Code of Conduct
The Salesagent Code of Conduct describes how we put our values into practice
while respecting the law and doing business in an ethical and transparent way.
We each have a personal responsibility to embody the principles of this Code and to encourage our colleagues to do the same in their work.
Our Ethics and Compliance Team consists of two independent attorneys retained by Salesagent to serve as our independent advisors. You can reach them at any time at legal@salesagent.com. They are bound by the principles of professional secrecy and the duty to report criminal conduct.
Although the Code is written primarily for Salesagent employees and executives, we also expect contractors, consultants, and anyone temporarily performing work or services for Salesagent to follow it in connection with that work.
If you believe a violation of law has occurred, you should always report it — either through Ethics & Compliance or to a government agency such as the police.
Contact Ethics & Compliance with any questions about implementing these measures in your work at Salesagent.
Supervisors and managers who learn of such an incident should likewise report it to Human Resources immediately. HR will investigate all complaints promptly and thoroughly and take appropriate action.
Illegal drugs are strictly prohibited in our offices or at company-sponsored events. If a manager has reasonable suspicion that an employee's use of drugs or alcohol may adversely affect that employee's job performance, or the safety of the employee or others in the workplace, the manager may request an alcohol or drug screening. Reasonable suspicion may be based on objective indicators such as the employee's appearance, behavior, or speech.
We should all avoid conflicts of interest, as well as circumstances that could reasonably create the appearance of one. Before taking an action, ask yourself whether it could create an incentive — or appear to create one — for you to benefit yourself, your friends or family, or an associated business at Salesagent's expense. If the answer is yes, you should avoid that course of action.
When determining whether a personal investment creates a conflict of interest, consider the relationship between the outside company's business and Salesagent's business, as well as your own role at Salesagent — including whether you can influence the company's business relationship with Salesagent, and how directly the company competes with us.
Investments in venture capital or similar funds that invest broadly across many companies — some of which may include Salesagent competitors or partners — generally do not create a conflict of interest. However, a conflict may exist if you control the fund's investment decisions.
Accepting inexpensive, token, non-cash gifts is generally permissible. Infrequent, moderate business meals and entertainment with clients, and occasional invitations to local sporting events or celebratory meals with clients, can also be an appropriate part of many Salesagent business relationships — provided they are not excessive and do not create the appearance of impropriety.
If you find yourself facing a conflict of interest involving Salesagent's products, services, tools, or information, discuss the situation with your manager, Legal, or Ethics & Compliance.
Salesagent policy may also require a prior security assessment of any outside party receiving confidential information. Be sure to complete the appropriate due diligence and have the proper agreement in place before disclosing any information.
Some of us may also have family members or other personal relationships with people employed by our competitors or business partners. As in most situations, common sense applies: don't share confidential information with your significant other or family members, and don't ask them for confidential information about their employer.
Likewise, respect the intellectual property rights of others. Improper use of others' intellectual property can expose both Salesagent and you personally to criminal and civil penalties.
If you suspect or observe any of the conduct described above, or any irregularity relating to financial integrity or fiscal responsibility — no matter how small — report it to Ethics & Compliance immediately.
If Legal asks you to retain records relevant to litigation, an audit, or an investigation, do so until Legal advises that retention is no longer necessary. If you have questions about how long to retain a record, contact your manager.
US, EU, and international trade laws govern where Salesagent can send or receive its products and services. These laws are complex and apply to:
a) imports and exports to or from the US and the EU;
b) imports and exports of products to or from other countries;
c) exports of services, or the provision of services, to non-US or non-EU persons; and
d) exports of technical data, particularly data of US or EU origin.
What counts as an "import" or "export" under these laws is defined quite broadly.
The bottom line: if you're involved in any way in sending or making available Salesagent products, services, software, equipment, or technical data from one country to another, work with your manager to ensure the transaction stays well within the bounds of applicable law. If you or your manager are unsure, contact Ethics & Compliance.
a) arrangements with competitors that restrain trade in some way;
b) abuse of intellectual property rights; and
c) use of market power to unfairly disadvantage competitors.
