Topia Code of Conduct

The use of recreational, illegal drugs, and/or alcohol misuse by employees is inconsistent with Topia's commitment to maintain a safe, healthy, and productive work environment and a drug-free workplace. Illegal drugs include controlled substances that are not being used or possessed under the supervision of a doctor or other licensed health care professional.

Topia respects the protection of internationally proclaimed human rights. Topia is committed to upholding the fundamental human rights of our fellow employees, and we expect our vendors, partners, and others who provide services on Topia's behalf to adhere to the same high standards. This means that Topia does not condone child or forced labor and prohibits unlawful discrimination.

You have an obligation to always do what's best for Topia. If your private interest interferes, or appears to interfere, in any way with the interests of Topia, that is a conflict of interest. You should avoid even the appearance of conflicts of interest.

Below is guidance in a few areas where conflicts of interest can arise. For any situation that may be a potential conflict of interest, seek guidance from your manager and/or People & Culture.

Avoid making personal investments in outside companies that are Topia competitors, customers, vendors, or business partners, which can easily create, or appear to create, a conflict of interest with Topia. A less than 1% interest in a public company is generally not an issue.

Accepting employment, advisory positions, or board seats with Topia competitors, customers, vendors, or business partners could, or could appear to, influence our judgment in a way that could harm Topia. Notify your manager and seek approval from People & Culture before accepting or engaging in any of these opportunities.

You should not start a business that competes with Topia's current or foreseeable future business, affects your ability to do your job at Topia, or uses Topia confidential or proprietary information or resources without appropriate written approval.

Business opportunities discovered through your work with Topia belong to Topia. Additionally, you may not compete with Topia directly or indirectly. We're all expected to lawfully advance Topia's interests.

Developing or helping to develop inventions outside of Topia that (i) relate to Topia's existing or reasonably anticipated products or services; (ii) relate to your position at Topia; or (iii) are developed using Topia confidential or proprietary information or resources likely create conflicts of interest. Refer to your invention assignment or employment agreements you may have with Topia for additional obligations.

Avoid participating in a Topia business situation in which you are hiring, managing, supervising, or conducting business with a relative, spouse, or significant other, or any other individual who could impair your objectivity. Romantic relationships between coworkers can, depending on the work roles and respective positions of the coworkers involved, create an appearance of a conflict of interest.

You should not use Topia products, services or information in a way that improperly benefits you or your friends and relatives.

Associating Topia with, or indicating Topia endorsement for, any civic, non-governmental, religious, political, or professional association without approval from Topia is strictly prohibited. Additionally, speaking on public issues or making a political campaign contribution as a representative of Topia without its consent is not permitted.

You are free to contribute to and endorse political campaigns or activities in your personal capacity. You are required to obtain approval from People & Culture for any Topia business activity that involves lobbying, or communication with, any member or employee of a legislative body.

Accepting gifts, entertainment and other business courtesies from a competitor, customer, vendor or business partner often creates the appearance of a conflict of interest, especially if the item is lavish. Generally, acceptance of inexpensive "token" non-cash gifts is permissible.

Infrequent and moderate business meals and entertainment with outside companies can be appropriate aspects of many Topia business relationships, provided they aren't excessive and don't create the appearance of impropriety.

We are passionate about our customers and products. To establish and maintain strong long lasting relationships, we must act with integrity and be honest and trustworthy in all of our dealings with customers, partners, vendors, and other third parties.

We should never take advantage of others through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair dealing practice.

You must fully understand and comply with all applicable antitrust and competition laws. Certain conduct is absolutely prohibited under these laws and could result in severe penalties for Topia, not to mention your possible imprisonment.

Examples of prohibited conduct:

• 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
• Sharing competitively sensitive information with competitors
• Entering into a business arrangement with the sole purpose of harming a competitor

Topia competes vigorously, but fairly, and respects its competitors. We don't want, nor will we use, confidential information from our competitors or our employees' former employers. We may use any publicly available information about competitors, but we may not unlawfully acquire or misuse their trade secrets or other confidential information.

