Governance and Ethics

We embed trust and integrity into our culture by building and evolving strong corporate governance and compliance frameworks that support transparency, risk management, ethical conduct, and accountability.

Ethics and Compliance

We operate under a number of governance policies, including our Code of Business Conduct and Ethics (the “Code”). The Code applies to all of our directors, officers, and employees, including our CEO, principal financial officer, principal accounting officer, and all other executive officers. We require all full-time employees, including our officers, to sign the Code upon hire. In fiscal year 2022, we adopted a Supplier Code of Conduct, which extends our standards to our value chain. Further, the Board periodically reviews our Corporate Governance Guidelines, which were most recently revised in December 2023, in relation to the oversight of our business in accordance with its fiduciary responsibilities. In March 2023, we amended our Insider Trading Policy in keeping with best practices and in a manner consistent with recent amendments to applicable federal securities regulations. In fiscal year 2024, we developed ethics and regulatory guidance on AI. More recently in March 2025, we amended our Supplier Code of Conduct to align with evolving expectations.

So that the expectations in our governance policies are understood, we require all of our employees, including our officers, to complete mandatory ethics, security, and compliance training. We also reinforce accountability by, for example, continuing to require all field-facing personnel to complete anti-bribery and anti-corruption training every two years. Furthermore, we have a Disclosure Committee review process that queries certain employees quarterly on ethical matters of concern, among other things. In order to build on our existing training and disclosure initiatives and further strengthen our risk-management culture, we periodically remind our employees of the various ethics programs available to them. Additionally, we regularly provide our Board with information on director education programs, covering topics including, but not limited to, ethics and privacy. We encourage attendance and cover the costs for directors to attend these external programs.

Facilitating Whistleblower Reports

We consider communication and remediation to be critical elements of our compliance framework. To support these efforts, we maintain, through an independent third-party vendor, an online submission form for employees and non-employees to submit complaints regarding accounting, internal accounting controls, or auditing matters they believe to be questionable. Employees and non-employees may also submit any such complaints via U.S. mail directly to the Chair of the Audit Committee or through a 24/7 telephone hotline. We have established an additional ethics reporting system consisting of a monitored email address for employees and suppliers to report suspected illegal or unethical non-financial concerns confidentially. Our Audit Committee has oversight over both the whistleblower hotline and the ethics reporting system.

Respecting Human Rights and the Environment

In fiscal year 2023, we aligned the inclusion commitment in our Human Rights Statement with the Code of Business Conduct and Ethics. The Sustainability team and the NCG Committee review our Human Rights Statement and Environmental Policy Statement on an annual basis. We have also taken steps since fiscal year 2020 to align with the UK Modern Slavery Act 2015.

Looking Forward

We intend to continue monitoring our identified key performance indicators and goals to track impact and make any necessary improvements within our specific governance, ethics, and compliance programs.