Certain conduct is absolutely prohibited under these laws and can result in imprisonment, as well as severe penalties for Salesagent. Examples include:
a) agreeing with competitors on prices;
b) agreeing with competitors to rig bids or allocate customers or markets; and
c) agreeing with competitors to boycott a supplier or customer.
Other activities may also be illegal, unfair, or create the appearance of impropriety, including:
a) sharing competitively sensitive information (such as prices, costs, or market distribution) with competitors;
b) entering into a business arrangement or pursuing a strategy solely to harm a competitor; and
c) using Salesagent's size or strength to gain an unfair competitive advantage.
While the spirit of these laws is straightforward, applying them to particular situations can be complex.
Salesagent is committed to competing fairly. Contact Ethics & Compliance with any questions about antitrust law and how it applies to you. Anyone found to have violated Salesagent's antitrust policies will, subject to local law, face discipline up to and including termination of employment. If you suspect anyone at the company is violating competition laws, notify Ethics & Compliance immediately.
Several laws worldwide — including the US Foreign Corrupt Practices Act and the UK Bribery Act — specifically prohibit offering or giving anything of value to a government official to influence an official action or secure an improper advantage. This includes not only traditional gifts but also meals, travel, political or charitable contributions, and job offers for a government official's relatives. Never give a gift to thank a government official for doing their job.
Effective date: September 15th 2026.
We each have a personal responsibility to embody the principles of this Code and to encourage our colleagues to do the same in their work.
Our Ethics and Compliance Team consists of two independent attorneys retained by Salesagent to serve as our independent advisors. You can reach them at any time at legal@salesagent.com. They are bound by the principles of professional secrecy and the duty to report criminal conduct.
Who Must Follow Our Code?
We expect all employees and executives to know and follow this Code. Failure to do so may result in disciplinary action, up to and including termination of employment.Although the Code is written primarily for Salesagent employees and executives, we also expect contractors, consultants, and anyone temporarily performing work or services for Salesagent to follow it in connection with that work.
What If I Have a Code-Related Question or Concern?
If you have a question or concern, contact your manager, your Human Resources representative, or Ethics & Compliance. You may also submit a question or report a suspected violation of this Code, or of any other Salesagent policy, through Ethics & Compliance.If you believe a violation of law has occurred, you should always report it — either through Ethics & Compliance or to a government agency such as the police.
Am I Safe to Report Violations?
Salesagent prohibits retaliation against anyone who reports or participates in an investigation of a possible violation of our Code, our policies, or the law. If you believe you are being retaliated against, please contact Ethics & Compliance.1. Privacy, Security, and Freedom of Expression
Clients and partners trust us with their personal information, and preserving that trust requires each of us to respect and protect its privacy and security. Our security procedures strictly limit access to and use of users' personal information and require each of us to take measures to protect user data from unauthorized access.Contact Ethics & Compliance with any questions about implementing these measures in your work at Salesagent.
2. Responsiveness
Being useful and honest means being responsive. We recognize relevant user feedback when we see it, and we act on it. We take pride in responding to communications from our users — whether questions, problems, or compliments. If something is broken, fix it.3. Taking Action
If you ever feel that our clients or partners aren't being well served, let someone at the company know.4. Equal Opportunity Employment
Employment here is based solely on individual merit and qualifications directly related to professional competence. We strictly prohibit unlawful discrimination or harassment on the basis of race, color, religion, veteran status, national origin, ancestry, pregnancy status, sex, gender identity or expression, age, marital status, mental or physical disability, medical condition, sexual orientation, or any other characteristic protected by law. We also make all reasonable accommodations required under laws protecting the rights of people with disabilities.5. Harassment, Discrimination, and Bullying
Salesagent prohibits discrimination, harassment, and bullying in any form — verbal, physical, or visual. If you believe you've been bullied or harassed by anyone at Salesagent, or by a Salesagent partner or vendor, we strongly encourage you to report the incident immediately to your supervisor, Human Resources, or both.Supervisors and managers who learn of such an incident should likewise report it to Human Resources immediately. HR will investigate all complaints promptly and thoroughly and take appropriate action.
