2024 Code of Ethics

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| Code of Ethics & Business Conduct | 2024 01 Affirm Code of Ethics & Business Conduct Purpose Affirms Code of Ethics & Business Conduct (the Code) is at the center of everything we do. It reflects our commitment to upholding high ethical and legal standards and is core to the Affirm brand. Our Code applies to members of the Affirm Board of Directors, Affirm officers (including Affirms Chief Executive Officer, Chief Financial Officer, Controller, and other persons performing similar functions), and all other Affirm employees (Affirmers). We will also use it as a guide for the behaviors we expect from those with whom we do business. Making legal and ethical choices guided by the Code builds trust in each other and with our customers and merchant partners. Affirmers should never compromise their personal integrity or the Companys reputation and trust. While the Code doesnt address every situation that might arise, the Code provides helpful contacts and resources that Affirmers can use to address those situations. Its on us to apply the principles of the Code to our daily work, so we can move forward with confidence in our ability to make decisions that build trust and empower our customers and merchant partners to achieve more. For purposes of this Code, we, our, Company, and Affirm refer to Affirm Holdings, Inc. and its subsidiaries and affiliates.

| Code of Ethics & Business Conduct | 2024 02 Table of contents Our mission & core values Using our Code to make good decisions Protecting our company Connecting with our investors and the public Speak up Compliance with the law Working with each other Our Code Professional conduct Consequences for violating the Code Conflicts Use of company equipment and materials (physical and electronic assets) Information security and privacy Respecting intellectual property Non-public information Records and reporting Communications with the investment community Media relations & public statement Speaking engagement Endorsements Social media & public forums How to report misconduct Non-retaliation A nti-bribery and corruptio n G ifts and entertainment Insider trading compliance F air competition & antitrust D ata privacy Modern Slavery A ct A dministration o f our Code Oversight W aiver of the Code L ast updated 31 31 31 Honesty & integrity Policy against harassment , discrimination , and retaliation Equal employment opportunity Conflicts of interest & self-dealin g Outside activities W orkplace safety & physical security D rug & alcohol policy Criminal convictions 0 5 0 6 0 6 0 6 18 19 19 20 2 9 30 30 3 0 0 8 0 9 2 3 2 4 2 5 2 6 2 7 2 7 11 11 12 13 15 16 16

| Code of Ethics & Business Conduct | 2024 03 Our mission & core values Affirm was founded with the mission of creating honest financial products that improve lives. Our commitment to corporate responsibility and integrity guides everything we do as a company. As Affirm grows, the ability to translate our ambitious mission into a clear and compelling day-to-day strategygoverned by our five core valuesis essential. Our core values are the enduring principles that help us do business with integrity and win trust every day. People come first We consider our impact on peoples lives before we think about our own interests. Its on us We take full accountability for our actions, never shirking responsibility or passing the buck. No fine print We are completely transparent and honest with our customers and with each other. Simpler is better We make complex things simple and clear. Push the envelope We never stop innovating, taking smart risks, and raising the bar.

| Code of Ethics & Business Conduct | 2024 04 Using our Code to make good decisions

| Code of Ethics & Business Conduct | 2024 05 Our Code Each Affirmer is responsible for understanding and following the spirit and letter of the Code, as well as the Company policies and laws that apply to the work that they do. Affirmers also are expected to cooperate with any inquiries or investigations concerning a possible or suspected violation of this Code, or any Company policy or law. Consult the Code regularly, ask questions, and incorporate the principles of the Code into your work. All Affirmers are required to attest to the Code upon commencement of employment and on an annual basis thereafter. Failing to read or attest to the Code does not excuse any Affirmer from their responsibilities under the Code. Additionally, Affirmers are required to complete mandatory training sessions on topics, including, but not limited to, harassment prevention, anti-bribery & corruption, and others. Failure to complete these training sessions by their assigned deadlines may result in disciplinary action, up to and including termination. Making good decisions and ethical choices builds trust between each of us and the people we interact with. Not all situations we encounter are straightforward. If you have a question about how to interpret the Code, contact the Ethics team. We expect each Affirmer to use good judgment to protect Affirms reputation and to seek help if they have questions or need guidance. U s i n g o u r C o d e t o m a k e g o o d d e c i s i o n s

| Code of Ethics & Business Conduct | 2024 06 Conflicts We are committed to ensuring that every action we take is in compliance with all applicable governmental laws, rules, and regulations. If there is a conflict between the Code and the law, or another Company policy and the law, making it impossible for any Affirmer to comply with both, then the law prevails. In many cases, the Codes standards will be stricter than applicable legal requirements. In these instances, follow the Code. If you have specific questions, contact the Ethics team. Consequences for violating the Code We are each accountable for our actions and for behaving ethically and responsibly. Affirmers who act in a manner inconsistent with the Code, Company policies, or the law may be subject to disciplinary action in accordance with their local Guide to Affirm and local employment laws, up to and including termination of employment. Professional conduct The success of Affirm depends not only on the knowledge, skills, and abilities of its employees, but also on the sound judgment, self-discipline, common sense, and integrity of those individuals. As such, all Affirmers are expected to adhere to our Professional Conduct Policy to guide their conduct in, or reasonably associated with, the workplace, whether in person or virtually. U s i n g o u r C o d e t o m a k e g o o d d e c i s i o n s

