CODE OF CONDUCT

Version: 1.1, Effective Date: 1st March 2022

1. INTRODUCTION

1. Bloomreach always respects applicable laws and requires its Business Partners to comply with the applicable laws as well. Compliance with all applicable laws and regulations must never be compromised.

2. Bloomreach likewise requires all its Business Partners to operate in accordance with the principles set out in this Code of Conduct. The Code of Conduct does not replace legislation and if the two are in conflict, legislation takes precedence. If the Code of Conduct sets a higher standard than the existing legislation, the reverse applies. The Code of Conduct is valid in the English language. Where there are different language versions of this document, these shall be considered as translations only.

2. TO WHOM IS THIS POLICY/PROCEDURE RELEVANT

1. The Code of Conduct applies to all our customers, consultants, distributors, agents, partners that provide products or services to Bloomreach, or that are engaged or instructed to act for or on behalf of Bloomreach, suppliers (and sub-contractors if used while engaging with Bloomreach), and other representatives (“Business Partners”).

3. CODE OF CONDUCT

1. Human Rights and Labour Standards

1. Workers’ contracts, working hours and compensation

Bloomreach expects its Business Partners to comply with local laws and regulations regarding workers’ contracts, working hours, including overtime and overtime compensation. Salaries should be paid regularly and comply with the applicable local legislation and the local market situation. Workers should be entitled to a minimum of one day off in seven days and to take time off for established national and local holidays. Workers should be granted the stipulated annual leave, sick leave and maternity/paternity leave without any negative repercussions.

2. Discrimination and Harassment

1. Diversity and gender balance

Bloomreach values and promotes diversity. This includes gender balance. Bloomreach gives priority to the underrepresented gender given equal qualifications and promotes diversity in the recruitment process. Bloomreach requires all its Business Partners to promote diversity and gender equality.

2. Discrimination, harassment and respect for others

Bloomreach expects its Business Partners to provide a work environment where everybody should be treated with respect and dignity and be given fair and equal opportunities for development. Bloomreach respects feelings and actions of others and does not tolerate any form of discrimination or harassment in the workplace. Business Partners of Bloomreach must not discriminate on the basis of origin, nationality, religion, race, gender, age or sexual orientation, or engage in any kind of verbal or physical harassment based on any of the above or any other potentially discriminatory reason.

3. Addictive substances, guns, porn

1. Alcohol and/or drug abuse, guns, porn

Bloomreach has zero tolerance on drugs, alcohol (except for beer and wine), guns, and porn and does not allow individuals who produce, sell, distribute, offer or are otherwise associated with drugs, alcohol (except for beer and wine), guns, and porn to sell products to Bloomreach or to provide services to Bloomreach, to be on company premises or to be affiliated with Bloomreach in any way.

4. Environment

1. Environment and sustainability

Bloomreach shall meet legal environmental requirements and expects its Business Partners to obtain, keep current, and comply with all required environmental permits and licenses needed for their operations. Bloomreach encourages the development of environmentally friendly technologies and recommends all its Business Partners with significant environmental impact to implement certifiable environmental management systems or similar systems that facilitate the Business Partners’ work with the environment.

Bloomreach continuously seeks ways to reduce the consumption of resources. Bloomreach expects its Business Partners to strive to reduce its consumption of resources, including energy, waste and water, prevent pollution, have noise levels at acceptable levels and improve the overall environmental impact of its operations and products along the value chain. Further, chemicals and hazardous materials shall be labelled properly and safely stored, and recycled, reused and disposed of correctly.

5. Business Ethics

1. Competition and antitrust legislation

Bloomreach is prepared to compete successfully in today’s business environment and will always do so in compliance with applicable antitrust, competition and fair dealing laws. Bloomreach does not engage in unfair, misleading or inaccurate comparisons, anti-competitive agreements or arrangements and requires that its Business Partners do the same. Business Partners must avoid any kind of anti-competitive agreement or concerted practice, tacit or otherwise.

2. Bribery and Fraud

Bloomreach does not accept bribes, facilitation payments or extortion in any form, be it as a giver/initiator or as a receiver. Bloomreach does not accept fraud in any form and expects Business Partners to behave in the same way.

6. Confidentiality

1. Confidential information

Confidential information consists of any information that is not or not yet in the public domain. It includes trade secrets, business, marketing and service plans, consumer insights, engineering and manufacturing ideas, product recipes, designs, databases, records, salary information and any non-published financial or other data.

Bloomreach respects that third parties have a similar interest in protecting their confidential information. In case that third parties, such as suppliers or customers of Bloomreach share confidential information with Business Partners of Bloomreach, such information shall be treated with the same care as if it was confidential information of Bloomreach.

7. Misrepresentation

1. Authenticity

Bloomreach always represents itself to its Business Partners and customers with authenticity. It has zero tolerance to misrepresentation in any form and expects its Business Partners to conduct themselves genuinely avoiding false perceptions.

2. Integrity

Bloomreach is committed to the quality of truthfulness guided by moral convictions. Bloomreach upholds moral uprightness and requires all its Business Partners to conform with values of true honesty and accuracy.