Introduction

Our Code of Conduct (the “Code”) is a reflection of ourcollective commitment to ethical and responsible conduct. The Code serves as acompass, guiding our actions and decisions, ensuring that everything we doaligns with the highest standards of integrity and professionalism.

This Code is applicable to each and every one of us, withoutexception, setting clear boundaries of what is and isn’t acceptable.

To whom does the Code apply?

All employees are required to understand and comply with theCode, company policies and the laws that govern our business activities.Together with our core values and other policies, the Code helps us make theright decisions and take appropriate actions, regardless of our role, locationor responsibilities.

We believe that every employee is a leader, regardless of jobtitle or function. By following the Code, each of us acts as a role model forcolleagues, business partners, customers and others who observe our actions.

What is Expected?

• Act professionally, honestly and ethicallyin all business interactions.
• Familiarize yourself with the Code andcompany policies, paying special attention to those relevant to your jobresponsibilities.
• When faced with uncertainty, seek guidancebefore making a decision.
• Be attentive to behaviors that maycontradict the Code, company policies or legal obligations.
• If you witness misconduct, do not ignoreit. Protect the company’s reputation by reporting violations promptly.

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How We Conduct our Business

Anti-Bribery andAnti-Corruption

All employees must comply with applicable anti-bribery andanti-corruption laws in the course of their work. Regardless of local customsor industry practices, all forms of bribery are strictly prohibited.

For the purposes of this Code, bribery includes any direct or indirectimproper payment made to a government official, government employee or anyother individual to secure or retain business or gain an unfair businessadvantage.

Additionally, employees are prohibited from offering,promising, or authorizing such payments, even if they are ultimately notcarried out. Likewise, accepting improper payments in exchange for providing anunfair business advantage is strictly forbidden.

Bribery can take many forms beyond direct cash payments. Hereare some examples of non-cash things that may violate anti-bribery oranti-corruption laws or our Code, and could be improper:

• Gifts
• Meals
• Entertainment
• Travel benefits
• Charitable donations
• Political contributions
• Job or internship opportunities
• Other business courtesies and personalfavors

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For more information, please refer to the Anti-Bribery andAnti-Corruption Policy and the Gifts and Hospitality Policy. If you are unsurewhether an action is permissible, consult Compliance before proceeding.

Gifts and Entertainment

Business gifts and hospitality should be used to fostergoodwill and professional relationships, never to gain an improper businessadvantage or influence approvals. Employees must ensure that all gifts andhospitality are appropriate, ethical and comply with company policies.

Employees are strictly prohibited from giving or acceptinggifts or hospitality involving government officials unless they have receivedexpress written pre-approval from the Compliance team.

Employees should exercise caution when giving or acceptinggifts and hospitality to avoid even the appearance of impropriety. Thefollowing are always inappropriate:

• Gifts or hospitality intended toimproperly influence business decisions, including securing or retainingbusiness.
• Any gift or hospitality given in exchangefor a favor or benefit.
• Cash or cash equivalents (such as giftcards).
• Gifts or hospitality that are illegal orviolate company policies.
• Gifts or hospitality not permitted by therecipient’s employer (employees must verify the recipient’s company policiesbefore offering any business courtesy).
• Any gift or hospitality that could harmthe company’s reputation if publicly disclosed.

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Gifts and hospitality must not be given to or accepted fromcurrent or potential customers and/or vendors while active sales negotiationsare in progress unless pre-approved by Compliance.

If there is any concern that a gift or hospitality mightinfluence business decisions or create a conflict of interest, it should bedeclined to ensure fair and ethical decision-making. Employees are responsiblefor ensuring that their actions reflect integrity and transparency.

Charitable Donations &Political Contributions

All charitable donations, sponsorships or initiatives involvingcompany assets must receive pre-approval from Compliance and undergo thoroughdue diligence to prevent conflicts of interest.

Charitable donations must never be used to gain an improperbusiness advantage or to influence decisions by government officials or otherentities. Employees are welcome to support personal charitable causes but mustdo so on their own time and without company resources.

Employees are also encouraged to participate in personalpolitical and civic activities, provided they do so on their own time and attheir own expense.

• Company funds cannot be used for politicalcontributions in any form.
• Personal political views or activitiesmust not be presented as representing the company or its employees.
• Public comments, including those on socialmedia, should be carefully considered to ensure they are not misinterpreted asofficial company statements or endorsements.

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If you are uncertain whether a political activity could beperceived as representing the company, consult Compliance before proceeding.

International Trade Compliance

We are committed to conducting business in full compliance withall applicable international trade laws and regulations. This includesadherence to export controls, trade sanctions, customs laws and anti-boycottregulations in every jurisdiction where we operate. Employees must ensure thattransactions involving goods, services, software and technology comply with allrelevant laws, including obtaining necessary licenses or approvals whenrequired.

Violations of trade compliance laws can result in severepenalties and we expect all employees to act with integrity, exercise cautionand seek guidance when in doubt.

For more information, please see our Sanctions CompliancePolicy.

