Laws and regulations.
At Workday, we play by the rules. That means we conduct our business in accordance with our core values and in compliance with applicable national, state, and local laws and regulations. Not all of those laws and regulations are covered specifically by this Code, and Workmates must familiarize themselves with applicable laws and regulations wherever they do business.
If there seems to be a difference between a legal requirement and the Code, always apply the more stringent standard. Seek guidance from Legal or the Integrity Team, particularly when a law or regulation could potentially be violated.
Trade laws.
As a global company, Workday is subject to the trade laws and regulations of the United States and other applicable jurisdictions. Workmates need to be mindful of the trade requirements that apply to the cross-border transfer of goods, services, and technologies, such as:
- Economic sanctions that prohibit us from doing business with certain countries, entities, or individuals
- Export controls and customs requirements that apply to the products, services, and technologies that we may transfer from country to country
- Anti-boycott restrictions that prohibit Workday from participating in or supporting any foreign boycott that is not sanctioned by the U.S. government
Inspiring integrity:
If you don’t know whether trade or export controls might apply or what those rules are in a particular case, DON’T GUESS. Ask before you act.
Learning link:
Insider trading.
Do not trade on inside information.
Workmates may become aware of material nonpublic information about Workday or our customers, suppliers, or partners. Trading in stock or other securities or influencing others to trade if you have material nonpublic information is considered insider trading and is strictly prohibited by both this Code and the law.
Information is material if it can influence someone’s decision to buy or sell stock. Information is nonpublic if it has not yet been announced through an official channel such as a press release, the Workday blog, or filings with the Securities and Exchange Commission. Examples of this information include company financial performance; global sales opportunities; new products or services; mergers or acquisitions; major developments with customers, partners, or key employees; or other major business plans.
We all play a role in maintaining Workday’s high ethical standards, trust with our shareholders and the public, and compliance with the law. You should familiarize yourself with our InsiderTrading Policy so you can avoid even the appearance of improper trading.
Restricted Trading Periods.
Starting July 15, 2025, all Workmates will be subject to Workday’s restricted trading periods. Workmates are prohibited from buying, selling, or transferring Workday stock during our quarterly restricted trading periods.
Learning link:
Inspiring integrity:
Are you planning to sell shares of Workday stock? Keep in mind that awareness of material nonpublic information prohibits you from trading, even if your reason for trading is unrelated to the information in question. Please make sure to plan your sales around any upcoming restricted trading periods.
Sharing material nonpublic information with others, known as tipping, is just as serious as trading on that information yourself. You should not share any material nonpublic information with anyone outside of Workday—even your spouse, family members, and friends—and you should refrain from giving trading advice about Workday stock to anyone, even if you are not aware of material nonpublic information. Within Workday, please limit the sharing of nonpublic information to only those Workmates with a business need to know.
Government relationships.
Workday has developed valuable relationships with national, regional, state, and local governments by working fairly and honestly with officials and others wherever they operate.
Workmates must be truthful and straightforward in their dealings with governments, and may not direct or encourage anyone to provide false or misleading information to any government agent or representative.
Workmates should also keep the following in mind:
- Doing business with government agents, employees, or officials may often mean complying with additional requirements. Be mindful of this Code, the Anti-Corruption Policy, other relevant policies, and all local laws.
- Any gifts or business entertainment involving government officials must first be preapproved by the Workday Integrity Team or Legal, Compliance, and Corporate Affairs. Do not even propose business entertainment to government officials without getting approval.
- Charitable donations should never be made in order to win improper influence over a business decision or as a quid pro quo.
- Unless preapproved by Corporate Affairs, you should not imply or indicate Workday’s position on any election outcome or policy matter.
- If an investigation ever arises or reasonably could arise, contact Legal immediately. All records related to investigations must be preserved, and any potential destruction of records relevant to an investigation should be reported.
Public disclosures.
All information shared outside of Workday, whether it is with the media, investors, or the general public, must be accurate, complete, and consistent. Any disclosures made in public or regulatory communications must be full, fair, accurate, timely, and understandable.
Information about Workday or its business activities should only be shared by an approved Workday spokesperson. If you receive inquiries from the press or industry analysts, please direct them to the Workday Corporate Communications team. For financial and investment-related questions, please refer them to the Workday Investor Relations department. Do not attempt to answer these questions yourself and be sure to inform your manager about any such inquiries. For guidance on discussing Workday online, please refer to our Social Media Policy.
Inspiring integrity:
Do not engage with media, analysts, or social media contacts regarding Workday matters. Direct all such inquiries to your manager or the appropriate Workday department: Corporate Communications; Investor Relations; or Legal, Compliance, and Corporate Affairs.
Our commitment to human rights.
In all of our operations we support:
- Fair and ethical labor: We condemn all forms of forced labor, exploitative child labor, and human trafficking and other types of modern slavery. We strive to create a workplace and supply chain free from modern slavery. We respect our employees’ lawful right to freedom of association.
- Fair and empowering employment: We provide fair compensation to our employees, enabling them to meet their basic needs. We foster an environment where employees can develop their knowledge, skills, and abilities, opening doors for professional growth. Hiring, compensation, promotion, discipline, and all other employment conditions are based solely on an individual’s qualifications and performance.
- Diversity and inclusion: We embrace diversity and foster an inclusive workplace where everyone feels valued and respected. We prohibit discrimination and ensure equal opportunity in all aspects of employment.
- Safe and healthy workplace: We prioritize the safety and health of our employees, maintaining a secure and healthy work environment.
- Environmental responsibility: We strive to minimize our environmental footprint through sustainable practices and responsible resource management.
- Ethical AI development: We develop and deploy AI technologies responsibly and prioritize fairness, transparency, and accountability.
- Conflict-free sourcing: We reject the use of conflict minerals and expect our suppliers to adhere to the same standards.
- Privacy protection: We safeguard personal data and consider privacy to be a fundamental human right.
Inspiring integrity:
Workday Giving & Doing provides information about our community activities and the permissible use of company resources.