| Code of Ethics & Business Conduct | 2024 07 Speak up

| Code of Ethics & Business Conduct | 2024 08 How to report misconduct At Affirm, we understand that our reputation is earned. This means that each Affirmer has a responsibility to report suspected violations of: (i) the Code and Company policies; (ii) any laws and governmental rules and regulations, including federal securities and consumer finance laws and the rules and regulations thereunder; or (iii) any accounting, internal controls, and auditing matters. We will treat and respond to all reports thoroughly, fairly, and promptly. There are multiple ways to report concerns at Affirm. You can: r Report the situation to your People Business Partner;g r Report the situation to Employee Relations;g r Contact the Ethics team; ob r Submit a report, either identifiably or anonymously, to our reporting hotline AffirmEthics.com by web, SMS, or phone. Reports submitted to the hotline will be shared with the Chief Legal Officer or their delegate, as appropriate, and, in instances where there is a financial or accounting related report, it will also be reviewed by the Chairperson of the Audit Committee. Affirm has put in place a Whistleblower Policy to ensure that Affirmers have a means of confidentially reporting concerns. If you wish to speak to someone about your concerns, or need some guidance as to whether you should report your concerns, please refer to the Whistleblower Policy. Affirm will conduct inquiries into all alleged or actual violations of the Code, other workplace policies, or the law. Affirmers are required to cooperate with Company investigations but should not investigate independently. Failing to cooperate with, interfering with, or deliberately providing false or misleading information during a Company investigation shall be grounds for disciplinary action, up to and including termination. We will maintain confidentiality throughout investigations, sharing information only as reasonably necessary and to the extent permitted by law, to conduct the investigation and allow the Company to take remedial action and/or to comply with applicable law. S p e a k u p

| Code of Ethics & Business Conduct | 2024 09 Non-retaliation Affirm has a strict non-retaliation policy, meaning Affirmers will not be disciplined or otherwise experience an adverse employment action for reporting a suspected violation of the Code, other workplace policies, or the law, in good faith, or participating in an investigation related to or opposing potential violations, of the Code, other workplace policies, or the law. An adverse employment action is conduct or an action that materially affects the terms and conditions of the Affirmers employment status, or would tend to discourage a reasonable person from reporting a suspected violation in good faith, or participating in an investigation related to or opposing potential violations, of the Code, other workplace policies, or the law. Reporting in good faith doesnt require certaintyit means honestly believing that information is being provided truthfully and accurately about the concern being raised. Any suspicion of retaliatory practices should be promptly reported to the Company by using any of the channels below: Anyone found to have engaged in retaliation against an Affirmer who reports (potential) misconduct in good faith is in violation of the Code, and may face disciplinary action, up to and including termination. Please refer to the Policy Against Discrimination, Harassment, and Retaliation in your local Guide to Affirm for the Companys policy prohibiting retaliation. Report the situation to your People Business Partner Report the situation to Employee Relation Contact the Ethics teat Submit a report, either identifiably or anonymously, to our reporting hotline AffirmEthics.com by web, SMS, or phone S p e a k u p

| Code of Ethics & Business Conduct | 2024 10 Working with each other

| Code of Ethics & Business Conduct | 2024 11 Honesty & integrity The connection we share with customers through our financial products and services is a privilege, one we must never take for granted. Affirm recognizes that our continued success depends upon a commitment to conducting business ethically and in compliance with the law everywhere we operate. We should always be transparent, learn from our mistakes, and ask for help when faced with a difficult situation. Affirm understands the importance of consumer protection. We enforce it as a corporate social responsibility through our transparent promotion of honesty and integrity, fairness and trust, fair competition, and diversity, equity, and inclusion in our products and how we conduct ourselves. These not only complement Affirms core values, but also define the spirit of our diverse workforce and how we function. Any Affirmer who is unsure of what choice to make should ask themselves: If the answer to any of these questions is no, or if there is pause, evaluate the situation and ask the Ethics team. Policy Against Discrimination, Harassment, and Retaliation We are committed to creating and maintaining a work environment that is free of unlawful discrimination, harassment, and retaliation. We will not tolerate discrimination, harassment, or retaliation in, or related to, the workplace on the basis of any protected characteristic under applicable law. More details on our policy and expectations can be found in the Policy Against Discrimination, Harassment, and Retaliation in your local Guide to Affirm. Please review the policy in your local Guide to Affirm to understand what conduct is prohibited, examples of such prohibited conduct, and mechanisms by which potential violations shall be reported and investigated. If any Affirmer sees, suspects, or experiences potential unlawful discrimination, harassment, or retaliation, please promptly: Does it follow our policies Does it comply with the law Will it help us maintain the trust people place in Affirm Would we feel comfortable if it were on the news or made public? Report it to your People Business Partner; Report it to Employee Relations Contact the Ethics team; o Submit a report, either identifiably or anonymously, to our reporting hotline AffirmEthics.com by web, SMS, or phone. W o r k i n g w i t h e a c h o t h e r

