Code of Conduct

Guiding Principles

Put Human Before Business

Success is "what happened" not "what was achieved"

Do your best to deliver what you have promised

Keep exploring new ways to drive excellence

Be strong and candid to say things as they are

Set the example that business achieve more with Ethics

We make judgements free from discrimination and dis-honesty

Code of Conduct

Employees of Ethos KMS and its subsidiaries and controlled affiliates (“Ethos”) should do the right thing – follow the law, act honorably, and treat co-workers with courtesy and respect.

We expect all of our employees and Board members to know and follow this Code of Conduct. Failure to do so can result in disciplinary action, including termination of employment. Any waivers of this Code for directors or executive officers must be approved by our Board.

I. Avoid Conflicts of Interest

When you are in a business situation in which competing loyalties could cause you to pursue a personal benefit for you, your friends, or your family at the expense of Ethos KMS or our users, you may be faced with a conflict of interest. All of us should avoid conflicts of interest and circumstances that reasonably present the appearance of a conflict.

When considering a course of action, ask yourself whether the action you’re considering could create an incentive for you, or appear to others to create an incentive for you, to benefit yourself, your friends or family, or an associated business at the expense of Alphabet. If the answer is “yes,” the action you’re considering is likely to create a conflict of interest situation, and you should avoid it.

Ensure Financial Integrity and Responsibility

Ensure that money is appropriately spent, our financial records are complete and accurate, and our internal controls are honored.

If your job involves the financial recording of our transactions, make sure that you’re familiar with all relevant policies, including those relating to revenue recognition.

Never interfere with the auditing of financial records. Similarly, never falsify any company record or account.

If you suspect or observe any irregularities relating to financial integrity or fiscal responsibility, no matter how small, immediately report them.

Obey the Law

Comply with all applicable legal requirements and understand the major laws and regulations that apply to your work. A few specific laws are easy to violate unintentionally and so are worth pointing out here. If you have any questions about these laws or other laws governing our work, please consult the Helpline or our legal counsel.

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