6. 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. Alcohol consumption is not banned at our offices, but use good judgment, and never drink in a way that impairs your performance, leads to inappropriate behavior, endangers others' safety, or violates the law.Illegal drugs are strictly prohibited in our offices or at company-sponsored events. If a manager has reasonable suspicion that an employee's use of drugs or alcohol may adversely affect that employee's job performance, or the safety of the employee or others in the workplace, the manager may request an alcohol or drug screening. Reasonable suspicion may be based on objective indicators such as the employee's appearance, behavior, or speech.
7. Safe Workplace
We are committed to a violence-free work environment and will not tolerate any level of violence or the threat of violence in the workplace. No one may bring a weapon to work under any circumstances. If you become aware of a violation of this policy, report it to Human Resources immediately. In the event of potential immediate violence, contact the police immediately.8. Avoiding Conflicts of Interest
A conflict of interest can arise when competing loyalties might lead you to pursue a personal benefit for yourself, your friends, or your family at the expense of Salesagent or our users.We should all avoid conflicts of interest, as well as circumstances that could reasonably create the appearance of one. Before taking an action, ask yourself whether it could create an incentive — or appear to create one — for you to benefit yourself, your friends or family, or an associated business at Salesagent's expense. If the answer is yes, you should avoid that course of action.
9. Personal Investments
Avoid making personal investments in companies that are Salesagent competitors or business partners when the investment might cause, or appear to cause, you to act in a way that could harm Salesagent.When determining whether a personal investment creates a conflict of interest, consider the relationship between the outside company's business and Salesagent's business, as well as your own role at Salesagent — including whether you can influence the company's business relationship with Salesagent, and how directly the company competes with us.
Investments in venture capital or similar funds that invest broadly across many companies — some of which may include Salesagent competitors or partners — generally do not create a conflict of interest. However, a conflict may exist if you control the fund's investment decisions.
10. Outside Employment, Advisory Roles, Board Seats, and Starting Your Own Business
Avoid accepting employment, advisory positions, or board seats with Salesagent competitors or business partners if doing so could influence, or appear to influence, your judgment in a way that could harm Salesagent. Because board seats carry fiduciary obligations that raise particular conflict-of-interest concerns, notify your manager before accepting any outside board seat. Do not start a business that would compete with Salesagent.11. Business Opportunities Found Through Work
Business opportunities you discover through your work at Salesagent belong first to Salesagent, unless Salesagent agrees otherwise.12. Accepting Gifts, Entertainment, and Other Courtesies
Accepting gifts, entertainment, or other business courtesies from a Salesagent competitor or business partner can easily create the appearance of a conflict of interest, particularly if the item is of significant value.Accepting inexpensive, token, non-cash gifts is generally permissible. Infrequent, moderate business meals and entertainment with clients, and occasional invitations to local sporting events or celebratory meals with clients, can also be an appropriate part of many Salesagent business relationships — provided they are not excessive and do not create the appearance of impropriety.
13. Use of Salesagent Products and Services
Avoiding conflicts of interest also means not using Salesagent's products, services, internal tools, or information in a way that improperly benefits you or someone you know, or that creates the appearance that you have an unfair advantage over users outside Salesagent.If you find yourself facing a conflict of interest involving Salesagent's products, services, tools, or information, discuss the situation with your manager, Legal, or Ethics & Compliance.
14. Confidential Information
Information classified as "Need to Know" or "Confidential" must be handled according to those classifications. At times, a project or negotiation may require disclosing Need to Know or Confidential information to an outside party. Any such disclosure should be made only as needed and only under a non-disclosure agreement.Salesagent policy may also require a prior security assessment of any outside party receiving confidential information. Be sure to complete the appropriate due diligence and have the proper agreement in place before disclosing any information.
Some of us may also have family members or other personal relationships with people employed by our competitors or business partners. As in most situations, common sense applies: don't share confidential information with your significant other or family members, and don't ask them for confidential information about their employer.
