Scale Business Partner 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 Partner Code of Conduct (“Code”) and in full compliance with all applicable laws and regulations.

This Code goes beyond compliance with applicable laws by drawing upon internationally recognized standards to advance social and environmental responsibility. This Code draws from industry and internationally accepted principles such as the Responsible Business Alliance (RBA), Ethical Trading Initiative, International Labor Organization’s (ILO) International Labor Standards, United Nations Guiding Principles on Business and Human Rights, Social Accountability International, SA 8000, the ILO’s Code of Practice in Safety and Health, National Fire Protection Association, Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises, the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, and OHSAS 18001.

When differences arise between standards and legal requirements, the stricter standard will apply, in compliance with applicable law. This Code outlines Scale’s expectations for Business Partner conduct regarding labor and human rights, health and safety, environmental protection, ethics, use of Scale resources, and management practices.

Scale will assess its Business Partners’ compliance with this Code, and any violations of this Code may jeopardize the Business Partner’s business relationship with Scale, up to and including termination. Consequences for legal violations can include heavy fines for companies and individuals, as well as jail time.

Labor and Human Rights

Scale believes all workers in our supply chain deserve a fair and ethical workplace. Workers must be treated with the utmost dignity and respect, and Scale Business Partners will uphold the highest standards of human rights. Business Partner acknowledges its compliance with the adopted principles and rights set by the International Labor Organisation in its “Declaration on fundamental principles and rights at work” (Geneva 06/98), the Directives of the UN Initiative Global Compact (Davos 01/99) and the UN Guiding Principles on Business and Human Rights (2011).

Anti-Discrimination

Business Partner will not discriminate against any worker based on age, disability, ethnicity, gender, marital status, veteran status, national origin, political affiliation, race, religion or belief, sexual orientation, gender identity, union membership or the like, or any other status protected by applicable national or local law, in hiring and other employment practices. Business Partner will not require pregnancy or medical tests, except where required by applicable laws or regulations or prudent for workplace safety, and will not improperly discriminate based on test results.

Anti-Harassment and Abuse

Business Partner will commit to a workplace free of harassment and abuse. Business Partner will not threaten workers with, or subject them to, harsh or inhumane treatment, including but not limited to verbal abuse and harassment, psychological harassment, mental and physical coercion, arbitrary personnel measures, and sexual harassment.

Prevention of Involuntary Labor and Human Trafficking

Business Partner will ensure that all work is voluntary. Business Partner will not traffic persons or use any form of slave, forced, bonded, indentured, or prison labor. Involuntary labor includes the transportation, harboring, recruitment, transfer, receipt, or employment of persons by means of threat, force, coercion, abduction, fraud, or payments to any person having control over another person for the purpose of exploitation.

Business Partner will not withhold workers’ original government-issued identification and travel documents. Business Partner will ensure that workers’ contracts clearly convey the conditions of employment in a language understood by the workers. Business Partner will not impose unreasonable restrictions on movement within the workplace or upon entering or exiting company-provided facilities.

Workers will not be required to pay employers’ or their agents’ recruitment fees or other similar fees to obtain their employment. If such fees are found to have been paid by workers, such fees will be repaid to the worker.

Third Party Employment Agencies

Business Partner will ensure that the third-party recruitment agencies it uses are compliant with the provisions of this Code and the law.

Prevention of Underage Labor

Business Partner will employ only workers who are at least 16 years of age, the applicable minimum legal age for employment, or the applicable age for completion of compulsory education, whichever is highest. Business Partner may provide legitimate workplace apprenticeship programs for educational benefit that are consistent with Article 6 of ILO Minimum Age Convention No. 138 or light work consistent with Article 7 of ILO Minimum Age Convention No. 138.

Juvenile Worker Protections

Business Partner may employ juveniles who are older than the applicable legal minimum age but are younger than 18 years of age, provided they do not perform work that might jeopardize their health, safety, or morals, consistent with ILO Minimum Age Convention No. 138. Business Partner will not require juvenile workers to work overtime or perform nighttime work.

Student Worker Protections

Business Partner will ensure proper management of student workers through proper maintenance of student records, rigorous due diligence of educational partners, and protection of students’ rights in accordance with applicable law and regulations. Business Partner will provide appropriate support and training to all student workers.

