Equal Opportunities Policy

EQUAL EMPLOYMENT OPPORTUNITY AND ANTI-HARASSMENT

It is the policy of the Veeva Systems Inc. (the Company) to base all employment-related decisions on principles of equal employment opportunity. In particular, it is the policy of the Company:

to recruit, hire, promote, reassign, compensate, train and otherwise employ highly qualified persons without regard to race (including traits historically associated with race, such as hair texture and protective hairstyles), color, religion (including religious dress practices and religious grooming practices), national origin, sex, gender, gender identity and/or expression (including transgender individuals), genetic predisposition or carrier status, ancestry, age (40 and over), physical or mental disability, medical condition (including pregnancy, childbirth, breastfeeding and related medical conditions), marital, parental, registered domestic partnership or military or veteran status, sexual orientation, citizenship status, victim of domestic violence status, or any other basis prohibited by applicable laws;
to provide reasonable accommodations where necessary and feasible for, and otherwise treat equally, qualified individuals with disabilities; and
to provide a workplace free of prohibited harassment, including, but not limited to, sexual harassment.

The Company is committed to complying with all applicable laws providing equal employment opportunities. This commitment applies to all persons involved in the operation of the Company and prohibits unlawful discrimination, harassment or retaliation by any employee of the Company, including managers, supervisors, co-workers and any partners of the Company.

Reasonable Accommodation

If you have a disability for which a reasonable accommodation would enable you to better perform the essential functions of your job, you are expected to discuss the accommodation with your immediate manager and/or your Employee Success Business Partner. The Company will work with you to determine whether it can provide a reasonable accommodation without undue hardship to the Company. Any information you provide regarding your disability will be kept confidential, except that:

your manager and other appropriate personnel may be informed of any restrictions on your work or duties and the necessary, reasonable accommodation(s) needed;
first aid, fire and life safety personnel may be informed when and to the extent appropriate; and
government officials investigating compliance with applicable laws and regulations may be informed to the extent required for the Company to comply with its obligations.

Prohibited Harassment

The Company maintains a strict policy prohibiting sexual harassment and harassment because of race (including traits historically associated with race, such as hair texture and protective hairstyles), color, religion (including religious dress practices and religious grooming practices), national origin, sex, gender, gender identity and/or expression (including transgender individuals), genetic predisposition or carrier status, ancestry, age (40 and over), physical or mental disability, medical condition (including pregnancy, childbirth, breastfeeding and related medical conditions), marital, parental, registered domestic partnership or military or veteran status, sexual orientation, citizenship status, victim of domestic violence status, participation in discrimination complaint-related activities or any other basis prohibited by applicable laws. All such harassment is prohibited. Anyone who violates this policy will be subject to disciplinary action, up to and including immediate termination of employment.

The Company’s harassment policy applies to all persons involved in the operations of the Company. The Company’s policy also prohibits harassment of employees by vendors or clients. If harassment occurs on the job by someone not employed by the Company, the procedures in the policy should be followed as if the harasser were an employee of the Company.

Harassment Defined

Harassing conduct may be verbal (including oral, electronic or written communications), physical or visual and includes, but is not limited to, derogatory comments, unwelcome and/or inappropriate jokes, posters, objects, inappropriate language, written communication including email messages, gestures, physical conduct, assault, battery and/or unwelcome sexual or romantic advances that create a hostile or offensive working environment.

Sexual Harassment

Applicable state and federal law defines sexual harassment as unwanted sexual advances, requests for sexual favors, or visual, verbal or physical conduct of a sexual nature when: (1) submission to the conduct is made a term or condition of employment; or (2) submission to or rejection of the conduct is used as a basis for employment decisions affecting the individual; or (3) the conduct has the purpose or effect of unreasonably interfering with the employee’s work performance or creating an intimidating, hostile or offensive working environment. This definition includes many forms of offensive behavior. The following is a non-exhaustive list of the types of behaviors that are prohibited under this policy:

Unwanted or inappropriate sexual or romantic advances;
Offering employment benefits in exchange for sexual favors;
Making or threatening reprisals after a negative response to sexual advances;
Visual conduct such as leering, staring, making sexual or inappropriate gestures, or displaying sexually suggestive objects, pictures, cartoons or posters;
Verbal conduct such as making or using suggestive or derogatory comments, epithets, slurs, sexually explicit jokes, whistling or comments about any employee’s body or dress;
Verbal sexual or romantic advances or propositions;
Inquiries into one’s sexual experiences or discussion of one’s sexual activities;
Verbal abuse of a sexual nature, graphic verbal commentary about an individual’s body, sexually degrading words to describe an individual, or suggestive or obscene letters, notes or invitations;
Verbal or written references to sexual conduct, gossip regarding one’s sex life, or comments about one’s sexual activities, deficiencies, or prowess;
Physical conduct such as touching, brushing up against one’s body, rubbing, assault, or impeding or blocking movements; and
Retaliation for reporting harassment or threatening to report harassment.

