CONFLICT OF INTEREST & INTEGRITY POLICY

HERPTIVARIUS, LLC

EFFECTIVE DATE: DECEMBER 2025

LAST UPDATED: DECEMBER 2025

SUPREMACY; INCORPORATION; NO INDEPENDENT REMEDIES: THIS CONFLICT OF INTEREST & INTEGRITY POLICY IS EXPRESSLY INCORPORATED INTO AND GOVERNED BY THE HERPTIVARIUS, LLC TERMS & CONDITIONS AND IS STRICTLY SUBORDINATE THERETO. THIS POLICY ALSO OPERATES IN CONJUNCTION WITH ALL APPLICABLE INTERNAL GOVERNANCE, ETHICS, SECURITY, PRIVACY, AND EMPLOYMENT POLICIES. NO PROVISION OF THIS POLICY CREATES ANY INDEPENDENT RIGHT, WARRANTY, OR REMEDY OUTSIDE THE SOLE AUTHORITY OF THE TERMS & CONDITIONS MASTER AGREEMENT. IN THE EVENT OF ANY CONFLICT, THE TERMS & CONDITIONS AND APPLICABLE LAW CONTROL.

PURPOSE AND STANDARD: HERPTIVARIUS, LLC REQUIRES DECISIONS TO BE MADE WITH INTEGRITY, NEUTRALITY, AND INDEPENDENT BUSINESS JUDGMENT. THE PURPOSE OF THIS POLICY IS TO PREVENT, IDENTIFY, DISCLOSE, AND MANAGE CONFLICTS OF INTEREST, BIASES, AND SITUATIONS THAT COULD REASONABLY CALL FAIRNESS, OBJECTIVITY, OR INTEGRITY INTO QUESTION. THIS POLICY IS DESIGNED TO PROTECT CUSTOMERS, THE PUBLIC, THE COMPANY, AND INDIVIDUALS ACTING ON BEHALF OF THE COMPANY FROM IMPROPER INFLUENCE, FAVORITISM, SELF-DEALING, RETALIATION, OR DECISION-MAKING TAINTED BY PERSONAL INTEREST.

WHO THIS APPLIES TO: THIS POLICY APPLIES TO HERPTIVARIUS, LLC, ALL DIVISIONS, OWNERS, OFFICERS, MANAGERS, EMPLOYEES, CONTRACTORS, AGENTS, REPRESENTATIVES, AND ANY PERSON ACTING FOR OR ON BEHALF OF THE COMPANY IN ANY CAPACITY. THIS POLICY APPLIES TO BOTH INTERNAL DECISION-MAKING AND EXTERNAL-FACING CONDUCT, INCLUDING PROCUREMENT, SALES, CUSTOMER SUPPORT, EMPLOYMENT ACTIONS, DISPUTE HANDLING, CONTENT MODERATION, SECURITY ENFORCEMENT, AND COMPLIANCE DETERMINATIONS.

DEFINITIONS; CONFLICT OF INTEREST: A CONFLICT OF INTEREST EXISTS WHEN A PERSON’S PERSONAL, FINANCIAL, RELATIONAL, OR OUTSIDE INTERESTS COULD INFLUENCE, APPEAR TO INFLUENCE, OR REASONABLY BE ALLEGED TO INFLUENCE THEIR JUDGMENT OR ACTIONS ON BEHALF OF HERPTIVARIUS, LLC. CONFLICTS CAN BE ACTUAL, POTENTIAL, OR PERCEIVED. PERCEIVED CONFLICTS MATTER, BECAUSE APPEARANCE OF BIAS CAN DAMAGE TRUST EVEN IF NO IMPROPER ACTION OCCURS.

INTEGRITY DISQUALIFIERS; THE “PERSONALLY INVOLVED” STANDARD: ANY INDIVIDUAL SHALL BE DISQUALIFIED FROM HANDLING, DECIDING, INVESTIGATING, APPROVING, OR ENFORCING A MATTER WHEN THEY ARE PERSONALLY INVOLVED, HAVE PRIOR DEALINGS OR A MATERIAL HISTORY WITH A PARTY, OR HAVE OTHERWISE BECOME AN ADVOCATE FOR ONE PERSON AGAINST ANOTHER SUCH THAT THEIR NEUTRALITY CAN REASONABLY BE QUESTIONED. THIS INCLUDES ANY SITUATION WHERE A REASONABLE PERSON COULD CONCLUDE THAT THE DECISION-MAKER’S INTEGRITY, OBJECTIVITY, OR FAIRNESS IS COMPROMISED, OR THAT THE PROCESS ITSELF HAS BEEN TAINTED. WHEN THE INTEGRITY OF THE DECISION-MAKER OR THE PROCESS IS IN DOUBT, THE PROCESS IS NO LONGER TRUSTWORTHY, AND RECUSAL OR REASSIGNMENT IS REQUIRED.

