Acoustic Global Code of Conduct

Since our inception, Acoustic, L.P. (“Company”) has served thousands of customers around the
globe and been recognized as a leader in our industry. We are a team that is driven to
succeed. How we carry out our mission is as important as the mission itself.

The Acoustic Global Code of Conduct (“Code”) is intended to be a practical guide that can help
us make sound decisions across a variety of situations involving our business. We are each
responsible for reading through it, understanding it and participating fully in associated training.
This Code and related trainings are valuable and should reinforce our pride in working at an
organization where ethical behavior and a commitment to honesty, integrity, and respect are
fundamental to everything we do.

Thank you for everything you do to make our organization, our fellow employees, our partners,
and our customers successful.

Mark Cattini

• Introduction
• Support Each Other
• Preserve Confidentiality
• Protect Acoustic’s Assets
• Ensure Financial Integrity and Responsibility
• Obey the Law and Employ Ethical Business Practices
• Asking Questions and Reporting Concerns
• Conclusion
Introduction
Our Values
Trust and security
We are responsible stewards and prioritize the safety, quality and privacy of all stakeholder
data and experiences.

Team and passion

We are one team! We have passion for what we do and inspire one another to deliver
exceptional results through accountability, recognition and reward.

Respect all people

We are honest and transparent, and recognize the diverse thoughts, feelings and backgrounds
of one another.

Innovation
We are relentless in our pursuit to empower our customers with the industry’s most relevant
solutions. We take bold risks and encourage curiosity.

Customer delight
We think like our customers and solve key business challenges to deliver beyond expectation.

The Code
The Code is built around the recognition that everything we do in connection with our work at
Acoustic should be measured against the highest standards of ethical business conduct. Our
commitment to these standards helps us hire great people, build great products, and attract loyal
customers.

Employees of Acoustic should do the right thing – follow the law, act honorably and ethically,
and treat co-workers with courtesy and respect.

In order to foster strong relationships and act with character, we must conduct all Company
business in accordance with our Code, our internal policies and applicable laws and regulations.
All employees should read and follow our Company policies, some of which are cited in this
Code. You can find other policies and guidance on Acoustic’s intranet Company Policy space.

Our Code helps us to uphold our values by providing guidance on how to identify and promptly
address ethical issues as they arise. It also provides clear channels of communication for asking
questions or reporting unethical conduct without fear of retaliation or retribution.
Who Must Follow Our Code?
We rely on one another’s good judgment to uphold a high standard of integrity for ourselves and
our Company. We expect all our employees, advisors, and third parties to know, follow, and
attest to the letter and spirit of this Code. Failure to do so can result in disciplinary action, up to
and including termination of their relationship with Acoustic.

What If I Have a Code-Related Question or Concern?

If you have a question or concern, please speak up. You can contact your manager, Human
Resources, Legal, or report your concern anonymously on AllVoices.

No Retaliation
Acoustic prohibits retaliation against any employee at Acoustic who reports or participates in an
investigation of a possible violation of our Code, policies, or the law. An employee will not be
subject to an adverse employment action for reporting, in good faith, a suspected violation of our
Code, Company policy or the law, or participating in an investigation. Acting in “good faith”
means that you come forward with the relevant information, without malice or ill intent, and that
you believe you are giving a sincere, complete and accurate report. Anyone who does take, or
attempts to engage in, retaliatory action will be subject to disciplinary action, up to and including
termination. If you believe you are being retaliated against, contact our anonymous speak up
hotline at AllVoices .

Our Code is Global

As a global company, this Code reflects the minimum standards to which we hold ourselves,
each other and our Company that will help drive success in every community in which we
operate. The laws and regulations of more than one country may apply to the work we
do. Regardless of location, we must understand and abide by the laws and regulations that apply
to the work we perform.

