Thank you for taking the time to read our Code. Our organization was founded on the belief that integrity and ethical conduct are fundamental to our long-term success. xl

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Therefore, in addition to compliance with the Code and applicable laws, rules and regulations, all Company employees, officers and directors are expected to observe the highest standards of business and personal ethics in the discharge of their assigned duties and responsibilities. If you experience sexual or discriminatory harassment or if you believe a co-worker is experiencing such harassment, ih-wl541 have both it-wo541 right and a duty to report it promptly.

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Am I permitted to provide this recommendation? To ensure fairness and integrity in the financial markets, ANSYS employees should it-al541 trade in ANSYS securities or those of any other company on the basis of material, non-public information acquired through employment.

Adherence to these requirements is a condition of both initial and continuing employment. In the event the report is made anonymously, however, the Company may not have sufficient information, without knowing the identity of and talking to the reporting employee, to look into or otherwise investigate or evaluate the allegations.

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Those core values govern how we behave in a wide variety of frequently encountered circumstances. Export Compliance All of us have a responsibility to comply with global trade laws, including export controls, sanctions, customs and anti-boycott regulations. Accordingly, ANSYS employees should take care to refrain from entering into agreements with competitors including channel partners that fix prices or the terms of sale that will be charged to customers.

The Board of Directors or a committee thereof will periodically receive a report of all such alleged violations and the outcome of the inquiry or investigation thereof lt-wl541 shall have access to all reports prepared regarding alleged violations of x; Code.

We continually face the risk of intruders getting into our network to access sensitive information. Over the course of our careers, each of us will face lt-wl541 decisions or an ethical dilemma.