GENERAL DUTY TO DISCLOSE AND RECUSAL: ALL COVERED PERSONS HAVE A CONTINUING DUTY TO PROMPTLY DISCLOSE ANY ACTUAL, POTENTIAL, OR PERCEIVED CONFLICT OF INTEREST. DISCLOSURE MUST OCCUR AS SOON AS THE CONFLICT IS KNOWN OR SHOULD HAVE BEEN KNOWN. UPON DISCLOSURE, THE INDIVIDUAL MUST IMMEDIATELY CEASE DECISION-MAKING, INVESTIGATION, ENFORCEMENT, OR NEGOTIATION ACTIVITIES RELATING TO THE MATTER UNTIL THE COMPANY ISSUES WRITTEN DIRECTION. FAILURE TO DISCLOSE IS ITSELF A VIOLATION, EVEN IF NO IMPROPER OUTCOME OCCURS.

PROHIBITED CONDUCT: NO PERSON ACTING FOR HERPTIVARIUS, LLC MAY USE THEIR POSITION FOR PERSONAL GAIN, FAVOR OR DISFAVOR A CUSTOMER OR VENDOR BASED ON PERSONAL RELATIONSHIPS, DIRECT COMPANY BUSINESS TO THEMSELVES OR AN AFFILIATE WITHOUT DISCLOSURE AND APPROVAL, ACCEPT IMPROPER GIFTS OR BENEFITS, OR ALLOW PERSONAL DISPUTES, GRUDGES, ALLIANCES, OR OUTSIDE ADVOCACY TO DRIVE COMPANY ACTIONS. NO PERSON MAY PARTICIPATE IN ANY DECISION IN WHICH THEY HAVE A FINANCIAL INTEREST OR A CLOSE PERSONAL INTEREST THAT COULD REASONABLY AFFECT OBJECTIVITY.

COMMON CONFLICT EXAMPLES: CONFLICTS INCLUDE BUT ARE NOT LIMITED TO PERSONAL OR FAMILY RELATIONSHIPS WITH A CUSTOMER, COMPETITOR, OR VENDOR; ROMANTIC OR HOUSEHOLD RELATIONSHIPS; BUSINESS PARTNERSHIPS OUTSIDE THE COMPANY; DEBTS OWED OR MONEY LENT; GIFTS OR FAVORS; OUTSIDE EMPLOYMENT OR CONSULTING THAT OVERLAPS WITH COMPANY BUSINESS; OWNING OR HAVING AN INTEREST IN A SUPPLIER OR COMPETITOR; USING NON-PUBLIC COMPANY INFORMATION FOR PERSONAL BENEFIT; HANDLING A DISPUTE WHERE THE DECISION-MAKER HAS A HISTORY OF CONFLICT WITH ONE PARTY; OR ANY SITUATION WHERE THE PERSON HAS ALREADY “TAKEN SIDES” AND BECOME AN ADVOCATE AGAINST ANOTHER PARTY.

GIFTS, ENTERTAINMENT, AND FAVORS: COVERED PERSONS MUST NOT SOLICIT OR ACCEPT ANY GIFT, DISCOUNT, SERVICE, FAVOR, TRAVEL, ENTERTAINMENT, OR OTHER BENEFIT THAT COULD REASONABLY APPEAR TO INFLUENCE COMPANY DECISIONS OR CREATE OBLIGATION. NOMINAL, CUSTOMARY ITEMS OF MINIMAL VALUE MAY BE ACCEPTED ONLY WHEN THEY DO NOT CREATE A PERCEIVED CONFLICT AND ARE PERMITTED BY LAW, BUT THE COMPANY MAY REQUIRE DISCLOSURE OR REFUSAL AT ITS SOLE DISCRETION. CASH OR CASH EQUIVALENTS ARE NEVER PERMITTED.

VENDOR, PARTNER, AND PROCUREMENT INTEGRITY: SELECTION OF VENDORS, CARRIERS, SERVICE PROVIDERS, OR PARTNERS MUST BE BASED ON LEGITIMATE BUSINESS FACTORS SUCH AS COMPLIANCE, SAFETY, PERFORMANCE, RELIABILITY, COST, AND RISK MANAGEMENT. ANY PERSONAL RELATIONSHIP OR FINANCIAL INTEREST CONNECTED TO A VENDOR OR POTENTIAL VENDOR MUST BE DISCLOSED. SELF-DEALING, KICKBACKS, SIDE DEALS, OR UNDISCLOSED REFERRAL BENEFITS ARE STRICTLY PROHIBITED.

EMPLOYMENT AND SUPERVISION CONFLICTS: NO PERSON MAY PARTICIPATE IN HIRING, FIRING, PROMOTION, COMPENSATION, SCHEDULING, DISCIPLINE, OR PERFORMANCE EVALUATIONS FOR A RELATIVE, ROMANTIC PARTNER, HOUSEHOLD MEMBER, OR ANY PERSON WITH WHOM THEY HAVE A RELATIONSHIP THAT COULD REASONABLY IMPAIR OBJECTIVITY, WITHOUT DISCLOSURE AND WRITTEN MANAGEMENT DIRECTION. WHERE SUCH A RELATIONSHIP EXISTS, THE COMPANY MAY REQUIRE REASSIGNMENT OF DUTIES OR CHANGES IN REPORTING STRUCTURE.

