Ethical Trading Policy

POLICY STATEMENT

Exabeam recognizes that our commercial activities have potential to impact our suppliers and our locality. As a socially responsible business, our suppliers, local community and customers have a right to expect that all workers involved in the delivery of products and services provided by Exabeam are treated with full consideration to their basic human rights. Exabeam represents and warrants that it shall comply with all governmental regulations and laws. Further, Exabeam acts in an ethical manner above and beyond basic legal requirements in areas including health and safety, labor, ethics, and the environment. Exabeam is committed to implementing the principles of the Ethical Trading Initiative Base Code with its operations, and Exabeam also routinely audits vendors, and performs pre-checks before engaging, to know that our vendors conform to, or exceed, the following policies and protocols.

CODE OF PRACTICE

This Code of Practice applies to staff: (1) directly employed by Exabeam on temporary or permanent basis; and (2) employed or provided by contractors or employment agencies to work on Exabeam premises or to undertake work for or on behalf of Exabeam. (collectively, “Staff”)

LABOR

Employment Is Freely Chosen – No forced, bonded or involuntary labor shall be used. Staff are not required to leave deposits or identity papers with us. Staff are free to leave employment, and Exabeam only requests reasonable notice.

Child Labor Shall Not Be Used – There shall be no recruitment of child labor. Individuals under 16 are not employed at any time. Individuals under 18 shall not be employed at night or in hazardous conditions.

Living Wages Are Paid – Staff pay rates are equal to or above the national legal minimum standards. Staff are given information about their employment conditions in respect to wages. No deductions are made from wages as a disciplinary measure, and payment stubs detailing lawful deductions are provided for each pay period. Staff are given clearly understandable written terms and conditions of employment that detail the employment relationship and the respective obligations of the employee and employer.

HEALTH & SAFETY

Working Conditions Are Safe and Hygienic – Reasonable steps are taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work by minimizing, so far as is reasonably practicable, the causes of hazards inherent in the working environment. Staff have access to clean and safe toilet facilities and drinking water. Exabeam has a published Health & Safety Policy as part of all employee handbooks—as training (regular and recorded).

Working Hours Are Not Excessive – Staff are not forced to work in excess of 48 hours per week, and Exabeam provides staff with all details related to working hours through the employee handbook.

No Harsh Or Inhumane Treatment Is Allowed – Physical, verbal and sexual threats, abuse, harassment or intimidation is expressly prohibited and grounds for summary dismissal or removal of a vendor or Staff, if proved.

ETHICS

No Discrimination Is Practiced – There is no discrimination in use of vendors, pay, hiring, compensation, access to training, promotion, and termination of employment or retirement on the grounds of race, nationality, ethnicity, religion, age, gender, disability, marital status, pregnancy, sexual orientation, gender identity or expression, union membership, covered veteran status, protected genetic information, or political affiliation. Opportunities for personal and career development are equally available to all employees.

California Supply Chain Transparency Act – Exabeam supports this act which was created to help eradicate human trafficking and slavery worldwide. We require direct vendors to certify that materials incorporated into their product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

Conflict Minerals – When applicable, vendors shall exercise due diligence with their relevant suppliers consistent with OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

Anti-Counterfeit – Exabeam requires that the vendors must meet or exceed the DoD Counterfeit Prevention Policy 4140.67.

Anti-Bribery – Staff must never, directly or through intermediaries, offer or promise any personal or improper advantage in order to obtain or retain business or other advantages from a third party, whether public or private. Staff will not pay or accept bribes, arrange or accept kickbacks, and shall not take any actions to violate, or cause its business partners to violate, any applicable anti-bribery laws and regulations including the U.S. Foreign Corrupt Practices.

Diversity – Exabeam believes that diversity and inclusion drive innovation and cutting-edge ideas. This is why we have a strong commitment to building a culture where differences are celebrated and respected. The diverse voices of our employees allow Exabeam to deliver on our mission of empowering enterprises to detect, investigate and respond to cyber-attacks more efficiently so their security operations and insider threat teams can work smarter. Exabeam will work with suppliers to ensure they have diversity initiatives. For example, Exabeam may survey our suppliers or collect their diversity initiatives from their websites and track those that have programs in place. When Exabeam sources diversity data directly from manufacturers, we will ask if they identify themselves as part of any established diversity group.

ENVIRONMENT

Exabeam maintains compliance with applicable environmental laws, regulations and other obligations, but also strives to continually improve and operate its business in an environmentally responsible manner. Exabeam requires vendors comply with all applicable legal environmental requirements and demonstrate continual improvement of its environmental performance.

RESPONSIBLE BUSINESS ALLIANCE

Exabeam declares its support for the RESPONSIBLE BUSINESS ALLIANCE® CODE OF CONDUCT and actively pursues conformance to the RBA Code and its standards in accordance with a management system as herein. For more information, please review the RBA Code at:

http://www.responsiblebusiness.org/media/docs/RBACodeofConduct6.0_English.pdf

Exabeam will use commercially reasonable efforts to notify third-parties of confirmed violations of this Code of Practice only to the extent that such violations materially impact third-party data.

Version 211206