Serve Our Customers and Partners

Our customers and partners value our Company not only because we listen and respond by
delivering great products and services, but also because we hold ourselves to a higher standard in
how we treat our customers and operate more generally. Keeping the following principles in
mind will help us to maintain that high standard.
Integrity
Our reputation as a company that our customers and partners can trust is our most valuable asset,
and it is up to all of us to make sure that we continually earn that trust. All of our
communications and other interactions with our customers and partners should increase their
trust in us.

Responsiveness
Part of earning the trust of customers and partners requires us to listen carefully and be
responsive: we recognize relevant feedback when we hear it, and we do something about it. We
take pride in responding to communications from our customers and partners, whether questions,
problems, or compliments. If something is broken, please fix it.

Privacy and Security

Always remember that we are asking customers and partners to trust us with their and others’
confidential information. Preserving that trust requires that each of us respect and protect the
privacy and security of that information. Our security procedures strictly limit access to and use
of all confidential information and require that each of us take measures to protect personal data
from unauthorized access. Know your responsibilities under these procedures, and collect, use,
and access confidential information only as authorized by our Security Policies, our Privacy
Notice, and applicable data protection laws.

Take Action
Any time you feel our customers or partners aren’t being well-served, don’t be bashful - let
someone in the Company know about it. Continually improving our products and services takes
all of us, and we’re proud that our employees champion our customers and partners and take the
initiative to step forward when their interests are at stake.

Support Each Other

We are committed to a supportive work environment, where employees have the opportunity to
reach their fullest potential. Employees are expected to do their utmost to create a workplace
culture that is free of harassment, intimidation, bias, and discrimination. Know your options for
reporting harassment, intimidation, discrimination and bias by reviewing the Company’s Speak
Up Policy

1. Equal Opportunity Employment

We are committed to making employment decisions based on qualifications, skills and

merit. Acoustic strictly prohibits unlawful discrimination on the basis of race, color, religion,
veteran status, national origin, citizenship, pregnancy status, sex, gender identity or expression,
age, marital status, mental or physical disability, medical condition, sexual orientation, or any
other basis protected by relevant laws. The Company is committed to complying with our
obligations under laws protecting disability, religious, or other country specific rights for
workplace accommodations. Please contact [email protected] to submit all accommodations
requests.

2. Harassment, Discrimination, and Bullying

Acoustic prohibits harassment, discrimination and bullying in any form – verbal, physical, or
visual. If you believe you have been bullied or harassed by anyone at Acoustic, or by an
Acoustic partner or vendor, we strongly encourage you to immediately report the incident to HR
or, if you wish to report anonymously, AllVoices. Similarly, employees and managers who learn
of any such incident should immediately report it to HR, or, if they wish to report anonymously,
AllVoices. HR & Legal will promptly and thoroughly investigate any complaints and take
appropriate action.

3. Drugs and Alcohol

Our position on substance abuse is simple: it is incompatible with the health and safety of our
employees, and we don’t permit it. Consumption of alcohol is not banned at our offices but use
good judgment and never drink during office hours and in a way that leads to impaired
performance or inappropriate behavior, endangers the safety of others, or violates the
law. Illegal drugs in our offices or at sponsored events are strictly prohibited.

4. Safe Workplace

We are committed to a violence-free work environment, and we will not tolerate any level of
violence or the threat of violence in the workplace. Under no circumstances should anyone bring
a weapon to work or any off-site locations where Company business is conducted or at
Company-sponsored events. If you become aware of a violation of this policy, you should report
it to the appropriate local authorities and HR immediately.

5. Employee Benefits

The Company is committed to providing employees with health and wellness benefits. As
benefits are determined based on employee's country of residence, employees can find their
benefits on Acoustic’s intranet or by contacting the [email protected].

Avoid Conflicts of Interest

The Company prohibits conduct that creates an actual or potential conflict of interest that
interferes or could interfere with your ability to act impartially and in the best interests of our
Company. Be aware that even the perception of a conflict could create an issue and be harmful to
the Company and your reputation and should be avoided.
Generally, a conflict of interest occurs when a personal interest or activity interferes or has the
potential to interfere with your professional judgment or ability to act or make decisions
impartially and in the best interests of the Company. It is your responsibility to understand that
circumstances change, and a situation that previously did not present a conflict of interest may
now present one.

