Akeyless Code of Business Conduct and Ethical Policy

Last Updated: December 1, 2021

In performing their job duties, Akeyless employees should always act lawfully, ethically, and in the best interests of Akeyless. This Code of Business Conduct and Ethics (the “Code of Conduct”) sets out basic guiding principles. Employees who are unsure whether their conduct or the conduct of their coworkers complies with the Code of Conduct, should contact their manager or legal advisors. Employees may also report any suspected noncompliance as provided in the legal advisors’s reporting guidelines below.

Compliance with Laws, Rules and Regulations

Employees must follow applicable laws, rules and regulations at all times. Employees with questions about the applicability or interpretation of any law, rule or regulation, should contact the Akeyless  legal advisors via the following dedicated email address: [email protected]

Conflicts of Interest

In performing their job duties, employees are expected to use their judgment to act, at all times and in all ways, in the best interests of Akeyless. A “conflict of interest” exists when an employee’s personal interest interferes with the best interests of Akeyless. For example, a conflict of interest may occur when an employee or a family member receives a personal benefit as a result of the employee’s position with Akeyless. A conflict of interest may also arise from an employee’s business or personal relationship with a customer, supplier, competitor, business partner, or other employee, if that relationship impairs the employee’s objective business judgment.

Because an employee’s receipt of gifts or services could create a conflict of interest, the legal advisors will develop and maintain guidelines for disclosure of gifts or services received from customers, suppliers, competitors or business partners.

Employees should attempt to avoid conflicts of interest and employees who believe a conflict of interest may exist should promptly notify the legal advisors. The legal advisors will consider the facts and circumstances of the situation to decide whether corrective or mitigating action is appropriate.

Discrimination and Harassment

Akeyless provides equal opportunity in all aspects of employment and will not tolerate any illegal discrimination or harassment of any kind. Employment at Akeyless is based solely upon individual merit and qualifications directly related to professional competence. We strictly prohibit unlawful discrimination or harassment on the basis of race, color, religion, veteran status, national origin, ancestry, pregnancy status, sex, gender identity or expression, age, marital status, mental or physical disability, medical condition, sexual orientation, or any other characteristics protected by law. We also make all reasonable accommodations to meet our obligations under laws protecting the rights of the disabled.

Akeyless prohibits discrimination, harassment and bullying in any form – verbal, physical, or visual. If you believe you’ve been bullied or harassed by anyone at Akeyless, or by Akeyless  partner or vendor, we strongly encourage you to immediately report the incident to your supervisor, Human Resources or both. Similarly, supervisors and managers who learn of any such incident should immediately report it to Human Resources. HR will promptly and thoroughly investigate any complaints and take appropriate action.

Health and Safety

Akeyless provides a clean, safe and healthy work environment. Each employee has responsibility for maintaining a safe and healthy workplace by following safety and health rules and practices and reporting accidents, injuries and unsafe conditions, procedures, or behaviors.

Violence and threatening behavior are not permitted. Employees must report to work in a condition to perform their duties, free from the influence of illegal drugs or alcohol.

Price Fixing

Employees may not discuss prices or make any formal or informal agreement with any competitor regarding prices, discounts, business terms, or the market segments and channels in which the Company competes, where the purpose or result of such discussion or agreement would be inconsistent with applicable antitrust laws. If you have any questions about this section or the applicable antitrust laws, please contact the legal advisors.

Bribery; Payments to Government Personnel

Employees may not bribe anyone for any reason, whether in dealings with governments or the private sector. Governing laws prohibit offering or giving anything of value, directly or indirectly, to government officials in order to obtain or retain business. Employees may not make illegal payments to government officials themselves or through a third party. Employees who are conducting business with the government officials of any country must contact the legal advisors for guidance on the law governing payments and gifts to governmental officials.

Recordkeeping, Reporting, and Financial Integrity

Akeyless books, records, accounts and financial statements must be maintained in appropriate detail, must properly reflect the Company’s transactions and must conform both to applicable law and to the Company’s system of internal controls. The Company’s financial, accounting and legal groups are responsible for procedures designed to assure proper internal and disclosure controls, and all employees should cooperate with these procedures.

Questions; Reporting Violations

Employees should speak with anyone in their management chain or the Legal Department when they have a question about the application of the Code of Conduct or when in doubt about how to properly act in a particular situation.

Akeyless will not allow retaliation against an employee for reporting misconduct by others in good faith. Employees must cooperate in internal investigations of potential or alleged misconduct.

Employees who violate the Code of Conduct will be subject to disciplinary action up to and including discharge.

Board of Directors

With respect to their service on behalf of the Company, Akeyless Board of Directors must comply with the relevant provisions of this Code of Conduct, including conflicts of interest and compliance with all applicable laws, rules and regulations.

Waivers

Waivers of this Code of Conduct may be made only in a manner permitted by law.