Standards & Ethical Principles

Policy Authority
Policy Owners	Compliance Officer Charles N. Bell Voice: INT+1(972)577-6758 PSC-Compliance@ps.net
Leadership Approval	Del Williams
Modify Date	June 6 , 2006

Applicable Audience
Geographic Regions	Global
Business Units	Perot Systems Corporation and its subsidiaries.
Associate Audience	All Perot Systems Associates.

I. Introduction

A. General

Perot Systems' success depends on the confidence and trust of the people with whom we do business. This document sets forth certain standards of conduct and key ethical principles that govern how we conduct our business. These "Standards & Ethical Principles" are supplemented by policies and procedures to address specific business and legal issues.

Our Standards & Ethical Principles are intended (1) to deter fraud and other wrongdoing and (2) to promote (a) compliance with applicable governmental laws, (b) prompt reporting of suspected and actual violations of these Standards & Ethical Principles or applicable law, (c) individual accountability, and (d) full, fair, accurate, timely and understandable disclosure in reports and documents filed with, or submitted to, government agencies, and in other public communications made by Perot Systems.

Associates who are assigned to customer accounts may be subject to the customer's code of conduct and related policies and procedures in addition to these Standards & Ethical Principles. If you work on a customer account and there is any conflict between these Standards & Ethical Principles and any laws, code of conduct, policy or procedure applicable to your job, you should comply with the most restrictive requirement.

If you have any questions about any of these Standards & Ethical Principles or have concerns about how they apply to a specific business situation, you should consult with your leader or a Compliance Delegate. In addition, you may request guidance by contacting Peter Altabef or Del Williams.

As used in this document: "Perot Systems" refers to Perot Systems Corporation and its subsidiaries, individually or collectively, as the context requires, and "business unit" refers to a corporation or other business entity, corporate department or account team, as the context requires. "Associate" refers to a director or officer of Perot Systems Corporation, a regular full-time, part-time, or temporary employee of Perot Systems, a substantially full-time consultant or contractor to Perot Systems, and any person representing the interests of Perot Systems, individually or collectively. The term "Associate" specifically includes Perot Systems Corporation's Chief Executive Officer, Chief Financial Officer, principal accounting officer and controller.

B. Our Values & Principles

Perot Systems expects Associates to conduct themselves in accordance with the core values of honesty, integrity and respect for people. Our Associates, communities, customers, stockholders and suppliers judge us by how we act, and the sum of these judgments is our reputation. We expect every Associate to recognize and avoid behavior and relationships that compromise our reputation.

A card containing the following values and principles should be delivered to every Associate when he or she joins Perot Systems. Our business culture is based upon these values and principles. Associates demonstrate their commitment to our Standards & Ethical Principles by adopting these values and practicing these principles.

1. Our Values.

We serve our customers—with innovative, responsive solutions to their needs.
We value our people—by attracting, developing and recognizing outstanding people and caring for them and their families.
We operate with integrity—by treating our customers, people, and suppliers in a fair and honest manner, as we would want to be treated.
We reward our stockholders—by producing strong financial performance from which everyone benefits.
We contribute to our community—by using our talents and resources to better the conditions in the diverse communities in which we work.

2. Our Principles.

Lead by example.
Conduct our personal and professional life in a manner that will bring credit to ourselves, our family, and our company at all times.
Operate in the center of the field of ethical behavior—never on the sidelines.
Create and maintain an atmosphere of mutual trust and respect.
Listen carefully to our customers and our team members who work directly with our customers, and be open to ideas.
Encourage every team member to take risks, exercise initiative, deliver quality results, and never be afraid to make honest mistakes.
Create a supportive environment that nurtures personal and professional growth.
Do what we say we're going to do—and more than is expected.
And finally, while we are building this great company—have fun!

II. Personal Responsibility

Our Standards & Ethical Principles apply to every interaction with Perot Systems' customers, suppliers, competitors and Associates. Associates are expected, as a condition of employment or engagement, to comply with the letter and spirit of these Standards & Ethical Principles, the policies and procedures relating to their duties, and the laws of every locality in which we do business. Perot Systems' directors, executive officers and other leaders must support our commitment to these Standards & Ethical Principles by:

Creating a work environment that trains Associates about, and promotes compliance with, these Standards & Ethical Principles;
Implementing control measures to detect, and take prompt action to correct, deviations from these Standards & Ethical Principles; and
Providing timely guidance to Associates on their ethics and compliance concerns.