Conflicts of interest can arise through a wide variety of circumstances, and this does not cover
every possible conflict of interest situation. It is the employee’s responsibility to raise any
potential conflicts of interest with HR and Legal. If you have any doubt regarding whether you
are in a conflict of interest situation, discuss it with HR & Legal.

Additional Information
Conflicts of interest often arise in the following areas:

• Personal investments
• Outside employment, advisory roles, board seats, and starting your own business
• Business opportunities found through work
• Inventions
• Friends and relatives; co-worker relationships
• Accepting gifts, entertainment, and other business courtesies
• Use of Acoustic products and services

Personal Investments
Avoid making personal investments in companies that are Acoustic competitors or business
partners when the investment might cause, or appear to cause, you to act in a way that could
harm the Company.

When determining whether a personal investment creates a conflict of interest, consider the
relationship between the business of the outside company, Acoustic’s business, and what you do
at Acoustic, including whether the company has a business relationship with Acoustic that you
can influence, and the extent to which the company competes with Acoustic. You should also
consider:

a) any overlap between your specific role at Acoustic and the company’s business,

b) the significance of the investment,

c) whether the investment is in a public or private company,

d) your ownership percentage of the company, and

e) the extent to which the investment gives you the ability to manage and control the company.

Investments in venture capital or other similar funds that invest in a broad cross-section of
companies that may include Acoustic competitors or business partners generally do not create
conflicts of interest. However, a conflict of interest may exist if you control the fund’s
investment activity.

Outside Employment, Advisory Roles, Board Seats, and

Starting Your Own Business
Avoid accepting employment, advisory positions, or board seats with Acoustic competitors or
business partners when your judgment could be, or could appear to be, influenced in a way that
could harm our Company. Additionally, because board seats come with fiduciary obligations that
can make them particularly tricky from a conflict of interest perspective, you should notify Legal
before accepting a board seat with any outside company. Do not start your own business, accept
other employment or roles if it will compete with Acoustic or interfere with your role at
Acoustic, including interfering with the time that you are required to spend working for
Acoustic.

Business Opportunities Found Through Work

Business opportunities discovered through your work here belong first to Acoustic, except as
otherwise agreed to by Acoustic.

Inventions
Developing or helping to develop outside inventions that: a) relate to Acoustic’s existing or
reasonably anticipated products and services; b) relate to your position at Acoustic, or c) are
developed using Acoustic corporate resources may create conflicts of interest and be subject to
the provisions of Acoustic’s Confidential Information and Intellectual Property Agreement and
other employment agreements executed during employee’s hiring process. If you have any
questions about potential conflicts or intellectual property ownership involving an outside
invention or other intellectual property, consult Legal.
Friends and Relatives; Co-Worker Relationships
Avoid participating in management of or decision-making regarding potential or existing
Acoustic business relationships that involve your relatives, spouse or significant other, or close
friends. This includes being the hiring manager for a position for which your relative or close
friend is being considered or being a relationship manager for a customer or vendor associated
with your spouse or significant other.

Just because a relative, spouse/significant other, or close friend works at Acoustic or becomes an
Acoustic competitor or business partner doesn’t mean there is a conflict of interest. However, if
you are also involved in that Acoustic business relationship, it can be very sensitive. The right
thing to do in that situation is to discuss the relationship with HR and Legal.

Preserve Confidentiality
We must take care to protect our company information and our responsibilities extend beyond
not revealing Acoustic Confidential information. We must also:

• properly secure, label, handle, and (when appropriate) dispose of Acoustic Confidential
information;
• safeguard Confidential information that Acoustic receives from others under non-
disclosure agreements;
• take steps to keep our trade secrets and other confidential intellectual property secret.