It is unlawful for males to sexually harass females or other males, and for females to sexually harass males or other females. Sexual harassment is unlawful whether it involves co-worker harassment or harassment by a manager, partner or persons doing business with or for the Company.

Other Types of Harassment

Other types of prohibited harassment include harassment on the basis of race, color, religion (including religious dress practices and religious grooming practices), national origin, sex, gender, gender identity and/or expression, genetic predisposition or carrier status, ancestry, age, physical or mental disability, medical condition (including pregnancy, childbirth, breastfeeding and related medical conditions), marital, parental, registered domestic partnership or military or veteran status, sexual orientation, citizenship status, victim of domestic violence status, participation in discrimination complaint-related activities or any other basis prohibited by applicable laws. Such harassment includes behavior similar to those described above under sexual harassment, such as:

Verbal conduct such as threats, epithets, derogatory comments or slurs;
Visual conduct such as derogatory posters, photographs, cartoons, drawings or gestures;
Physical conduct such as assault, unwanted touching or blocking normal movement; and
Retaliation for reporting harassment or threatening to report harassment.

Reporting Harassment, Discrimination or Retaliation

If you believe you or anyone else at the Company has been subjected to any form of prohibited harassment, discrimination, or retaliation, you should immediately report the matter to your manager, your ES Business Partner, any other member of management with whom you feel comfortable discussing the matter, the Legal Department of by making a report through the Company’s Whistleblower Hotline toll free 1 855 595-9577 or complete a report online at www.veeva.ethicspoint.com. Employees can raise concerns and make reports anonymously and without fear of retaliation. Preferably, your complaint should be in writing. Your complaint should be as thorough as possible and include the names of any potential witnesses.

Supervisors and managers must report all complaints of prohibited harassment, discrimination, or retaliation to the General Counsel, Associate General Counsel – Global Employment Law, Internal Audit or the Whistleblower Hotline.

It is unlawful to retaliate against an employee for filing a complaint of discrimination or harassment or for cooperating with an investigation of discrimination or harassment. Retaliation for making a complaint of discrimination or harassment, for cooperating with an investigation of discrimination or harassment, or for supporting another employee in making a complaint of discrimination or harassment is also a violation of this policy. The Company will not retaliate against you for filing a complaint, supporting another in filing a complaint or participating in an investigation and will not knowingly permit retaliation by management employees, partners, or your co-workers.

The Company will conduct a fair, timely and thorough investigation of the complaint and reach a conclusion based on the information gathered during the investigation. During the investigation, the claim will be documented and tracked for reasonable progress. If the Company determines that prohibited harassment, discrimination, retaliation or other conduct in violation of Company policy has occurred, appropriate action will be taken to resolve the matter. The Company will strive to keep such investigations confidential provided doing so will not compromise the Company’s ability to conduct a thorough and fair investigation. Participants in investigations of this nature may be required to keep the investigation confidential to the extent such confidentiality is in accordance with applicable laws when the Company concludes that confidentiality is necessary to maintain the integrity of the investigation (for example, where confidentiality is necessary to prevent a cover-up, collusion, fabrication of information, copycat testimony or evidence, retaliation against the accused, accuser, or witness, damage to the reputation of any employee, witness, accused, accuser, or the Company, destruction or manipulation of evidence, or theft or misappropriation of trade secrets, confidential information, or privileged information, or where there is a potential for future criminal charges arising out of the matters under investigation). Failure to do so may result in disciplinary action. Appropriate action will also be taken to deter any future harassment, discrimination or retaliation.

Any person who is found to have engaged in prohibited harassment, discrimination, retaliation or other conduct that violates any Company policy is subject to disciplinary action, up to and including immediate termination of employment. Any employee who engages in prohibited harassment may be held personally liable for monetary damages. The Company does not consider conduct in violation of this policy to be within the course and scope of employment or the direct consequence of the performance of one’s duties. Accordingly, to the extent permitted by law, the Company reserves the right not to provide a defense or pay damages assessed against employees for conduct in violation of this policy.

The responsibility to investigate complaints of discrimination, harassment and retaliation has been assigned to either the Legal Department, Associate General Counsel – Global Employment Law, VP of Internal Audit or Employee Success Any employee who believes that he or she has been subject to harassment, discrimination or retaliation should report the alleged act to Whistleblower Hotline toll free 1 855 595-9577 or complete a report online at www.veeva.ethicspoint.com.as soon as possible.