Intercom strives to be a company that pursues its mission in an ethical and honest manner.

Because we are committed to operating with greatest integrity and in compliance with all applicable laws, we also expect and require our merchants, vendors, suppliers, distributors, agents, representatives, and other business partners, as well as their employees, agents, representatives, and subcontractors (collectively, "Partners"), to share in this commitment.

As such, Intercom will require Partners to agree to abide by all applicable laws, including anti-bribery, anti-harassment, anti-modern slavery, competition, data privacy and security, environmental, labor and employment and trade compliance laws, as well as this Partner Code of Conduct (the "Code"). We expect Partners to ensure that these requirements are communicated, understood, and abided by all people working for them, including, but not limited to, direct employees, contract workers, temporary workers, and subcontractors when doing business with or for Intercom. This Code is in addition to and does not reduce, replace, or limit any obligations that Partners have under applicable laws and regulations, or other legal and contractual obligations that Partners have to Intercom. Failure to comply with the Code or applicable laws will be considered a breach of the Partner's contract with Intercom and may result in immediate termination of our business relationship.

Labor Practices and Human Rights

Freely Chosen Employment and Combating Modern Slavery

Intercom is committed to upholding the fundamental human rights of our employees, and we require Partners to adhere to the same high standards by ensuring that their employees are treated fairly and with dignity and respect, and by conducting their employment practices in full compliance with all applicable laws and regulations. Intercom expects Partners to reject all forms of child, forced, or involuntary labor in any part of their business, including within their own supply chains, and to adhere to all applicable child labor, anti-modern slavery and human trafficking laws and regulations. This includes, but is not limited to, the UK's Modern Slavery Act 2015, the Australian Modern Slavery Act 2018 and the ILO Conventions on Child Labour and UN Global Compact.

Fair Treatment and Non-Discrimination

Partners must prohibit unlawful discrimination, harassment or retaliation in their workplaces, which includes any behavior that creates an intimidating, unsafe, or hostile environment, and such prohibition extends to the behavior of Partners' personnel towards any Intercom personnel or Intercom customer. Partners must further provide fair compensation and comply with all applicable wage and hour laws and regulations, including those related to minimum wage, overtime pay and maximum working hours. Partners must respect the rights of their employees to freely associate, join unions, seek representation, and engage in collective bargaining, consistent with applicable law and practice, without fear of discrimination, retaliation, intimidation or harassment for exercising such right.

Equal Opportunity Employment

It's our belief that all people are entitled to equal employment opportunities. Partners must comply with all applicable anti-discrimination and anti-harassment laws, and assure equal treatment in the administration of all personnel matters from recruitment and hiring to compensation and advancement without regard to race, color, creed, sex, gender, religion, marital status, veteran or military status, registered domestic partner status, age, national origin or ancestry, physical or mental disability, medical condition, genetic information, sexual orientation, taking or requesting statutorily protected leave, or any other consideration made unlawful by federal, state, or local laws (the "Protected Categories").

Diversity and Inclusion

Intercom encourages Partners to develop policies and practices that identify, measure, and build a culture of diversity and inclusion throughout the workplace.

Health and Safety

Partners must strictly comply with all applicable health and safety laws and regulations applicable in all markets where they operate. This includes having policies and practices in place to ensure the health and safety of employees, taking necessary steps to provide a safe working environment, and offering emergency training and resources as appropriate.

Ethical Business Practices

Anti Corruption and Bribery

Partners are required to comply with all applicable anti-corruption regulations and international anti-corruption conventions, including but not limited to the U.S. Foreign Corrupt Practices Act ("FCPA"), UK Anti-Bribery Act (the "Bribery Act"), the Brazilian Clean Company Act (the "Clean Company Act"), the Irish Criminal Justice (Corruption Offences) Act 2018 (the "Criminal Offences Act") and equivalent laws of Partner's jurisdiction. Partners must never directly or through a third party offer, promise, make or authorize any payment, bribe, gift, loan, fee, reward or other thing of value in connection with Intercom's business if the purpose or intent is to obtain or retain business, gain a business advantage or to improperly influence any action or decision. This applies to dealings with governments and the private sector, including but not limited to government officials, government employees, Intercom employees and Partners' other customers and their employees.

