| 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.