Revised March 1, 2024

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INTRODUCTION

Integrity and transparency are core Qualtrics’ business values. We expect our Partners (as defined below) to share those values so that together we can earn and maintain trust with our customers, partners, and employees. This Partner Code of Conduct (“Code”) sets forth your obligations as a Qualtrics Partner to act ethically, fairly, and legally in our business transactions. This Code 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 partner 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. The definition also includes employees and subcontractors of the Partner.
• “Qualtrics” refers to Qualtrics International Inc. and all international Qualtrics subsidiaries who act as local contracting party for agreements with Partners.

COMPLIANCE WITH LAWS, RULES, AND REGULATIONS

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, or in partnership with 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.

ANTI-CORRUPTION AND ANTI-BRIBERY 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, 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 as defined by the Qualtrics Business and Hospitality Events Policy (available upon request)

Partners are required to comply with applicable anti-bribery laws, including but not limited to the U.S. Foreign Corrupt Practices Act and the UK Bribery Act.

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 all applicable antitrust and competition laws, 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 between the Partner and any customer, vendor, competitor, or other 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.

EXPORT LAWS

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

• A product’s technical characteristics (i.e. the product is classified as Dual Use good or has military specific functionalities),
• The destination (i.e. the country of destination is subject to trade sanctions),
• The end-user (i.e. the end-user is subject to trade restrictions), and
• The end-use (i.e. the software is intended for a military end-use in a crisis area)

An export is a delivery of goods or services 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.

SECURITIES AND INSIDER TRADING LAWS

Partners are expected to comply with applicable insider trading and securities laws . Securities include common stocks, bonds, options, futures, and other financial instruments. Partners that possess or have access to material, non-public information (“MNPI”) gained through their work with Qualtrics may not use MNPIto trade in the securities of any other company to which the information pertains. Partner shall ensure that its employees do not engage in any other action to take advantage of, or pass on to others, MNPI gained through working with Qualtrics until a reasonable time after full public disclosure has occurred. These restrictions also apply to family members, friends, and associates. MNPI 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.

MODERN SLAVERY

Partners must comply with all applicable employment, labor and related laws (including those aimed at eradicating modern slavery) and meet in full their obligations under such laws. In addition, at a minimum, Qualtrics expects Partners to take all reasonably practicable steps to ensure that participants in their supply chains do not engage in conduct amounting to modern slavery.

Qualtrics takes human rights violations extremely seriously. Any concerns that a violation of this policy or a violation of human rights has occurred may result in an investigation being conducted by Qualtrics, and may lead to the suspension and/or termination of the Partner’s services to Qualtrics. Qualtrics shall not be liable for any such suspension or termination.

You can report violations of modern slavery or human rights to compliance@qualtrics.com or anonymously via Qualtrics Ethics Hotline.

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 may result in contract termination depending on the partner status. Partners are also requested to complete any compliance training required based on their partner type.

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 or the negotiation of agreements and contracts for Qualtrics products or services must ensure that all statements, communications, and representations to Qualtrics are accurate and truthful.

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. Partners should not knowingly shift an expense to a different accounting period.

CONFLICTS OF INTEREST

The term “conflict of interest” describes any circumstance that affects or appears to affect a Partner’s ability to act with total objectivity with regard to the supply of products and services to Qualtrics and/or its customers. Qualtrics wants its Partners’ services to be free from any conflicts of interests.

While engaged in Qualtrics-related work, Partner must exercise reasonable care and diligence to avoid any actions or situations that could result in a conflict of interest or the appearance thereof. This includes not accepting other outside activity that creates a conflict of interest with Qualtrics or in any way compromises the work the Partner is to perform for Qualtrics.

Partners shall not encourage or influence current or former Qualtrics employees in any manner which would cause them to disclose or provide any confidential, proprietary, or other restricted information obtained while employed or engaged by Qualtrics so as to influence Qualtrics existing or proposed commercial transactions for the purpose of gaining a commercial advantage.

In order to avoid any conflict of interest or appearance thereof, if a Qualtrics employee leaves Qualtrics and thereafter is engaged by a Partner, Qualtrics may in its’ sole discretion decide whether current or former Qualtrics employees who are engaged by a Partner, may (i) act on behalf of the Partner in discussions or negotiations with Qualtrics, or (ii) be part of the service delivered by the Partner to Qualtrics.