Associates must act within the boundaries of acceptable business ethics and be able, in all business situations, to answer "Yes" to the question: "Would I do business in complete trust with a person who acts the way I do?" Associates must not intentionally mislead or misinform others about Perot Systems' or other's business activities, and promptly correct misunderstandings. If the proper action is not clear, Associates should consult their leader or another Associate with appropriate expertise before acting. Any Compliance Delegate can help you find an appropriate resource.

Associates have an obligation to prevent, detect and report fraud, misappropriation of corporate assets and other financial misconduct. Perot Systems leaders are further responsible for preventing and detecting fraud, misappropriations and other financial irregularities within the scope of their responsibilities. Associates should become familiar with the types of improprieties that might occur with their scope of responsibilities.

If you believe that unethical or illegal conduct has occurred, you must report it to your leader or a Compliance Delegate. Additional information about our Compliance Program is set forth in Section IV.

Perot Systems supports its commitment to honesty, integrity and respect to people by providing ethics and compliance training, including mandatory annual training on these Standards & Ethical Principles for all employees. Speak to your leader to learn more about this training.

These Standards & Ethical Principles are not an employment contract. They will change over time.

III. Key Standards of Conduct

A. Professional Work Environment

Perot Systems is proud of the spirit of cooperation and mutual respect that extends throughout our company. We are committed to a professional work environment:

where all individuals are treated with respect and dignity;
without harassing or abusive behavior based on race, color, sex, national origin, age, marital status, religion, disability, sexual orientation, or veteran status;
that provides opportunities for professional success and advancement equally, regardless of characteristics unrelated to their work skills and abilities; and
where Associates, without fear of personal or professional retaliation, request that inappropriate behavior cease and receive a prompt, appropriate response to their request.

1. Equal Employment Opportunity and Discrimination. Perot Systems desires a diverse workforce and a workplace free from unlawful discrimination of all kinds. Our Associates include citizens of many countries and diverse cultural groups. Associates should be sensitive to cultural differences when interacting with other Associates, customers and suppliers.

Perot Systems seeks to attract develop, retain and promote diverse talent to succeed in a diverse and ever-changing world. We will adopt lawful policies and practices in all aspects of employment, including recruiting, selection, hiring, evaluation, promotion, training, discipline, development, compensation and termination.

Perot Systems will provide equal opportunity to Associates consistent with their work skills and abilities and our business needs. Associates must make employment-related decisions without regard to the race, color, sex, national origin, age, marital status, religion, disability, sexual orientation, veteran status or other protected status of another person. We will not tolerate unlawful discrimination by our Associates. All company facilities made available for use by Associates will be provided on a lawful and nondiscriminatory basis.

Each business unit should seek to achieve and maintain a diverse workforce, and regularly appraise its performance in this area. Business units should also identify qualified small businesses and businesses owned by disadvantaged individuals capable of supplying the materials, equipment and services we need.

If you believe that you have been, or another individual has been, subjected to inappropriate discrimination, you must promptly notify your leader or a Compliance Delegate.

2. Harassment. Harassment takes many forms, but is considered by Perot Systems to be any behavior that is, or can reasonably be perceived as, offensive, obscene, insulting, threatening or unwelcome to a person or that unreasonably disrupts a person's work. Harassment includes crude, derogatory and insulting remarks or jokes directed at a person or his or her characteristics or beliefs.

One form of harassment is sexual harassment. The following situations, among others, may be considered sexual harassment:

a request for a date, sexual favor, or other verbal or physical conduct of a sexual nature that is unwelcome or made a condition of employment or used as a basis for employment decisions;
displaying, transmitting or openly discussing sexually explicit or other inappropriate pictures, subjects or materials; and
an intimidating, offensive, or hostile work environment is created by unwelcome sexual advances, insulting jokes, or other offensive verbal or physical behavior of a sexual nature.

Perot Systems leaders in some jurisdictions are required to complete training to prevent sexual harassment on a periodic basis. If you are a leader, contact your human resources representative to determine if this requirement applies to you.