Working Hours

A workweek will be restricted to 60 hours, including overtime, and workers will have at least one day off every seven days except in emergencies or unusual situations. Regular workweeks will not exceed 48 hours. Business Partner will follow all applicable laws and regulations with respect to working hours and days of rest, and all overtime must be voluntary. Rest time and periodic leaves must be respected, in line with local legislation and/or collective bargaining agreements, where applicable.

Wages and Benefits

Business Partner will pay at least the minimum wage and provide any benefits required by law and/or contract. Business Partner will compensate workers for overtime hours at the legal premium rate. In compliance with local laws, workers will be compensated for overtime at pay rates greater than regular hourly rates. Business Partner will communicate pay structure and pay periods to all workers. Business Partner will meet all legal requirements relating to wages and benefits, pay accurate wages in a timely manner, and wage deductions will not be used as a disciplinary measure. All use of temporary and outsourced labor will be within the limits of the local law.

Freedom of Association and Collective Bargaining

Business Partner will freely allow workers’ lawful rights to associate with others, form, and join (or refrain from joining) organizations of their choice, peacefully assemble, openly communicate and share ideas and concerns with management regarding working conditions and management practices, and bargain collectively, without interference, discrimination, retaliation, or harassment.

Grievance Systems

Business Partner will ensure that workers have an effective mechanism to report grievances and that facilitates open communication between management and workers.

Health and Safety

Worker health, safety, and well-being is important to Scale. Business Partner will provide and maintain a safe work environment and integrate sound health and safety management practices into its business. Workers will have the right to refuse unsafe work and to report unhealthy working conditions.

Health and Safety Permits

Business Partner will obtain, keep current, and comply with all required health and safety permits.

Occupational Health and Safety Management

Business Partner will identify, evaluate, and manage occupational health and safety hazards through a prioritized process of hazard elimination, substitution, engineering controls, administrative controls, and/or personal protective equipment. Where hazards cannot be adequately controlled by these means, workers educational materials about risks to them associated with these hazards. Reasonable steps must also be taken to remove pregnant women/nursing mothers from working condition with high hazards, remove or reduce any workplace health and safety risks to pregnant women and nursing mothers including those

associated with their work assignments, as well as include reasonable accommodations for

nursing mothers

Emergency Preparedness and Response

Business Partner will identify and assess potential emergency situations. For each situation, Business Partner will develop and implement emergency plans and response procedures that will minimize harm to life, environment, and property.

Incident Management

Business Partner will have a system for workers to report health and safety incidents and near-misses, as well as a system to investigate, track, and manage such reports. Business Partner will implement corrective action plans to mitigate risks, provide necessary medical treatment, and facilitate workers’ return to work.

Working and Living Conditions

Business Partner will provide workers with reasonably accessible and clean toilet facilities and potable water. Business Partner-provided dining, food preparation, and storage facilities will be sanitary. Worker dormitories provided by Business Partner or a third-party will be clean and safe and provide reasonable living space.

Health and Safety Communication

Business Partner will provide workers with appropriate workplace health and safety training in their primary language. Health and safety related information will be clearly posted in the facility.

Environment

Scale is committed to protecting the environment. To the extent Business Partner produces goods for Scale’s supply chain, Business Partner will develop, implement, and maintain environmentally responsible business practices and will use necessary resources, particularly energy and water, effectively and efficiently in order to reduce environmental impact. This also applies to the effort and expense of transportation and logistics.

Environmental Permits and Reporting

Business Partner will obtain, keep current, and comply with all required environmental permits. Business Partner will comply with the reporting requirements of applicable permits and regulations.

Regulated Substances

Business Partner will comply with all applicable international laws or directives, regulatory agency or eco-label requirements related to the use of certain chemical substances or materials with respect to all goods it manufactures for, and provides to, Scale. Business Partners must take action to reduce or eliminate the use of chemicals of concern and make available full material disclosures to Scale upon request.

Waste Management

Business Partner will implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle hazardous waste and non-hazardous waste.

Wastewater Management

Business Partner will implement a systematic approach to identify, control, and reduce wastewater produced by its operations. Business Partner will conduct routine monitoring of the performance of its wastewater treatment systems.

Stormwater Management

Business Partner will implement a systematic approach to prevent contamination of stormwater runoff. Business Partner will prevent illegal discharges and spills from entering storm drains, the public water supply, or public bodies of water.

