Code of Conduct

Last updated: September 21, 2026

Cognition AI, Inc. (“Cognition”)

Supplier/Vendor Code of Conduct

Purpose

The Cognition Code of Conduct (“Code”) is built around our belief that everything we do will be measured against the highest possible standards of ethical business conduct. Our commitment to high standards helps us hire great people, build great products, and attract loyal customers, partners, and vendors.

Who must follow the Code?

We expect our vendors, suppliers, and other third parties engaged to provide goods or services to Cognition (“Vendors”) to follow the applicable standards of this Code in connection with their work for or on behalf of Cognition. Vendors should be onboarded through Cognition's standard procurement and due-diligence process. Cognition may require Vendors to acknowledge this Code, or an equivalent standard, as a condition of doing business with Cognition. Failure of a supplier/vendor to comply may result in suspension or termination of the business relationship.

No Retaliation

Cognition prohibits retaliation against anyone who reports, or participates in an investigation of, a possible violation of our Code, our policies, or the law, including reports made by a Vendor or about a Vendor. Please contact a member of senior management if you believe that you are the subject of retaliation within Cognition.

Preserve Confidentiality

Throughout its lifecycle, all nonpublic information that is processed, transmitted, and/ or stored by Cognition and its Vendors must be protected in a manner that is consistent with our contractual and legal requirements and reasonable and appropriate for the level of sensitivity, value, and risk associated with Nonpublic information (please see the Data Classification Policy). Information that contains data elements from multiple classifications must be protected at the highest level of information represented. For example, a document that contains Nonpublic and Public information must be treated as Nonpublic information. Nonpublic information must be secured against disclosure, modification, and access by unauthorized individuals. Therefore, the information must be:

Secured at rest;
Secured in transit; and
Securely destroyed in accordance with record retention policies and procedures.

Vendors who are given access to Cognition's Nonpublic information must protect it under a written confidentiality or data protection agreement that provides at least the same level of protection required by this section, and must return or destroy that information at the end of the engagement.

Information Security

Vendors who have access to Cognition's computer resources are responsible for using Cognition's computer resources properly – especially with regard to information security – and must be thoroughly familiar with Cognition's Information Security policies and procedures.

In particular, Vendors should observe these steps to prevent unauthorized access:

Never share login information.
Lock workstations when stepping away.
Log off workstations when you leave for the day.
Clear workstations, waste can, printers and fax machines of sensitive information, such as PII or company-sensitive information.

Vendors with access to Cognition systems or data must follow security requirements at least as protective as those in their agreement with Cognition, and must promptly report any suspected security incident involving Cognition information.

Protect Cognition's Assets

Intellectual Property

Cognition's intellectual property rights (e.g. patents, trademarks, copyrights, trade secrets, and “know-how”) are valuable assets. Unauthorized use can lead to their loss or serious loss of value. Vendors must comply with all intellectual property laws, including laws governing the fair use of copyrights and trademarks. Vendors must never use Cognition's trademarks or other protected information or property for any business or commercial venture without pre-clearance from legal@cognition.ai. Report any suspected misuse of trademarks or other Cognition intellectual property to legal@cognition.ai.

Likewise, Vendors must respect the intellectual property rights of others. Inappropriate use of others' intellectual property may expose the Vendor to criminal and civil fines and penalties. Vendors should get advice from legal@cognition.ai before soliciting, accepting, or using proprietary information from individuals outside the company or allowing them to obtain access to Cognition proprietary information. Vendors should also check with legal@cognition.ai if developing a product feature that uses content not belonging to Cognition in the course of their work for Cognition.

Vendors and contractors who create work product for Cognition must assign their rights in that work product to Cognition under their written agreement, and must not use Cognition's trademarks, brand assets, or confidential technical information for any other purpose without written approval.

Ensure Financial Integrity and Responsibility

Financial integrity and fiscal responsibility are core aspects of corporate professionalism. Each Vendor has a role in making sure that money is appropriately spent, that financial records are complete and accurate, and internal controls are honored. This is applicable every time Vendors expend Cognition resources or seek reimbursement.

