Revised September 30, 2021

****************

INTRODUCTION
Integrity and transparency are core Qualtrics’ business values. We expect our Partners to share those values so that together we can earn and maintain trust with our customers, partners, and employees. The following guidelines set forth your obligations as a Qualtrics Partner to act ethically, fairly, and legally in our business transactions. These guidelines must be reviewed and followed by any employees who work directly with Qualtrics products or customers.

Our Partners are critical to our operations and future success. We thank you for continuing to make compliance and integrity a top priority as you work with Qualtrics.

DEFINITIONS
“Partner” means all Technology, Solution, Service (i.e., Consulting, Implementation, System Integration, Hosting, Education), Channel (Resellers, Co-sell and Referral) and all other Partners participating in any Qualtrics Partner program. It also includes employees of the Partner.

“Qualtrics” refers to Qualtrics International Inc. and all international Qualtrics subsidiaries who act as local contracting party for agreements with Partners.

Policy Content

I. Compliance with laws, rules, and regulations

A. GENERAL
As a Partner, you agree to abide by the terms of this Code, and acknowledge that compliance with this Code is required to maintain your status as a Qualtrics Partner. You agree that all business conducted on behalf of Qualtrics shall be accomplished in full compliance with applicable laws, rules, regulations and policies. If local laws are less restrictive than the principles set forth in this Code, Partners are expected to, at a minimum, comply with the Code. If local laws are more restrictive than this Code, Partners are expected to, at a minimum, comply with applicable local laws.

B. ANTI-CORRUPTION LAWS
Partners shall not make, authorize or offer any bribes, kickbacks, or payments of money or anything of value to anyone, including any officials, employees, or representatives of any government or public or international organization, or to any other third party (public or private sector) for the purpose of obtaining or retaining business, or influencing any other favorable business decision, that is related in any way to Qualtrics.

This includes giving money or anything of value to anyone where there is reason to believe that it will be passed on to a government official or the decision maker at a private sector customer or potential customer for this purpose. Accordingly, it is prohibited to invite Public Sector customers which includes government officials, public sector employees, employees of state-owned enterprises, employees of a department or agency of the government (military, public schools, scientific research bodies established by the government), representatives of political parties, etc. to hospitality events. For reference, hospitality events do not have an agenda that is principally business focused.

Partners are required to comply with the U.S. Foreign Corrupt Practices Act, the UK Bribery Act and all applicable local anti-bribery laws.

C. OFFERING/ACCEPTING BUSINESS COURTESIES
Partners should use discretion and care to ensure that any expenditure (i.e., gifts or meals) offered to or received by any Qualtrics employee or third party is in the ordinary and proper course of business and could not reasonably be construed as a bribe or improper inducement. Business courtesies cannot be designed or appear to be designed to influence the recipient and secure unfair preferential treatment. A general guideline for evaluating whether a business courtesy is appropriate is whether public disclosure would be embarrassing to Partner or Qualtrics. Employees of Partner are permitted to offer and accept meals and other business entertainment from third parties in connection with Qualtrics business only where accepting such business courtesy:

• Serves a bona fide business purpose, and
• Does not inappropriately influence, or appear to influence, any business decision, and
• Is not offered during any pending bidding or negotiation process, and
• Is given openly and transparently, and
• Is not unlawful or contrary to ethical business principles, local business customs or the customer, vendor, competitor or partner’s company policy.

Generally, meals or business entertainment must be reasonable, appropriate and consistent with applicable local laws; Qualtrics recommends that they should not exceed 150 USD per person. However, the Partner shall take into account local rules and habits which may lead to a stricter limit as recommended above.

D. ANTITRUST AND COMPETITION LAWS
Antitrust and competition laws are designed to protect consumers and competitors against unfair business practices and promote and protect healthy competition. Qualtrics is committed to observing the applicable antitrust and competition laws of all nations or organizations, and Qualtrics expects its Partners to comply with all applicable antitrust and competition laws as well. Antitrust or competition laws vary from country to country, but generally, such laws prohibit agreements or actions that unreasonably restrain trade, are deceptive or misleading, or unreasonably reduce competition.

An agreement with a customer, vendor, competitor, or other partner of the Partner not to conduct business with, or not to deliver goods or provide services to any other customer, vendor, competitor, partner, or service provider (boycott) is unlawful.