Partners are further forbidden from promising, giving, or authorizing the provision of "facilitating payments" to expedite or secure the performance of a non-discretionary, routine governmental or commercial duties, even if permitted by the FCPA, Bribery Act, Clean Company Act, Criminal Offences Act or other local laws.

Conversely, Partners also may not request, agree to accept, or accept a thing of value as a reward or in exchange for improperly performing any activity related to Intercom's business or if doing so could create or appear to create actual or potential conflicts of interest between Partners and Intercom.

Conflict of Interest

Partners must avoid conflicts of interest relating to their activities as Partners of Intercom. Partners will report to Intercom any existing or potential situation that may appear as a conflict of interest, and disclose to Intercom if any Intercom employee or professional under contract with Intercom may have an interest of any kind in such Partner's business or any kind of economic ties with such Partner.

Competition

Partners must comply with all applicable laws and regulations regarding fair competition and antitrust. Partners must avoid engaging in types of tactics and activities that unreasonably restrict competition or reflect competing in bad faith including, but not limited to, price fixing, bid rigging, dividing or allocating customers or territories, group boycotts, no poach/non-solicitation agreements that restrain or otherwise limit employee hiring and recruitment, and improperly sharing competitively sensitive information.

International Trade and Export Controls

Partners must comply with all applicable import, export, customs, sanctions, embargoes, boycott, and other trade compliance laws and regulations.

Recordkeeping, Financial Integrity, and Honest and Accurate Dealings

Partners' books, records, accounts and financial statements related to business with Intercom must be maintained accurately and with appropriate detail, and in compliance with relevant laws (local, federal, or global) and industry standards. Partners are required to cooperate fully with Intercom in any government or regulatory audits to the extent relevant and applicable to Partner. Partners must not make any false representations related to any Intercom transaction, including, but not limited to, written or oral misrepresentations of fact or the promotion or use of false documentation such as fraudulent or forged contracts, forged letters of destruction, or any other false or inaccurate records.

Data Privacy and Security

Partners must comply with all applicable data protection, privacy and information security laws and regulations concerning the gathering, storage, processing, transfer, and disclosure of personal data, including but not limited to the EU's and UK's General Data Protection Regulation ("GDPR"), the Privacy and Electronic Communications (EC Directive) Regulations 2003 ("PECR"), the California Consumer Privacy Act ("CCPA") and California Privacy Rights Act ("CPRA"), and must implement strong information security and privacy controls for the protection of personal data. Partners must safeguard data, including their own, Intercom's, and Intercom's customers' and partners' information, and must never disclose personal data except as required by law or as agreed by Intercom.

Intellectual Property and Confidential Information

Partners may only use Intercom's intellectual property, such as trade secret information, copyrights, patents, or trademarks, to the extent and in the manner permitted by Partners' contract with Intercom. Partners may not infringe the intellectual property rights of others, nor misuse any trade secrets or proprietary or confidential information of Intercom or others for their own purposes or disclose such information to unauthorized third parties. Partners must safeguard and take necessary steps to protect Intercom's and its customers' intellectual property, even if it is public, and must notify Intercom if they become aware of any unauthorized use of Intercom's intellectual property or of any unauthorized disclosure of Intercom's confidential information.

Environmental Sustainability

Partners must conduct their operations in ways that are environmentally responsible and comply with all applicable environmental laws and regulations regarding the protection of the environment. Partners are required to obtain and keep current all required environmental permits, approvals and registrations and to follow all applicable operational and reporting requirements. Partners are also encouraged to maintain a system of conservation measures appropriate to the business purpose to minimize environmental pollution and hazards, reduce Greenhouse Gas emissions, and to improve environmental protection in day-to-day operations of their businesses.

Raising Issues and Concerns

Intercom encourages and expects Partners to immediately report any violations of laws, rules, regulations, or this Code in connection with Intercom transactions or engagements by sending an email to legal@intercom.io or by sending a confidential report via email to Intercom's Ethics inbox (ethics@intercom.io). We also expect Partners not to retaliate against anyone who, in good faith, reports a violation or suspected violation or assists in an inquiry into such a report.

Certification and Application

Where Intercom requires, Partners covered by this Code will have their authorized representatives certify that they have read and understood this Code and commit Partners to complying with the Code. Intercom reserves the right to terminate its relationship with any Partners who do not comply with this Code, or upon discovery of noncompliance, do not work in good faith with Intercom to achieve compliance.