Air Emissions Management

Business Partner will identify, manage, reduce, and responsibly control air emissions emanating from its operations that pose a hazard to the environment. Business Partner will conduct routine monitoring of the performance of its air emission control systems.

Business Partner will regularly quantify, set targets, monitor progress, and reduce its emissions of greenhouse gasses through conservation, use of clean energy, or other measures.

Boundary Noise Management

Business Partner will identify, control, monitor, and reduce noise generated by the facility that affects boundary noise levels.

Resource Consumption Management

Business Partner will regularly quantify, set targets, monitor progress, and reduce consumption of fossil fuel, water, hazardous substances, and natural resources through conservation, re-use, recycling, substitution, or other measures.

Ethics

Scale expects the highest standards of ethical conduct in all of our endeavors. Business Partner will always be ethical in every aspect of its business, including relationships, practices, sourcing, and operations.

Business Integrity

Business Partner will not engage in corruption, extortion, embezzlement, bribery, kickbacks, or payments of money or anything of value to anyone, including officials, employees, journalists, political candidates, or representatives of any government or public or international organization, or to any other third party (public or private sector) for the purpose of obtaining or retaining business, or influencing any other favorable business decision, that is related in any way to Scale. This includes giving money or anything of value to anyone where there is reason to believe that it will be passed on to a government official or the decision maker at a private sector customer or potential customer for this purpose.

Business Partner will abide by all applicable anti-corruption laws and regulations of the countries in which it operates, including the Foreign Corrupt Practices Act (FCPA), Sapin II, and the UK Bribery Act and applicable international anti-corruption and anti-money laundering laws or conventions.

Business Partners will have a policy relating to business with Scale that prohibits the giving and acceptance of gifts. Gifts include items such as cash, or cash equivalents including entertainment, gift cards, product discounts, and non- business activities. Business Partners will have a process to investigate and report any violations to the policy.

Antitrust and Competition

Scale is committed to observing the applicable antitrust and competition laws of all nations or organizations, and Scale expects its Business Partners to comply with all applicable antitrust and competition laws as well. Business Partners will not engage in practices that unreasonably restrain trade (including price fixing, market sharing or bid rigging), are deceptive or misleading, or unreasonably reduce competition.

Record-Keeping and Disclosure of Information

Business Partner will accurately record information regarding its business activities, labor, health and safety, and environmental practices and will disclose such information, without falsification or misrepresentation, to all appropriate parties and as required by law.

Protection of Intellectual Property

Business Partners will respect the intellectual property rights of others and will only use technology that has been legitimately acquired or licensed.

Whistleblower Protection and Anonymous Complaints

Business Partner will provide an anonymous complaint mechanism for managers and workers to report workplace grievances. Business Partner will protect whistleblower confidentiality and prohibit retaliation.

Community Engagement

Business Partner is encouraged to help foster social and economic development and contribute to the sustainability of the communities in which it operates.

Trade Laws and Export Controls

To the extent that Business Partner transports goods for Scale into the United States, Business Partner will comply with the C-TPAT (Customs-Trade Partnership Against Terrorism) security procedures on the U.S. Customs website at www.cbp.gov (or other website established for such purpose by the U.S. government).

United States export laws govern export, re-export and use of products and technical data of United States origin, wherever located or sold from, and Business Partners must comply fully with such export laws in addition to applicable non-U.S. and multilateral export laws. Business Partners may not export, re-export or transship Scale products, services or technical data: (1) to any destination subject to U.S. embargoes or trade sanctions; (2) to any entity or individual specified on U.S. government-maintained exclusion lists; or (3) for use directly or indirectly in the design, development or fabrication of nuclear, chemical, or biological weapons or missile technology.  Business Partners must immediately notify Scale if they become prohibited from participating in U.S. export transactions by any federal agency of the U.S. government. Information regarding economic sanctions and trade embargoes are available at the U.S. Treasury’s website: www.treasury.gov/resource-center/sanctions.

Responsible Sourcing of Materials

Business Partners will exercise due diligence on relevant materials in their supply chains. Business Partners will develop particular due diligence policies and management systems in order to identify applicable risks and take appropriate steps to mitigate them. Due diligence will be conducted to the material processing level in order to determine whether relevant materials originate from regions with high risks, which include areas associated with conflict, worst forms of child labor, forced labor and human trafficking, gross human rights violations such as widespread sexual violence, or other reasonably objective high risk activities, including severe health and safety risks and negative environmental impacts.

