Introduction To Our Code

Learn. Implement. Speak Up.

Colleague Responsibilities

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All colleagues should:

  • Work with the goal of Bringing Our Core Values to Life.
  • Take responsibility for following our Code, our policies, and the law.
  • Understand that you’re expected to uphold our Values no matter your role, location, job duties, or work environment.
  • Seek clarity if any legal or ethical responsibility isn’t clear.
  • Speak up about any seen or suspected violation.
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Additionally, all managers should:

  • Model Bringing Our Core Values to Life.
  • Learn the Code well enough to answer questions.
  • Promote the Code, or topics within the Code, whenever possible.
  • Be a safe space for others to speak up.
  • Escalate colleagues’ concerns when needed.
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If you’re a Senior Financial Officer, also:

  • Know and follow our disclosure controls and all applicable procedures.
  • Provide full, fair, accurate, timely, and understandable disclosures to the U.S. Securities and Exchange Commission (SEC), consulting with colleagues or taking other appropriate steps for guidance when needed.
  • Ensure all reports and documents filed with the SEC follow applicable securities laws and rules.
  • Notify the Audit Committee of the Board of Directors with concerns regarding the recording, processing, summarizing, and reporting of financial data, including any:
    • - Issue with the design or implementation of internal controls
    • - Fraud that involves management or other colleagues with significant roles in finance

Senior Financial Officers include our:

  • - Chief Executive Officer
  • - Chief Financial Officer
  • - Chief Accounting Officer
  • - Controller
  • - Others performing similar functions
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Senior Financial Officers include our:

  • - Chief Executive Officer
  • - Chief Financial Officer
  • - Chief Accounting Officer
  • - Controller
  • - Others performing similar functions

Note that the Audit Committee will determine appropriate actions to be taken in the event of violations of this Code by any Senior Financial Officer.

Any waiver of or amendments to the Code with respect to any Senior Financial Officer must be approved by the Audit Committee and will be promptly disclosed to the extent required under applicable law, rule, or regulation.

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Two people ready for a digital payment