We Are Accountability Driven

Our Code of Conduct explains the standards all team members are expected to embody so that we can live up to our corporate values, comply with Seagate policies, and adhere to specific laws and regulations.

We periodically assess and update this code, along with other related policies, programs, and processes, for ongoing effectiveness and compliance.

We take a continuous, cross-functional approach to improving and strengthening Seagate’s compliance and ethics (C&E) program. By doing so, we have a comprehensive system of policies, processes, and standards that prevent, detect, and correct violations of laws, regulations, and corporate policies.

Our C&E program is supported by a global cohort, including the Chief Compliance Officer, Regional Compliance Officers, Corporate Compliance Committee, our compliance and ethics team, subject matter experts, and experienced lawyers.

Seagate is governed by an annually elected Board of Directors, responsible for directing and overseeing management of the business and its affairs. The Board serves as the ultimate decision-making body of the Company, except for matters reserved for Seagate shareholders.

Seagate’s Ethics Helpline is available to our employees on the homepage of our internal website and to those outside Seagate via our external investor relations website. Contact information is available on the homepage of both Seagate websites. Concerns may be reported by phone or email in English, Spanish, French, Chinese, Korean, Malay, Portuguese, or Thai.

Throughout FY2025, we continued to internally and externally promote our Ethics Helpline so that employees and business partners are aware that they can report illegal or unethical situations confidentially and anonymously, to the extent anonymity is permitted by local law, without any fear of retaliation. We benchmark our Ethics Helpline to stay current with industry standards for information security, process improvements, reporting, and resolution.

The Board of Directors (the “Board”) of Seagate Technology Holdings plc (the “Company”) has adopted guidelines to clarify how it exercises its responsibilities. Additionally, these guidelines demonstrate that the Board has the necessary authority and practices in place to review and evaluate the Company's business operations as appropriate and to make decisions that are independent of the Company's management.

These guidelines, along with the charters of the committees of the Board, describe the Board’s framework for the governance of the Company. The Board will continue to assess the appropriateness and efficacy of these guidelines, which are subject to change as the Board deems appropriate in the best interests of the Company or as required by applicable laws and regulations. The Nominating and Corporate Governance Committee of the Board (the “Nominating and Corporate Governance Committee”) reviews these guidelines periodically and recommends changes to the Board as appropriate.