Reporting Accountability Concerns

Procedures Regarding Complaints or Concerns Regarding
Accounting, Internal Accounting Controls, Auditing and Other Matters

The Pegasystems Audit Committee has established a means for employees to report any violations or suspected violations of Company polices and laws or regulations related to accounting, internal accounting controls and auditing matters, bribery, banking and financial crime, or any substantial serious wrongdoings that affect the vital interests of the Company or its employees (collectively, “Reportable Matters”).

It is the intention of the Company to comply with Privacy and Data Protection regulations and other related regulations.

Reporting

Employees are encouraged to discuss issues and concerns relating to Reportable Matters with their manager or local management. In addition, employees and others should immediately file a complaint about Reportable Matters (“Complaints”) through Pegasystems’ third party reporting system, Lighthouse Services, via 24/7 telephone hotline, website, email or fax, as described below:


or by communicating via telephone, email or government postal mail with any of the following persons:

General Counsel & Chief Compliance Officer
Anne T. Warner
Pegasystems Inc.
One Rogers Street
Cambridge, MA 02142
(617) 866-6972
[email protected]

Senior Director of Internal Audit
Phil Benvenuti
Pegasystems Inc.
One Rogers Street
Cambridge, MA 02142
(617) 866-6030
[email protected]

Audit Committee Chairperson
Steven F. Kaplan
Pegasystems Inc.
One Rogers Street
Cambridge, MA 02142
[email protected]

Lighthouse Services will send notifications of any Compliants directly to Pegasystems’ General Counsel & Chief Compliance Officer, Senior Compliance Officer and/or Senior Director of Internal Audit. Persons reporting a Reportable Matter are urged to provide as much information and specificity as possible in order to facilitate resolution.

Confidentiality and Privacy

Pegasystems employees may submit Complaints anonymously or they may give their name and contact information in order that any follow-up questions might be answered. Whether or not a Complaint is submitted anonymously, Pegasystems will endeavor to keep confidential the source and details of a Complaint to the extent reasonably possible and allowed by law or regulation. All data collected and processed during the notification and investigation process are subject to relevant data protection and privacy regulations.

Treatment of Complaints

Complaints will be promptly forwarded to the Chairman of the Audit Committee and, assuming they are not personally involved in the matters which are the subject of the Complaint, the Chief Executive Officer and the Chief Financial Officer. Either the Chairman of the Audit Committee or the Audit Committee as a whole will evaluate the merits of Complaints received and authorize such follow-up actions, if any, as he or it deems necessary or appropriate to address the substance of the Complaint.

If an investigation of a Complaint is required it will be conducted as expeditiously as possible. Reasonable security standards will be followed to protect information related to the Complaint.

If an employee is named in a Complaint, the employee will be notified at the earliest time possible that will not affect any investigation required. The named employee will be advised of the facts of the Complaint, which departments may receive information related to the Complaint, the employee’s rights of access and rectification. The name of the person filing the Complaint will not be disclosed unless required by law or regulation.

Retaliation

Consistent with Pegasystems' Code of Conduct, Pegasystems will not discipline, discriminate against or retaliate against any person who in good faith submits a Complaint.

Authority

These procedures have been established by the Audit Committee of the Board of Directors of Pegasystems Inc. pursuant to Rule 10A-3 of the U.S. Securities Exchange Act of 1934 and European Union Directive 95/46/EC and EC Article 18 and 29 and related laws and regulation.

Questions

Any person with questions regarding these procedures should not hesitate to contact either of the persons named above.