Pendo Vendor Code of Business Conduct and Ethics

Last Updated: February 1, 2025

At Pendo, we are committed to excellence, integrity, and innovation in our products and services. We hold our vendors to the same high standards of ethical conduct and compliance that we set for ourselves. This detailed Vendor Code of Business Conduct and Ethics outlines the principles and expectations that guide our vendor relationships. This Code applies to all Pendo suppliers of products or services, including independent contractors, consultants, licensees, regardless of their title or the product or services they provide (“Vendors”). We also expect our Vendors to encourage third parties they work with to comply with our standards.

I. ETHICAL BUSINESS PRACTICES

Vendors must conduct their business ethically, with integrity, honesty, and in full compliance with all applicable laws and regulations. These include, but are not limited to, laws covering bribery and kickbacks, copyrights, trademarks and trade secrets, information privacy, insider trading, illegal political contributions, antitrust prohibitions, foreign corrupt practices, offering or receiving gratuities, environmental hazards, employment discrimination or harassment, occupational health and safety, false or misleading financial information or misuse of corporate assets.

II. REPORTING AND NON-RETALIATION

We expect our Vendors to uphold our values and we rely on this Code to establish a framework for ethical conduct. If you become aware of, or suspect, a violation of this Code or other unethical or unlawful conduct by Pendo, whether by its employees or any third-party in connection with Pendo’s business, we encourage you to report your concerns. We are committed to creating an environment where issues can be raised without fear of retaliation. Reports can be made to Pendo’s Ethics Reporting Line (“EthicsPoint”): http://pendo.ethicspoint.com/, an anonymous confidential platform. Pendo will thoroughly investigate all matters submitted via EthicsPoint and respond appropriately.

We strictly prohibit any form of retaliation against individuals who report concerns in good faith.

III. PROTECTING PROPERTY AND INFORMATION

Vendors are responsible for safeguarding both Pendo property (including any Pendo-issued equipment or systems) and privileged/confidential information, assets, and data entrusted to them by Pendo or by third parties. Additionally, Vendors must comply with all applicable data privacy and information security laws and regulations.

Confidential Information can include, but is not limited to, sales goals/marketing plans, contracts, intellectual property, personnel information, business plans/strategies, financial information, and any non-public information. Confidential Information should be used solely for authorized purposes and should not be disclosed or distributed except when disclosure is authorized by Pendo or required by applicable law, rule, regulation, or pursuant to an applicable legal proceeding.

IV. ANTITRUST, FAIR DEALING, AND TRADE CONTROLS.

At Pendo, we are committed to competing fairly and complying with antitrust and competition laws and regulations and we expect the same from our Vendors.

INTERNATIONAL TRADE COMPLIANCE AND ANTI-CORRUPTION

Vendors engaged with Pendo are required to comply with international trade regulations, including import, export, and financial transaction laws. The United States and other nations where Pendo operates have strict prohibitions against participating in boycotts not sanctioned by the U.S. government or engaging with entities under sanctions. Vendors must be knowledgeable about and comply with all relevant tax, verification, licensing, and permit requirements associated with international trade.

Economic and trade sanctions, as enforced by the U.S., the UN, the EU, and other global authorities, include country-specific, regional, and list-based programs targeting terrorism, arms embargoes, travel restrictions, asset freezes, and blocked property. Pendo adheres to these regulations and expects its vendors to do the same, even if it impacts business opportunities.

Vendors must also observe laws governing the export of encryption controls, which regulate the transfer of encryption items, including technology and software with encryption capabilities, to foreign entities or nationals. Compliance with these laws is crucial to maintain Pendo’s export privileges and avoid legal penalties.

AVOIDING BRIBERY AND CORRUPTION

Pendo strictly prohibits bribery, facilitation payments, kickbacks, or any form of corrupt practices. Such actions are illegal and contravene Pendo’s Anti-Bribery and Corruption Policy. As Pendo operates globally, adherence to international anti-corruption laws, including the U.K. Bribery Act, the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, and the U.S. Foreign Corrupt Practices Act, is mandatory. These laws forbid offering bribes to any individual, including government officials and private sector employees, to influence business outcomes.

Vendors must not offer or accept any form of payment or benefit intended to improperly influence a business relationship with Pendo. This includes, but is not limited to, contracts, incentives, and hospitality. While it may sometimes be appropriate to exchange business courtesies, Vendors should not offer gifts or entertainment to Pendo employees that could influence or appear to influence business decisions. Any gifts or entertainment must be modest, infrequent, and comply with Pendo’s policies. Any form of bribery can result in severe legal consequences and reputational damage.

Should you require clarification on any transaction or Pendo’s Anti-Bribery and Corruption Policy, contact Pendo’s legal department for guidance. It is imperative to ensure all dealings are lawful and align with Pendo’s ethical standards. If you suspect any violations of this section or anti-bribery regulations within Pendo’s supply chain, please report it to Pendo immediately.