1. Confidential Information

Make sure that information that is classified as Acoustic Confidential in Acoustic’s Information
Security policy is handled in accordance with such policy. At times, a particular project or
negotiation may require you to disclose Acoustic Confidential information to an outside party.
Disclosure of Acoustic Confidential information should be on an “only as needed” basis and only
under a non-disclosure agreement (“NDA”). See Legal Department NDA

There are, of course, gray areas in which you will need to apply your best judgment in making
sure you don’t disclose any Acoustic Confidential information. If you are unsure, don’t hesitate
to ask for guidance from the Legal Department.

In addition, Acoustic policy may require a prior security assessment of the outside party that is to
receive the Acoustic Confidential information. Be sure to conduct the appropriate due diligence
and have the appropriate agreement in place before you disclose any information. If you have
any questions or require further guidance, please contact Acoustic’s Chief Information Security
Officer (CISO).

2. Acoustic Partners/Competitors/Former Employers

Just as you are careful not to disclose confidential Acoustic Confidential information, it’s equally
important not to disclose any confidential information from our partners. Don’t accept
confidential information from other companies without first having all parties sign an appropriate
NDA approved by the Legal Department. Also, we respect our competitors and want to compete
with them fairly. If an opportunity arises to take advantage of a competitor’s or former
employer’s confidential information, don’t take it; we don’t want their confidential information.
Should you happen to come into possession of a competitor’s confidential information, contact
Acoustic’s General Counsel immediately.

3. Outside Communications

It is our policy to be extremely careful about disclosing confidential proprietary information, and
you should ensure your outside communications (including online and social media posts as
outlined in our Social Media Policy) do not disclose confidential proprietary information or
represent, or otherwise give the impression, that you are speaking on behalf of Acoustic unless
you’re authorized to do so by the Company.

For company spokesperson requests received from members of the media, please direct them to
Corporate Communications. Additionally, we require that all spokespeople representing
Acoustic complete media training. Please route all media requests through Corporate
Communications before agreeing to participate in any opportunities.

It is important that our Corporate Communications and Marketing teams are aware of any other
forums where you plan to represent the Acoustic brand (webinars with customers or partners,
other industry speaking events, contributions to industry forums, etc.). Check with your manager
or the Chief Marketing Officer before accepting any public speaking engagement on behalf of
Acoustic.

4. Privacy and Personal Information

Acoustic is committed to protecting and responsibly using personal information of employees,

customers and other third parties and upholding an environment of trust and integrity with the
business community. Privacy laws address the requirement around the obligations of security
and confidentiality of personal information, which generally refers to information that can be
used to identify, contact or locate an individual, and in some cases behavioral data, which
generally refers to information concerning an individual’s activities. Like Acoustic Confidential
information, personal information requires special care and handling which is consistent with
Acoustic’s policies and relevant laws and regulations. Please consult Acoustic’s Privacy Notice
and all relevant Acoustic IT policies, processes and standards when handling personal
information, including the Acoustic Information Security policy.
Protect Acoustic’s Assets
Our ability to work collaboratively and openly with each other contributes to our ability to make
our employees and Acoustic successful. To preserve our collaborative culture, we must be
mindful to conserve and protect Company assets and information.

1. Intellectual Property

Acoustic’s intellectual property rights (our trademarks, logos, copyrights, trade secrets, “know-
how”, and patents) are among our most valuable assets. Unauthorized use can lead to their loss
or serious loss of value. You must respect all copyright and other intellectual property laws,
including laws governing the fair use of copyrights, trademarks, and brands. You must never use
Acoustic’s logos, marks, or other protected information or property for any business or
commercial venture without proper clearance. You should report any suspected misuse of
Acoustic intellectual property to the Legal Department.