| Code of Ethics & Business Conduct | 2024 12 Equal employment opportunity Diversity, equity, and inclusion are business imperatives for Affirm to deliver on our mission. We believe that the financial services industry works better for everyone when it is inclusive. We value the individual differences, experiences, and capabilities of each Affirmer. To that end, all Affirmers are expected to treat each other with civility, professionalism, and inclusivity. Our collective strengthenhanced by the diverse backgrounds and perspectives of our growing global footprintmakes Affirm a better place to work and a better business partner for our customers and merchant partners. Affirm is an equal employment opportunity employer and makes employment decisions on the basis of merit and business needs. Our commitment to non-discrimination and equal employment applies to all aspects of employment and our employment processes, including, but not limited to, hiring, transfers, promotions, compensation, benefits, and disciplinary action. We do not unlawfully discriminate on the basis of any protected characteristic identified in the Policy Against Discrimination, Harassment, and Retaliation in your local Guide to Affirm, or otherwise identified by applicable law. To ensure equal employment opportunity and nondiscrimination, its on each Affirmer to understand the importance of this policy, their local Policy Against Discrimination, Harassment, and Retaliation, and their responsibilities to make our workplace free from unlawful discrimination. W o r k i n g w i t h e a c h o t h e r

| Code of Ethics & Business Conduct | 2024 13 Conflicts of interest & self-dealing Our business is built on public trust and confidence and an expectation by customers and merchants that they can depend on our products and services. We expect Affirmers to always act in the best interests of Affirm and avoid conflicts of interest. A conflict of interest arises when a personal interest conflicts or appears to conflict with the Companys interests. Conflicts of interest can arise in many situations, including through personal relationships with family and friends, financial interests in companies that do business with Affirm, and business opportunities that Affirmers may learn about through their positions at Affirm. Affirmers must avoid situations where a conflict (actual, apparent, or potential) exists. Even a potential or apparent conflict of interest can hurt Affirms business and reputation. A potential conflict of interest involves a situation that may develop into an actual conflict of interest. An apparent conflict of interest involves a situation where an observer might conclude that an employees judgment was influenced by something other than the Companys best interest. For example, if an Affirmer has a personal or financial relationship with a third-party vendor, it might appear to others that they are giving the vendor preferential treatmenteven if thats not the case. While it may not be possible to identify every potential conflict of interest, here are some notable examples: In line with our core value No fine print, the best rule for any conflict situation is to be transparent. Affirmers must promptly disclose to their manager and the Ethics team any situation in which they are involved or plan to become involved which could result in an actual, apparent, or potential conflict of interest, and abstain from making any decisions that might be affected by the conflict. The Ethics team reserves the right to use its discretion in resolving conflicts of interestwhich may include reassignment or removal of the employees duties. Further, failure to disclose a conflict of interest may lead to disciplinary action, up to and including termination. Engaging your former employer, with whom you have equity, as a vendor for the Compan Soliciting funds for your own political campaign on Company premises, at Company events, or through Company channel Using your role or Affirms name or reputation to gain personal benefit or favor Having a romantic relationship with an Affirmer in your reporting chain or someone whom you have influence over at wor Personally investing in a company with which you are also negotiating a business deal on behalf of Affirm Building, advising, or consulting on a product or business that competes (or may compete) with Affirm business Hiring and/or managing a romantic partner or family member, defined as a spouse or domestic partner, parent, legal guardian, sibling, child, grandparent, grandchild, or in-law (natural, step-, or adopted relationships are included in this definition) W o r k i n g w i t h e a c h o t h e r

| Code of Ethics & Business Conduct | 2024 14 Outside activities Affirmers may not engage in or pursue any activities or interests that interfere or conflict with their job or the best interests of the Company. This restriction includes, but is not limited to, starting your own competing business, or employment in, consulting, advising, or sitting on a Board of Directors in businesses competitive with Affirm. Before engaging in any for-profit outside business activity, whether it is competitive with Affirm or not, like consulting, advising, starting your own business, or accepting a directorship or employment Affirmers must obtain written approval from their manager and the Ethics team. Employees who have been asked to sit on the Board of Directors of a public company must additionally obtain written approval from the Chief Legal Officer. Failure to obtain proper approvals may lead to disciplinary action, up to and including termination. If you obtain written approval from your manager and the Ethics team to engage in such activities, under no circumstances may you: In addition, promptly disclose to the Ethics team any investment or other interest you or any member of your household has in a merchant, partner, vendor, or competitor of Affirm, if: This does not include investments in fully diversified exchange-traded funds (ETFs) or mutual funds where you (or a member of your household) do not direct the fund allocation. For help in determining if your investment or interest triggers any of these criteria, or if you are unsure whether a particular company is a merchant, partner, vendor, or competitor, reach out to the Ethics team. In cases where conflicts cannot be effectively managed, Affirmers may need to divest some or all of their personal investments or interest in the outside company. use Affirm non-public information use Affirm equipment or property; take for yourself a business opportunity that was presented to, or that rightfully belongs to, Affirm (unless Affirm knowingly and specifically declines to take advantage of that opportunity); o interact in your Affirm capacity with your own business or a company for which you consult, advise, are employed by, or serve on the Board of Directors. that investment or interest is significant enough, either in absolute value or in relation to your net worth, that it could cause a conflict or the appearance of one; if you have confidential information about that merchant, partner, vendor, or competitor of Affirm obtained in connection with your position with Affirm if you engage with that merchant, partner, vendor, or competitor in the course of your position with Affirm; o that investment or interest otherwise could reasonably be perceived as causing your judgment to be influenced by something other than the Companys best interests. W o r k i n g w i t h e a c h o t h e r

