3Com Code of Ethics - Amendments and Waivers

On June 26, 2007, the Board of Directors amended the Corporation's Code of Ethics and Business Conduct. The principal changes are as follows: The Board terminated the H3C Code of Ethics; accordingly, the new Code of Ethics and Business Conduct applies globally to all 3Com personnel, including H3C employees; The Board clarified some of the disclosure and reporting requirements under the Code; The Board tightened the policy on gifts, to make it clear that gifts from companies we do business with are not permitted except in very limited circumstances; and The Board clarified and enhanced the internet/email policy. On February 19, 2007, the Board of Directors amended the Corporation's Code of Ethics and Business Conduct. Under the existing Code's conflict of interest provisions, company employees, directors and officers may not have any financial interest in any 3Com supplier, vendor, customer, competitor, or any other entity affiliated with 3Com. An exception is provided for owning up to one percent of the total outstanding shares of a security traded on a public market. The amendment added an exception for ownership of up to five percent of the stock of a private company. The amendment recognizes that company representatives may from time-to-time make small investments in private companies (in addition to public companies) that may be affiliated with 3Com. The Board believes that investments at this level should not be presumed to raise conflicts of interest. Employees and directors should, nevertheless, use their discretion in making investments that could raise conflicts of interest between their professional and personal duties.