Code of Conduct

1. Our Commitment

We work hard to meet or exceed our clients' expectations without compromising our integrity, violating the law, or acting unethically. Integrity and trust are the bedrock of our culture.

RainFocus operates according to five guiding principles, known collectively as our FOCUS values: Forward-Thinking, Optimistic, Customer-Centric, Unified, and Stewards. These values shape every decision we make, from how we build our platform to how we engage with clients, partners, and one another.

This Code of Conduct applies to all directors, officers, employees, contractors, and agents of RainFocus. RainFocus expects its suppliers and business partners to uphold equivalent standards of ethical conduct when acting on behalf of, or in connection with, the Company.

2. Ethical Business Practices

RainFocus complies with all applicable laws and regulations in every jurisdiction where it operates. Each employee, officer, and director is responsible for understanding and following the legal requirements relevant to their role.

Anti-Corruption. RainFocus maintains zero tolerance for bribery in any form. The company complies with the U.S. Foreign Corrupt Practices Act, the UK Bribery Act, and all other applicable anti-corruption laws. No employee or agent may offer, promise, authorize, or accept bribes, kickbacks, or improper inducements to or from any party, whether in the public or private sector.

Fair Competition. RainFocus competes on the merits of its platform and services. Price-fixing, bid-rigging, market allocation, and all other forms of anti-competitive conduct are prohibited.

Conflicts of Interest. Employees must avoid situations where personal, financial, or family interests could compromise, or appear to compromise, their business judgment. Employees must promptly disclose any actual or potential conflict to their manager or the Legal Department.

Gifts and Entertainment. Business courtesies must be nominal in value, infrequent, and consistent with applicable law. No gift or entertainment may create an obligation, or the appearance of impropriety, on the part of the giver or recipient.

Accurate Books and Records. All financial records, expense reports, and business transactions must be documented accurately, completely, and in a timely manner. Falsifying records or misrepresenting transactions is prohibited and may violate the law.

3. Data Privacy and Security

As a SaaS platform processing attendee, event, and customer data at scale, RainFocus treats data protection as a core business responsibility. RainFocus complies with the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and all other applicable data protection laws in every jurisdiction where it operates.

RainFocus maintains the following data protection standards across its operations:

• Technical and Organizational Controls: RainFocus implements appropriate technical and organizational security measures to protect data against unauthorized access, loss, alteration, or misuse.
• Lawful Processing: RainFocus collects and processes personal data only for authorized, lawful, and specified purposes. Data subjects' rights are respected in accordance with applicable law.
• Incident Response: RainFocus maintains incident response procedures designed to ensure timely detection of security incidents and prompt breach notification to affected parties and regulators as required by law.
• Employee Training: RainFocus provides ongoing training to ensure its personnel understand their data handling obligations.
• Data Retention: RainFocus retains documentation in accordance with its data retention policies. After the applicable retention period expires, RainFocus disposes of data through secure disposal procedures that prevent unauthorized recovery or access.

4. Confidentiality and Intellectual Property

RainFocus's proprietary technology, trade secrets, source code, algorithms, product roadmaps, pricing strategies, and confidential business information are valuable assets. All personnel must protect these assets from unauthorized disclosure, whether during or after their relationship with RainFocus.

Customer and partner confidential information receives the same level of protection. RainFocus personnel may access, use, or share such information only as authorized by the applicable agreement and only for the purpose for which it was provided.

The following requirements apply:

• All employees are bound by confidentiality and proprietary rights obligations that survive the termination of employment.
• Third parties must execute nondisclosure agreements before receiving any Confidential Information from RainFocus.
• No director, officer, employee, contractor, or agent may trade in securities, or tip others to trade, on the basis of material nonpublic information obtained through their role at RainFocus. This prohibition extends to information about RainFocus's customers, partners, and vendors.
• RainFocus honors whistleblower protections under applicable law. No individual will be subject to retaliation for disclosing information in confidence to a government official or attorney solely for the purpose of reporting or investigating a suspected violation of law. RainFocus maintains an independent, anonymous reporting hotline for individuals to report suspected violations. Contact information is available in the Employee Handbook.

5. Our People and Human Rights

RainFocus is an equal opportunity employer. All employment decisions, including hiring, promotion, compensation, and termination, are based on qualifications and merit without discrimination on the basis of race, color, religion, sex, sexual orientation, gender identity, national origin, age, disability, veteran status, or any other characteristic protected by applicable law. For additional detail, refer to RainFocus's Equal Employment Opportunity Policy.

RainFocus maintains zero tolerance for harassment, intimidation, bullying, or any form of offensive behavior in the workplace. Every individual is entitled to a work environment free from such conduct, and violations will be addressed through prompt corrective action.

RainFocus provides safe and healthy working conditions and enforces a drug- and alcohol-free workplace. Employees are expected to comply with all applicable health and safety requirements and to report unsafe conditions immediately.

RainFocus respects internationally recognized human rights throughout its operations and supply chain. The following principles apply without exception:

• No forced, bonded, indentured, or compulsory labor in any form.
• No child labor. Minimum working age requirements under applicable law are strictly observed.
• Fair wages and reasonable working hours in compliance with all applicable wage, hour, and overtime laws.
• Freedom of association and the right to collective bargaining are respected in accordance with local law.

6. Environmental Responsibility

RainFocus strives to minimize its environmental impact through efficient use of resources, reduced energy consumption and waste, and sustainable technology practices, including operating energy-efficient cloud infrastructure. RainFocus complies with all applicable environmental laws and regulations in every jurisdiction where it operates.

7. Reporting Concerns

RainFocus encourages any individual to report known or suspected violations of this Code, applicable laws, or company policies. Reports may be made to a supervisor, the Legal Department, or through RainFocus's independent reporting hotline. Details are available upon request.

All reports are investigated promptly and handled with appropriate confidentiality. Where an investigation confirms a violation, RainFocus takes corrective action proportionate to the circumstances, up to and including termination of employment or termination of a business relationship.

RainFocus reviews and updates this Code periodically to reflect changes in law, regulation, and business operations. Direct questions about this Code or its application to the Human Resources Department.