Likewise, respect the intellectual property rights of others. Inappropriate use of others’
intellectual property may expose Acoustic and you to criminal and civil fines and penalties. You
should seek advice from the Legal Department before you solicit, accept, or use proprietary
information from individuals outside the Company or let them use or have access to Acoustic
proprietary information. You should also check with Acoustic’s Legal Department if developing
a product that uses content, including, for example, photographs, music, film or video clips, not
belonging to Acoustic.

A word about open source – Acoustic is committed to open source software

development. Consistent with our policy of respecting the valid intellectual property rights of
others, we strictly comply with the license requirements under which open source software is
distributed. Open Source Software Usage policy. Failing to do so may lead to legal claims
against Acoustic, as well as significant damage to the company’s reputation and its standing in
the open source community. Contact the Legal Department for guidance before incorporating
open source code into any Acoustic product, service, or internal project. We also support the safe
and responsible contribution of code to open source projects. Prior to submitting any code, it
must be reviewed by the Chief Information Security Officer or his/her designee for compliance
with the Open Source Software Usage policy linked above. In addition, prior approval is
required if any of the assets or intellectual property (including code) to be contributed are owned
by or utilize any assets or intellectual property (including code), of Acoustic.

2. Company Equipment

Acoustic gives us the tools and equipment we need to do our jobs effectively but counts on us to
be responsible and not wasteful with them. Company funds, equipment, software, electronic
files, data and other physical and non-physical assets are not to be requisitioned for purely
personal use. If you use Acoustic equipment outside of an Acoustic office or facility, take
precautions to protect it from theft or damage. If you are unsure if a certain use of company
assets is okay, please ask your manager or HR. If you leave Acoustic employment for any
reason, you must immediately return all Acoustic resources, assets and equipment in normal
operating condition.
3. The Network

Acoustic’s communication facilities (which include both our network and the hardware that uses
it, like computers and mobile devices) are a critical aspect of our Company’s property, both
physical and intellectual. Be sure to follow all security policies. If you have any reason to believe
that the network security has been violated – for example, you lose your laptop or smart phone or
think that your network password may have been compromised – please promptly report the
incident to Information Security at [email protected].

4. Physical Security

Always secure your laptop, important equipment, and your personal belongings, even while on
Acoustic’s premises. Do not tamper with or disable security and safety devices. Promptly report
any suspicious activity to your manager.

5. Use of Acoustic’s Equipment and Facilities

Anything you do using Acoustic’s corporate electronic facilities (for example, our computers,
mobile devices, network, etc.) or store on our premises (for example, documents) might be
disclosed to people inside and outside the company. For example, Acoustic may be required by
law (for example, in response to a subpoena or warrant) to monitor, access, and disclose the
contents of corporate email, voicemail, computer files, and other materials on our electronic
facilities or on our premises. In addition, as permitted by local law, the company may monitor,
access, and disclose employee communications and other information on our corporate electronic
facilities or on our premises where there is a business need to do so, such as protecting
employees and customers, maintaining the security of resources and property, or investigating
suspected employee misconduct.

6. Employee Data

We collect and store personal information from employees around the world. It is each
employee’s responsibility to update their personnel data maintained in the Company’s self-
service portal as soon as changes occur. An employee’s home address, telephone number,
dependent information, emergency contacts, and other related information should be current at
all times. Any update to your home address that involves a relocation outside of your primary
state or country shall require pre-approval by HR no less than thirty (30) days prior to the
relocation event. The Company maintains the right to review and deny such request or adjust
compensation and benefits based on employee’s new residence.

As a global company, in order to perform its function as an employer, Acoustic may need to
transfer your personal data between the countries in which Acoustic is located to group
companies and third-party service providers. Therefore, your personal data may be processed
outside your jurisdiction, including in countries and jurisdictions that are not subject to an
adequacy decision by the European Commission or your local legislature or regulator, and that
may not provide for the same level of data protection as your jurisdiction. We ensure that the
recipient of your personal data offers an adequate level of protection and security, for instance by
entering into the appropriate back-to-back agreements and, if required, standard contractual
clauses or an alternative mechanism for the transfer of data as approved by the European
Commission (pursuant Art. 46 GDPR) or other applicable regulators or legislators. Where
required by applicable law, we will only share, transfer or store your personal data outside of
your jurisdiction with your prior consent.