Perot Systems will not tolerate harassment of any type including unlawful harassment (i.e., harassment based on race, color, sex, national origin, age, marital status, religion, disability, sexual orientation, veteran status, or other protected status). Associates must not harass others, submit to harassment by others, or remain silent while others are harassed by anyone (including supervisors, customers, or suppliers) while conducting Perot Systems business. Submitting to harassment (including, for example, a request for sexual favors) is never a term or condition of employment for any Associate.

If you believe that you have been, or another individual has been, subjected to harassment, you must promptly notify your leader or a Compliance Delegate.

3. Workplace Violence. Violence in our workplace will not be tolerated. Associates who commit or threaten to commit acts of violence at Perot Systems facilities or while conducting Perot Systems business are subject to disciplinary action, up to and including termination of employment or engagement. No Associate, customer, supplier or guest, except law enforcement officials and Perot Systems security personnel who have the appropriate permits, is allowed to carry a weapon, concealed or otherwise, into any Perot Systems' facility or onto our premises.

B. Confidential Information and Privacy

1. Perot Systems Information. Associates must use reasonable care to protect the confidentiality of information about Perot Systems that is not generally known to the public. "Confidential information" includes information about business activities and plans, customers, employees, finances and financial results, know-how, marketing, suppliers, and technologies. Associates must not disclose or use, or authorize the disclosure or use of, confidential information to third parties, except in the good faith performance of their duties for Perot Systems.

2. Customer and Supplier Information. Perot Systems' customers and suppliers entrust us with information about their business activities and plans, customers, employees, finances and financial results, know-how, marketing, suppliers, and technologies that is not generally known to the public. In addition, we are entrusted with private information about our customers' customers, such as financial, identification and health information.

ssociates must not disclose this information to anyone, or use this information for any purpose, except in the good faith performance of their duties in connection with Perot Systems' obligations to the applicable customer or supplier. Associates must become familiar and comply with the confidential information and privacy policies of the customers for whom they provide services.

3. Personal Information. Personal information about Perot Systems' Associates, their families and other individuals involving their health, compensation, religious and political beliefs, family relationships, and contact information is strictly confidential. Personal information about our customers' employees and their individual customers must also be treated as strictly confidential. Associates must comply with Perot Systems' Personal Data Privacy Policy and Healthcare Services Privacy Policy. Associates must also become familiar and comply with the confidential information and privacy policies of the customers for whom they provide services.

4. Insider Trading. While working for Perot Systems, you may learn confidential information about Perot Systems, its customers or suppliers, or other companies that a reasonable investor could consider important in deciding whether to buy, sell or hold the stock or other securities of a company (i.e., "material inside information"). Examples of material inside information include unannounced marketing plans, new product releases, financial data, changes in dividends, earnings or management, obtaining or terminating significant contracts, mergers or acquisitions, stock splits, decisions to enter into or terminate lines of business operations, and business strategies. However, every kind of information that is not available to the public, whether it is negative or positive, could be material inside information. It is illegal to buy or sell stock or other securities (including puts, calls or other options) in any company while possessing material inside information about that company, or to pass this information on to someone else who then buys or sells stock. Associates must comply with Perot Systems Insider Trading Policy and all applicable laws.

5. Physical and Information Security. The security and protection of confidential information depends upon every Associate's compliance with Perot Systems' and, where applicable, our customers' physical and information security policies and procedures. Associates should use strong passwords and must not share their passwords with other Associates or any third party to prevent unauthorized access to confidential information stored in electronic form.

C. Conflicts of Interest and Improper Influences

Associates must avoid situations in which their individual interests conflict with—or appear to conflict with—the interests of Perot Systems. Conflicts of interest arise where (1) an Associate has an interest in or a relationship with a party that has entered, or proposes to enter, into a transaction with Perot Systems, and (2) the Associate is in a position to make, influence, or benefit from decisions pertaining to the transaction.

In situations that may involve a conflict of interest or improper influence, you must excuse yourself from making any decisions about the matter at hand and fully disclose the relevant facts and circumstances to your leader or a Compliance Delegate. Some common conflict of interest situations are discussed below. Because a complete list of all situations in which a conflict of interest or an improper influence may arise is not possible, we must rely on the integrity and good judgment of our Associates to inform us about situations involving them that could be perceived by others to be inappropriate and to avoid, whenever possible, situations that present the possibility of conflicts of interest or improper influence.

