Code of Conduct

Dell's Higher Standard

Dell's success is built on a foundation of personal and professional integrity. We hold ourselves to standards of ethical behavior that go well beyond legal minimums. We never compromise these standards and we will never ask any member of the Dell team to do so either. We owe this to our customers, suppliers, shareholders and other stakeholders. And we owe it to ourselves because success without integrity is essentially meaningless.

Our higher standard is at the heart of what we know as the "Soul of Dell" - the statement of the values and beliefs which define our shared global culture. This culture of performance with integrity unites us as a company that understands and adheres to our company values and to the laws of the countries in which we do business. Just as the Soul of Dell articulates our values and beliefs, the following Code of Conduct provides guidance to ensure we meet our higher standard and conduct business the Dell Way - the right way, which is "Winning with Integrity." Simply put, we want all members of our team, along with our shareholders, customers, suppliers and other stakeholders, to understand that they can believe what we say and trust what we do. Our higher standard includes several key characteristics that both underpin the Soul of Dell and provide the foundation for our Code of Conduct:

Trust - Our word is good. We keep our commitments to each other and to our stakeholders.

Integrity - We do the right thing without compromise. We avoid even the appearance of impropriety.

Honesty - What we say is true and forthcoming - not just technically correct. We are open and transparent in our communications with each other and about business performance.

Judgment - We think before we act and consider the consequences of our actions.

Respect -We treat people with dignity and value their contributions. We maintain fairness in all relationships.

Courage - We speak up for what is right. We report wrongdoing when we see it.

Responsibility - We accept the consequences of our actions. We admit our mistakes and quickly correct them. We do not retaliate against those who report violations of law or policy.