Conflicts of Interest

Employees have a duty to act in the best interests of thecompany, prioritizing its success over personal gain. A conflict of interestarises when personal relationships, financial interests, or outside engagementscould interfere, or appear to interfere with objective decision-making for thecompany.

Decisions should always be made based on what is best for thecompany, not personal benefit. Employees must never use their position forimproper personal advantages, either for themselves or others, including familymembers or organizations in which they have significant involvement.

Conflicts can be actual (direct and existing), potential (coulddevelop into a conflict) or perceived (appears to be a conflict, even if itisn’t). All types of conflicts can harm both the company’s and the employee’sreputation. Examples include:

• Holding a position (director, advisor,employee, contractor) at a company that has a business relationship with orcompetes with our company.
• Owning stock in a competitor, customer,partner, vendor or acquisition target.
• Influencing business decisions forpersonal benefit or to favor a company in which you have financial interests.
• Engaging in private financial transactionswith colleagues that could interfere with work or violate regulations.
• Developing personal relationships withsubordinates, competitors or customers that might compromise judgment.
• Knowing of plans to hire a family memberor close associate for a position that reports directly or indirectly to you.
• Exploiting business opportunitiesdiscovered through your position for personal gain instead of benefiting thecompany.

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 If you are aware of an actual, potential or perceived conflict,do not proceed with the activity until you have disclosed it. Please consultwith your manager, the Compliance team or the Legal Department for guidance.

Confidentiality

Confidential information is one of our most valuable assets,and it is the responsibility of every employee to protect it.

Confidential information includes non-public information thatcould benefit competitors or harm our company or customers if disclosed, suchas:

• Business, marketing and servicestrategies;
• Financial details, such as actual costsand revenue strategies;
• Product designs, engineering concepts,technical roadmaps and innovations;
• Operational methods and internalprocesses;
• System architectures, strategic frameworksand internal workflows;
• Source codes, object codes and databases,including those classified as open-source;
• Lists of customers and other businesscontacts;
• Personal data relating to employees andcustomers;
• Intellectual property, including patents,trademarks and copyrights;
• Any additional data derived from orrelated to confidential business information.

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Additionally, employees may come across confidentialinformation about other companies we work with. This information must betreated with the same level of confidentiality as our own. Even the fact thatwe are in discussions with another company should not be disclosed withoutauthorization.

Confidential and proprietary information must never be sharedor disclosed unless it has been made public through approved channels.Employees should only discuss such information with colleagues who have alegitimate business need to know. Unauthorized use, sharing or distribution,whether intentional or accidental, could be illegal and may result in civil orcriminal penalties.

To prevent accidental disclosure, you should:

• Avoid discussing sensitive information inpublic or semi-public places.
• Be cautious when handling emails andinternal communications, treating them as confidential.
• Never forward or share confidentialcontent outside the company unless it is necessary for legitimate businessreasons.

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Protecting confidential information is essential to maintainingour competitive advantage, legal compliance and the trust of our customers andpartners. If you are unsure whether certain information is confidential,consult with the Legal or Compliance team before sharing it.

Assets and IntellectualProperty

Employees are responsible for protecting and using companyassets appropriately. Physical assets, such as computer equipment, products andbuildings, should be used only for legitimate business purposes, with limitedpersonal use permitted when appropriate.

Employees must not misuse, exploit or personally benefit fromthe company’s intellectual property, including source code, technology,corporate name, brand names or trademarks.

When acting on behalf of the company or using company computingor communication systems, employees are prohibited from:

• Gaining unauthorized access to anotherorganization’s internal computer systems or resources (hacking).
• Engaging in unlawful or unethicalactivities, such as harassment, libel, fraud, sending unsolicited bulk emails(spam), or accessing materials that could harm personal or company reputationif made public.
• Participating in illegal activities,including trafficking contraband or espionage.

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Employees must also respect the intellectual property andassets of others, ensuring there is no unauthorized use or misappropriation.

If you become aware of misuse or unauthorized access to companyor third-party assets, report it immediately to your manager or the Complianceteam.

Side Deals

Employees must ensure that all agreements, promises andcommitments made on behalf of the company are formally documented in executedcontracts, purchase orders or other approved legal documents.

Employees must not create verbal or written commitments thatestablish new agreements or alter existing ones without proper authorizationand review by the Legal Department. Any modifications to company agreementsmust follow the official approval process.

Sustainability andEnvironmental Compliance

We are committed to protecting the environment and responsiblymanaging natural resources in line with our core values. Guided by thiscommitment, we continuously work to reduce our environmental footprint acrossour operations and products.

You are expected to:

• Comply with all environmental laws andcompany policies related to sustainability, waste management, emissions andresource conservation.
• Minimize environmental impact by usingresources efficiently, reducing waste and supporting energy-saving initiatives.
• Properly handle hazardous materials andwaste in accordance with safety regulations and company guidelines.
• Report any environmental risks orviolations to the appropriate department to ensure corrective action is taken.
• Support company sustainability initiativesby engaging in environmentally responsible practices at work and encouragingsustainable solutions.

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Responsible Use of GenerativeAI

Generative Artificial Intelligence (GenAI) refers to AI systemscapable of creating various forms of content, including text, images, audio andother media, based on the data they have been trained on. While this technologyoffers vast opportunities across industries, it remains in a state ofcontinuous development. As such, it must be used with caution and in alignmentwith our ethical principles.

