Scale’s Business Partners Code of Conduct

Scale is committed to the highest standards of social and environmental responsibility and ethical conduct. Scale’s vendors, suppliers, service providers, and all other similar parties that provide goods or services to, for, or on behalf of Scale and their subsidiaries, affiliates, and subcontractors to the extent that they also provide goods or services to, for, or on behalf of Scale (collectively, “Business Partners”) are required to provide safe working conditions, treat workers with dignity and respect, act fairly and ethically, protect the privacy and data of Scale’s customers and employees, and use environmentally responsible practices wherever they make products or perform services for Scale in accordance with the principles in this Scale Business Partners Code of Conduct (“Code”) and in full compliance with all applicable laws and regulations.

Conformance with Scale’s Business Partners Code of Conduct

Underlying Obligations. In addition to these responsibilities, business partners must comply with all applicable laws; legal regulations, directives, and guidelines; and all obligations in any contract a supplier may have with us. Where this Supplier Code sets higher standards than what the law provides, scale expects business partners to adhere to such standards. It supplements, but does not supersede, the contracts between Scale and the Supplier.

On-Site Work. Business partners using our properties or facilities will comply with all of our applicable policies and requirements.

Information Disclosure. Business partners will accurately disclose information regarding their labor, health and safety, environmental practices, business activities, structure, financial situation, and performance, in accordance with Business partners industry practices.

Cooperation. Business partners will cooperate with any information requests or audits we may initiate to confirm their fulfillment of these responsibilities. Though we seek to work with business partners to improve conditions, we may terminate our relationship with any supplier that fails to meet these responsibilities.

Business partners must avoid engaging in any activity that would create an actual or apparent conflict of interest regarding their provision of products or services to Scale. A conflict of interest exists where Scale personnel have a financial or close personal interest relating to the Supplier or its personnel, and such relationship could interfere with or influence the award, conduct or oversight of work for Scale. In the event an actual or potential conflict of interest does arise, Supplier must immediately report it to Scale.

LABOR AND HUMAN RIGHTS

Scale is committed to upholding the human rights of workers and treating them with dignity and respect. This applies to all workers, including temporary, migrant, student, contract, direct employee, and any other type of worker. As a result, business partners must manage their own workforce in order to achieve the following results:

Freely Chosen Employment and Combating Modern Slavery. Business partners will not use or permit any form of forced, bonded, or indentured labor. All work must be voluntary, and all workers must be free to terminate their employment at any time. Business partners will not hold workers’ identity, immigration, or work permit documents longer than reasonably necessary for administrative processing. Business partners are expected not to require workers to pay recruitment fees or other fees for their employment, either directly or through third parties, and are expected to repay any worker that has paid such fees. Business partners will not unreasonably restrict workers’ freedom to move into, out of, or at working facilities. As part of the hiring process, business partners are expected to give each worker a written agreement describing the worker’s terms of employment in a language understood by the worker, and, if internationally relocating, the written agreement will be provided before they leave their country of origin.

Young Workers and Student Interns. Business partners will not use child labor. “Child” means any person under age 15, under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. Workers under the age of 18 will not perform work that is likely to jeopardize their health or safety, including night shifts and overtime. Business partners may use legitimate, properly-managed apprenticeship programs, such as student internships. Unless otherwise addressed by local law, business partners are expected to pay student workers, interns, and apprentices at least the same wage rates as other entry-level workers performing equal or similar tasks.

Wages. Business partners will pay legally-mandated wages and benefits, will comply with the law regarding wage deductions, and will provide workers with the basis on which workers are paid via pay stub or similar documentation. Business partners are expected not to deduct from wages as a disciplinary measure.

Working Hours. Except in emergency or unusual situations, for business partners’ workers paid hourly, workweeks are expected not to exceed 60 hours per week (including overtime) or, if less, the maximum set by local law. Workers should be allowed at least one day off every seven days.

