Non-Retaliation Policy

Michael & Susan Dell Foundation (the “Foundation”) is committed to ensuring that it provides a workplace for its employees at which business practices are ethical and comply with federal and state law. Employees should report any unethical or dishonest conduct, or potential violation of federal or state law.

I. Oversight

The Foundation’s Board of Directors or Board Committee, as applicable, will oversee treatment of employee complaints. The Foundation’s Executive Director has the delegated authority to develop, implement and, from time to time revise, procedures to facilitate the confidential and, to the extent possible, anonymous reporting of complaints by employees regarding the Foundation’s business practices.

II. Review, Retention and Treatment of Employee Complaints

The Executive Director will develop procedures regarding the review, retention and treatment of employee complaints, and will provide such procedures to the Foundation’s employees.

III. Non-Retaliation

The Foundation will not discharge, demote, suspend, threaten, harass or in any manner discriminate against any employee in the terms and conditions of his or her employment based upon any lawful actions of such employee with respect to good faith reporting of complaints or as otherwise specified in Section 806 of the Sarbanes-Oxley Act of 2002.

If an employee believes that he or she has been subjected to any action that violates this policy, he or she should file a complaint with his or her supervisor, the General Counsel or the Foundation’s Director of Human Resources. If it is determined that an employee has experienced any improper employment action in violation of this policy, the Foundation will take prompt and appropriate corrective action.