Code of Conduct

Preamble

Triops was founded on the belief that technology should serve people, protect their rights, and solve problems that matter. We help our customers turn complex data into clear, actionable insight while upholding privacy, civil liberties, and the highest ethical standards. That mission shapes everything we do: the products we build, the partnerships we form, and the way we conduct ourselves every day.

We hold ourselves to the same standard of excellence we promise our customers. Quality, integrity, and accountability are not aspirational goals; they are baseline expectations for everyone who works at Triops. This Code puts those expectations in writing so that every member of our organization understands the principles we share and the conduct we require.

Purpose of This Code

This Code articulates the core commitments that define our culture. It is not an exhaustive rulebook. Triops maintains separate, detailed policies and procedures that govern specific areas of our operations. The Code instead captures the values that underpin all of those policies and provides a framework for making sound decisions when the right course of action is not immediately obvious.

By setting out clear expectations, the Code helps us pursue our mission effectively while maintaining the safeguards needed to prevent, detect, and address unethical conduct.

Questions and Reporting

If you have questions about this Code or need guidance on how it applies to a specific situation, you may reach out to the Legal team, the Privacy and Ethics team, your manager, the People team, or any member of leadership you are comfortable contacting.

Triops strictly prohibits retaliation against anyone who, in good faith, reports a potential violation of this Code or assists in an investigation. If you believe you are experiencing retaliation, please contact the Legal team immediately.

If you prefer not to raise a concern directly with a colleague, you can use the Triops Ethics Committee: whistleblower@3ops.io.

I. Protect Privacy and Civil Liberties

Respect for privacy and civil liberties is fundamental to who we are. We design our software with data protection at its core, and we evaluate the potential impact on individual rights at every stage of development and deployment. We commit to building products that meet not only the requirements of applicable law, including the EU General Data Protection Regulation (GDPR) and the French Data Protection Act (Loi Informatique et Libertés), but also incorporate forward-looking protections that anticipate evolving societal expectations.

A. Uphold Democratic Values

We will not interfere with the ability of any people to establish, maintain, or participate in free and fair democratic processes, particularly through the expression of protected speech.

B. Protect the Vulnerable

We will not create or perpetuate the unfair treatment or stigmatization of individuals or groups, especially where such treatment is based on characteristics protected under French and EU anti-discrimination law.

C. Respect Human Dignity

We will not develop products that intentionally exploit or disenfranchise disadvantaged populations or that undermine the rights and livelihoods of workers, in keeping with the protections set out in the EU Charter of Fundamental Rights and the French Labor Code.

D. Promote Truthful Information

We will not undermine the free exchange of accurate information, whether through data sets, analytical workflows, or capabilities that create or propagate distortions, false information, or false identities.

E. Encourage Responsible Data Use

We will not enable any workflow that infringes disproportionately or unnecessarily on an individual's right to control personal information or their right to a private life, as guaranteed by the GDPR and the European Convention on Human Rights.

F. Safeguard the Integrity of Information Systems

We will not compromise the security of information infrastructure, including by facilitating unlawful cyber-attacks, unauthorized interception of communications, or other activities prohibited under the EU Directive on Attacks Against Information Systems (Directive 2013/40/EU) and French criminal law.

G. Prevent Misuse

Technology is not ethically neutral. We acknowledge a continuous responsibility to work toward ensuring our software is used for beneficial purposes. Where our tools could be misused to produce outcomes that conflict with the commitments in this Code, we are prepared to deploy every available measure to mitigate that risk, including contractual provisions, thorough customer vetting, privacy-enhancing technical features, on-site engineering support and auditing, cooperation with oversight and judicial bodies, and, if necessary, termination of customer relationships.

II. Comply with Applicable Law

Legal compliance is a minimum standard, not a ceiling. We are committed to following the laws of every jurisdiction in which we operate, with particular attention to French and EU regulatory requirements.

A. Know and Respect the Rules

Every member of our team should have a working understanding of the laws and regulations most relevant to their role and should know when to seek guidance from the Legal team. While no one is expected to be an expert in every area of law, personal accountability for compliance is non-negotiable.

B. Zero Tolerance for Corruption

Triops strictly prohibits bribery and corruption in any form, whether involving public officials or private parties. We comply with all applicable anti-corruption legislation, including the French Sapin II Law (Loi n° 2016-1691 of 9 December 2016) and the EU Anti-Corruption Directive. This prohibition extends to gifts, entertainment, and hospitality that could create even the appearance of improper influence. Third parties acting on behalf of Triops are held to the same standard, and we exercise appropriate due diligence and oversight over all such relationships. All personnel must read and follow the Triops Anti-Corruption Policy.

C. Prohibition of Insider Trading

In the course of our work, we may become aware of material non-public information about Triops or other companies. Using such information to trade securities, or sharing it to enable others to do so, constitutes insider trading and is both a violation of this Code and a criminal offense under the EU Market Abuse Regulation (Regulation (EU) No 596/2014) and French securities law. Trading in Triops securities during designated blackout periods is prohibited. All personnel must read and follow the Triops Insider Trading Policy.