15. Salesagent Partners
Just as we're careful not to disclose Salesagent's confidential information, it's equally important not to disclose confidential information belonging to our partners. Don't accept confidential information from another company until all parties have signed an appropriate non-disclosure agreement approved by Legal. Even after the agreement is signed, accept only as much information as you need to accomplish your business objectives.16. Competitors and Former Employers
We respect our competitors and want to compete with them fairly — but we don't want their confidential information, and the same goes for confidential information belonging to a former employer. If an opportunity arises to make use of a competitor's or former employer's confidential information, don't take it. If you come into possession of a competitor's confidential information, contact Legal immediately.17. Salesagent's Intellectual Property
Salesagent's intellectual property rights — our trademarks, logos, copyrights, trade secrets, and know-how — are among our most valuable assets. Unauthorized use can seriously diminish or destroy their value. You must respect all copyright and other intellectual property laws, including those governing fair use of copyrights, trademarks, and brands. Never use Salesagent's (or its affiliates') logos, marks, or other protected information or property for any business or commercial purpose without pre-clearance from your manager.Likewise, respect the intellectual property rights of others. Improper use of others' intellectual property can expose both Salesagent and you personally to criminal and civil penalties.
18. Company Equipment
Salesagent provides the tools and equipment we need to do our jobs effectively and expects us to use them responsibly. Company funds, equipment, and other physical assets should not be used for purely personal purposes. If you're unsure whether a particular use of company assets is appropriate, ask your manager or Human Resources.19. The Network
If you have reason to believe our network security has been compromised — for example, if you lose your laptop or phone, or suspect your network password has been exposed — report the incident to your manager promptly.20. Physical Security
Always secure your laptop, equipment, and personal belongings, even while on Salesagent's premises. Don't tamper with or disable security or safety devices, and watch for anyone "tailgating" behind you through secured doors.21. Use of Salesagent's Equipment and Facilities
Anything you do using Salesagent's corporate electronic facilities (such as computers, mobile devices, or the network) or store on our premises (such as letters, memos, or other documents) may be disclosed to people inside or outside the company. For example, Salesagent may be legally required — such as in response to a subpoena or warrant — to monitor, access, and disclose the contents of corporate email, voicemail, computer files, or other materials on our electronic facilities or premises.22. Employee Data
We collect and store personal information about our employees. Access this data only in accordance with local law and Salesagent's internal policies, and handle employee data in a manner that respects the law. Contact Ethics & Compliance with any questions.23. Spending Salesagent's Money
If you submit an expense for reimbursement or spend money on Salesagent's behalf, ensure the cost is reasonable, directly related to company business, and supported by appropriate documentation. Always record the business purpose — for example, if you take someone to dinner on Salesagent's behalf, record the full names and titles of everyone who attended, along with the reason for the dinner — and comply with all other submission requirements. If you're unsure whether to spend money or submit an expense, check with your manager. Managers are responsible for all spending and expenses incurred by their direct reports and should review them carefully before approving.24. Signing a Contract
Every business transaction entered into on Salesagent's behalf must be documented and approved by the Legal Department. Signing a contract on Salesagent's behalf is a significant responsibility — always check with your manager first.25. Recording Transactions
If your role involves the financial recording of our transactions, report any transaction you believe is recorded incorrectly to Finance immediately.26. Reporting Financial or Accounting Irregularities
Never interfere in any way with the auditing of Salesagent's financial records. Similarly, never falsify any record or account, including time reports, expense accounts, or any other Salesagent records.If you suspect or observe any of the conduct described above, or any irregularity relating to financial integrity or fiscal responsibility — no matter how small — report it to Ethics & Compliance immediately.
27. Hiring Suppliers
As Salesagent grows, we enter into more agreements with suppliers of equipment and services. We should always strive to get the best possible deal for Salesagent, which almost always means soliciting competing bids to ensure we're getting a fair offer. Price is important, but it isn't the only factor to weigh — quality, service, reliability, and the terms of the proposed deal should also inform the final decision.28. Retaining Records
It's important that we retain records for an appropriate length of time. Our Retention Policy sets minimum retention periods for certain types of records, generally five years or longer where required by law.If Legal asks you to retain records relevant to litigation, an audit, or an investigation, do so until Legal advises that retention is no longer necessary. If you have questions about how long to retain a record, contact your manager.