Partners are expected to cooperate with Qualtrics investigations and to provide reasonable assistance as requested.

Qualtrics expects Partners to prevent or disclose in writing a conflict of interest or the appearance of a conflict of interest immediately to the Qualtrics Compliance team (compliance@qualtrics.com). Qualtrics may require, and Partner shall comply, with any instruction to Partner correct any actual or perceived conflict of interest at any time during the agreement.

Offering and Accepting Business Courtesies
Partners should use discretion and care to ensure that any expenditure offered to or received by any Qualtrics employee 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 the Partner or Qualtrics. Employees of the Partner are permitted to offer and accept meals and other business entertainment from third parties in connection with Qualtrics business only when accepting such business courtesy:

• Serves a bona fide business purpose;
• Does not inappropriately influence, or appear to influence, any business decision;
• Is not offered during any pending bidding or negotiation process;
• Is given openly and transparently;
• 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. Meals and business entertainment should not exceed $200 USD (or equivalent in local currency) per person.

Gifts in kind, payment, loan, vacation, or other privilege (collectively, a “Gift”) from current or prospective customers, vendors, competitors, or partners to Qualtrics employees orand their relations, life companions, and other people with whom they have a close personal connection should not be given where:

• The Gift is worth more than the financial threshold described in Qualtrics’ Code of Ethics and Business Conduct. This amount is currently $100 USD per person (or equivalent in local currency), but is subject to change.;
• Accepting the Gift would prejudice Qualtrics’ business interests; or
• Accepting the Gift would create a payback obligation; or
• The Gift is given during negotiation or bidding, directly or indirectly by a party to that negotiation or bidding; or
• Accepting the Gift would allow an impression of unjust advantage to arise; or
• The Gift is unlawful or contrary to ethical principles; or
• The Gift is associated with earlier gifts.

This rule does not apply to promotional gifts of low value of a customary kind, such as branded ink pens, mugs or other small tokens.

Discounts and other privileges offered to an employee of Qualtrics as part of private transactions with customers, vendors, competitors, and partners of Qualtrics may only be accepted if these are granted to all Qualtrics employees in that region.

EMPLOYMENT/LABOR STANDARDS

Partners are committed to uphold the human rights of workers and to treat them with dignity and respect.

Freely Chosen Employment
Forced, bonded, or indentured labor or involuntary prison labor is prohibited. All work will be voluntary and workers should be free to leave upon giving reasonable notice and at their own will. Workers shall not be required to forfeit any documents related to travel or identification, including but not limited to government-issued identification, passports, or work permits, as a condition of employment.

Child Labor Avoidance
Child labor is prohibited in any and all stages of manufacturing or the delivery of goods or services. The term “child” refers to any person employed under the age of 15 (or 14 where the law of the country permits), under the age of completing compulsory education, or under the minimum age for employment in the country – whichever is the greatest. The use of legitimate workplace apprenticeship programs, which comply with all laws and regulations, is supported. Workers under the age of 18 should not perform hazardous work and must be restricted from night shifts, with consideration given to educational needs.

Working Hours
Partner shall ensure that it complies with local laws relating to working hours and rest periods.

Wages and Benefits
Qualtrics expects its Partners to adhere to minimum wage laws. All benefits required by local laws must need to be provided. Payments need to be made regularly and directly to the workers. Deductions from or withholding of payments need to be in compliance with local laws only, and the workers need to have full understanding of the actions taken. The same goes for advances and loans. Workers must receive information about hours worked, rates of pay, and the calculation of legal deductions. Workers must retain full and complete control over their earnings. Wage deductions to keep workers tied to the employer or to their jobs are not permitted. Holding workers in debt bondage, forcing them to work in order to pay off a debt, and deception in wage commitments, payment, advances, and loans are prohibited.

Humane Treatment
There is to be no harsh or inhumane treatment, including any sexual harrassment, sexual abuse, corporal punishment, mental or physical coercion, or verbal abuse of workers; nor is there to be the threat of any such treatment.

