Last Updated: August 28, 2023

Objectives

Trilliant’s success depends on winning and keeping the confidence of our stakeholders – customers, business partners and investors. No less important is sustaining mutual trust, respect and teamwork among all of Trilliant’s employees. As you read this policy, please consider that the conduct it promotes is how each of us would want to be treated in all facets of our lives.

Scope and Applicability

 This policy applies to all Trilliant activities globally and is required reading of all Employees. Violations of the policy can be grounds for disciplinary action, up to and including termination of employment.

Core Practices

WE VALUE OUR EMPLOYEES AND OUR WORKPLACE

Trilliant’s success depends on our acting as One Trilliant: working together to sustain an ethical, fair, congenial and productive workplace. Our conduct with one another can support or undermine that goal.

Trilliant values and supports Diversity and inclusion in everything we do. Trilliant provides employment and professional opportunities on a non-discriminatory basis. Workplace actions, decisions, evaluations and all other business conduct cannot be based, in whole or in part, on a person’s race, color, national origin, age, religion, disability status, sex, sexual orientation, gender identity or expression, genetic information or marital status. Moreover, Trilliant will take appropriate actions to protect our employees if they are subjected to discriminatory behavior by customers, vendors or others.

Sexual harassment will not be tolerated. Remember that harassment includes unwelcome sexual advances, requests for sexual favors and offensive remarks of a sexual nature. Our Anti-Harassment Policy goes into detail.

Bullying in the workplace is never acceptable. Bullying includes but isn’t limited to persistent verbal and nonverbal aggression at work, including disrespectful behaviors, personal attacks, intimidation, and humiliating, degrading and demotivating comments and actions. Bullying often involves a real or perceived power imbalance between the bully and the target. Bullying is not an isolated behavior that occurs once; it is not a flare up when under job stress; nor is it constructive criticism or even conflict, provided the conflict is handled respectfully. If you are the target of bullying or you see colleagues who appear to be subjected to bullying, please take the issue immediately to HR, or consider other reporting options (see the “Reporting” section of this Policy).

WE VALUE OUR CUSTOMERS, SUPPLIERS AND CONTRACTORS

Our work for Trilliant puts us in contact with customers, potential customers, suppliers, government officials, regulators and the public, all of whom are entitled to courtesy, respect and transparency. Each of us represents Trilliant during those contacts, and Trilliant will be judged by our individual behaviors. Behavior that wouldn’t be tolerated in the Trilliant workplace is equally out of line where third parties are involved.

One way we show respect is by honoring our partners’ internal policies, such as policies against gift giving and invitations to meals and entertainment. Many companies post these policies on their websites, but it’s also acceptable (and a positive demonstration of integrity) to simply ask whether something is permitted.

Trilliant and its many suppliers, contractors and business partners must have confidence in one another’s integrity. Trilliant publishes a Supplier Code of Conduct https://trilliant.com/code-of-conduct/. If a supplier or contractor is not behaving in accordance with the policy, it should be reported to the Global Supply Chain Vice President.

WE AVOID EVEN THE APPEARANCE OF A CONFLICT OF INTEREST

A person has a conflict of interest if her own personal (or family) interests are at odds with Trilliant’s interests. Disclosure of potential conflicts to your manager, HR or Legal is the best way to demonstrate integrity and avoid problems. Some examples of conflicts of interest:

• The spouse of a Trilliant employee is an expert in sales Encouraging Trilliant to hire the spouse without disclosing the relationship would be aconflict. Suggesting that Trilliant consider the qualifications of the spouse, with full disclosure of the relationship, is OK if the employee also does not participate in the hiring decision.
• An employee takes on a second job, working weekends (“moonlighting”). If that job is with a company that competes with Trilliant, even indirectly, it’s a conflict of interest unless it has been fully reviewed with and approved by the Chief People Officer.
• Moonlighting where the second job is unrelated to Trilliant’s business may also be a conflict if it makes it difficult for the employee to perform effectively for Taking on such a second job requires discussion with the Chief People Officer and may be permitted depending on the facts and circumstances.
• A person who formerly worked for a Trilliant competitor applies for a job at Trilliant. If hired, it would be a serious ethical breach for that person to disclose the competitor’s confidential information to Trilliant, or for Trilliant to ask that person for such information. Either situation potentially exposes Trilliant and the individual to legal action.
• If the disclosed conflict can’t be managed, the employee and Trilliant can make decisions on next An undisclosed conflict, on the other hand, can be grounds disciplinary action, up to and including termination of employment.