1. Entertainment, Gifts and Gratuities. Associates must not accept entertainment, gifts or gratuities from, or offer entertainment, gifts or gratuities to, any person or entity doing or seeking to do business with Perot Systems, other than those permitted by this standard. This applies to current, former and prospective customers, contractors, joint venture and other "business" partners, suppliers, and contractors of all types. The terms "entertainment," "gifts" and "gratuities" have the broadest meanings possible, and include trips, services, and any other gratuitous item, event, benefit or thing of value. Additional rules apply to entertainment, gifts or gratuities offered, directly or indirectly, to any official or employee of any government agency, any member of their families or any related party.

You must not accept or offer a gift of cash, securities or any other cash equivalent (except for gift certificates described below), except for reasonable and customary gratuities (or "tips") paid to taxi drivers, waiters and other service industry personnel. As a general standard, you should not accept or offer gifts or entertainment that (1) you would be unable to reciprocate without the approval of your leader; (2) involve significant or "out of the ordinary" expense; (3) carry any business obligation whatsoever; or (4) present any potential embarrassment for you or Perot Systems. Subject to the general standard, you may accept or offer (except to officials and employees of government agencies, their families or any related party):

normal advertising giveaways of nominal value;
flowers, candies, fruits and other consumables of reasonable value;
gift certificates of reasonable value (e.g., the price of "dinner for two" at a local, modestly-priced restaurant);
prizes of reasonable value (i.e., winnings from lotteries, door prizes, raffles, contests and similar games of chance); and
social invitations that are reasonable and customary under the business circumstances for your level of responsibility in the company.

If you are in doubt as to whether you may offer or accept entertainment, a gift, or a gratuity, you should consult your leader or a Compliance Delegate.

2. Outside Activities. Associates who are regular, full-time employees of Perot Systems ("Full-time Associates") must not hold jobs with other employers or engage in outside businesses (including self-employment) or other activities that adversely impact their job performance or Perot Systems' business interests. Substantially full-time contractors (i.e., more than 800 hours of services provided during any six-month period) must not engage in activities that adversely impact their job performance or Perot Systems' business interests. Examples of typical adverse impacts include (i) an inability to work scheduled shifts or perform on-call duties, and (ii) possible misuse or contamination of intellectual property rights.

D. Fair Competition and Markets

Perot Systems believes in free markets in which the competitor offering the best product or service at the best price gets the business. Associates should deal fairly with Perot Systems' customers, suppliers, competitors and other Associates. Associates should not take unfair advantage of anyone through manipulation, concealment, abuse of confidential information, misrepresentation of material facts or any other unfair dealing practice.

The countries in which Perot Systems does business have laws—referred to as "anti-trust", "competition" and "restraint of trade" laws—that prohibit behavior and activities that restrain free markets. Perot Systems must not participate in, formally or informally, any practice that violates such laws. Examples of prohibited practices include: price fixing; bid rigging; market division; boycotts; and tying arrangements. Associates should consult with the Legal Department to determine how these complex laws may apply to a specific transaction.

Participation in trade associations and professional organizations, as well as informal contacts with Perot Systems' competitors, may serve useful and legitimate purposes – for example, the exchange of information about governmental regulations. If you meet with Perot Systems' competitors, you must not discuss Perot Systems' or any competitor's prices or other terms of sale, or costs, or any plans or marketing strategies that have not been disclosed to the public. If a competitor begins to talk about any of these matters, you must object, refuse to participate and contact the Legal Department as soon as possible.

1. Bribes and Kickbacks. Associates must not make or receive improper, illegal or secret payments of any kind to or from any person. Associates must not pay or allow someone else to pay, any bribe, payoff, gratuity or kickback to any government official or employee (including political parties and their employees) to influence him in carrying out his duties. Associates may not do anything to influence any government official or employee in an unethical or unlawful way. In countries where it is customary to give gifts to government officials or employees in a business context, you must obtain the prior written approval of the Compliance Officer or the Associate Compliance Officer before giving any such gifts.