| Code of Ethics & Business Conduct | 2024 15 Workplace safety & physical security policy Affirm is committed to preventing workplace violence and to maintaining a safe working environment. In keeping with this commitment, Affirm has established a workplace violence prevention program and Policy Against Workplace Violence prohibiting any direct or indirect threat of violence, act of violence, and any other conduct that generates a reasonable concern for physical safety from violence that occurs on Company premises, at any Company sponsored event, or any other location where Affirmers are engaging in work-related activities. Affirm does not permit the use, or possession, of any weapon of any kind while on Company premises or at Compan-sponsored events. All instances of real, perceived, or expected workplace violence must be reported promptly to the Global Safety & Physical Security team, your manager, or your People Business Partner. People managers and People Business Partners who receive a report or otherwise learn of real, perceived, or expected workplace violence must immediately inform the Global Safety & Physical Security team. Affirm is committed to keeping our workplaces as secure as possible, which requires the participation of all Affirmers. Access to all Affirm corporate offices, and affiliated locations (e.g., shared workspaces), is restricted to authorized employees, contractors, and vendors through use of their corporate access and identification card. All guests, visitors, and other external personnel must be registered, approved, and logged in Affirms visitor management software. Employee identification badges and visitor badges must be visible at all times. Employees must immediately report lost, missing, stolen, or damaged badges to the Global Safety & Physical Security team. All guests and visitors are to be escorted by an authorized Affirm employee at all times while on Affirm premises. Be curious. If you see something suspicious, report it to the Global Safety & Physical Security team immediately. Always secure personal and Company property, whether on Company premises or in a remote working environment, and never leave anything visible to the public overnight or for extended periods of time. See the Global safety & physical security page for more information. W o r k i n g w i t h e a c h o t h e r

| Code of Ethics & Business Conduct | 2024 16 Drug & alcohol policy Affirm maintains a drug-free workplace, and we all have the responsibility to maintain a safe and efficient working environment. Affirmers must report to work fit to perform the duties of their job (with or without a reasonable accommodation). Any Affirmer who engages in the following conduct may be subject to discipline, up to and including termination0 . Manufacturing, possessing, storing, distributing, transferring, purchasing, selling, using, or soliciting illegal drugs while on duty, on Company premises, at Company-sponsored events, or while performing their Company duties* . Unauthorized consumption of alcohol, or unauthorized use or possession of open alcohol containers while performing your duties, on Company premises, or at Company-sponsored events; and/oK . Reporting to work or performing your duties while impaired by alcohol or controlled substances, including medical or recreational marijuana. On occasion, Affirm may sponsor Company events where alcohol is available, served, or consumed. Affirmers may of course choose to consume alcohol during these events, but always are expected to drink responsibly and act professionally. Illegal drug possession (under federal, state, or local law) or use is strictly prohibited while performing your duties, on Company premises, or at Company-sponsored events. Criminal Convictions To the extent consistent with applicable law, within five business days of being convicted of, pleading guilty or no contest to, or entering into a pre-trial diversion or similar program for, any felony or any crime involving breach of trust, deceit, money laundering, bribery, sanctions violations, dishonesty, or fraud, all Affirmers are required to notify the Ethics team that they may need to discuss a new criminal conviction since completing their authorized background check as a condition of employment. Please do not initially disclose the nature or type of criminal conviction to the Ethics team, as there are certain processes that need to be followed. At all times, the Company will take action consistent with applicable law and Affirms framework on criminal convictions, which may result in termination of employment depending on the type and severity of the offense and/or relationship to the employees job duties. Where and when required, Affirm will notify any agency to which it has a duty or obligation to report such a conviction. W o r k i n g w i t h e a c h o t h e r

