| 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.

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