D. Fair Competition

We compete on the merits of our products. Sharing commercially sensitive information (pricing, costs, customer data) with competitors or engaging in conduct designed to improperly harm competitors is prohibited, in line with EU and French competition law. Information obtained through public-sector contracts must not be used to gain an unfair advantage in future procurement.

E. Whistleblower Protection

Triops protects whistleblowers in accordance with the EU Whistleblower Protection Directive (Directive (EU) 2019/1937) and the French Sapin II Law. No adverse action may be taken against any person who reports a concern in good faith. For further details, see the Triops Whistleblower Procedure.

III. Respect Our Customers

A. Stay Focused on the Mission

Our purpose is to build software that helps customers solve their most demanding data challenges and, in doing so, improve outcomes for the people those institutions serve. While we may not always agree with every decision a customer makes, we evaluate our work in the context of the broader mission and engage where we believe our contribution creates genuine value.

B. Protect Customer Assets

Customers place their trust in us by granting access to their environments and data. We treat their physical and information assets with the highest level of care and maintain the security standards necessary to justify that trust.

C. Honor Customer Policies

We respect and follow our customers' internal rules and regulations, and we dedicate our skills and resources to supporting them in achieving their objectives.

D. Handle Disagreements Constructively

When our values appear to diverge from those of a customer, we raise the matter promptly and constructively. Where appropriate, we involve a broader group of colleagues in the discussion. If a conflict between our work and the principles in this Code cannot be resolved, we are prepared to modify, limit, or end the relationship.

IV. Maintain a Safe and Positive Workplace

A. Foster a Safe Environment

Triops is committed to a working environment free from harassment, intimidation, bias, and discrimination of any kind, in full compliance with French labor law and the EU Equal Treatment Directives. Our Policy Against Harassment requires that:

• Any person at Triops who witnesses or learns of possible discrimination or harassment must report it to their manager or the People team immediately.
• Every member of the organization is personally responsible for upholding this policy.
• Every reported incident will be thoroughly investigated and, where warranted, met with appropriate corrective action.

Violence and threats of violence, whether verbal, online, or physical, are strictly prohibited. Triops is also committed to the responsible handling of employee personal data, as described in our Employee Privacy and Security Statement and our Acceptable Use Policy.

B. Engage with Respect

We assume good intentions and treat colleagues and customers with genuine respect. We value the diverse strengths, experiences, and perspectives within our team and draw on them to advance our shared mission.

C. Equal Opportunity

Triops is an equal opportunity employer. Hiring, promotion, and all other employment decisions are based solely on individual merit and job-related qualifications. We do not discriminate on any ground protected by French law, EU directives, or any other applicable legislation. We make reasonable accommodations for employees with disabilities as required by law.

D. Responsible Communication

We welcome constructive feedback and open debate. At the same time, derogatory remarks about colleagues, partners, customers, or third parties, whether written or spoken, are not tolerated.

V. Avoid Conflicts of Interest

A conflict of interest arises when personal interests interfere, or appear to interfere, with the best interests of Triops. We are all expected to act in the company's interest and to avoid situations that could create even the perception of divided loyalty. When in doubt, discuss the matter with your manager or the Legal team before taking action.

A. Recognizing Potential Conflicts

The following questions can help determine whether a conflict may exist:

• Would this situation reflect poorly on me or Triops if it became public?
• Does this relationship or circumstance make it harder for me to be objective in my work?
• Does this situation require me to act in a way that conflicts with the values in this Code?

B. Government Contracts and Non-Public Information

We comply with all applicable public procurement rules, including those arising from French and EU procurement law. Non-public information obtained through a government contract may not be used for any purpose unrelated to the performance of that contract.

C. Personal Investments

A significant personal investment in a customer, supplier, partner, or competitor of Triops may create a conflict. Investments in competitors are prohibited. Where an investment in a customer, supplier, or partner could influence your professional judgment, consult the Legal team and, if necessary, refrain from the investment.

D. Personal Relationships

If a close relative, partner, or friend works for a customer, supplier, partner, or competitor of Triops, a conflict could arise. In such cases, speak with your manager or the People team to ensure appropriate safeguards are in place. Workplace romantic relationships that create a reporting-line conflict may require adjustments to the work relationship.

E. Outside Opportunities

Business opportunities that arise in the course of your work at Triops belong to the company. Employment or advisory roles with a customer, supplier, partner, or competitor, even in an unpaid capacity, may create a conflict. Working for or maintaining a business relationship with a direct competitor is not permitted. Developing inventions that compete with Triops may also violate the terms of your employment agreement.