| Code of Ethics & Business Conduct | 2024 17 Protecting our company

| Code of Ethics & Business Conduct | 2024 18 Use of company equipment and materials Physical Assets Affirmers have a wide range of access to tangible things, like furniture, funds, supplies, and facilities. We expect Affirmers to treat physical assets with care and take measures to prevent them from being lost, stolen, or damaged, including any unauthorized removal from Affirm offices. Reach out to our Workplace team if any of our assets appear to be defective, unsafe, or in need of repair. We reserve the right to search Company property, such as desks, lockers, or other storage areas, and inspect their contents consistent with applicable laws. Electronic Assets Our technology resources, including computer hardware, software, mobile devices, and tablets, are important to the work we do at Affirm. We expect Affirmers to protect, secure, and use them appropriately for business purposes. Affirm has strict rules about securing electronic assetsin the office and while traveling. Occasional personal use of things, like email or the web, is generally permitted, but use good judgment, and never access unauthorized websites (e.g., gambling or adult content). In addition, Affirm may review the contents of Affirm systems at any time, where permitted by law. Personal use of Company resources does not create an expectation of privacy. Be careful how you utilize our electronic assets and never use them to engage in illegal activity, activity that violates our policies, or anything that would negatively affect the Company or its reputation. Affirmers are required to immediately return all Company-issued equipment and materials upon request by or upon their separation from Affirm. Affirmers are required at all times to adhere to the Acceptable Use Policy. P r o t e c t i n g o u r c o m p a n y

| Code of Ethics & Business Conduct | 2024 19 Information security and privacy As a financial technology company, some of our most valuable assets are intangible. Information drives our business and allows us to connect people globally. Our non-public information, including intellectual property and personal data, is an important asset and critical to our business. Both our information systems and our data are especially vulnerable to security risks. Protecting our information systems When using our information systems and technology, do your part to protect them from viruses, data breaches, and other risks. Never: Refer to the Information Security Policy and Acceptable Use Policy for additional information. Respecting intellectual property The innovative ideas, works, and solutions we develop in our work, such as copyrights, trademarks, patents, utility designs, industrial and community designs, trade secrets, know-how, databases, and the Affirm brand, are all forms of intellectual property. Protect our intellectual propertynever disclose it to a third party without legal approval and a Non-Disclosure Agreement (NDA) in place. Also, remember that anything you create, invent, design, or develop within the scope of your work for Affirm is either the sole property of or must be transferred to the Company pursuant to your respective employment agreement. Our responsibilities also include respecting the intellectual property rights of others. We take care not to infringe copyrights, trademarks, patents, or other rights of third parties. Intellectual property is a critical component of our business and the business of others. We all must do our part to ensure that it is protected. You should ensure that your work for Affirm is either original or that you have secured the necessary permissions or licenses for any third-party intellectual property you might use. If using open-source code or code generated using generative AI tools (e.g., ChatGPT or Bard), you should ensure compliance with the Open Source Policy. Install unapproved software, applications, or hardware Use unauthorized devices to access our network Access unauthorized websites Share passwords, access codes, or non-public data without authorization; o Open suspicious or unsolicited email. P r o t e c t i n g o u r c o m p a n y

| Code of Ethics & Business Conduct | 2024 20 Non-public information While working at the Company, Affirmers may have access to non-public information (including trade secrets and personal data) about the Company, our customers, or our merchant partners. This information could cause harm if made public without permission, and could be in violation of law. Affirmers all have a responsibility to protect this information from unauthorized access and disclosure. Some examples of non-public information include, but are not limited to: Treat our non-public information with carejust as you would your own personal information. You should follow the requirements outlined in our Information Security Policy and Privacy Policy when handling or sharing any non-public information. Before sharing any non-public information outside of the Company, consult with the Ethics team even if you think you have permission to disclose it and be sure to have a Non-Disclosure Agreement (NDA), a Data Sharing Agreement (DSA), and/or a Data Processing Addendum (DPA) in place, as applicable. Always properly label and identify any information with the appropriate classifications in accordance with the Data Classification Policy. Be mindful of the risks associated with sharing different data types as identified by their classification. Do not share our non-public information with Generative AI tools (e.g., ChatGPT or Bard) unless the tool is an approved vendor and sharing non-public information is explicitly authorized. Additionally, your use of the tool should be in accordance with the Acceptable Use Policy and Open Source Policy. Once you confirm you can disclose non-public information to a particular party, please continue to be cautious. Affirmers must not use, reveal, or divulge any such information except as permitted and strictly necessary. Make sure the person who receives the information understands any restrictions related to its use or dissemination. Generally, access to non-public information should be provided on a need-to-know basis and must be authorized in writing by your manager. Business plans and strategie Budgets, projections, forecasts, and result Financial and operating informatio Technical dat Sales goals and marketing plan Unpublished data and report Business contract Database Employee, consultant, and contractor personal informatio Customer and merchant partner informatio Compensation information (where such information is learned solely through the performance of your job duties) Intellectual property and know-ho Confidential Supervisory Information (CSI), pertaining to our regulator Other Affirm-internal data or information P r o t e c t i n g o u r c o m p a n y