WE COMPLY WITH LAW

Trilliant does business globally and strives to follow the relevant laws and regulations where it does business. Managing compliance is not just for the Legal department. Each of us must take responsibility for familiarity with the rules governing how we do our Trilliant work. If you are unsure, ask. Trilliant policies and guidance documents include:

• Trilliant’s Anti-Corruption Policy and Due Diligence
• Confidential Information and Data Classification Policies
• Privacy Policy
• Anti-Harassment policy
• IT Acceptable Use
• Substance Abuse
• Information Security

WE PROTECT CONFIDENTIAL INFORMATION

Customers and others we work with expect that we will protect their communications and business information (including intellectual property) from misuse and unauthorized disclosure. We must live up to that expectation, as well as insisting that others protect Trilliant’s confidential information, through the appropriate use of nondisclosure agreements. If you are uncertain what obligations NDAs impose and how to comply, please review:

• Data Classification and Best Practices for Handling Confidential Information
• Use of Information Authored by Third Parties
• Privacy

WE COMPETE VIGOROUSLY AND FAIRLY

Fair competition, a hallmark of an ethical organization, is competition based on the value and quality of the products and services Trilliant offers its customers.

Unethical conduct can be illegal, but even if not, it will damage Trilliant’s reputation and success. For example, we might receive confidential information when we are jointly bidding with another company in response to an RFP. It would be unethical (as well as a breach of any applicable non-disclosure agreement) to use that confidential information in an RFP with a different partner to get a competitive edge. A useful way of thinking about this: if this particular conduct happened to Trilliant, we’d probably conclude the competition was both unfair and unethical.

Unethical business practices also include potentially criminal acts, such as offering bribes to persuade customers to choose Trilliant. Nearly all countries (and states, provinces, cities etc.) have enacted laws criminalizing bribery and other corrupt practices. Trilliant’s Policy Against Corrupt Business Practices is required reading for all employees and must be observed.

WE ARE GOOD CORPORATE CITIZENS IN OUR COMMUNITIES

Trilliant applies uniformly high standards of ethics and business conduct in every country in which it operates, and in every business relationship or affiliation. In some circumstances, of course, that may mean that Trilliant will do business somewhat differently from country to country. But, while laws may conflict, one thing is constant: we are committed to doing business ethically and within the law. Another constant is Trilliant’s commitment to sustainability, an activity to which each of us contributes.

REPORTING

Part of our ethical responsibility as Trilliant employees is to help Trilliant enforce its policies. One way to do this is to ask questions before we act in situations where we’re unsure of the right thing to do. Our managers, as well as the Finance, Human Resources and/or Legal Department can provide guidance.

Each of us also must be willing to speak up if we see conduct at Trilliant that we believe might be illegal, against policy or a matter of questionable ethics. Trilliant holds each of us responsible for reporting possible violations (whether past, threatened or ongoing) promptly. Failure to report is a failure to act in accordance with this Policy.

Ethical concerns or knowledge of actual or suspected violations can be reported to:

• Your direct-line manager
• Trilliant’s Ethics Helpline
• The next-level-up manager
• A Trilliant officer
• The General Counsel
• Human Resources
• In Colombia, reports can be made to the Labor Coexistence Committee as required under local Please see Bogotá HR or Legal for details.

Reporting can be hard, especially if we aren’t sure that the situation involves an actual violation, or that we know all the facts, or we are concerned about breaking trust with our colleagues. Trilliant offers employees an Ethics Hotline, independently operated by Navex, which enables anonymous reporting. The Ethics Hotline portal can be accessed from the landing page of Trilliant’s Sharepoint intranet, https://trilliant.sharepoint.com/SitePages/Home.aspx and includes details on how the Hotline operates.

• You will be asked a series of questions aimed at gathering enough information to enable a meaningful inquiry into your
• The report is encrypted and delivered to the General Counsel and Chief People (If the report is about something that happened in the Legal department, only the CPO gets the report; if it happened in HR, only the GC would receive the report.) A prompt investigation will follow, which might include outside specialists.
• We will not attempt to discover your It is possible, however, that the investigator – without knowing that you were the reporter – might ask you questions because the facts and circumstances make you a logical source of information. If you are comfortable identifying yourself, the investigation becomes easier as we can come to you with follow up questions. But this is your choice.
• The Hotline will give you a means to check on the status of the
• At the end of the investigation, appropriate corrective and/or disciplinary actions may Violations of the law or Trilliant Policies can lead to disciplinary action up to and including termination of employment. Because of confidentiality requirements, however, you may not be informed of the outcome.

Whichever means of reporting you use, please remember that keeping quiet about a possible problem does not help anyone.

RETALIATION AGAINST EMPLOYEES WHO HAVE REPORTED IN GOOD FAITH WILL NOT BE TOLERATED

No matter what the outcome of an investigation may be, Trilliant will not tolerate any form of retaliation against individuals who make a good faith report of suspected policy, legal or ethical violations. Any employee who believes that s/he is being subjected to retaliation should report it immediately to the General Counsel or Chief People Officer. Such reports will be thoroughly investigated and disciplinary action, up to and including termination of employment, may be taken against any individual found to have engaged in retaliatory actions.

Training

 Recorded training will be available in LMS from October 2, 2023.

Additional Reference

 None