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Our Code of Conduct, “How We Win,” provides general guidance on how to carry out our daily activities in accordance with our purpose and values, as well as in compliance with the letter and spirit of applicable legal requirements and Dell policies, standards and ethical principles. All Dell team members, including officers and directors, and employees of Dell subsidiaries and controlled affiliates, must follow our Code. We also expect all our suppliers, assigned workers, agents and others doing business with Dell or acting on our behalf to hold themselves to equally high standards.

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