You are required to follow the Guidelines on the ResponsibleUse of Generative AI and must not utilize GenAI for any activities that wouldconflict with existing policies. The use of GenAI must be conducted in atransparent and accountable manner. Any past or future implementation of GenAIwithin business operations must be disclosed.

Additionally, outputs generated by AI must be carefullyreviewed to mitigate potential risks, such as inaccuracy, bias, accountabilityconcerns and violations of open-source software licenses.

For further clarification or guidance, please reach out to theLegal, Privacy or Information Security teams.

Fair Dealing

We are committed to conducting business fairly and honestly,ensuring that our success is based on the quality of our products and services,not on unethical or illegal business practices.

Employees must not acquire, use or attempt to obtainproprietary information or trade secrets through improper means. Pressuring orencouraging current or former employees of other companies or any otherindividuals, to disclose confidential information is strictly prohibited.

If you come across trade secrets or confidential informationbelonging to another business or customer or if you are unsure about handlingsuch information, seek guidance from your manager, Compliance team or the LegalDepartment immediately.

Antitrust and Competition

We are committed to conducting business in full compliance withantitrust and competition laws, which protect fair competition, innovation andconsumer choice. These laws ensure that customers receive the best products andservices at competitive prices.

To comply with these laws, the company strictly prohibits anyagreements, coordinated practices or informal understandings with competitorsthat could unfairly restrict competition. The following are not permitted,whether formal or informal, written or oral:

• Price fixing, customer or vendorallocation, market allocation.
• Agreements to eliminate competitors, limitproduction, reduce quality or restrict capacity.
• Agreements on compensation or employmentterms with another company.

Violating competition laws can lead to severe penalties,including criminal charges, administrative fines and lawsuits. In some cases,fines may be tripled and violations can significantly damage our reputation andbusiness operations.

If you are unsure whether a business practice complies withcompetition laws, seek guidance from the Legal Department or Compliance beforeproceeding.

Human Rights

We are committed to respecting and promoting human rights inall aspects of our business operations. Our actions align with internationallyrecognized human rights principles, including those outlined in the UnitedNations Universal Declaration of Human Rights and the International LabourOrganization’s core conventions.

We do not tolerate any form of forced labor, child labor, humantrafficking or discrimination. We strive to ensure fair wages, safe workingconditions and freedom of association for all employees. Employees and businesspartners are expected to uphold these values.

If you become aware of any human rights violations or risks,you must report your concerns to Compliance immediately.

Diversity and Inclusion

We are dedicated to creating a workplace that embracesdiversity, fosters inclusion and ensures equal opportunities for all. Werecognize that individuals bring unique perspectives, backgrounds andexperiences that enrich our company and drive innovation. Our commitment todiversity extends across all aspects of our business, ensuring that everyone,regardless of race, gender, age, disability, sexual orientation, religion, orany other protected characteristic, is treated with fairness, dignity andrespect.

Discrimination, harassment or exclusion of any kind has noplace in our workplace. We actively promote policies and practices that supportequity in hiring, career advancement and decision-making.

We encourage open dialogue, collaboration and accountability toensure that every individual feels a sense of belonging. Employees are expectedto uphold these principles and report any concerns related to discrimination orbias without fear of retaliation.

Harassment-Free Workplace

We are committed to maintaining a workplace that is free fromharassment, intimidation and any form of inappropriate behavior. Harassment,whether verbal, physical, visual or online, will not be tolerated under anycircumstances. This includes, but is not limited to, unwelcome comments,offensive jokes, bullying, threats, inappropriate physical contact or anyconduct that creates a hostile or uncomfortable work environment.

Our zero-tolerance policy applies to all interactions in theworkplace, including those involving employees, clients and business partners.

We encourage employees to speak up and report any concernsrelated to harassment without fear of retaliation. Complaints will be takenseriously, investigated promptly and addressed with appropriate action.

Health and Safety

Employees must comply with all applicable health and safetyregulations, follow company policies and use protective equipment as required.Hazardous conditions, unsafe practices or workplace injuries must be reportedimmediately to prevent harm and ensure corrective action is taken. We alsopromote a culture of well-being, encouraging employees to prioritize bothphysical and mental health.

Substances in the Workplace

Employees are expected to avoid illegal or controlledsubstances that could impair their ability to perform their job effectively.Possessing, using, soliciting, distributing or manufacturing illegal drugs orsubstances in the workplace or while working is strictly prohibited.

Addressing Concerns

We do not tolerate malpractice or wrongdoing in any part of thecompany. If you witness or experience something concerning at work, our SpeakUp Policy outlines how you can report it safely and confidentially.

For employees, concerns should normally be raised through yourline manager, their manager or your HR business partner. If these channels arenot appropriate, you should refer to the Speak Up Policy for alternativereporting options.

Employees can be assured that no one will face penalties forraising a concern in good faith, even if it turns out to be a mistake. Concernsshould not be raised for personal grievances, and any malicious falseallegations will result in disciplinary action.