As permitted by local law, it is important to understand that information created, accessed,

transmitted or stored using Acoustic’s technology resources, such as email, messages, computer
files, telephone messages, or websites in your browsing history are Acoustic resources and
assets. To the extent permitted by law, we may access, monitor or inspect Acoustic resources,
assets, and property at any time without prior approval or knowledge or consent of affected
employees.

From time to time, employees might require verification of employment. The Company shall
provide a neutral reference policy that will only provide facts as legally permitted by local
government regulations.

For further information, please review the Acoustic Information Security policy.

Ensure Financial Integrity and Responsibility

Financial integrity and fiscal responsibility are core aspects of corporate professionalism. This is
more than accurate reporting of our financials. The money we spend on behalf of Acoustic is not
ours; it is the Company’s. Each person at Acoustic, not just those in the Finance Department,
has a role in making sure that money is appropriately spent, our financial records are complete
and accurate, and internal controls are honored. This matters every time we hire a new vendor,
expense something to Acoustic, sign a new business contract, or enter any deals on Acoustic’s
behalf. Stay in full compliance with our system of internal controls, and do not hesitate to
contact the Finance Department if you have any questions.

1. Spending Acoustic’s Money

A core Acoustic value is to spend money wisely. When you submit an expense for
reimbursement or spend money on Acoustic’s behalf, make sure that the cost complies with our
Company’s Travel and Expense Policy. Always record the business purpose (for example, if you
take someone out to dinner on Acoustic, always record in our expense reimbursement tool the
full names and titles of the people who attended as well as the reason for the dinner) and comply
with other submission requirements. Managers are responsible for all money spent and expenses
incurred by their direct reports and should carefully review such spend and expenses before
approving.

2. Signing a Contract

Each time you enter into a business transaction on Acoustic’s behalf, there should be
documentation recording that agreement, approved by the Legal Department. Signing a contract
on behalf of Acoustic is a very big deal. Never sign any contract on behalf of Acoustic unless
you are authorized in writing to do so and the contract has been approved by Legal. All approved
authorized signers are listed on Legal’s Confluence page. Any contracts signed without the
proper approval or signatories can result in a serious infraction, including but not limited to,
termination of employment. All contracts at Acoustic should be in writing and should contain all
the relevant terms to which the parties are agreeing. Acoustic does not permit “side
agreements,” oral or written.

3. Reporting Financial or Accounting Irregularities

You should never, ever interfere in any way with the auditing of Acoustic’s financial
records. Similarly, you should never falsify any record or account, including time reports,
expense accounts, and any other Acoustic records.

If you suspect or observe any of the conduct mentioned above or, for that matter, any
irregularities relating to financial integrity or fiscal responsibility, no matter how small,
immediately report them to the Legal Department.

4. Hiring Suppliers

We should always strive for the best possible deal for Acoustic. While price is very important, it
isn’t the only factor worth considering. Quality, service, reliability, and the terms and conditions
of the proposed deal may also affect the final decision. Please work with your manager and
contact Acoustic Procurement when procuring equipment or services.

5. Managing and Retaining Records

It’s important that we keep records for an appropriate length of time and certain types of records
will have certain required retention periods pursuant to relevant guidelines. Legal may ask you to
retain records relevant to a litigation, audit, or investigation, and if you receive this request, you
must do so until Legal tells you retention is no longer necessary. If you have any questions
regarding the correct length of time to retain a record, please refer to the Acoustic Records
Management Policy or contact the Legal Department with any questions.

6. Non-Solicitation

The Company supports the efforts of its employees to be involved in the community and to
further charitable causes. However, to avoid distractions, solicitation, and distribution during
working time, in work areas, or via the Company's communication infrastructure is prohibited.
This policy prohibits solicitations via the Company's email. “Working time” is the time an
employee is engaged, or should be engaged, in performing his/her work tasks for the Company.
Solicitation of any kind by non-employees in the office or on Company premises is prohibited at
all times.