It's important that Vendors also keep records for an appropriate length of time. Contractual obligations may sometimes specify longer retention periods for certain types of records. In addition, if a Vendor is asked by the Cognition's Legal team to retain records relevant to a litigation, audit, or investigation, Vendors should do so until the Legal team informs the Vendor that retention is no longer necessary. If Vendors have any questions regarding the correct length of time to retain a record, contact legal@cognition.ai.

Company Policy on Prohibition of Slavery, Child Labor, Sex Trafficking, and Human Rights Violations

This policy outlines Cognition's commitment to conduct business in a manner that respects and promotes human rights and dignity. It explicitly prohibits any form of collaboration or involvement, whether directly or indirectly, with companies, organizations, or activities associated with slavery, child labor, sex trafficking, or any human rights violations.

This policy applies to all employees, contractors, suppliers, partners, and any other entities associated with Cognition, across all operations globally.

Cognition strictly prohibits:

Engaging in, supporting, or condoning slavery, child labor, or sex trafficking in any part of our operations or supply chain.
Working with any company or organization that is known or found to be involved in slavery, child labor, sex trafficking, or significant human rights violations.

Vendors and suppliers must certify compliance with this policy on request and must promptly disclose to Cognition any known or suspected violation within their own operations or sub-supply chain. Cognition reserves the right to audit Vendor compliance and to terminate any Vendor relationship for a violation of this policy.

In addition, Vendors are expected to: (a) provide workers with wages and benefits that meet or exceed local legal minimums, paid regularly and on time; (b) keep working hours and overtime within applicable legal limits and properly compensated; (c) respect workers' rights to freedom of association consistent with local law; (d) provide a safe and healthy workplace, including access to clean facilities and appropriate protective equipment; and (e) maintain a grievance mechanism through which their workers can raise concerns without fear of retaliation.

Sanctions and Export Controls. Each Vendor represents that it will comply with applicable sanctions, export control, and anti-boycott laws; that neither it nor its affiliates, directors, officers, agents, or employees appear on any sanctions or restricted-party list; and that it is not headquartered or resident in a country subject to comprehensive economic sanctions (currently including Cuba, Iran, North Korea, Syria, and the Crimea region of Ukraine). Vendors will provide written certification of the foregoing on request.

Government Contracting

Cognition provides products and services to government customers, including through our FedRAMP environment, and government contracting is subject to special rules that go beyond ordinary commercial practice. If your work touches government customers or contracts, you must comply with all applicable procurement laws and contract requirements. This includes not offering gifts, meals, or anything of value to government officials except as expressly permitted by law and the relevant agency's rules; not offering, soliciting, or accepting kickbacks or other improper payments in connection with government business; never seeking or using a competitor's proprietary information or protected contractor bid or proposal information or nonpublic government source-selection information; accurately representing our products, pricing, and certifications; following the specific rules that apply to recruiting or hiring current or former government personnel; and promptly reporting to Cognition potential violations of these requirements or known overpayments relating to the Vendor's work for Cognition, and making any disclosures or repayments to the government required by applicable law or contract requirements. Contact the Legal team before acting if you are unsure.

Anti-Bribery and Anti-Corruption Policy

Purpose and Scope

This policy outlines the commitment of Cognition to conduct all business activities with integrity, ethics, and in compliance with all applicable laws. It applies to all directors, officers, employees, and contractors, as well as Vendors, agents, and other third parties acting on Cognition's behalf (collectively, “Representatives”) worldwide. The policy strictly prohibits bribery and corruption in any form, whether directly or through intermediaries.

Policy Statement

Cognition prohibits any form of bribery and corruption. This includes, but is not limited to, offering, promising, giving, or accepting any undue pecuniary or other advantage to or from any person or entity. This policy extends to all business dealings and transactions in all countries where Cognition operates.

Compliance with Laws

Representatives must comply with all applicable anti-bribery and anti-corruption laws, including, but not limited to, the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and any local laws in the countries where Cognition operates.

Prohibited Conduct

Representatives are strictly prohibited from:

Offering, giving, or promising to give anything of value, including gifts, hospitality, or expenses, to any public official or private sector employee to influence their actions.
Soliciting, accepting, or agreeing to receive anything of value in return for favorable treatment.
Making facilitation payments, which are small, unofficial payments made to secure or expedite routine government actions.
Engaging in any form of laundering of proceeds of crime.