2. Corrupt Practices. It is illegal for Perot Systems or its agents (i) to give anything of value to government officials or their family members to obtain or retain business, or (ii) to make unlawful political contributions to any political party or candidate for political office to obtain or retain business. Consulting agreements and contracts with companies owned by government officials or their relatives may violate this law. You must contact the Compliance Officer or the Associate Compliance Officer for advice before entering into such agreements.

E. Business Records

Accurate and complete records of our activities are essential to Perot Systems' and our customer's businesses. Records are created in many forms, including paper documents, magnetic or optical media, microfiche, instant messages, voice mail and e-mail (including server-, customer-, personal data assistant-, cell-phone and pager-based e-mail). These records preserve information about our businesses and our contractual and other legal obligations. All entries in Perot Systems' books and accounts and all records created in the course of Perot Systems' business, including all financial and customer records, must be timely, accurate, complete and understandable, and should fairly reflect our business activities. All financial transactions must conform to, and consistently apply, generally accepted accounting principles.

Associates must obtain the proper reviews and approvals before entering into agreements on Perot Systems' behalf. Unless otherwise approved, all agreements should be in writing. These reviews and approvals ensure that our agreements conform to applicable laws and are properly reflected in our books and records.

Associates must report, and remain vigilant to prevent and detect, suspected fraudulent activities within their business units. Examples of fraudulent activities include: (1) improper alteration or forgery of Perot Systems' business records; (2) misappropriation of funds, securities, supplies or other assets owned by or under the control of Perot Systems, including embezzlement, payroll fraud, external theft, procurement fraud, and unauthorized personal use of Perot Systems assets; (3) improper financial reporting, including improper revenue and expense recognition, overstatement of assets and understatement of liabilities, in connection with Perot Systems' financial statements or any department or project subcomponent thereof, including over-billing and improper avoidance of expenses; (4) improper expenditures, including commercial and public bribes and gratuities; and (5) financial misconduct by senior management. As part of this responsibility, department and project center leaders are responsible for reviewing, or supervising the review of, their financial statements to determine whether any unauthorized, unusual or other fraudulent transactions have occurred.

Associates should promptly report concerns about the ethics or legality of particular conduct involving Perot Systems to a Compliance Delegate. If you receive a record that characterizes conduct as unethical or illegal, you should send a copy of the record to the originator of the record and the Compliance Department with a notation that you are requesting a review of the applicable conduct.

Associates should regularly review records in their possession or under their control to determine whether they should be discarded in accordance with the applicable Records Retention Policy and their business unit's Records Retention Procedure. Records owned by a customer are subject to that customer's records retention policy. Associates must retain all documents and records that are (i) required to be retained under applicable law or (ii) related to an active or foreseeable audit, lawsuit or government inquiry. Records that are subject to a "Legal Hold" are listed on your business unit's intranet. If you are uncertain about the need to retain a particular record, please contact your leader, your business unit's Records Retention Coordinator or the Legal Department.

F. Perot Systems Facilities and Assets

Perot Systems must comply with all health, safety, and environmental laws. Associates must report all accidents and injuries that occur on Perot Systems premises or while conducting Perot Systems' business. If your job requires the use of hazardous materials, you must comply with all laws regarding the proper purchase, handling, storage and disposal of those materials. Associates must not conceal, or condone the concealment of, any improper discharge or disposal of hazardous materials.

Associates must protect against the waste, loss, damage, misuse, theft, misappropriation, or infringement of Perot Systems' buildings, data, documents, equipment, funds, know-how and technology, and other assets. Perot Systems' information technology and communications systems (including computers, telephones, instant messaging, Internet and network access, TRAIN, voice mail, e-mail, on-line chat and bulletin boards, facsimile machines. and teleconferencing services) are intended for business use. Reasonable personal use of these systems is permitted provided that the Associate complies with all applicable Perot Systems' policies. However, all e-mail, voice-mail and other information stored on, or transmitted through, these systems is Perot Systems' property. Perot Systems has the right to access, audit, disclose, inspect, monitor, read, review and print all such items at any time and shall not be required to treat any such items as an Associate's confidential personal date or information, except as otherwise provided by applicable law or Perot Systems' policy. If you wish to keep your personal information private, do not store or transmit the information on our systems.