U.S. and international trade laws control where Topia can send or receive its products and/or services. The U.S. and other countries restrict the export (and in some cases, import) of goods, software, and technology that could have military or other applications.

Examples of unlawful exports under U.S. laws include:

• Exposing or allowing access by a non-U.S. national on a "Denied Persons" list to U.S. technical data
• Permitting the download of software from the U.S. into an embargoed country
• Transporting technical data or software on your laptop to an embargoed country

As of 1 May 2019, U.S. law prohibits exports to: Crimea Region of Ukraine, Cuba, Iran, North Korea, Syria. Targeted sanctions lists can be found at trade.gov/consolidated-screening-list.

We have a legal and ethical responsibility to ensure that all of our advertising is truthful and not deceptive. We must market Topia's products and services based on their merits and have substantiation for any public statements we make.

Like all global businesses, Topia is subject to domestic and international laws that prohibit bribery. The rule is simple: don't bribe anybody, anytime, for any reason. Be careful when giving gifts or paying for meals, entertainment or other business courtesies on behalf of Topia. Never give cash or cash equivalent gifts, or lavish gifts or courtesies.

Offering gifts, entertainment, or other business courtesies that could be perceived as bribes becomes especially problematic when interacting with a government official. The definition of "government official" is broad and includes any government employee, candidate for public office, or employee of government-owned or controlled companies.

Topia's consultants, partners, and other third parties may at times represent Topia and their actions may be attributed to Topia. We must make sure their conduct properly represents Topia and our standards and values. Before engaging such third parties, conduct careful and proper due diligence.

Money laundering is an attempt by individuals or organizations to hide or disguise the proceeds of criminal activity through a series of otherwise legitimate business transactions. Topia does not tolerate the misuse of its systems as a vehicle to launder proceeds from improper activities.

Immediately consult with People & Culture if a government or law enforcement officer or regulator requests any disclosure about Topia or its business activities.

We respect all applicable laws that protect the personal information of individuals we may obtain in the course of doing business or employment. For questions or concerns about our privacy obligations, please review the Topia Atlas or contact privacy@topia.com.

Topia's intellectual property rights (e.g., patents, trademarks, logos, copyrights, trade secrets and "know-how") are among our most valuable assets and provide Topia with a competitive advantage. Unauthorized use can lead to loss of value and may be catastrophic to our business.

Topia provides the tools, equipment, and amenities to do your job effectively, and you are counted on to be responsible and not wasteful. Topia funds, equipment, and other physical assets are not to be used for purely personal use. Topia is also committed to sustainable business practices, which includes complying with all applicable environmental laws and regulations.

While Topia respects employee privacy, you should not assume that your computer, tablet, mobile device, or telephone equipment that accesses the Topia network or is used in conducting Topia business, or anything stored on other electronic facilities are private or confidential. Subject to local laws and under the guidance of People & Culture, Topia may monitor, search and review such items where there is a business need.

Topia's communication facilities (which include both our on-premise and cloud-based networks and the hardware that uses it) are a critical aspect of our company's property. Be sure to follow our IT-related policies. If you have any reason to believe that our network security has been compromised, immediately report the incident to security@topia.com.

You should take all reasonable steps to protect against loss or theft of any company assets or personal belongings.

When spending money on Topia's behalf, make sure that the cost is reasonable, directly related to company business and supported by appropriate documentation. Always record the business purpose and comply with other submission requirements.

Each time we enter into a business transaction on Topia's behalf, there should be sufficient documentation to reflect that it has been approved by Legal/Contracts and the responsible business owner supporting the arrangement. All contracts at Topia should be in writing and should contain all of the relevant terms to which the parties are agreeing.

Whenever you enter into transactions with suppliers of goods and services, you should strive for the best possible terms for Topia. This almost always requires that you solicit competing bids. While price is very important, quality, service, reliability, and the terms and conditions of the proposed transaction may also affect the final decision.

It's important that you appropriately manage your business records. Various laws require that we keep certain records for minimum periods of time. It is equally important to know when to periodically dispose of documents that are no longer useful or do not need to be retained.