Fair Treatment, Non-Discrimination, Diversity and Inclusion. Business partners will not permit harassment, abuse, corporal punishment, or inhumane treatment. Business partners will not subject workers or potential workers to unlawful medical tests or physical exams. Business partners will not discriminate in screening, hiring, or employment practices based on race, color, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, ethnicity, national origin, caste, disability, genetic information, medical condition, pregnancy, religion, political affiliation, union membership, covered veteran status, or body art. Workers’ religious practices will be reasonably accommodated. Business partners will not inquire about potential workers’ criminal histories on employment applications or before initial interviews, or, if no interview is conducted, before making conditional offers of employment. In addition, business partners will demonstrate a commitment to identify, measure, and improve a culture of diversity and inclusion through all aspects of workplace management.

Freedom of Association and Collective Bargaining. Workers will be permitted to associate freely, bargain collectively, and seek representation in accordance with local laws. Business partners are expected to permit workers to openly communicate and share grievances with management about working conditions without fear of reprisal or harassment.

HEALTH AND SAFETY

Business partners will integrate the following health and safety management requirements into business processes to provide workers with a healthy and safe work environment:1) Occupational Safety and Health. Business partners will comply with all applicable safety and health laws and regulations, and identify, evaluate, and control worker exposure to safety and health hazards, including chemical, biological, physical, and ergonomic stressors, through proper design, engineering controls, maintenance, safe work procedures, and ongoing health and safety guidance. Where these means cannot adequately control hazards, business partners will protect workers with appropriate personal protective equipment and provide them with information about risks to them from these hazards. Business partners will implement procedures to prevent, manage, track, and report occupational injury and illness, including encouraging worker reporting, classifying and recording cases, providing medical treatment, investigating cases, implementing corrective actions, and facilitating workers’ return to work.2) Emergency Preparedness. Business partners will identify and plan for potential emergencies, and will implement emergency plans and provide guidance to workers on emergency response procedures, including emergency reporting, worker notification and evacuation, drills, fire detection and suppression equipment, exit facilities, and recovery plans.3) Sanitation, Food, and Housing. Business partners will provide workers with ready access to clean toilet facilities, potable water, and sanitary food preparation, storage, and eating facilities. If business partners provide workers with residential facilities, those facilities will be clean and safe, with adequate personal space, entry and exit privileges, emergency egresses, heat and ventilation, and hot water for bathing and showering.

ENVIRONMENTAL

Scale recognizes that environmental responsibility is integral to producing world-class products. In manufacturing operations and construction, business partners will strive to create regenerative processes and will minimize adverse effects on the community, environment, and natural resources while safeguarding the health and safety of the public. In addition:Environmental Permits and Reporting. Business partners will obtain and keep current all required environmental permits, approvals, and registrations, and follow their operational and reporting requirements.

Resource Efficiency and Clean Energy. Throughout their operations, business partners will work to reduce consumption of resources, including raw materials, energy, and water. Business partners will track, document, and seek to minimize energy consumption and greenhouse gas emissions, and seek ways to improve energy efficiency and use cleaner sources of energy.

Hazardous and Restricted Substances. Business partners will identify and manage chemicals and other materials that pose a hazard to the environment, to ensure their safe handling, use, storage, and disposal. Business partners will identify, monitor, control, treat, and reduce hazardous air emissions, wastewater, and waste generated from its operations. Business partners will adhere to our requirements restricting use of specific substances, including labeling for recycling or disposal.

Waste Mitigation: Wastewater, Solid Waste and Stormwater Management. Business partners will work to reduce or eliminate waste of all types. Where waste cannot be eliminated, business partners will manage and control all waste streams to comply with applicable laws and regulations, and in an environmentally responsible and secure way; this includes, but is not limited to, preventing illegal discharges and spills from entering storm drains, and treating as required prior to discharge or disposal of all wastewater and solid waste from operations, industrial processes, and sanitation facilities.

ETHICS AND COMPLIANCE

Business partners will uphold the highest standards of ethics to promote honesty and integrity in business operations, including:

Business Integrity. Business partners will avoid even the appearance of conflicts of interest in their work with us, and will immediately disclose any known family or other close personal relationships with our employees who have an influence over their engagements with us. If business partners extend any business courtesies to our employees, they will do so infrequently and the courtesies must be of no more than moderate value. Business partners will also accurately reflect their business dealings in their books and records. Business partners will not offer or accept any form of bribery, corruption, extortion, or embezzlement. Business partners will not make illegal payments directly or indirectly. Business partners will implement monitoring and enforcement procedures to ensure compliance with anti-corruption laws. Violations should be reported to SupplierEthics@scale.com.

