Code of Conduct

Last updated: August 4, 2026

Introduction

This page summarizes the Code of Conduct that Scalr, Inc. ("Scalr") maintains internally and requires all staff to follow. It applies to full-time employees, part-time employees, and contractors at every seniority level, in all business settings: at the office, while working remotely, at conferences and industry events, and in communications with customers, partners, and the public on Scalr's behalf.

Workplace Standards

Scalr is committed to a friendly, safe, and welcoming environment for all staff, regardless of race, ethnicity, national origin, color, immigration status, social and economic class, educational level, sexual orientation, gender identity and expression, age, size, family status, political belief, religion (or lack thereof), and mental and physical ability.

All Scalr staff are expected to:

• Exercise consideration and respect in speech and actions at all times
• Attempt collaboration before conflict
• Refrain from demeaning, discriminatory, or harassing behavior and speech
• Alert Scalr leadership to dangerous situations, people in distress, or violations of this Code, even when they seem inconsequential

Harassment and Discrimination

Scalr does not tolerate harassment or discrimination in any form. Unacceptable behavior includes, without limitation: violence or threats of violence; discriminatory jokes and language; posting or displaying sexually explicit or violent material; publishing others' personally identifying information ("doxing"); personal insults; inappropriate photography, recording, or physical contact; unwelcome sexual attention; deliberate intimidation or stalking; and advocating for or encouraging any of the above.

Ethics and Business Conduct

Scalr conducts business with honesty and integrity and in full compliance with applicable law. All staff must:

• Avoid conflicts of interest. Staff must disclose in writing any personal interest, outside activity, or relationship that interferes with, or could reasonably appear to interfere with, acting in Scalr's best interest, before any related business decision is made.
• Refuse bribery and corruption in all forms. Neither Scalr staff nor any third party acting on Scalr's behalf may offer, promise, give, request, or accept bribes, kickbacks, facilitation payments, or any other improper advantage, whether the counterparty is a government official or a private party. Scalr complies with the U.S. Foreign Corrupt Practices Act, the UK Bribery Act, and equivalent anti-corruption laws in every jurisdiction in which it operates.
• Keep gifts and hospitality modest. Business gifts and entertainment must be reasonable in value, infrequent, customary for the context, and unrelated to any pending business decision. Cash and cash equivalents may never be given or accepted. Gifts above internal thresholds, and anything involving government officials, require prior written approval.
• Maintain accurate books and records. All payments and benefits exchanged with third parties must be accurately recorded. Off-book accounts, false invoices, and misleading expense entries are prohibited.
• Protect material non-public information. Staff may not trade securities of any company while in possession of material non-public information about it, disclose such information to others who might trade on it, or use it for any purpose other than performing their role at Scalr. This obligation continues after employment ends.

Reporting and Non-Retaliation

Staff who are subject to or witness unacceptable behavior are expected to notify Scalr leadership as soon as possible. Retaliation against anyone who reports a concern in good faith, or who participates in an investigation, is itself a violation of this Code. Third parties can raise concerns about the conduct of Scalr staff by contacting [email protected].

Enforcement

Anyone asked to stop unacceptable behavior is expected to comply immediately. Violations of this Code result in disciplinary action proportionate to the violation, up to and including termination and, where appropriate, referral to law enforcement.

About This Document

This page is a summary of Scalr's internal Code of Conduct policy, which contains additional procedural detail and is maintained as part of Scalr's compliance program.