All forms of price-fixing among market participants are forbidden. Generally, price fixing is defined as a verbal or written agreement between participants on the same (supplying) side in a market to buy or sell a product, service, or commodity only at a fixed price, or maintain the market conditions such that the price is maintained at a given level by controlling supply and demand.

Partners must not accept, read, or use information about products and plans of market participants which is identified or identifiable as confidential information unless the Partner is authorized by the other market participant to do so. Also, Partners must not talk with market participants about Qualtrics internal matters, such as pricing and conditions of sale, costs, overviews of the market, organizational processes, or other confidential information, from which other market participants could draw competitive advantage over Qualtrics.

E. EXPORT LAWS
Certain exports require prior authorization and/or licenses from the export control authorities or may be prohibited at all. Authorization and license requirements are dependent upon:

• a product’s technical characteristics (the product is classified as Dual Use good or has military specific functionalities),
• the destination (the country of destination is subject to trade sanctions),
• the end-user (end-user is subject to trade restrictions (“black-listed”), and/li>
• the end-use (the software is intended for a military end-use in a crisis area)

An export is a delivery of goods across borders, regardless of the method used for the transfer. While most of Qualtrics’ services do not constitute “exports” because they are delivered via SaaS, certain Qualtrics services such as apps and downloadable files may be considered an export and subject to application laws.

Qualtrics requires Partners to comply fully with these laws. Failure to comply could result in criminal fines for the involved persons or corporate bodies and administrative fines for the company as well as the loss or restriction of export privileges.

F. SECURITIES AND INSIDER TRADING LAWS
Partners are expected to comply with applicable insider trading and securities laws governing transactions in the securities of Qualtrics. Securities include common stocks, bonds, options, futures, and other financial instruments. Partners that possess or have access to material, non-public information gained through their work with Qualtrics may not use that information to trade in Qualtrics securities or the securities of another company to which the information pertains. The Management and/or the Directors of the Partner shall ensure that its employees do not engage in any other action to take advantage of, or pass on to others, material information gained through work with Qualtrics until a reasonable time after full public disclosure has occurred. These restrictions also apply to family members, friends, and associates. Material information includes any information that a reasonable investor would consider important in a decision to buy, hold, or sell securities. Such information may include financial and key business data; merger, acquisition, or divestiture discussions; award or information related to the cancellation of a major contract; changes in key management; forecasts of unanticipated financial results; significant litigation; and/or gain or loss of a substantial customer or Partner.

G. VALID DUE DILIGENCE STATUS
Qualtrics Partners are expected to comply fully with any information requests required by Qualtrics to carry out due diligence checks when joining any Qualtrics partner program and any subsequent due diligence renewal requests. Failure to supply information or not meeting due diligence requirements may lead to application rejection, delays or inability for Qualtrics to accept sales leads, process related orders and payments or contract termination depending on the partner status. Partners are also requested to complete any compliance training available based on their partner type.

II. Business conduct

Qualtrics expects Partners to compete fairly and ethically for all business opportunities. Partners’ employees involved in the sale or licensing of products and services and the negotiation of agreements and contracts to Qualtrics must ensure that all statements, communications, and representations to Qualtrics are accurate and truthful.

A. FINANCIAL INTEGRITY
Accurate and reliable financial and business records are of critical importance in meeting Qualtrics’ financial, legal, and business obligations. Partners should not have any false or inaccurate entries in the accounting books or records related to Qualtrics for any reason. Partners’ business records must be retained in accordance with record retention policies and all applicable laws and regulations.

B. CONFLICTS OF INTEREST
The term “conflict of interest” describes any circumstance that could cast doubt on the Partner’s ability to act with total objectivity regarding the supply of products and services to Qualtrics. Qualtrics wants its Partners’ services to come easily and free from any conflicting interests.

A conflict of interest also exists where there is a choice between acting in a personal interest (financial or otherwise) or in the interest of Qualtrics. While engaged in Qualtrics-related work, you must exercise reasonable care and diligence to avoid any actions or situations that could result in a conflict of interest. Qualtrics expects Partners to prevent or immediately disclose a conflict of interest or the appearance of a conflict of interest as soon as possible to Qualtrics.

