Supplier Code of Conduct

Overview, Purpose and Scope

Socure Inc. (“Socure”) expects Suppliers with whom it has a business relationship to act in good faith and conduct business honestly and ethically. At Socure, we strive to maintain a reputation of fairness, respect, responsibility, integrity, trust, and sound business judgment. Doing things the right way is not just policy at Socure, it’s part of our culture and Socure’s success and reputation depend on it.

This Supplier Code of Conduct (“Code”) sets out Socure’s expectations with regards to its suppliers, including its service providers, vendors, and any other entities and/or individuals not employed by Socure who provide goods and services to Socure (collectively referred to herein as, “Suppliers”).

Expectations and Responsibilities

Law and Ethics

Socure expects its Suppliers to comply with all applicable laws and regulations that apply to their business operations. Socure strives to ensure that its Suppliers are not named on any sanctions and/or related restricted parties list, including without limitation, Specially Designated Nationals and Blocked Persons List maintained by the Office of Foreign Asset Control of the U.S. Department of the Treasury, or other related authority. Suppliers should not be located, organized, residing, or doing business in any country or territory subject to U.S. trade embargoes, which currently includes, Crimea, Cuba, Iran, North Korea, Russia, and Syria (collectively “Sanctioned Countries”).

Conflicts of Interest

Suppliers should avoid any relationship or activity that might impair, or even appear to impair, one’s ability to make objective and fair decisions. If a Supplier has or becomes aware of an actual or potential conflict of interest with Socure or its employees or representatives, they are encouraged to report the details to corporatecompliance@socure.com in a timely manner.

Anti-Corruption & Anti-Bribery

Socure expects Suppliers to comply with the U.S. Foreign Corrupt Practices Act, 1977 (“FCPA”), UK Bribery Act, and other applicable anti-bribery, anti-corruption laws and regulations. Suppliers should neither offer, nor accept any bribes, kickbacks, or improper advantages in the course of their engagement(s) with Socure. Suppliers are expected to oversee the conduct of their employees, affiliates, and subcontractors to ensure adherence to all applicable laws related to corruption and bribery.

Intellectual Property and Confidential Information

Socure respects the rights of others regarding their intellectual property and confidential information and expects its Suppliers to do the same. Suppliers may not use or access the confidential information or intellectual property of others without prior authorization – this includes trade secrets, trademarks, patented technology or copyrighted materials of any kind. Suppliers should additionally protect such information within their control from unauthorized disclosure using reasonable administrative, technical, and physical safeguards. Where Supplier shares any intellectual property or confidential information with Socure, Supplier must ensure that it is authorized to do so and that any third party sources or owners thereof are clearly disclosed. Unauthorized access, use or disclosure of any intellectual property or confidential information should be reported to Socure immediately upon discovery.

No Harassment, Discrimination, or Retaliation

Socure is an equal opportunity employer and treats all employees equally regardless of age, race, creed/religion, color national origin, alienage or citizenship status, sexual orientation, military/veteran status, sex/gender, gender identity, gender expression, disability, genetic information/genetic predisposition or carrier status, marital status, partnership status, victim of domestic violence, or other characteristics protected by applicable law.

Suppliers should strive to maintain a work environment that is free from unlawful discrimination, harassment, intimidation, and bullying. In keeping with this commitment, Socure does not tolerate discrimination or retaliation against its employees by anyone, including any member of management, co-workers, contractors, vendors, or customers. Suppliers should have a process in place to ensure complaints, concerns, and allegations may be reported in a safe and confidential manner in accordance with applicable law.

Freedom of Association & Human Rights

Socure respects the legal rights of its employees to freely associate with and/or join worker organizations or labor unions. Socure is committed to ensure that there is no modern slavery and/or human trafficking in any element of its business operations. Socure expects that its Suppliers will not accept any use of forced or bonded labor, prisoners, illegal workers, or child labor and will adhere to applicable local laws, regulations, and standards concerning working hours and conditions for all workers.

Reporting

If you become aware of any circumstance inconsistent with this Code, you are encouraged to report such alleged conduct as follows:

1. Contact corporatecompliance@socure.com.

2. If you wish to report anonymously, please raise your concern via Integrity Counts – an independent third-party vendor aimed at facilitating reporting of potential illegal or unethical misconduct.