Responsibility for Scale Resources

Business Partner will safeguard Scale resources which include property, assets, intellectual property, company technology assets (network, phone, Internet, software applications and e-mail systems), trade secrets and other confidential, proprietary or sensitive information while performing work for Scale. Use of Scale resources without proper approvals or for anything other than to perform Scale work activities is strictly prohibited. Intellectual property rights of Scale must be protected.

Confidential Information

Scale confidential or sensitive information must be protected. Business Partners and their respective employees and contractors may only possess such information if they need to do so to perform work activities. Business Partners should not use this information for gain or advantage, and never share this information without appropriate Scale approval. All confidential or sensitive information obtained by a Business Partner must have documented authorization in place. Business Partners must follow any security guidelines provided to them in the course of their work for or with Scale. Inappropriate use of Scale internet or e-mail is strictly prohibited.

Business Partners are expected to safeguard confidential information by not reproducing copyrighted software, documentation, or other materials without permission, and not transferring, publishing, using or disclosing it other than as necessary in the ordinary course of business or as directed or authorized. Scale may require Business Partners to sign non-disclosure agreements for specific and confidential projects or other agreements that may contain confidentiality terms, in which case the confidentiality provisions of those agreements will govern confidentiality terms between the parties.

Data Privacy

Business Partners must track, understand and comply with, all laws and regulations relating to data protection. Any Scale customer personal and/or private data that Business Partner collects or receives must be kept confidential, shared strictly to those employees with a “need to know” such data, and used exclusively for the purpose for which it was disclosed. Business Partner must use safeguards to ensure the protection, integrity and security of such information, applying at least the same level of data protection for such data as that set forth in the Privacy Policy posted on Scale’s website or, if applicable, in their data processing agreements with Scale.

Monitoring

Scale retains the right to monitor its assets and work environments in compliance with applicable federal, state and local law. Scale monitors to promote safety, prevent criminal activity, investigate alleged misconduct and security violations, manage information systems, and for other business reasons. Please see the Scale Privacy Policy for more information.

Management Systems

Scale believes that sound management systems and commitment are key to enriching the social and environmental well-being of our supply chain. Business Partner will implement or maintain, as applicable, management systems that facilitate compliance with this Code and the law, identify and mitigate related operational risks, and facilitate continuous improvement.

Company Statement

Business Partner will develop a company statement affirming its commitment to high standards of social and environmental responsibility, ethical conduct, and continuous improvement. Business Partner will post this statement in the primary local language at all of its facilities.

Management Accountability and Responsibility

Business Partner will identify company representatives responsible for ensuring implementation and periodic review of its management systems. Business Partner will have a Corporate Social Responsibility (CSR) or Sustainability representative that reports directly to executive management and has the responsibility and authority to manage social and environmental compliance requirements for the business.

Risk Assessment and Management

Business Partner will develop and maintain a process to identify labor and human rights, health and safety, environmental, business ethics, and legal compliance risks associated with its operations; determine the relative significance of each risk; and implement appropriate procedures and controls to minimize the identified risks.

Performance Objectives with Implementation Plans and Measures

Business Partner will have written standards, performance objectives, targets, and implementation plans, including periodic assessments of the performance against those objectives.

Audits and Assessments

Business Partner will perform periodic evaluations of its facilities and operations, and the facilities and operations of its subcontractors and next-tier suppliers that provide goods or services to Scale to ensure compliance with this Code and the law.

Business Partner will permit Scale and a third party designated by Scale to periodically evaluate Business Partner’s facilities and operations, and those of its subcontractors and next-tier suppliers, to the extent they are providing goods or services to Scale, for Scale’s benefit, or for use in Scale products.

Training and Communication

Business Partner will develop and maintain management and worker training programs to facilitate proper implementation of its policies and procedures and to fulfill Business Partner’s continuous improvement objectives. Scale may find it necessary to oversee mandatory Code training for some Business Partners.

Business Partner will have a process for communicating clear and accurate information about its performance, practices, policies, and expectations to its workers, next-tier supplier(s), and customers.

Business Partner will have an ongoing process to obtain feedback on its practices related to this Code and to foster continuous improvement.

Corrective Action Process

Business Partner will have a process for timely correction of any deficiencies or violations identified by an internal or external audit, assessment, inspection, investigation, or review.

                                 This Code is not intended to create new or additional rights for any third party. Version 1.0.