III. Human rights and labor standards

Partners should respect human rights understood as the principles expressed in the International Bill of Human Rights and in the eight International Labor Organization core conventions. This means Partners should not only respect their employees’ fundamental rights at work, but they should also uphold their duty in all business activities with Qualtrics, such as:

• Freely Chosen Employment
• Child Labor Avoidance
• Compliance with local Working Hours requirements
• Compliance with local Wages and Benefits requirements
• Humane Treatment
• Non-Discrimination
• Freedom of Association

IV. Health & safety/environmental

Partners recognize that quality of products and services, consistency of production and workers’ morale are enhanced by a safe and healthy work environment, and shall prevent workers’ exposure to potential safety hazards. Partners recognize that environmental responsibility is integral to producing world class products. In manufacturing operations, adverse effects on the community, environment and natural resources are to be minimized while safeguarding the health and safety of the public. All required environmental permits and registrations are to be obtained, maintained and kept current and their operational and reporting requirements are to be followed.

V. Compliance management system

Partners shall adopt or establish a management system whose scope is related to the content of this Code. Partners agree to provide information and evidence tied to their Compliance Management Systems to Qualtrics, whenever requested as part of our diligence processes or Partner Audits. The management system shall be designed to ensure:

• Compliance with applicable laws, regulations and customer requirements related to the Partner’s operations and products;
• Conformance with this Code;
• Identification and mitigation of operational risks related to this Code; and
• Documentation of the Compliance Management System for auditing purposes.

VI. Responsibility for company resources

Partners are expected to safeguard Qualtrics resources which include property, assets, intellectual property, company technology assets (network, phone, Internet, software applications and e-mail systems), trade secrets and other confidential, proprietary or sensitive information while performing work for Qualtrics. Use of Qualtrics resources without proper approvals or for anything other than to perform Qualtrics work activities is strictly prohibited. Intellectual property rights of Qualtrics must be protected.

A. CONFIDENTIAL INFORMATION
Qualtrics confidential or sensitive information must be protected. Partners may only possess such information if they need to do so to perform work activities. Partners should not use this information for gain or advantage, and never share this information without appropriate Qualtrics approval. All confidential or sensitive information obtained by a Partner must have documented authorization in place. Inappropriate use of Qualtrics Internet or e-mail is strictly prohibited.

Partners are expected to safeguard confidential information by not reproducing copyrighted software, documentation, or other materials without permission, and not transferring, publishing, using or disclosing it other than as necessary in the ordinary course of business or as directed or authorized. Qualtrics may require Partners to sign Non-Disclosure Agreements for specific and confidential projects.

B. TRADEMARKS
Partners are expected to respect Qualtrics’s trademarks (i.e., if Partner is granted permission to use the Qualtrics logo, the Partner must use such Qualtrics logo exclusively in Qualtrics’s interest, that is to say, only to identify Qualtrics products and in advertising such products). Partners are not permitted to grant sublicenses.

C. DATA PRIVACY
Partners should observe applicable data privacy standards. Materials that contain confidential information or which are protected by privacy standards should be stored securely and should be shared only internally with those employees with a “need to know”. For example, Qualtrics confidential information may include, but is not limited to, software and other inventions or developments (regardless of the stage of development) developed or licensed by or for Qualtrics, marketing and sales plans, competitive analyses, product development plans, pricing, potential contracts or acquisitions, business and financial plans or forecasts, and prospect, customer and employee information. However, the terms of any confidentiality provision in the agreement between Partner and Qualtrics will govern confidentiality terms between the parties.

D. COMMUNICATION
Partners must not commit Qualtrics to future functionality toward third parties.

Outside the scope of the relevant Qualtrics Partner program, Partners should not provide Qualtrics-related statements or speak and act on behalf of Qualtrics toward third parties unless specifically and explicitly authorized by Qualtrics to do so.

This does also include the obligation of the Partner to protect Qualtrics’s reputation and to avoid unauthorized communication by its employees on behalf of the Partner with reference to Qualtrics.

E. MONITORING
Qualtrics retains the right to monitor its assets and work environments in compliance with applicable federal, state and local law. We monitor to promote safety, prevent criminal activity, investigate alleged misconduct and security violations, manage information systems, and for other business reasons.

VII. Reporting concerns and raising questions

The standards of conduct described in this Qualtrics Partner Code of Conduct are critical to the ongoing success of Qualtrics’s relationship with its Partners. If you have questions or concerns about compliance or ethics issues or want to report illegal or unethical activities:

• Submit a report via our confidential Ethics Hotline; or
• Send an email to ethics@qualtrics.com.

All matters raised in good faith through these reporting lines will be handled on a confidential, non- retaliatory basis. All information will be maintained as confidentially as practical in light of the need to conduct an investigation and implement remedial measures. Anonymity will be granted upon request by the reporting person.