OUTSIDE ACTIVITIES AND COMPETING INTERESTS: COVERED PERSONS MUST DISCLOSE OUTSIDE EMPLOYMENT, CONSULTING, OR BUSINESS ACTIVITIES THAT COULD CONFLICT WITH COMPANY INTERESTS, COMPROMISE CONFIDENTIALITY, CREATE TIME OR PERFORMANCE IMPAIRMENT, OR CREATE A PERCEIVED COMPETITIVE RELATIONSHIP. THE COMPANY MAY RESTRICT OR PROHIBIT OUTSIDE ACTIVITIES THAT PRESENT MATERIAL RISK OR CONFLICT.

CONFIDENTIAL INFORMATION AND INSIDE ADVANTAGE: NON-PUBLIC INFORMATION OBTAINED THROUGH COMPANY ACTIVITIES MUST NOT BE USED FOR PERSONAL BENEFIT OR FOR THE BENEFIT OF ANY OUTSIDE PARTY. CONFIDENTIAL INFORMATION MUST NOT BE SHARED WITH FRIENDS, FAMILY, VENDORS, COMPETITORS, OR THE PUBLIC EXCEPT AS AUTHORIZED BY COMPANY POLICY AND LAW.

DISPUTE HANDLING AND INVESTIGATION INTEGRITY: ANY CUSTOMER COMPLAINT, INTERNAL COMPLAINT, INVESTIGATION, OR ENFORCEMENT ACTION MUST BE HANDLED BY A NEUTRAL DECISION-MAKER. IF A DECISION-MAKER IS PERSONALLY INVOLVED, HAS PRIOR DEALINGS, HAS A HISTORY WITH A PARTY, OR HAS BECOME AN ADVOCATE FOR ONE PERSON AGAINST ANOTHER, THEY MUST RECUSE THEMSELVES. WHERE SUCH CONDITIONS EXIST, THE COMPANY SHALL REASSIGN THE MATTER OR REQUIRE INDEPENDENT REVIEW. IF INTEGRITY OF THE PROCESS CANNOT BE MAINTAINED, THE COMPANY MAY PAUSE ACTION UNTIL AN UNBIASED PROCESS IS AVAILABLE.

MANAGEMENT AND MITIGATION MEASURES: AFTER DISCLOSURE, HERPTIVARIUS, LLC MAY IMPLEMENT MITIGATION MEASURES INCLUDING RECUSAL, REASSIGNMENT OF DUTIES, DUAL-APPROVAL REQUIREMENTS, INDEPENDENT REVIEW, VENDOR ROTATION, FIREWALLS AROUND INFORMATION, OR OTHER CONTROLS. THE COMPANY MAY ALSO DETERMINE THAT A CONFLICT REQUIRES TERMINATION OF A RELATIONSHIP, CANCELLATION OF A TRANSACTION, OR REMOVAL OF A PERSON FROM A ROLE IF RISK CANNOT BE ADEQUATELY CONTROLLED.

REPORTING: ALL CONFLICTS OF INTEREST, SUSPECTED CONFLICTS, OR INTEGRITY CONCERNS MUST BE REPORTED PROMPTLY. REPORTS MAY BE SUBMITTED TO LEGAL@HERPTIVARIUS.COM.

NON-RETALIATION: HERPTIVARIUS, LLC STRICTLY PROHIBITS RETALIATION AGAINST ANY PERSON WHO, IN GOOD FAITH, REPORTS A CONFLICT OF INTEREST, REQUESTS RECUSAL, RAISES AN INTEGRITY CONCERN, OR COOPERATES WITH A REVIEW OR INVESTIGATION.

ENFORCEMENT AND DISCIPLINE: VIOLATIONS OF THIS POLICY MAY RESULT IN DISCIPLINARY ACTION UP TO AND INCLUDING TERMINATION OF EMPLOYMENT OR CONTRACTS, REVOCATION OF AUTHORITY, CANCELLATION OF TRANSACTIONS, DEMANDS FOR RESTITUTION, CIVIL REMEDIES, AND REFERRAL TO LAW ENFORCEMENT OR REGULATORS WHEN APPROPRIATE.

NO CONTRACTUAL RIGHTS CREATED: NOTHING IN THIS POLICY CREATES A CONTRACT OF EMPLOYMENT OR MODIFIES ANY AT-WILL EMPLOYMENT RELATIONSHIP.

MODIFICATION AUTHORITY: HERPTIVARIUS, LLC RESERVES THE UNRESTRICTED RIGHT TO MODIFY THIS POLICY AT ANY TIME. CONTINUED ASSOCIATION WITH OR ENGAGEMENT BY HERPTIVARIUS, LLC CONSTITUTES ACCEPTANCE OF ANY REVISIONS TO THE MAXIMUM EXTENT PERMITTED BY LAW.