Gifts and Hospitality

Gifts, hospitality, and expenses should be modest, reasonable, and given in the ordinary course of business. No gift or hospitality should be offered or accepted if it could influence or appear to influence the impartiality of the recipient.

Reporting and Whistleblowing

Representatives are encouraged to report any suspicious activities or breaches of this policy confidentially. Cognition ensures that no individual will suffer any detrimental treatment as a result of reporting in good faith.

Enforcement and Sanctions

Violations of this policy will result in disciplinary action, up to and including termination of employment or contractual relations, and may also have legal consequences.

Review and Monitoring

Cognition will review and monitor the effectiveness of this policy and make necessary improvements to ensure its objectives are achieved.

This policy reflects Cognition's commitment to operating with integrity and compliance with all applicable laws and standards. By adhering to this policy, Cognition and its Representatives uphold their reputation for ethical business practices and contribute to the fight against corruption.

Policy Compliance

Compliance Measurement

The Legal team will verify compliance with this Code through appropriate methods.

Exceptions

Any exception to this Code must be approved by the Legal team in writing.

Non-Compliance

Any Vendor who violates this Code may be subject to suspension or termination of its business relationship with Cognition, in addition to any civil or criminal liability.

Competing Fairly

All Representatives must follow the antitrust/competition laws that apply wherever Cognition does business. These laws prohibit agreements or understandings — even informal ones — that unfairly restrain trade. If any of the following come up in a conversation with a competitor, end the conversation immediately and report it to Legal:

Price fixing — agreeing with a competitor on prices or pricing terms.
Bid rigging — agreeing in advance who will win a bid.
Market or customer allocation — agreeing with a competitor to divide up customers, territories, or markets.
Boycotts — agreeing with a competitor to avoid a particular customer or Vendor.

Waivers

Waivers of this Code may be granted on executive and legal consideration.

Employee Code of Conduct

Purpose

Who must follow the Code?

We expect all employees to know and follow the Code. Failure to do so can result in disciplinary action, up to and including termination of employment. We also expect our contractors, consultants, and others who may be temporarily assigned to perform work or services for Cognition to follow the Code when they work with us. Failure of a Cognition contractor, consultant, or other service provider to follow the Code can result in termination of their relationship with Cognition.

Who to ask about the Code?

If you have a question or concern about the Code, be proactive and contact your manager. You can also submit a question or raise a concern regarding a suspected violation of our Code (or any other Cognition policy) to your manager, or contact legal@cognition.ai.

No Retaliation

Speak Up — Reporting Concerns

If you see or suspect conduct that violates this Code, our policies, or the law, speak up. You can raise a concern with your manager, any member of management, HR, or the Legal team at legal@cognition.ai. You may also report a concern confidentially — and anonymously where permitted by law — through our reporting channel at ethics@cognition.ai. Cognition takes all good-faith reports seriously, will handle them as confidentially as possible consistent with conducting a fair investigation, and prohibits retaliation against anyone who reports a concern or participates in an investigation in good faith.

Duty to Report

Reporting is not optional. Every employee has an affirmative duty to promptly report any known or suspected violation of this Code, Cognition policy, or applicable law, and to cooperate fully and honestly in any investigation. Failing to report a violation you are aware of, or providing false or incomplete information during an investigation, is itself a violation of this Code and may result in disciplinary action, up to and including termination of employment.

Code of Conduct

As a Cognition employee, you're expected to be honest, act ethically, and demonstrate integrity in all situations. You have a duty to follow policies and procedures found in this Code of Conduct, as well as those that are specific to your job. You must also comply with all laws that apply to our business. Most of the time, common sense and good judgment provide excellent guideposts. If you're unsure about the right thing to do, ask someone on the management team.

Before You Act, Ask Yourself:

Is this the right thing to do?
Is it legal?
Do I have the authority to act?
Does the action comply with the Code of Conduct and policies and procedures?
If this action became public, how would it look in the news media?
Would I be upset or embarrassed if other people found out about this action?