All sales and loans of Perot Systems assets to Directors and executive officers of Perot Systems must be approved by the Compliance Officer or the Associate Compliance Officer and, if the terms and conditions relating to such sales or loans are materially different than the terms and conditions regularly offered to other Associates (e.g., in the case of a sale of excess inventory), the Audit Committee.

G. Government Contracts

Perot Systems must comply with all laws relating to contracts with national, regional and local government agencies. Associates who provide, directly or indirectly, products or services to a government agency or under a government contract, should contact a Compliance Delegate for special policies and procedures that apply.

H. Copyrights, Patents and Trademarks

Perot Systems' intellectual property, including our copyrights, patents and trademarks are valuable and must be protected. Associates must respect intellectual property owned by our customers, our suppliers and other persons, just as we expect others to respect Perot Systems' intellectual property.

Copyright laws protect articles, documents, images, movies, music, stories, software and other works of authorship, including those you find on the Internet. A copyright notice is not required. Associates must not copy, download, distribute, modify or use any articles, documents, images, movies, music, stories, software or other works of authorship copyrighted by anyone other than Perot Systems for personal use or for use in connection with Perot Systems or any customer's business unless, as the case may be, Perot Systems, that customer, or the individual Associate has a license or appropriate consent to do so.

Patent laws protect original designs, processes, systems, products and other inventions. Perot Systems must not infringe any valid patent. Associates who receive a communication alleging, or who otherwise believe that, Perot Systems may be infringing a patent must contact the Legal Department immediately.

Trademark laws "brand names" under which products and services are marketed. Associates must not use trademarks, whether "registered" or unregistered, that are not owned by Perot Systems to market or sell our products or services.

I. Doing Business Internationally

Perot Systems is subject to the laws and regulations of the many countries, states, provinces, municipalities and other jurisdictions where we and, in some cases, our customers do business. The laws of more than one jurisdiction may apply at the same time. Associates should recognize the possibility that laws of more than one jurisdiction may apply to their work. Associates should consult the Legal Department for advice on how to resolve an apparent conflict between laws of multiple jurisdictions.

Perot Systems and each Associate must comply with all laws governing the import, export and re-export of technical information, goods, technology, software (including source code) and services while conducting Perot Systems business. In some cases, export laws may restrict your travel outside your home country, your transmission of electronic or other communications, or the development of an Internet web site. Associates who are working on multi-national projects are responsible for knowing about and following all laws that apply to their projects.

Governments often impose restrictions on doing business with certain individuals or other countries. Associates must understand and comply with these restrictions when doing business internationally.

Before traveling to another country on business or doing business in a country where Perot Systems does not have established business operations, Associates should discuss their anticipated activities with the human resources and legal departments to ensure that any restrictions on those activities are understood.

J. Political Activities and Contributions

Perot Systems' Compliance Officer or the Associate Compliance Officer must approve in advance every contribution or payment to a government official, political candidate, party, or organization or their representatives. This includes both direct contributions and indirect assistance, such as furnishing goods, services, or equipment, regardless of the fees charged for such assistance. If you contribute your personal time or money to political candidate you should make it clear that you are acting as an individual and not on behalf of Perot Systems. You must not use Perot Systems resources to assist, and Perot Systems will not reimburse you for any financial contributions to, any political candidate or party. In addition, you must not aid candidates on Perot Systems' time.

IV. Compliance Program

Perot Systems' Compliance Program is intended to discover, investigate and respond to violations and suspected violations of our Standards & Ethical Principles, including violations or suspected violations of applicable laws or regulations. Compliance Delegates have been appointed throughout Perot Systems to respond to reports of violations and suspected violations. Contact information for our Compliance Delegates and other ways to report violations is available at the Compliance Program's website on TRAIN. You may always report violations and suspected violations to Peter Altabef or Del Williams.

A. Reporting Suspected Violations. If you suspect that someone associated with Perot Systems (including Associates, suppliers, contractors and joint venture partners) has violated our Standards & Ethical Principles or any law or regulation, you should promptly report this to your leader. If you are a Director or executive officer of Perot Systems, you should report this to the Compliance Officer or the Associate Compliance Officer. The report should be made without regard to the identity or position of the suspected offender and may be made anonymously. Because failure to report inappropriate activity can be understood to condone the activity, we emphasize the importance of reporting violations and suspected violations. If, for any reason, you are uncomfortable reporting to your leader, or believe that your leader is not responding appropriately, you may report your concern to any Compliance Delegates identified on TRAIN, or through any of the following means:

E-mail: PSC-Compliance@ps.net or psc-auditcommittee@ps.net

Phone: (800) 753-9173 (charges will be paid by Perot Systems)
Outside the United States, you may need to call a local number before dialing this number. These local numbers are available at www.ethicspoint.com.