CONFLICTS OF INTEREST

Pendo vendors are required to conduct their business dealings with Pendo in a manner that is consistent with Pendo’s best interests and to uphold the highest standards of integrity and ethics. Vendors must avoid any actions or situations that could lead to, or appear to lead to, a conflict of interest. A conflict of interest occurs when a Vendor’s personal interests, or those of their family members or close associates, could potentially influence or conflict with the best interests of Pendo and its stakeholders.

Such conflicts may arise from various situations, including but not limited to personal investments, external consulting or employment, board memberships in other organizations, starting an independent business, or accepting or providing gifts or hospitality from or to entities with whom Pendo has a current or prospective business relationship. Additionally, forming romantic relationships with Pendo employees or business partners that could affect business decisions may also constitute a conflict of interest.

If there is any uncertainty regarding a potential conflict of interest, Vendors are expected to promptly seek guidance from internal Pendo resources.

V. FINANCIAL INTEGRITY & ACCOUNTING

FINANCIAL STATEMENTS

Pendo must report any and all financial transactions with accurate, clear, and complete information about Pendo’s business, earnings, and financial condition in accordance with applicable laws and Pendo internal controls. As a Vendor of Pendo, we require you to adhere to these standards as well and maintain accurate records of all your business dealings with Pendo. Misrepresentations, omissions and/or inaccuracies of any kind may lead to civil or criminal liability.

For additional information on any actual or potential financial issue related to accounting or record-keeping, please contact your internal Pendo resource.

INSIDER TRADING

Insider Trading means buying or selling securities, or telling others to buy and sell securities, while in possession of material nonpublic information and is considered illegal.

As a Vendor, you might gain access to confidential, non-public information regarding Pendo or other entities. Such information is deemed material if a reasonable investor would likely find it significant when determining whether to buy, sell, or retain securities of a company. It is imperative that you refrain from buying or selling securities when in possession of any material, non-public information. Additionally, you must not disclose this information to others who could potentially use it for trading purposes.

If you have any doubt whether nonpublic information you possess is material, do not trade on or pass along that information. Please contact Ethicspoint.

VI. WORKPLACE ENVIRONMENT

EQUAL EMPLOYMENT AND NON-DISCRIMINATION

Pendo is dedicated to fostering a culture of belonging, respect, and support, ensuring everyone is valued. We engage with vendors who echo this ethos. Our vendors must adhere to all relevant employment and safety regulations, champion human rights, and cultivate diversity and inclusion in their workplaces. We also require our vendors to actively prohibit, discourage, and address any instances of hate speech or violence, whether onsite or via electronic and data communication channels.

As an Equal Employment Opportunity employer committed to a diverse workforce, we prioritize vendors who incorporate diversity into their recruitment and supply chain practices, considering factors such as race, ethnicity, religion, disability, and sexual
orientation.

HUMAN RIGHTS & LABOR PRACTICES

Pendo is committed to the protection of human rights and fair and ethical labor practices and we expect the same of our contractors, and Vendors. While working with Pendo, you must comply with the ILO Declaration on Fundamental Principles and Rights at Work and conduct your business operations consistent with the intent and spirit of the United Nations Global Compact and Universal Declaration of Human Rights. Pendo does not tolerate inhumane treatment or practices of workplace employees, whether within our business or our supply chain. For more information, please refer to our Statement on Modern Slavery & Human Trafficking.

ACCESSIBILITY

Pendo is dedicated to creating an accessible and inclusive environment for all users, including those with disabilities. Our vendors play a crucial role in this effort and are expected to adhere to the following guidelines, which are informed by Pendo’s own approach to accessibility:

Accessibility Standards: Suppliers are expected to comply with all applicable accessibility laws, standards, and regulations, such as the Americans with Disabilities Act (ADA) and the Web Content Accessibility Guidelines (WCAG).

Communication: Suppliers must offer accessible communication channels for customers with disabilities. This includes providing alternative formats for printed materials, sign language interpreters, captioning, and audio descriptions for videos, as well as ensuring digital content is accessible.

Physical Accessibility: Suppliers must ensure their physical spaces are accessible, providing accessible parking, entrances, restrooms, and removing architectural barriers.

WORKPLACE HEALTH & SAFETY

We also expect our Vendors to fully comply with all safety and healthplace-related laws, regulations, and practices to ensure that workers are provided with a safe and healthy work environment. These laws, practices, and regulations include those applicable to the areas of occupational safety, emergency preparedness, occupational injury and illness, industrial hygiene, physically demanding work, machine safeguarding, sanitation, and food safety.

ENVIRONMENTAL SUSTAINABILITY

Pendo recognizes the duty we have to our environment and we have always been invested in ways to reduce our environmental impact on the world around us. At a minimum, we expect all of our vendors to comply with all applicable environmental laws, regulations, and guidelines. Vendors should have their own environmental management system, including goals to reduce environmental impact, measures and controls, and training. These measures include requirements regarding chemical/waste management and disposal recycling, industrial wastewater treatment and discharge, air emissions controls, environmental permits and environmental reporting.

VII. ACKNOWLEDGEMENT AND COMPLIANCE

Vendors must formally acknowledge their understanding and agreement to comply with this Code of Conduct. Pendo reserves the right to terminate relationships with vendors who fail to adhere to these standards.