Non-discrimination
Partners should be committed to a workforce free of harassment and unlawful discrimination. Companies shall not engage in discrimination based on culture, race, color, age, gender, gender identity or expression, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership, or marital status in hiring and employment practices, such as promotions, rewards, and access to training. In addition, workers or potential workers should not be subjected to medical tests that could be used in a discriminatory way.

Freedom of Association
Open communication and direct engagement between workers and management are the most effective ways to resolve workplace and compensation issues. Partners are to respect the rights of workers to associate freely, join or not join labor unions, seek representation, or join workers’ councils in accordance with local laws. Workers shall be able to communicate openly with management regarding working without fear of reprisal, intimidation, or harassment.

Contracts of Employment
All employees shall be provided with an employment contract in a language they understand, clearly indicating their rights and responsibilities with regard to wages, working hours, and other working and employment conditions . Any changes to the employment contract or/and the working conditions agreed upon must be in alignment with local laws.

Workplace Equality
Qualtrics expects that all workers, irrespective of their nationality, sex, gender identity, sexual orientation, age, religious beliefs, disabilities, legal status, or other relevant characteristics, are treated fairly and equally. No employee shall be threatened with denunciation to authorities to coerce them into taking up or or maintaining employment.

HEALTH AND SAFETY

Partners recognize that the quality of products and services, consistency of production, and workers’ morale are enhanced by a safe and healthy work environment. Partners also recognize that ongoing worker input and education are key to identifying and solving health and safety issues in the workplace in order to comply with their necessary duty of care to their employees.

Partners shall prevent worker exposure to potential safety hazards (for example, electrical and other energy sources, fire, vehicle, and fall hazards, and exposure to chemical, biological, and physical agents) and make sure they are controlled through proper design, engineering and administrative controls, preventive maintenance, and safe work procedures (including lockout-tagout). Where hazards cannot be adequately controlled by these means, workers are to be provided with appropriate personal protective equipment.

Workers shall not be disciplined for raising safety concerns. Partners identify and assess emergency situations and events, and minimize their impact by implementing emergency plans and response procedures, including emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, adequate exit facilities, and recovery plans.

Procedures and systems are to be in place to manage, track, and report occupational injury and illness, including provisions to encourage worker reporting, classify and record injury and illness cases, provide necessary medical treatment, investigate cases and implement corrective actions to eliminate their causes, and facilitate the return of workers to work.

Partners identify, evaluate, and control worker exposure to physically demanding tasks, including manual material handling and heavy lifting, prolonged standing, and highly repetitive or forceful assembly tasks. Physical guards, interlocks, and barriers are to be provided and properly maintained for machinery used by workers.

Partners provide workers with clean toilet facilities, access to potable water, and sanitary food preparation and storage facilities. Where provided, worker dormitories provided by the Partner or a labor agent are to be clean, safe, and provide emergency egress, adequate heat and ventilation, and reasonable personal space.

DIVERSITY, EQUITY AND INCLUSION (DEI)

DEI is a cornerstone of Qualtrics’ company culture. We are taking action to improve DEI through our people, processes, and technology, and we expect the same from our supply chain. Partners are encouraged to provide an inclusive, healthy, bias-free work environment to their employees. Partners should, if applicable, strive to foster:

• Gender equity by offering equal rights for men and women
• Have practices and policies that do not condone or tolerate racism
• Create safe environments that do not discriminate against LGBTQ+ employees
• Cross-generational intelligence by having people of all ages and at every work and career stage
• Culture and identity by empowering many voices to help gain strength from people’s differences
• Opportunities for disabled people by focusing on their unique abilities and providing a work environment that considers the needs and skills of each employee
• Empower small, diverse businesses and promote sustainability and diversity in supply chains

Partners are encouraged to deliver goods and services that are accessible to everyone, including those with disabilities. If accessibility standards – for example, Web Content Accessibility Guidelines (WCAG) 2.0 Level AA, included in US Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. § 794d), and the harmonized EN 301 549 including WCAG 2.1 Level AA , and WCAG 2.2 Level – are applicable for the goods or services delivered, Partners are strongly encouraged to take these standards into consideration and meet them.

