chief ethics and compliance officer in making improvements where appropriate; · The expansion of the role of HP’s chief privacy officer to include review of HP’s investigation practices to ensure that they address matters related to privacy and ethics; · The expansion of HP’s employee and vendor codes to ensure that they include legal and ethical standards applicable to the conduct of investigations; · The creation of a Compliance Council within HP that will be responsible for developing, initiating, maintaining and revising policies and procedures for the general operation of HP’s ethics and compliance programs consistent with applicable laws and regulations; and · The redesign of HP’s annual training requirement to ensure that business ethics plays a more prominent role, and the provision of additional training to employees engaged in the conduct of investigations for HP. The board has designated its newest member, G. Kennedy Thompson, who serves as chief executive officer of Wachovia Corp., as its independent director with responsibility reviewing and reporting on HP’s compliance with legal and ethical requirements related to the conduct of investigations to the board. “HP has traditionally been a leader in the area of business ethics and I look forward to working with the management team to help ensure that the company operates with the highest standards of integrity,” Thompson said. Oversight of the ethics and compliance program will be run by Jon Hoak, whom the company appointed in October to the newly created position of chief ethics and compliance officer. Hoak had previously served for over 12 years as senior vice president and general counsel for NCR, where he oversaw the ethics organization. As “Qualified Authority,” HP is utilizing the services of Bart M. Schwartz to review its investigative processes. Schwartz was retained by HP in September and previously served under U.S. Attorney Rudolph Giuliani as chief of the Criminal Division in the Southern District of New York. The company’s chief privacy officer, Scott Taylor, named to his post in June, will expand his role to include review of HP’s investigative processes to ensure that they appropriately address matters related to privacy and ethics. He will also continue to work on assuring the privacy of information obtained by HP in the normal course of business. The Compliance Council will be headed by the chief compliance officer and will include the chief privacy officer along with other representatives from the company’s legal and ethics functions. HP is engaged in reviewing its employee and vendor codes to ensure that they comply with the undertakings provided to the Attorney General. | 