Intellectual Property. Business partners will respect intellectual property rights, and will conduct technology and know-how transfers in a manner protecting intellectual property rights.

Responsible Materials Sourcing. Business partners will maintain a policy reasonably assuring that any tantalum, tin, tungsten, and gold in products they manufacture does not directly or indirectly benefit armed groups that commit human rights abuses in or near the Democratic Republic of the Congo. Business partners will exercise, and will make available to us upon request, due diligence on the source and chain of custody of these minerals.

Privacy and Information Security. Business partners will protect the privacy of personal information of everyone with whom they do business, including business partners, customers, consumers, and workers.

Accessibility. Business partners will embed relevant web accessibility standards, innovation, and best practices to deliver inclusive products and services for our users and stakeholders.

MANAGEMENT SYSTEM

Business partners are expected to adopt or establish a management system to carry out these responsibilities. The management system will be designed to ensure business partners’ operations: (a) comply with our requirements and applicable laws and regulations; (b) conform to these responsibilities; and (c) identify and mitigate operational risks related to these responsibilities. It should also facilitate continual improvement:

The management system should contain the following elements: executive level commitment and accountability; processes to identify, monitor, and comply with all applicable laws, regulations, standards, and requirements; risk management processes; communications and training for all workers and business partners as determined by business partners; ongoing assessments, monitoring, and continued improvement, including corrective action processes; a program that provides workers with a means to report grievances anonymously and without fear of retaliation, unless prohibited by law; and a program to ensure business partners will continuously monitor these reporting processes, record issues raised, investigate as appropriate, and take appropriate action.

REPORTING CONCERNS; ENGAGEMENT WITH SCALE

Business partners must promptly report concerns and potential or actual violations of this Supplier Code.

Business partners to anti-corruption laws. Violations should be reported to SupplierEthics@Scale.com or to our independent hotline. Business partners must provide reasonable assistance to any investigation by Scale of a violation of this Supplier Code. Business partners must protect anyone who works for them, either as an employee or a contractor, from any form of retaliation for reporting suspected or actual violations.

We have designed the above portal and hotline to handle questions from any concerned party, including Business partners and members of the public. We encourage anyone with a question or concern regarding this Supplier Code to contact us using the above methods. Your question or concern will be documented and submitted to Scale where an assessment will occur to assure a prompt and effective response.

Scale reserves the right to review or audit Supplier’s compliance with this Supplier Code. Business partners are to promptly respond to requests for information from Scale, or a third party working on our behalf, regarding matters covered by this Supplier Code. These may include surveys, questionnaires, requests for supporting documentation and other measures intended to increase visibility into our supply chain.

Scale will incorporate ongoing Supplier Code compliance into its business relationships and procurement decisions. Violations of this Supplier Code will require the prompt establishment of corrective action plans or training, may affect Supplier’s standing with Scale, may lead to disqualification from future opportunities with Scale, and may even result in the termination of the Supplier’s business relationship with Scale.

References

We developed these requirements for our business partners based on our values and the following:1. RESPONSIBLE BUSINESS ALLIANCE CODE OF CONDUCT (PREVIOUSLY KNOWN AS THE ELECTRONIC INDUSTRY CITIZENSHIP COALITION)2. UNITED NATIONS GUIDING PRINCIPLES ON BUSINESS AND HUMAN RIGHTS3. UNIVERSAL DECLARATION OF HUMAN RIGHTS4. WEB CONTENT ACCESSIBILITY GUIDELINES (WCAG) 2.0, LEVEL AA5. UNITED STATES FEDERAL ACQUISITION REGULATION (FAR)6. GOOGLE’S SUPPLIER CODE OF CONDUCT7. LIVERAMP’S SUPPLIER CODE OF CONDUCT

8. 47 U.S.C. Section 222(h)(1)