| Code of Ethics & Business Conduct | 2024 21 Safeguard our non-public informationN - Do not leave it where others can see or have access to it; - Access and store it only on approved devices; - Do not discuss it in public places, including on social media (even private or direct messages); - Make sure confidential documents are secure always, even if they are in your desk or office; an8 - Dispose of all confidential information according to our policies. All Affirmers must sign the appropriate confidentiality agreement as a condition of their association with Affirm. If you become aware of any improper use or disclosure of the Companys non-public information, consult with the Ethics team. If you improperly use or disclose any of the Companys non-public information, you may be subject to disciplinary and/or legal action and liability, regardless of whether you receive any benefit from the use or disclosure. As applicable, an individual shall not be held criminally or civilly liable under any federal or state trade secret law for the disclosure of a trade secret that: (i) is made (a) in confidence to a federal, state, or local government official, either directly or indirectly, or to an attorney; and (b) solely for the purpose of reporting or investigating a suspected violation of law; or (ii) is made in a complaint or other document filed in a lawsuit or other proceeding, if such filing is made under seal. An individual who files a lawsuit for retaliation by an employer for reporting a suspected violation of law may disclose the employers trade secret to the attorney of the individual and use the trade secret information in the court proceeding if the individual files any document containing the trade secret under seal and does not disclose the trade secret, except pursuant to court order. Affirmers responsibility to protect our non-public information does not end when they leave the Company. You are still legally obligated and bound by your employment contract to protect non-public information. Do not share it with any current, former, or future employers. We depend on Affirmers to do what is right and take appropriate measures to preserve our non-public information. Help us protect Company assets. If you know or suspect that any of our assets, including non-public information, have been lost, stolen, or misused, report it immediately (within 24 hours) to the Global Safety & Physical Security team and/or the Information Security team, as applicable. They will promptly investigate the matter and take appropriate action. P r o t e c t i n g o u r c o m p a n y

| Code of Ethics & Business Conduct | 2024 22 Compliance with the law

| Code of Ethics & Business Conduct | 2024 23 Anti-bribery and corruption We are committed to winning business through fair and honest competition in the marketplace. Never offer, promise, or pay anything of value to someone with the intention of improperly influencing an official action or business decision in order to secure a business advantage. Affirm has implemented an Anti-Bribery & Anti-Corruption Policy to inform and guide compliance with both the letter and spirit of applicable anti-corruption laws, including the Foreign Corrupt Practices Act (FCPA). As further detailed in the Policy, you should never participate in bribery and, if you ever are unsure what to do, always ask the Ethics team before you act. The consequences of violating the FCPA, as well as the anti-corruption laws of other countries in which Affirm operates, can be severenot just for Affirm, but also for any individuals involved. Criminal and civil enforcement actions for violating these laws often carry harsh prison sentences and large monetary fines and penalties. This is serious business, and Affirmers must treat it as such. Be particularly careful when interacting with public officials, including employees of state-owned enterprises. Many countries, states, and local jurisdictions have limits and restrictions on what gifts and other things of value can be offered to these parties and those limits may be lower than the threshold specified in the Gifts and entertainment section below. While gifts and business entertainment provided to a public official for a legitimate business purpose may be reasonable in some locations, they may violate legal thresholds or be prohibited in others. Therefore, Affirmers must contact the Ethics team for approval prior to offering gifts or hospitality of any value, even a cup of coffee, to a public official. If you are not certain whether someone is a public official, contact the Ethics team. Refer to the Financial Crimes Global Anti-Bribery and Corruption Policy for more information. P r o t e c t i n g o u r c o m p a n y

| Code of Ethics & Business Conduct | 2024 24 Gifts and entertainment We always demonstrate sound judgment and moderation when exchanging business courtesies, even when using our own personal funds. Giving and receiving gifts and hospitality can build strong working relationships and goodwill between Affirm and those we do business with (for example, a meal with a merchant or partner to discuss bona fide business). However, gifts or hospitality that are extravagant or lack transparency or a legitimate purpose may be viewed as bribes, call into question our business decisions, or simply be inappropriate, erode trust, and harm our business. Before offering or receiving any kind of gift or entertainment to or from an external party, follow these rules: Whether offered or received, gifts and entertainment must always be: P r o t e c t i n g o u r c o m p a n y reasonable and appropriate under the circumstances, for a legitimate business purpose (such as to promote or provide an opportunity to discuss the business of the Company), and properly documented and supported per our Expense and Travel Policiesg when offered, valued at USD$200 or less per gift or entertainment expense, per external person, per yearg when received, valued at USD$200 or less per gift or entertainment expense, per entity, per yearg infrequentg provided and received transparently; anx if involving a public or foreign official, approved in advance by the Ethics team. for the purpose of obtaining new business, retaining existing business, expediting government action, or obtaining any improper advantage; in cash or a cash equivalent; extravagant in appearance; solicited by Affirmers from third partiesg provided by a representative, such as a merchant, partner, or vendor, on our behalf without first obtaining approval from the Ethics team; o offered to or received from a public or foreign official without first obtaining approval from the Ethics team. Gifts and entertainment must never be: Always contact the Ethics team if you are unsure what to do, or to obtain an exception to the above requirements based on business justification.

