| 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