Distribution of advertising material, handbills, any other printed or written literature in working
areas of the Company premises is prohibited at all times. Distribution of literature by non-
employees on Company premises is prohibited at all times.
Obey the Law and Employ Ethical Business
Practices
Acoustic takes its responsibilities to comply with laws and regulations very seriously and each of
us is expected to comply with applicable legal requirements and prohibitions and conduct
ourselves with integrity in all our business interactions. As noted in the introduction to this Code,
the laws and regulations of more than one country may apply to the work we do. Regardless of
location, we must understand and abide by the laws and regulations that apply to the work we
perform. If the laws of the territory in which you do business provide for higher standards than
this Code, the standards of those local Laws will apply. Likewise, if there is a conflict between
this Code and the Employee Handbook that applies to your location, the terms of the Employee
Handbook will apply. If you believe there is a conflict between U.S. or local laws and this Code
or an Employee Handbook, or you have any questions, please contact the Legal Department for
guidance. It is worth highlighting the following areas:

1. Trade Controls

U.S. and international trade laws control where Acoustic can send or receive its products and/or
services. These laws are complex and what constitutes an “import” or “export” under the law is
pretty broad. If you have any questions around sending or making available Acoustic products,
services, or technical data from one country to another, please contact the Legal Department.

Acoustic and its personnel are prohibited by US law from participating in unsanctioned boycotts
of other countries. If you receive any request to participate in, or for information related to, any
boycotts, you must report the request to Acoustic’s General Counsel, as Acoustic is required to
report promptly any such requests.

2. Free and Fair Competition Laws

Most countries have laws – known as “antitrust,” “competition” or “unfair competition” laws –
designed to promote free and fair competition and protect consumers. Generally speaking, these
laws prohibit 1) arrangements with competitors that restrain trade or distort fair competition in
some way, 2) abuse of intellectual property rights, and 3) abuse of market power to unfairly
disadvantage competitors.

Certain conduct is absolutely prohibited under these laws, and could result in your imprisonment,
not to mention severe penalties for Acoustic. Examples of prohibited conduct include:

• agreeing with competitors about prices

• agreeing with competitors to rig bids or to allocate customers or markets
• agreeing with competitors to boycott a supplier or customer

In addition, specific countries have laws that prohibit and penalize conduct that might be
acceptable in under the laws of other countries. Examples of this prohibited conduct include:
 • agreeing with a reseller to only sell at a price specified by Acoustic
• agreeing with a reseller to only sell in a designated territory

Acoustic is committed to fair competition. Please contact the Legal Department if you have any
questions about the antitrust laws, the types of conduct specified above and the laws apply to
you. If you suspect that anyone at the company is violating the competition laws, notify General
Counsel immediately.

3. Anti-Bribery Laws

Acoustic is subject to many laws that prohibit bribery in virtually every kind of commercial
setting. Our rule at Acoustic is simple – don’t offer a bribe to or solicit a bribe from anybody,
anytime, for any reason.

Be careful when you give gifts and pay for meals, entertainment, or other business courtesies on
behalf of Acoustic. We want to avoid the possibility that the gift, entertainment, or other
business courtesy could be perceived as a bribe and be especially mindful when dealing with a
government official. “Government officials” include any government employee, candidate for
public office, or employee of government-owned or -controlled companies, public international
organizations, or political parties. Several laws around the world, including the U.S. Foreign
Corrupt Practices Act and the UK Bribery Act, specifically prohibit offering or giving anything
of value to government officials to influence official action or to secure an improper advantage.
Never give gifts to thank government officials for doing their jobs. Under certain circumstances
and with relevant approvals, it may be acceptable to make infrequent and moderate expenditures
for gifts and business entertainment for government officials.