29. Trade Controls
Salesagent is based in the United States, where we comply with local law, and our clients and partners are based mainly in the United States and the European Union.US, EU, and international trade laws govern where Salesagent can send or receive its products and services. These laws are complex and apply to:
a) imports and exports to or from the US and the EU;
b) imports and exports of products to or from other countries;
c) exports of services, or the provision of services, to non-US or non-EU persons; and
d) exports of technical data, particularly data of US or EU origin.
What counts as an "import" or "export" under these laws is defined quite broadly.
The bottom line: if you're involved in any way in sending or making available Salesagent products, services, software, equipment, or technical data from one country to another, work with your manager to ensure the transaction stays well within the bounds of applicable law. If you or your manager are unsure, contact Ethics & Compliance.
30. Competition Laws
Most countries have antitrust, competition, or unfair-competition laws designed to promote free and fair competition. Generally speaking, these laws prohibit:a) arrangements with competitors that restrain trade in some way;
b) abuse of intellectual property rights; and
c) use of market power to unfairly disadvantage competitors.
Certain conduct is absolutely prohibited under these laws and can result in imprisonment, as well as severe penalties for Salesagent. Examples include:
a) agreeing with competitors on prices;
b) agreeing with competitors to rig bids or allocate customers or markets; and
c) agreeing with competitors to boycott a supplier or customer.
Other activities may also be illegal, unfair, or create the appearance of impropriety, including:
a) sharing competitively sensitive information (such as prices, costs, or market distribution) with competitors;
b) entering into a business arrangement or pursuing a strategy solely to harm a competitor; and
c) using Salesagent's size or strength to gain an unfair competitive advantage.
While the spirit of these laws is straightforward, applying them to particular situations can be complex.
Salesagent is committed to competing fairly. Contact Ethics & Compliance with any questions about antitrust law and how it applies to you. Anyone found to have violated Salesagent's antitrust policies will, subject to local law, face discipline up to and including termination of employment. If you suspect anyone at the company is violating competition laws, notify Ethics & Compliance immediately.
31. Insider Trading Laws
Internally, we share information — including non-public information — about Salesagent's business fairly freely. You may also overhear a hallway conversation or come across a memo at the copier that involves confidential information. Using non-public information to buy or sell stock, or passing it to others so they can do so, may constitute insider trading. Insider trading violates both this Code and the law. Don't do it.32. Anti-Bribery Laws
Like all businesses, Salesagent is subject to numerous laws — in the US, the EU, and elsewhere — that prohibit bribery in virtually every commercial context. Our rule is simple: don't bribe anyone, anytime, for any reason.33. Non-Government Relationships
Exercise care when giving gifts or paying for meals, entertainment, or other business courtesies on Salesagent's behalf. To avoid any perception that such a gesture could be seen as a bribe, offer these courtesies infrequently and keep their value moderate. Contact Ethics & Compliance with any questions.34. Dealing with Government Officials
Gifts, entertainment, or other business courtesies that could be perceived as bribes are especially problematic when dealing with government officials. "Government officials" include any government employee; candidate for public office; or employee of a government-owned or -controlled company, a public international organization, or a political party.Several laws worldwide — including the US Foreign Corrupt Practices Act and the UK Bribery Act — specifically prohibit offering or giving anything of value to a government official to influence an official action or secure an improper advantage. This includes not only traditional gifts but also meals, travel, political or charitable contributions, and job offers for a government official's relatives. Never give a gift to thank a government official for doing their job.
Conclusion
We rely on one another's good judgment to uphold a high standard of integrity for ourselves and our company. We expect all colleagues to be guided by both the letter and the spirit of this Code. If you're ever unsure, don't hesitate to ask your manager, Legal, or Ethics & Compliance.Effective date: September 15th 2026.