CODE OF ETHICS

Last updated: October, 2024

Ethical Principles

Our ethical principles are the values that set the ground rules for all that we do as HighRadius employees. In order to be a dotONE company, we expect high ethical standards. If we find that these principles are compromised because of your actions, you may be faced with a verbal/written warning or if egregious enough, termination of your employment:

HONESTY: We will not say things that are false. We will never deliberately mislead. We will be as candid as possible, openly and freely sharing information, as appropriate to the relationship.

PROMISE-KEEPING: We will go to great lengths to keep our commitments. We will not make promises that can’t be kept and we will not make promises on behalf of HighRadius unless we have the authority to do so.

FAIRNESS: We will create and follow a process and achieve outcomes that a reasonable person would call just, even-handed and non arbitrary.

RESPECT FOR OTHERS: We will be open and direct in our communication, and receptive to influence. We will honor and value the abilities and contributions of others, embracing the responsibility and accountability for our actions in this regard.

COMPASSION: We will maintain an awareness of the needs of others and act to meet those needs whenever possible. We will also minimize harm whenever possible. We will act in ways that are consistent with our commitment to social responsibility.

INTEGRITY: We will live up to HighRadius’ ethical principles, even when confronted by personal, professional and social risks, as well as economic pressures.

Code of Conduct

As you seek to achieve responsible commercial success for HighRadius, you will be challenged to balance the Ethical Principles against each other.

Conflicts of Interest

All employees are required to:

Conduct themselves and HighRadius’ business with honesty and integrity.
Refrain from accepting or being influenced by business gifts.

Legal Compliance

All employees are required to comply with all laws, rules, and regulations of federal, state, and local governments, foreign governments, and other appropriate private and public regulatory agencies that govern our business, including:

Refraining from making or accepting any bribes or kickbacks or asking others to do so. See the Section titled “Anti-Corruption and Bribery Policy” for more information.
Complying with antitrust laws and other regulations relating to fair competition and pricing. See the Section titled “Competition and Fair Dealing” for more information.
Complying with sanctions laws and antiboycott laws. See the Section titled “Trade Compliance” for more information.

While it is difficult to completely understand the details of these laws, it is important to know enough to determine when to seek advice from work team leaders or other appropriate management personnel or HighRadius’ legal department.

Confidentiality

All employees are required to protect and maintain the confidentiality of the Company’s and third parties’ confidential information. “Confidential information” includes:

Confidential information, trade secrets or other non-public information of the Company and third parties (including our affiliates, vendors, customers, partners, and employees).
Personally identifiable or other sensitive information of business contacts, employees or other individuals.
Financial information, including performance, plans, and projections.
Internal emails.
Anything related to a legal or regulatory issue or investigation.

You should never disclose confidential information to anyone, internally or externally, who does not have a legitimate business reason to have and need to know the information. In addition, you must not disclose any confidential information outside the Company unless we have a non-disclosure agreement or other confidentiality obligation approved by the Legal Department in place with the recipient. You may only use confidential information for a legitimate business reason and not for personal gain. You are also required to take all reasonable precautions to safeguard the access, storage and transmission of confidential information, including complying with the Company’s information security policies. If you become aware of any privacy or security risks or breaches, you are required to promptly report these to the Legal Department.

Workplace Practices

All employees are expected to:

Promote ethical behavior in the work environment.
Promptly report dishonest, unethical, or illegal activities by other employees to a member of management or Human Resources.
Comply with this Code of Ethics, knowing that failure to do so may result in disciplinary action, up to and including termination of employment.
Use company property for conducting company business and not for personal use.
Maintain a safe and a workplace free from illegal drugs.
Ensure that the workplace is free from discrimination, harassment, and retaliation, and respects diversity and individual rights.
Respect Human Rights and prevent modern slavery in accordance with the HighRadius Human Rights Policy

Reporting and Enforcement

Internal theft, fraud, or other serious abuses, such as accounting and auditing irregularities, affect everyone. In the most serious cases, the negative impact on a company’s reputation and financial well being can even lead to the loss of jobs. If an employee becomes aware of theft, fraud, or other abuses in the workplace, he/she should not ignore it.

If an employee suspects possible violation of this Code of Ethics, such employee should contact the HR Department at their location immediately, without fear of any retaliation.

Regardless of how any suspected violation is reported, there will be no form of retaliation for doing so. HighRadius will investigate fully all matters related to alleged violations and take appropriate action. It is everyone’s responsibility to help create and ensure a safe and effective workplace. Employees are expected to participate fully in any investigation of alleged misconduct.