| Code of Ethics & Business Conduct | 2024 25 Insider trading compliance While working at Affirm, Affirmers may from time to time be aware of material non-public information about the Company or may learn of material non-public information about other companies, such as our merchants and partners. Under federal and state securities laws, it is illegal to trade in the securities of any company while being aware of material non-public information about that company. Accordingly, trading (including without limitation, in secondary market transactions and/or other transactions with third parties) in securities of Affirm or other companies while being aware of such information could constitute insider trading and violate the law, as could tipping (which is the act of providing material non-public information to others who then trade on the basis of that information). The consequences of insider trading or the tipping of material non-public information can be severethe person violating the laws, as well as Affirm, may be subject to criminal and civil lawsuits and financial penalties in connection with a violation of the insider trading laws. Information is material if a reasonable investor would consider it important in deciding whether to buy or sell securities. Information is non-public until it has been widely disseminated to the public market. Widely disseminated means that the information must be publicly released and sufficient time must have passed for the securities markets to digest the information. Refer to the Insider Trading Policy for examples of what may constitute material non-public information. In order to facilitate compliance with insider trading laws and Affirms Insider Trading Policy, Affirm has established quarterly trading windows. In addition, the Chief Legal Officer of Affirm may from time to time establish special closed trading windows, during which time some or all Affirmers will be prohibited from trading in Affirm securities. Refer to the Insider Trading Policy for additional information. Additionally, certain types of transactions involving Affirm securities are never allowed, such as: trading in publicly traded options, warrants, puts and calls or similar instruments on Affirm securities; engaging in short sales of Affirm securities; or engaging (directly or indirectly) in hedging transactions that are designed to hedge or offset any decrease in the market value of Affirm securities. Refer to the Insider Trading Policy for additional information. P r o t e c t i n g o u r c o m p a n y

| Code of Ethics & Business Conduct | 2024 26 Fair competition & antitrust Competition laws are designed to promote competition in the marketplace and protect consumers. These laws are complex and may differ from country to country. Make sure you understand the laws that apply to your work. We comply with applicable antitrust and competition laws and company policies in the countries where we operate. This policy applies to any proposal, agreement, or understanding, express or implied, formal or informal, written or oral, with any competitor. Examples of conduct prohibited under competition laws include, but are not limited to, proposals, agreements, or understandings with any competitor: Affirmers who have questions about how antitrust and competition laws apply in a particular situation should schedule a call with a member of the Legal team. Refer to the Fair Competition & Antitrust Policy for more information. | regarding pricesy | to rig bids or to allocate or divide customers or marketsy | to boycott a customer, merchant, or partnery | to limit fair employment practicesy | to reduce or eliminate discounts; and/ou | Regarding product or service offerings. P r o t e c t i n g o u r c o m p a n y

| Code of Ethics & Business Conduct | 2024 27 Data privacy Data privacy generally refers to the protection of personal data (also called personal information, PII, or PI), which is any information that identifies or can be used alone or in combination with other information to identify an individual. We protect personal data to comply with several United States and International data protection regulations, to mitigate risks to Affirm and our customers, and to meet our obligations to protect an individuals rights in, and to, data we collect about them. Affirm is committed to protecting the personal information of our customers, merchant partners, employees, and other individuals. Promoting the data privacy and security of our customers information is a critical responsibilityone that cannot be ignored, minimized, or sacrificed. Affirm has adopted policies to handle and safeguard data carefully and sensibly in a secure and appropriate manner. In compliance with data privacy laws, we work to keep personal data private. We collect, access, use, store, retain, transfer, and share our customers information only for verifiable legitimate business purposes and always in accordance with our privacy, information security, and records and information governance policies and applicable laws. To be able to share information, we may be required to obtain an NDA, DSA, or other documentation containing the appropriate confidentiality provisions. In addition, consent from the customer, employee, or merchant partner, and/or a risk assessment and approval by the Privacy team is frequently required. Sharing personal data (unless its your own or otherwise permitted by law) with any external or internal parties without a legitimate business need and permission from Legal is prohibited. We also are required to store proprietary and confidential personal data in a protected environment in accordance with Affirms Information Security Policy. We count on Affirmers to adhere to Affirms Information Security and Privacy policies. If you ever have any questions or concerns about how you should collect, protect, use, or share personal information, or suspect any violation of our policies or the law, immediately contact the Privacy team. Refer to the Privacy Policy for additional information. Modern Slavery Act Affirm and its United Kingdom (UK) business are fully committed to preventing modern slavery and human trafficking in our business and supply chains. The Modern Slavery Act (Act) sets forth a range of measures to prevent modern slavery and human trafficking in the UK. The term modern slavery describes the deprivation of a persons liberty in order to exploit them for personal or commercial gain. It is a criminal offense, a violation of fundamental human rights, and can take a number of forms, including slavery, forced or compulsory labor, servitude, human trafficking, and trafficking for prostitution or sexual exploitation. At Affirm, we take a zero-tolerance approach to modern slavery and will not knowingly support or deal with any business or supplier involved in such practices. P r o t e c t i n g o u r c o m p a n y

| Code of Ethics & Business Conduct | 2024 28 Communicating with our investors and the public