In sum, it's always best to provide such business courtesies infrequently and, when you do, to
keep their value moderate. Familiarize yourself with Acoustic’s Anti-Bribery and Anti-
Corruption policy and Gifts and Client Entertainment policy, and before offering any gifts or
business courtesies to a U.S. or other government official, carefully follow the limits and
prohibitions described in those policies and obtain any required pre-approvals.

4. Social Responsibility

Acoustic is committed to corporate responsibility and protecting the environment and will work
to comply with all applicable environmental laws. Acoustic will comply with all applicable
laws prohibiting forced or involuntary labor, child labor, human trafficking and slavery. In
addition, Acoustic supports fair labor practices, including the freedom to associate, within the
legal framework of the respective country in which employees work.

5. Global Sanctions

As outlined in the Global Sanctions Policy, our Company will not engage in prohibited
transactions with individuals, entities or restricted countries designated by Office of Foreign
Assets Control of the U.S. Department of the Treasury (“OFAC”), the United Nations (“UN”),
the European Union (“EU”), the United Kingdom (“UK”) or imposed under similar sanctions
regulations in other countries where the Company does business. All Acoustic employees,
officers and directors, and all those acting for or on behalf of Acoustic, including affiliates and
third-party vendors, must comply with all applicable sanctions restrictions in our operations
worldwide.

If an employee suspects or becomes aware of any known or suspected violation of a global

sanction involving Acoustic, such employee should promptly report Legal.

What are Sanctions?

Sanctions are restrictive measures imposed on countries, governments, entities, individuals,

industries, and targeted regimes by international bodies such as OFAC, the UN, the EU, the UK,
or other individual countries or groups of countries.

Restrictions relating to sanctions can have a very wide application, often applying to all persons
within the jurisdiction that imposes the restrictions, including companies and other legal entities
that are incorporated or organized, or are conducting business, within that jurisdiction.

All Acoustic personnel must be aware of sanctions requirements. The potential restrictions may
be related to:

• Where we do business: ensuring compliance with sanctions on restricted

countries/territories
• Who we do business with: ensuring compliance with sanctions on restricted
persons/entities
• How we do business: ensuring we do not circumvent, evade, or facilitate the
contravention of sanctions

Red flags: ensuring we report any suspicions which may raise sanctions concerns

Penalties for Violating Global Sanctions

Sanctions violations may lead to severe civil and/or criminal penalties against Acoustic and
individuals, including significant monetary fines, imprisonment, public reprimand, limitation on
business, and other serious consequences. In addition, violations can lead to damaging practical
consequences, including reputational damage, harm to commercial relationships and extensive
time and cost in conducting internal investigations and/or defending against government
investigations and enforcement actions.

Anyone who violates this Policy is subject to appropriate disciplinary action, up to and including
dismissal, and may also be subject to individual criminal and/or civil prosecution in relevant
jurisdictions.

Third parties working with Acoustic who violate this Policy are subject to termination of all
commercial relationships with Acoustic in addition to potential criminal and/or civil prosecution.

Asking Questions and Reporting Concerns

We value honesty, integrity, and respect, so always speak up to ask questions or report issues
with appropriate urgency. If you become aware of a situation that may violate our Code,
Company policy or the law, you should report it to your manager, Human Resources or the Legal
Department. When a report or inquiry is made, the Company will respond promptly and
appropriately, and all reports and inquiries will be treated confidentially to the extent possible.\

Conclusion
It’s impossible to spell out every possible ethical scenario you might face. If you find yourself in
a situation in which you are unsure whether a decision or action is the most appropriate one, try
to answer the following questions and if you still wish to speak to someone, seek guidance from
your manager, HR or the Legal Department.

1. Is this the right thing to do?

2. Does it follow our Code, policies and applicable laws and regulations?

3. Am I being respectful, honest and fair?

4. If my decision were reported in the media, how would I or Acoustic be perceived?

Acoustic Code last updated: February 1, 2023