Seagate Technology Code of Ethics for Senior Financial Officers

In addition to the Business Conduct Policy, this Code of Ethics applies to the Chief Executive Officer, the Chief Financial Officer, and the principal accounting officer or controller or persons performing similar functions (the "Senior Financial Officers") of Seagate Technology plc ("Seagate"). The purpose of this Code of Ethics is to promote honest and ethical conduct and compliance with the law, as related to the maintenance of Seagate's financial books and records and the preparation of its financial statements. The obligations of this Code of Ethics supplement, but do not replace, Seagate's other policies applicable to directors, officers and employees.

Pursuant to this Code of Ethics, the Senior Financial Officers are expected to:


Engage in and promote ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships, and to disclose to Seagate's Chief Legal Officer any material transaction or relationship that reasonably could be expected to give rise to such a conflict.


Carry out your responsibilities honestly, in good faith, and with integrity, due care, and diligence, exercising at all times the best independent judgment.


Assist in the production of full, fair, accurate, timely, and understandable disclosure in reports and documents that Seagate files with or submits to all applicable regulatory bodies, including the Securities and Exchange Commission, and in other public communications made by Seagate.


Comply with applicable securities laws and regulations, and government laws, rules, and regulations applicable to business operations.


Promptly report, openly, confidentially, or anonymously, to the Audit Committee of Seagate's Board of Directors or the Chief Legal Officer (i) any questionable accounting, internal accounting controls, or auditing matters, including fraud that involves management or other employees; (ii) noncompliance with applicable legal and regulatory requirements or the Business Conduct Policy or this Code of Ethics; (iii) significant deficiencies in the design or operation of internal controls which could adversely affect the Company's ability to record, process, summarize, and report financial data; or (iv) retaliation against employees and other persons who make, in good faith, allegations regarding the matters in this Section 5, in each case through any avenue available, including:

a. in writing to the Chief Legal Officer, c/o Seagate Technology, 47488 Kato Road, Fremont, CA 94538, USA, or by emailing;

b. in writing to the Chair of the Audit Committee, c/o Seagate Technology, 47488 Kato Road, Fremont, CA 94538, USA or

c. by calling the Seagate's Ethics Helpline, 1–800–968–4925, or using the Seagate Ethics Helpline website, https://seagate., both of which are available 24 hours a day.

The reports should be factual rather than speculative or conclusory, and should contain as much specific information as possible to allow for proper assessment. In addition, the reports should contain sufficient corroborating information to support the commencement of an investigation, including, for example, the names of individuals suspected of violations, the relevant facts of the violations, how the person became aware of the violations, any steps previously taken by the person who may be harmed or affected by the violations, and, to the extent possible, an estimate of the misreporting or losses to Seagate as a result of the violations.


Never take, directly or indirectly, any action to coerce, manipulate, mislead, or fraudulently influence Seagate's independent auditors in the performance of their audit or review of Seagate's financial statements.


Be accountable for adherence to this Code of Ethics, both by yourself and by other directors, officers, and employees of Seagate.

For Senior Financial Officers, waivers of the Code of Ethics must be approved by the Board of Directors or its designated committee. Waivers of the Code of Ethics will be disclosed promptly as required by law or stock exchange regulations.

Seagate will take all necessary actions to enforce this Code of Ethics, up to and including immediate dismissal. Violations of this Code of Ethics may also constitute violations of law which may expose both you and Seagate to criminal and civil penalties.

If you have any questions about how this Code of Ethics should be applied in a particular situation, you should promptly contact Seagate's Chief Legal Officer or one of the members of the Legal Department listed below. In addition, directors, officers, and employees of Seagate should review Seagate's other policies applicable to them.

Kate Schuelke

Senior Vice President, Chief Legal Officer, and Corporate Secretary

Location: Fremont, California USA
Tel: 510-661-1975

Laurie Webb

Vice President, Legal, Compliance, and Government Relations

Location: Fremont, California USA
Tel: 510 661-1976

Anu Gandhi

Senior Corporate Counsel, Asia

Location: Singapore, Singapore
Tel: 011–65–6807–7200

David Hasson

Associate General Counsel, EMEA

Location: Dublin, Ireland
Tel: 353–1–234–3139

Tracy He

Senior Corporate Counsel

Location: China
Tel: 86 010 58751909