If your answer to any of these questions raises doubts, talk with your supervisor, anyone in management, or a member of the Legal team. If you're a supervisor or a manager, you're responsible for knowing the rules and reviewing the Code of Conduct with the people who report to you to make sure they're familiar with its contents. You're also responsible for preventing violations of the Code, as well as detecting violations that may occur and reporting them appropriately.

You're Expected to:

Lead with integrity.
Encourage employees to ask questions and expand their knowledge of the rules.
Demonstrate integrity by acting promptly and effectively when necessary.
Educate employees on compliance policies specific to their job responsibilities.

Quality Work Environment

We are committed to a supportive work environment, where our employees have the opportunity to reach their fullest potential. Members of our Cognition team are expected to do their utmost to create a workplace culture that is free of harassment, intimidation, bias, and unlawful discrimination.

Equal Opportunity Employment

Employment at Cognition is based solely upon individual merit and qualifications directly related to professional competence. We strictly prohibit unlawful discrimination or harassment on the basis of race, color, religion, veteran status, national origin, ancestry, pregnancy status, sex, gender identity or expression, age, marital status, mental or physical disability, medical condition, sexual orientation, or any other characteristics protected by law. We also make reasonable accommodations to meet our obligations under laws protecting the rights of the disabled.

Harassment, Discrimination, and Bullying

Cognition strictly prohibits discrimination, harassment, and bullying in any form – verbal, physical, or visual. If you believe that you've been bullied or harassed by anyone at Cognition, or anyone connected to Cognition (such as a partner or vendor), please immediately report the incident to your manager or the HR team. HR will promptly and thoroughly investigate any complaints and take appropriate action.

Drugs and Alcohol

Substance abuse is incompatible with the health and safety of our employees, and we don't permit it. Consumption of alcohol is allowed at our offices and at work-related events on certain occasions, but we ask everyone to use good judgment and never drink in a way that: (i) leads to impaired performance or inappropriate behavior, (ii) endangers the safety of others, or (iii) violates the law. Illegal drugs in our offices or at work-related events are strictly prohibited.

Safe Workplace

We are committed to a violence-free work environment. We will not tolerate any level of violence or the threat of violence in the workplace. No one should bring a weapon to work under any circumstances. If you become aware of a violation of this policy, report it to a member of senior management immediately.

Avoid Conflicts of Interest

As Cognition employees, we should avoid conflicts of interest and circumstances that reasonably present the appearance of a conflict of interest (whether directly or indirectly).

Here Is List of Areas Where Conflicts of Interest Often Arise:

Personal investments (e.g. with competitors)
Outside employment, advisory roles, and board seats
Business opportunities found through your work at Cognition
Inventions influenced by your work at Cognition
Business opportunities involving friends and relatives
Acceptance of gifts, entertainment, and other business courtesies
A financial or personal relationship with a Vendor that could influence, or appear to influence, a hiring, procurement, or contracting decision

Financial interests.Holding a significant or controlling financial interest in a Cognition competitor, customer, or Vendor — whether held by you or a member of your household or immediate family — requires advance disclosure to, and approval from, your manager and Legal.

If you are unsure if there is a conflict of interest, contact the Legal team to discuss.

Preserve Confidentiality

Throughout its lifecycle, all nonpublic information that is processed, transmitted, and/ or stored by Cognition must be protected in a manner that is consistent with our contractual and legal requirements and reasonable and appropriate for the level of sensitivity, value, and risk associated with Nonpublic information (please see the Data Classification Policy). Information that contains data elements from multiple classifications must be protected at the highest level of information represented. For example, a document that contains Nonpublic and Public information must be treated as Nonpublic information. Nonpublic information must be secured against disclosure, modification, and access by unauthorized individuals. Therefore, the information must be:

Secured at rest;
Secured in transit; and
Securely destroyed in accordance with record retention policies and procedures.