Internet: www.ethicspoint.com

Mail:  Perot Systems Corporation
         Attn: Compliance Officer
         2300 West Plano Parkway
         Plano, TX 75075

B. Responding to Compliance Reports. All conversations and reports involving unethical or illegal behavior will be taken seriously. Associates must inform a Compliance Delegate when they receive a report alleging a violation of our Standards & Ethical Principles or any law or regulation. Compliance Delegates must notify the Compliance Officer of all such reports. Perot Systems will promptly investigate all such reports. To the extent practical and appropriate under the circumstances, the identities of individuals who report suspected violations and who participate in investigations will be kept confidential.

All Associates are required to cooperate, to respond accurately, completely, and promptly to requests for information, and to preserve records that may be related to a compliance investigation. If a government agency or other third party has initiated the audit or investigation, all requests for information will be coordinated by the Legal Department.

C. Responding to Violations. If, after completing an internal investigation, Perot Systems determines that inappropriate or illegal conduct has occurred, the Compliance Officer, the Associate Compliance Officer or his designee will take appropriate action to respond to and correct such conduct. Appropriate action may include disciplinary action, up to and including termination of employment or engagement for Associates engaged in such conduct, implementing procedural or organizational changes to reduce the possibility of a recurrence of such conduct, or notifying the appropriate governmental agency.

D. Retaliation Prohibited. Perot Systems will not retaliate or take adverse action against any individual who merely (a) reports suspected inappropriate or illegal conduct in good faith, even if the report is unfounded or mistaken, or (b) helps us to investigate or resolve an ethical or legal violation. Retaliation, in any form, against such an individual is itself a serious violation of our Standards & Ethical Principles and must be reported immediately. Associates who engage in retaliatory conduct are subject to disciplinary action, up to and including immediate termination of employment for cause. However, reports made to spread falsehoods or threaten others, or with the intent to damage another person's reputation, violate our Standards & Ethical Principles.

E. Waiver Procedure. Associates may request that a specific provision of our Standards & Ethical Principles be waived by submitting a detailed request to the Compliance Officer or the Associate Compliance Officer after obtaining their leader's approval. The Compliance Officer, the Associate Compliance Officer or his designee may grant a waiver, subject to applicable law, provided that the Audit Committee of the Board of Directors must also approve a waiver requested by a director or executive officer of Perot Systems Corporation. All waivers of these Standards & Ethical Principles granted to directors and executive officers of Perot Systems must be publicly disclosed and posted to our website.

F. Disciplinary Action. Violations of these Standards & Ethical Principles or applicable laws jeopardize our relationships with our customers and suppliers, and can have serious consequences for Associates and Perot Systems. Associates who violate our Standards & Ethical Principles or any applicable laws—whether by improper acts or failures to act, condoning or failing to report improper acts or failures to act by others, retaliation against any individual who reported or cooperated in an investigation of an ethics or compliance issue, or discouraging others to report an ethical or compliance issue—are subject to disciplinary action up to and including immediate termination of employment for cause. Forms of disciplinary action may include verbal or written counseling or warnings, performance improvement plans, suspension or other forms of disciplinary action approved by the Compliance Officer or the Associate Compliance Officer. In considering what discipline is appropriate, the Company will treat with appropriate leniency Associates who come forward to report their own ethics or compliance violations. In addition, certain violations can result in fines or criminal penalties against Perot Systems and individual Associates.

Country / Geographic Exceptions & Modifications

This is a global policy.

Related Documents & Policies

All policies and procedures of Perot Systems Corporation and its subsidiaries applicable to an Associate's employer and job duties.

Keywords

honesty, ethics, integrity, harassment, abusive behavior, sexual, equal opportunity, gender, sexual orientation, race, color, national origin, age, disability, religion, complaint, associate relations