F. Gifts and Hospitality

Accepting significant gifts from customers, suppliers, partners, or competitors is prohibited. Modest meals and entertainment that form a normal part of a business relationship may be acceptable, but anything beyond routine hospitality requires prior approval from your manager. Cash or cash-equivalent gifts are never permitted. All personnel must comply with both the Anti-Corruption Policy and Triops's internal guidelines on gifts and hospitality.

G. Corporate Opportunities

You may not exploit opportunities discovered through your role at Triops for personal benefit, or for the benefit of close associates such as friends or family members, unless the opportunity is disclosed to and approved in writing by the Legal team.

VI. Act with Integrity

A. Freedom and Responsibility

Triops affords its people considerable autonomy. That freedom carries a corresponding duty to exercise sound judgment in every interaction, whether internal, with customers, or with the wider world. When you are unsure about the right course of action, consult your manager, the Privacy and Ethics team, or the Legal team.

B. Financial Integrity

Accurate record-keeping and honest financial reporting are essential to the trust our stakeholders place in us.

Open and honest accounting: We adhere to all applicable accounting rules and standards. Every member of the organization shares responsibility for ensuring that funds are spent appropriately, records are complete and correct, and internal policies are followed.

Prudent spending: Requests for reimbursement or expenditure on Triops's behalf must be reasonable, mission-related, and properly documented.

Procurement processes: All vendor and supplier relationships must comply with Triops's procurement policies. Only authorized signatories may execute contracts on behalf of the company.

Accurate reporting: Falsification of financial records is strictly prohibited. Suspected irregularities must be reported immediately to the Legal team or through the Ethics Committee (whistleblower@3ops.io). Every team member is expected to exercise sound judgment regarding the company's finances and to comply with our system of internal controls, applicable laws, and applicable accounting standards.

Triops files reports and communications with regulatory authorities as required by French and EU law. Depending on your role, you may be asked to supply information that supports the accuracy and completeness of those disclosures. If you believe any public disclosure is materially misleading, or if you become aware of material information that you believe should be disclosed, bring it to the attention of the Legal team without delay.

C. Confidentiality

Protecting confidential information is critical to maintaining our competitive position and the trust of our partners and customers.

Internal information: Do not disclose Triops's confidential information to the press, competitors, or any unauthorized party. Store, protect, and dispose of confidential materials, including trade secrets and intellectual property, in accordance with internal policy.

Customer and partner information: Safeguard the confidential information entrusted to us by our customers and partners. Do not accept confidential information from another company until a valid non-disclosure agreement is in place.

Competitor information: We compete fairly. Using confidential information belonging to a competitor, or brought by a new colleague from a former employer, is prohibited. Report any inadvertent exposure to the Legal team immediately.

Public representation: Only authorized individuals may speak publicly on behalf of Triops. All external communications must comply with the Triops External Communications Policy. Even in a personal capacity, every team member should be mindful that their public statements can reflect on the company.

Nothing in this Code prevents any person from engaging in lawful protected activities, including filing reports or cooperating with competent French or EU regulatory and judicial authorities. You do not need Triops's prior authorization to communicate with such authorities. However, you must take all reasonable precautions to prevent unauthorized disclosure of Triops's confidential information to anyone other than the relevant authority. Disclosure of information protected by legal professional privilege without Triops's written consent remains a violation of this Code.

D. Protect Company Assets

Our intellectual property, including patents, copyrights, trade secrets, business strategy, and trademarks, is among Triops's most valuable assets. If you become aware of unauthorized use of our intellectual property, notify the Legal team. Equally, Triops respects the intellectual property of others and complies with all open-source license requirements. Consult the Legal team before using any third-party content in our products.

Maintain the security of Triops's network and all connected devices by following our information security policies. Report any suspected breach, including device loss or password compromise, to IT Operations immediately.

Personal data relating to employees, visitors, and contractors is handled in strict compliance with the GDPR and the French Data Protection Act. We treat this data with the same level of care we apply to customer data.

E. Waivers and Amendments

Any waiver or amendment of this Code requires written approval from the Board of Directors or its authorized delegates and will be disclosed promptly in accordance with applicable law.

F. Investigating and Reporting Potential Violations

Triops is committed to an environment in which every person feels free to raise concerns in good faith, without fear of retaliation, discrimination, or harassment. Potential violations of this Code, other Triops policies, or applicable law should be reported through one of the following channels:

• Direct discussion with your manager;
• Contact with the People team, the Legal team, or senior leadership;
• The Triops Ethics Committee (whistleblower@3ops.io).

Every report will be taken seriously and investigated. Accounting and auditing complaints will be reviewed by the appropriate officers and, where applicable, by the Audit Committee of the Board. Other complaints will be handled by the relevant department. Information disclosed during an investigation will be kept confidential to the greatest extent practicable.

Review

This Code is reviewed periodically and updated to reflect changes in applicable legislation and our operational practices. Questions should be directed to the Triops Technologies Legal team (legal@3ops.io).