Data Privacy and Personal Data

In addition to protecting Cognition's confidential information, you must safeguard personal data — information that identifies or relates to an individual, such as employees, candidates, customers, and their end users. Collect, use, share, and retain personal data only for legitimate business purposes, only as permitted by applicable privacy and data protection laws (such as the GDPR and CCPA/CPRA) and our agreements, and only with appropriate safeguards. Access personal data only when you have a genuine business need. Report any actual or suspected loss, unauthorized access, or other privacy or security incident promptly to the Legal team so that Cognition can meet its notification obligations. When in doubt about how personal data may be handled, contact the Legal team before acting.

Information Security

You're responsible for using Cognition's computer resources properly – especially with regard to information security – and you need to be thoroughly familiar with Cognition's Information Security policies and procedures.

These Steps Can Go a Long Way in Preventing Unauthorized Access:

Never share your login information.
Lock your workstation when you step away.
Log off your workstation when you leave for the day.
Clear your workstation, waste can, printers and fax machines of sensitive information, such as PII or company-sensitive information.

Responsible Use of AI

As an AI company, Cognition holds itself to a high standard for how artificial intelligence is built and used. You must develop, deploy, and use AI systems — including our own products and any third-party AI tools — responsibly, lawfully, and consistent with Cognition's policies and our customer commitments. Do not use AI tools in a way that exposes Cognition or customer confidential information, personal data, or source code to unauthorized parties or unapproved services, and do not use customer data to train or improve models except as permitted by the applicable agreement. Be alert to accuracy, bias, safety, and security risks in AI output, keep a human accountable for consequential decisions, and raise any concern about potential misuse to the Legal team.

Protect Cognition's Assets

Intellectual Property

Cognition's intellectual property rights (e.g. patents, trademarks, copyrights, trade secrets, and “know-how”) are valuable assets. Unauthorized use can lead to their loss or serious loss of value. You must comply with all intellectual property laws, including laws governing the fair use of copyrights and trademarks. You must never use Cognition's trademarks or other protected information or property for any business or commercial venture without pre-clearance from the Marketing team. Report any suspected misuse of trademarks or other Cognition intellectual property to the Legal team.

Likewise, respect the intellectual property rights of others. Inappropriate use of others' intellectual property may expose Cognition and you to criminal and civil fines and penalties. Seek advice from the Legal team before you solicit, accept, or use proprietary information from individuals outside the company or allow them to obtain access to Cognition proprietary information. You should also check with the Legal team if developing a product feature that uses content not belonging to Cognition.

Company Equipment

Cognition gives us the tools and equipment that we need to do our jobs effectively, but counts on us to be responsible and not wasteful. Uncertain whether personal use of company assets is okay? Ask your manager.

User Device Travel Policy

User devices (e.g., laptops, cell phones) with access to Cognition's FedRAMP environment are strictly prohibited from entering any country specified in 22 CFR 126.1 and any of the following countries or regions: Belarus, People's Republic of China, Cuba, Hong Kong, Iran, Democratic Republic of (North) Korea, Kazakhstan, Macau, Russian Federation, Syria, Venezuela, Saudi Arabia, Taiwan, and Ukraine.

The Network

Cognition's network, software, and computing hardware are a critical aspect of our company's physical property and intellectual property. Follow all security policies diligently. If you have any reason to believe that our network security has been violated – for example, you lose your laptop or think that your network password may have been compromised – promptly report the incident to your manager.

Physical Security

Bad actors may steal company assets. Always secure your laptop, important equipment, and your personal belongings, even while on company premises. Promptly report any suspicious activity to your manager.

Ensure Financial Integrity and Responsibility

Financial integrity and fiscal responsibility are core aspects of corporate professionalism. Each person at Cognition has a role in making sure that money is appropriately spent, our financial records are complete and accurate, and internal controls are honored. This is applicable every time that we hire a new vendor, expense something to Cognition, or sign a new business contract.

It's important that we also keep records for an appropriate length of time. Contractual obligations may sometimes specify longer retention periods for certain types of records. In addition, if you are asked by the Legal team to retain records relevant to a litigation, audit, or investigation, do so until Legal tells you that retention is no longer necessary. If you have any questions regarding the correct length of time to retain a record, contact the Legal team.

