Vendor Code of Conduct

Last updated April 9, 2026

WHO IS PERSONIFY HEALTH?
Personify Health, Inc., is a software and healthcare administration company that provides a personalized health platform aimed at optimizing business healthcare investments and empowering people to engage with their health.

WHO DOES THIS CODE APPLY TO?
Personify Health is committed to respecting people and supporting universal human rights, adhering to local laws and regulations, contributing positively to our communities, and minimizing our impact on the environment. This Vendor Code of Conduct (“Code”) applies to any entity (“Vendor”) that (1) contracts with Personify Health to provide goods or services to Personify Health, (2) provides services on behalf of Personify Health, or (3) participates in our platform partner programs.

BUSINESS ETHICS
Personify Health expects Vendor to conduct all its business in an ethical and fair manner. This includes but is not limited to the following:

Conflicts of Interest
Personify Health is committed to conducting all business and operations with the utmost integrity and high standards of behavior so that no conflict of interest exists or can be reasonably implied or construed to exist. A conflict of interest is any personal or financial interest, any business or personal activity or relationship, prior or current employment, or any obligation that may interfere with the ability to objectively perform job duties and responsibilities or impair independence and objectivity. Vendor must disclose any actual or potential conflict of interest related to its activities with Personify Health to the Personify Health compliance department.

Bribes, Kickbacks, and Other Improper Payments
Vendor shall comply with all applicable national and international anti-corruption laws and regulations, including the United States Foreign Corrupt Practices Act of 1977, the United Kingdom Bribery Act 2010, and all other applicable anti-bribery or anti-corruption laws and regulations at a local level. Vendor shall not (neither directly nor indirectly) offer, provide, or accept anything of value to improperly influence an official act or to secure an improper advantage to obtain or retain business. This includes facilitation payments or other benefits provided to public officials for routine non-discretionary actions.

Entertainment and Gifts
We believe in fair competition among Vendors for Personify Health’s business and that sound business decisions are based on objective criteria. To ensure that fair competition and objectivity are maintained, Personify Health prohibits its employees from accepting material gifts from outside business associates or from participating in lavish meals or other entertainment paid for by Vendor. Employees cannot accept any gifts, meals, or entertainment, regardless of value, from Vendors that are actively engaged in contract negotiation with Personify Health. Similarly, Personify Health employees may not give gifts to Vendors in a way that might influence the nature of the relationship between Personify Health and the Vendor.
 
Money Laundering and Financial Records
Vendor shall comply with applicable laws and regulations designed to combat money laundering activities. Vendor shall maintain financial records and reports according to applicable laws and regulations.

Antitrust
Vendor shall comply with applicable competition and anti-trust laws, which are designed to prevent one business from gaining an unfair advantage and forcing other businesses out of the marketplace, such as price fixing, market allocation, group boycotts, price discrimination, or monopolization.

Trade Regulations and Sanctions
Vendor shall comply with all applicable export control, sanctions and customs laws, regulations, and trade laws. Vendor must notify Personify Health if it is listed on, or added to, any US or international sanctions lists. Vendor must cooperate with Personify Health to avoid violating any international sanctions.

DATA PROTECTION AND INFORMATION SECURITY
When handling or processing personal data of any sort, it is important for Vendor to protect the confidentiality, integrity, and availability of the personal data. Vendor must adhere to applicable data protection laws, including security of personal data, as well as to respective regulation regarding personal data of Personify Health members, clients, employees, and stakeholders.
At all times the required level of information security and control to be ensured by Vendor must be commensurate with the sensitivity, value, and criticality of the information being processed throughout the lifecycle of the information. Vendor must notify Personify Health of any security incident that compromises the confidentiality integrity or availability of personal data. Vendor can send notices to [email protected].

HUMAN RIGHTS AND FAIR LABOR PRACTICES
Vendor must operate in a fashion that supports human rights and adheres to fair labor practices at all of its locations worldwide. This includes but is not limited to the following topics.

Human Trafficking and Modern Slavery
As part of our commitment to eradicating human trafficking and modern slavery, Personify Health is committed to ensuring that there is no modern slavery or human trafficking within its supply chain as described in our Anti-Modern Slavery Statement located here: https://personifyhealth.com/legal/modern-slavery-statement/.
Vendor must comply with applicable international and US federal, state, and local laws and regulations.

Child Labor
Vendor shall not employ individuals who are (1) under the legal age of employment in any country or local jurisdiction, or (2) under the minimum age established for developing countries by the International Labour Organization, whichever is higher. See https://www.ilo.org/.

Forced Labor
Vendor shall not use any form of forced, bonded, compulsory labor, or modern forms of slavery. All labor must be voluntary. Workers must be allowed to maintain control over their identification documents (e.g., passports, work permits or any other personal legal documents). Vendor shall ensure that workers do not pay fees or make any payment connected to obtaining employment throughout the hiring process and the employment period. Punishment, mental and/or physical coercion as well as any other form of human trafficking is prohibited. Disciplinary policies and procedures shall be clearly defined and communicated to the workers.

Compensation and Working Hours
Vendor shall comply with all applicable local laws and mandatory industry standards regarding working hours, including overtime, rest breaks, and paid vacation. Vendor shall compensate its workers in accordance with local minimum wage legislation and terms of applicable collective bargaining agreements as well as with industry standards.

Freedom of Association and Collective Bargaining
Vendor shall recognize and respect the right to collective bargaining in accordance with applicable local laws.

Diversity and Inclusion
Vendor shall promote an inclusive work environment that values the diversity of its employees. Vendor must not discriminate in employment, including hiring, compensation, advancement, discipline, termination, or retirement, on the grounds of race, caste, gender, gender identity, sexual orientation, color, national origin, age, mental or physical disability, health conditions or diseases, pregnancy, religion, union membership, marital status, veteran status, or political affiliation.

SAFE AND HEALTHY WORK ENVIRONMENTS
Safety is a priority for Personify Health, and we expect it from our Vendors.
Personify Health requires that the conditions within which the employees of our Vendors are working align with applicable US and international standards. The care of the local environment through waste management and similar initiatives sufficiently conforms with US and internationally recognized standards.

SUSTAINABILITY
Protecting the environment is an ongoing commitment. Vendor must comply with all applicable national, state, and local laws and regulations in their country of operation and meet or exceed international standards for environmental protection. Vendor of manufactured goods to Personify Health must maintain supply chain records and make them available as required. Records must include material sources and any environmental certifications as applicable.

REPORTING CONCERNS TO PERSONIFY HEALTH

Vendors are encouraged to report to Personify Health any questions, concerns, or potential violations of this Vendor Code of Conduct.