| Code of Ethics & Business Conduct | 2024 29 Records, records retention, and reporting All Affirmers have a responsibility to ensure that Affirms financial and business records are full, fair, accurate, timely, understandable reflections of Affirms business and operations, and are retained pursuant to Company policy. Affirmers should never falsify, forge, or improperly alter any Company records; doing so is grounds for disciplinary action up to and including termination. Any discovery of suspected falsified, forged, or altered records should be reported promptly to the Ethics team or by submitting a report, either identifiably or anonymously, to our reporting hotline, AffirmEthics.com by web, SMS, or phone, per the Whistleblower Policy. All Affirm financial transactions must be lawful, duly authorized, properly recorded, and executed in accordance with all Company policies and controls. All Affirmers also are required to cooperate with the Companys auditors. All Affirmers are responsible for ensuring that our financial reports and public filings, including all reports and other documents that Affirm files with, or submits to, the U.S. Securities and Exchange Commission (SEC), are complete, fair, accurate, timely, and understandable and otherwise satisfy applicable legal requirements and accounting standards. The Company may have obligations to preserve certain financial and business records, including electronic communications, in connection with existing or reasonably foreseeable legal and compliance matters, such as litigation, investigations, subpoenas, or enforcement proceedings. Electronic communications include, but are not limited to: email, messaging (Slack and Zoom Chat), video conferencing, electronically transmitted files, collaboration tools (Google Workspace, Asana), chat rooms, internal wikis (Confluence, Google sites), text messages, phone, and fax. Upon direction from the Legal team (known as a Litigation Hold Notice), Affirmers must not alter, delete, or destroy electronic communications or information subject to a Litigation Hold Notice. Please remember that your communications on or through Affirm systems may be shared or become public through these legal events or publication in the media. Potential risks from inaccurate or misleading statements include, but are not limited to, claims of false advertising, misrepresentation, breach of contract, securities fraud, unfair disclosure, and antitrust violations. C o m m u n i c a t i n g w i t h o u r i n v e s t o r s a n d t h e p u b l i c

| Code of Ethics & Business Conduct | 2024 30 Communications with the investment community Affirms communications with the Investment Community are closely regulated by the SEC. The Investment Community generally includes holders and potential holders of Affirm securities, as well as investment analysts, brokers, dealers, investment advisers and companies, certain institutional investors, and associated or affiliated persons of the foregoing. To facilitate compliance with SEC rules, the only persons authorized to speak on behalf of Affirm to the Investment Community are: Media relations & public statements For communications with external audiences other than the Investment Community, only specifically designated and trained employees (Spokespeople) may provide commentary on behalf of, or as a representative of, the Company with prior written approval from the Affirm Communications team. If any Affirmer is approached for interviews or commentary by members of the press, bloggers, analysts, vendors and/or customers in service of a news story or to discuss non-public information, direct the inquiry to the Affirm Communications team. As discussed above, please direct inquiries from the Investment Community to the Affirm Investor Relations team. Do not accept a media interview or engage in a conversation with the press as a representative of Affirm without prior approval from the Affirm Communications team. This includes off the record, background, or not for attribution comments as well. Speaking engagements All speaking engagements relating to an Affirmers job duties must be approved by the Communications and Ethics teams using the Speaking Request form, in addition to their department head, prior to acceptance. Once confirmed, all content and talking points should be approved by the Communications team before use. E ndorsements Affirmers may not give an endorsement on behalf of or as a representative of Affirm about our vendors, users, or merchants without prior written approval from the Communications, L egal, and Compliance teams, in addition to their department head. Affirmers must also obtain approval from the Communications team prior to agreeing (orally or in writing) to have Affirm publicly identified as a user of a third-partys services. If you are not one of these authorized spokespersons, please contact the Affirm Investor Relations team before communicating with the Investment Community. Refer to the Regulation FD P olicy for additional information. X the Chief Executive Officer^ X the Chief Financial Officer^ X the Chief Legal Officer^ X the Head of Investor Relations; anS X other persons specifically designated by any of the above persons to speak with respect to a particular topic or purpose. C o m m u n i c a t i n g w i t h o u r i n v e s t o r s a n d t h e p u b l i c S ocia l me d ia & p u bl ic f o r ums All Affirmers are required to comply with the Companys P ersonal U se of Social M edia P olicy and Business U se of Social M edia P olicy, which govern what type of social media behavior is permitted and prohibited, depending on whether the Affirmer is using their personal social media account or Affirms social media account.

Administration of our Code Oversight Affirms Code of Ethics & Business Conduct and its Ethics Program are endorsed by and have the full support of Affirms Board of Directors. Affirms executive team and their designees are responsible for managing and directing Affirms Ethics Program and for implementing measures to facilitate compliance with the Code. The Board of Directors is responsible for overseeing the efforts of the executive team and their designees in that regard. Waiver of the Code Only the Board of Directors may waive a provision of the Code for a director or executive officer. Any waiver that is granted to a director or executive officer will be publicly disclosed as required by SEC rules or Nasdaq marketplace rules. All other requests for waivers, should there be any, should be sent to the Ethics team. Last updated This version of the Code of Ethics & Business Conduct was approved by the Board of Directors and effective as of January 10, 2024.