Company Policy on Prohibition of Slavery, Child Labor, Sex Trafficking, and Human Rights Violations

This policy outlines Cognition's unwavering commitment to conduct business in a manner that respects and promotes human rights and dignity. It explicitly prohibits any form of collaboration or involvement, whether directly or indirectly, with companies, organizations, or activities associated with slavery, child labor, sex trafficking, or any human rights violations.

This policy applies to all employees, contractors, suppliers, partners, and any other entities associated with Cognition, across all operations globally.

Cognition strictly prohibits:

Engaging in, supporting, or condoning slavery, child labor, or sex trafficking in any part of our operations or supply chain.
Working with any company or organization that is known or found to be involved in slavery, child labor, sex trafficking, or significant human rights violations.

Obey the Law

Cognition takes its responsibilities to comply with laws very seriously. Every employee is expected to comply with applicable legal requirements and restrictions. You should understand the laws and regulations that apply to your work. Contact the Legal team if you have any questions.

Anti-Bribery and Anti-Corruption Policy

Purpose and Scope

Policy Statement

Compliance with Laws

Prohibited Conduct

Representatives are strictly prohibited from:

Offering, giving, or promising to give anything of value, including gifts, hospitality, or expenses, to any public official or private sector employee to influence their actions.
Soliciting, accepting, or agreeing to receive anything of value in return for favorable treatment.
Making facilitation payments, which are small, unofficial payments made to secure or expedite routine government actions.
Engaging in any form of laundering of proceeds of crime.

Gifts and Hospitality

Reporting and Whistleblowing

Enforcement and Sanctions

Violations of this policy will result in disciplinary action, up to and including termination of employment or contractual relations, and may also have legal consequences.

Review and Monitoring

Cognition will review and monitor the effectiveness of this policy and make necessary improvements to ensure its objectives are achieved.

Policy Compliance

Compliance Measurement

The Legal team will verify compliance with this Code through appropriate methods.

Exceptions

Any exception to this Code must be approved by the Legal team in writing.

Non-Compliance

Any employee who violates this Code may be subject to disciplinary action, up to and including termination of employment in addition to any civil and criminal liability.

Competing Fairly

Price fixing — agreeing with a competitor on prices or pricing terms.
Bid rigging — agreeing in advance who will win a bid.
Market or customer allocation — agreeing with a competitor to divide up customers, territories, or markets.
Boycotts — agreeing with a competitor to avoid a particular customer or Vendor.

Material Nonpublic Information About Customers and Partners

Through our work, you may learn material nonpublic information about our customers, partners, and other companies — for example, unannounced products, financial results, acquisitions, or other developments. Although Cognition is a private company and its own shares are not publicly traded, many of the companies we work with are public. It is illegal to buy or sell the securities of any company while in possession of material nonpublic information about it, or to pass that information to others (so-called ‘tipping’) so they can trade. Do not trade in, or recommend trading in, the securities of a customer, partner, or other company based on information you learn through your work at Cognition, and do not share such information outside the company. Contact the Legal team if you are unsure whether information is material or nonpublic.

Fair Dealing

Cognition is committed to being honest and truthful with its customers, Vendors, and other business partners. Never misrepresent the quality, features, or availability of Cognition's products, and never use illegal or unethical means to win business. If you receive another company's confidential or proprietary information by mistake, do not use it — return or destroy it and contact Legal.

Political Activities

You may participate in the political activities of your choice on your own time. Be clear that your participation reflects your own views, not Cognition's. Cognition will not reimburse personal political contributions, and Company time, funds, or resources may not be used for personal political activity. If your role involves lobbying on Cognition's behalf, you must do so in compliance with applicable law.

External Communications

Social Media

The internet is a public place — act accordingly. Protect Cognition's confidential and proprietary information; do not discuss legal matters, trade secrets, or unpublished business plans online; if you identify yourself as a Cognition employee when discussing the company or its products, make clear that your views are your own; and remember that anything posted online can persist indefinitely.

Speaking Engagements

If you are invited to speak or present publicly on Cognition's behalf, notify the appropriate manager or officerbefore accepting, and have the appropriate parties review any materials in advance. Confirm that any travel or accommodation offered in connection with the event fits within the gift and hospitality rules.

Waivers

Waivers of this Code may be granted on executive and legal consideration.