Governance Global Code of Conduct

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Global Code of Conduct

Western Digital Corporation’s Global Code of Conduct provides information about the minimum standards of integrity that Western Digital Corporation expects all of its employees worldwide (including those of WDC’s subsidiaries) to follow and takes into account varying practices due to cultural differences in international locations. The standards set forth in the Global Code of Conduct are supported by more detailed Company policies and procedures, which are issued in various geographic regions to supplement or implement those standards. These policies and procedures provide clear, specific directions concerning many of the business practices and behaviors discussed in the Code.

A copy of the Global Code of Conduct in the appropriate language is given, or is available online, to all employees of Western Digital Corporation (including employees of domestic and foreign subsidiaries). In addition, new employees are given a copy of the Code of Conduct on their first day of employment. All employees are informed that they are expected to comply with the provisions of the Code of Conduct and that failure to do so is regarded as misconduct that can result in disciplinary action.

Each year, senior members of management and several hundred key designated employees worldwide are required to complete an online questionnaire certifying that they have complied with the provisions of the Global Code of Conduct. This certification process is required by the Audit Committee and is managed by the Corporation’s General Counsel.