PROTECTING THE ENVIRONMENT

Qualtrics is committed to protecting and respecting our environment. At a minimum, we expect our Partners to follow all applicable environmental laws, regulations, and standards. This includes requirements for chemical and waste management and disposal, recycling, industrial waste, water treatment and discharge, air emissions controls, environmental permits, certifications and environmental reporting. Partners should have their own environmental management system, including goals to reduce environmental impact, measures and controls (including audits), reporting, and training. Partners must comply with all requirements regarding conflict minerals, exercise proper due diligence, and provide evidence that they are in compliance.

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 services for Qualtrics. Use of Qualtrics resources without proper approvals or for anything other than to perform contracted services for Qualtrics is strictly prohibited. Qualtrics’ intellectual property rights, confidential information and sensitive information must be protected.

Partners should not use Qualtrics’ information for gain or advantage, and should 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 written permission, and not transferring, publishing, using or disclosing it other than as necessary in the ordinary course of business or as directed or authorized by Qualtrics. Qualtrics may require Partners to sign Non-Disclosure Agreements for specific and confidential projects.

Materials that contain confidential information or that 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, or/and employee information. However, the terms of any confidentiality provision in the agreement between the Partner and Qualtrics will govern confidentiality terms between the parties.

Qualtrics retains the right to monitor its assets and work environments in compliance with applicable laws, including any 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.

Additionally, if Partners, or any of their resources supporting Qualtrics, have been assigned Qualtrics-owned assets, such as laptops or monitors, it is required that all asset usage complies with Qualtrics’ policies, and that all assets be returned within the designated time frame specified by Qualtrics. If there are any questions about the IT return process, please contact the Procurement team at procurement@qualtrics.com.

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. For more information on the use of Qualtrics Trademarks, please visit https://www.qualtrics.com/trademark/.

DATA PRIVACY

Qualtrics requires its Partners to protect the privacy of individuals and Partners must ensure compliance with applicable data protection laws as such laws relate to the services being provided by the Partner.

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.

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.

Partners shall adopt or establish a management system whose scope is related to the content of this Code. The management system shall be designed to ensure compliance with applicable laws, regulations, and customer requirements related to Partner operations and products; conformance with this Code; and identification and mitigation of operational risks related to this Code. It should also facilitate continual improvement.

Partners should commit to statements on corporate social and environmental responsibility, affirming compliance and continual improvement. Partners should appoint company representatives responsible for ensuring implementation and periodic review of the status of the management systems. Partners should identify, monitor, and understand applicable laws, regulations, and customer requirements. Partners should establish a process to identify the environmental, export control and trade sanctions, health, and safety and labor practice risks associated with Partner operations.

Partners should determine the relative significance for each risk and implementation of appropriate procedural and physical controls to ensure regulatory compliance to control the identified risks. Partners should create and maintain written standards, performance objectives, targets, and implementation plans including a periodic assessment of Partner performance against those objectives. Partners must establish programs for training managers and workers to implement Partner policies and procedures.

Partners should establish and monitor ongoing processes to assess employees’ understanding of and obtain feedback on practices and conditions covered by this Code. Periodic self-evaluations shall be conducted by Partners to ensure conformity to legal and regulatory requirements, the content of the Code, and requirements related to social and environmental responsibility.

Partners should establish a process for timely correction of deficiencies and creation of documents and records to ensure compliance and conformity, along with appropriate confidentiality to protect privacy.

REPORTING CONCERNS AND RAISING QUESTIONS

The standards of conduct described in this Code 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:

• Reach out to the Qualtrics Compliance team (compliance@qualtrics.com). Your message will be routed to the appropriate team member for assistance or guidance as necessary;
• If you are not comfortable reaching out to the Qualtrics Compliance directly, or if you would prefer to reach out on an anonymous basis, you can use the Qualtrics Ethics Helpline page (also known as the Qualtrics Whistleblower webpage) – options include:
1. Report an incident or concerns on our Ethics Helpline webpage at ethics.qualtrics.com. These reports can be fully anonymous if you chose so.
2. Leave a message on the Ethics Helpline at (800) 461-9330 . (Additional international numbers can be located on the Ethics Helpline webpage at 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.