Fivetran Code of Business Conduct and Ethics

·Fivetran Code of Business Conduct and Ethics

·Last updated: October 30, 2025

·Message from the Founders

·Fivetranners,

·Our values are central to everything we do - they represent who we are at our best. From how we operate internally, to how we collaborate with and serve our customers, our core values are the principles guiding our decisions. Fivetran is a global community where each of us depends on every one of us to do the right thing, daily. We are committed to building a transparent, diverse, and ethical workplace where everyone feels welcome and supported.

·This Code provides us with the resources and information we need to operate with high ethical standards and keep our values at the forefront of our decision-making. Included are the guiding principles for our business and the commitments we make to each other and those we do business with. You are expected to read the Code carefully and in its entirety; and have it serve as a frequent reference guide to making the right decisions at Fivetran.

·While many times doing "the right thing" is clear, there are other times where the right course of action is less clear. If you are uncertain about how to proceed in any situation, we encourage you to speak up and reach out to your supervisor, the People team, our Legal Ethics and Compliance Team, or the Fivetran Hotline via AllVoices.

·We work with integrity, we go above and beyond for each other and our customers, and we move the needle forward every day. Thank you for everything you do, for getting stuck in and embodying the 1 Team, 1 Dream mentality as we continue to scale and execute at the highest possible level. George Fraser - Founder, CEO Taylor Brown - Founder, COO

·Our Mission and Values

·Our mission is to fuel insights, power progress, and change lives by making access to data as simple and reliable as electricity. The invention of the lightbulb spawned generations to change the world through electricity, creating millions of new products, devices, and services. At Fivetran, we empower future "Thomas Edisons" to transform the way the world makes decisions through our always-on access to accurate data. This helps drive better data-driven decisions in pursuits like discovering new drugs, serving humanity in ways big and small, and enabling organizations to do what they do best by improving lives everywhere.

·Our core values make us who we are. At Fivetran, we are committed to achieving the highest standards of professionalism and ethical conduct and upholding our values no matter how much we grow, or how fast. We share the pains and successes of our customers, partners, and Team Members. We seek, gather, and trust a diverse group of Team Members with different perspectives to guide our progress. We get after it, work hard, and follow through on everything we do. We take initiative and ownership and are accountable for getting things done.

·Fivetran belongs to all of us. As a team, we share a common commitment to our mission and values. When representing Fivetran, you are responsible for living our mission and demonstrating our values through your actions and interactions every day. We do the right thing at Fivetran and have the highest standards of integrity in everything we do.

·Our Global Code of Business Conduct and Ethics ("Code"), is grounded in our mission and values. We must always act ethically and with integrity. This means that we respect the law, our policies, our fellow Team Members, and everyone with whom we interact. As you act on Fivetran's behalf, always ask yourself if the actions that you are taking are consistent with our mission and values and with the standards set in this Code.

·Our Responsibilities

·Our Code applies to all directors, officers, employees, contingent workers, employees providing service via a professional employer organization, and agents acting for or on behalf of Fivetran (collectively, "Team Members"). Every Team Member is responsible for following the Code, our policies and applicable laws and regulations. This means:

• ·Reading, understanding, and certifying your commitment to following the principles set forth in our Code, policies, and applicable laws and regulations;
• ·Seeking guidance through the appropriate channels when questions arise;
• ·Educating yourself about Fivetran's policies and procedures;
• ·Completing all required trainings;
• ·Avoiding actions that are inconsistent with our mission and values, unethical, unlawful, or may lead to an appearance of impropriety, or harm to Fivetran's reputation; and
• ·Reporting suspected or known unethical or unlawful behavior through the channels described below.

·Violations of this Code, Fivetran policies, or applicable laws and regulations may be subject to disciplinary action, up to and including termination of employment or contract.

·Responsibilities of Managers

·Team Members in supervisory roles have a special responsibility to maintain and promote a culture of compliance by clearly communicating Fivetran's expectations and values for appropriate and ethical conduct. Managers are expected to model Fivetran's mission and values when interacting with others and promote the values within their teams and workplace. Managers must also promote our inclusive work environment where Team Members feel comfortable speaking their minds, asking questions, and raising concerns without fear of retaliation. Any concerns or potential violations of this Code, Fivetran's policies, or applicable laws and regulations must be promptly escalated through the Speak Up Resources described below.

·Raising Questions and Reporting Concerns or Potential Violations

·Team Members who have questions about compliance with our Code, or become aware of any concerns or potential violations of our Code or other policies, or applicable laws and regulations, should speak up using any of the following Speak Up Resources: Our Managers The Legal Ethics and Compliance Team Any Human Resources Business Partner Fivetran Legal Fivetran's Hotline via AllVoices

·Team Members have the option of reporting anonymously using Fivetran's Hotline via AllVoices.

·Any Manager who is aware of conduct inconsistent with this Code or who receives a report of conduct that is inconsistent with this Code must report it immediately to the Legal Ethics and Compliance Team or one of Fivetran's Speak Up Resources. Managers must never independently investigate concerns or potential violations. Managers should consider questions or concerns raised by Team Members as a necessary and encouraged form of business communication that helps Fivetran identify and address potential areas of continuous improvement.

·Investigating Reports

·Fivetran takes all reports seriously. We conduct timely, thorough, and impartial investigations of reported concerns or potential violations of our Code or other company policies. We treat all reports confidentially consistent with legal and business requirements. Information will be shared on a need-to-know basis only with those involved in investigating and resolving reported issues.

·Full cooperation is essential for a successful investigation. This includes providing truthful and complete information when requested. Team Members must never engage in independent fact-finding or interfere in an investigation in any way, including by altering or destroying evidence.

·Fivetran is committed to taking appropriate action based on investigation findings. This may involve internal measures or reporting to external authorities as required by law.

·Fivetran encourages Team Members to report any potential or known misconduct using one of our Speak Up resources. Team Members also have the right to report misconduct to government agencies, and our Code does not restrict those rights.

·Non-Retaliation

·Fivetran does not tolerate retaliation against Team Members who, in good faith, raise concerns or ask questions, make reports, participate in an investigation, refuse to participate in suspected improper or wrongful activity, or exercises workplace rights protected by law. If you witness retaliation or believe you have been retaliated against, please report your concerns immediately. For additional information see Fivetran's Anti-Retaliation and Reporting Policy.

·Legal Compliance

·Fivetran is committed to conducting business lawfully and with integrity. Fivetran strives to comply with applicable laws, regulations, and standards governing business conduct, including restrictions on who we can do business with, how we conduct business, and where we can operate. Team Members are required to adhere to this expectation globally while interacting with fellow Team Members, customers, partners, and other third parties.

·Anti-Bribery and Anti-Corruption

·At Fivetran, we strive to do the right thing, including conducting business honestly and fairly. We are committed to complying with applicable laws and regulations related to anti-bribery and anti-corruption. We do not offer, give, or pay bribes, kickbacks, or anything of value, nor do we accept them. Likewise, we do not authorize our partners or other third parties to offer, give, or accept bribes or kickbacks on our behalf.

·We take particular care when entering into relationships with government officials or entities, whether directly or through our partners or other third parties. We must never offer, authorize, or provide anything of value to obtain an improper business advantage or influence a government official. We require all third parties working on our behalf to also comply with applicable anti-corruption laws. Additional information can be found in our Global Anti-Bribery and Anti-Corruption Policy.

·Fair Competition

·We succeed because we compete fairly and honestly, not through unethical practices. To compete fairly in the marketplace, we must comply with the antitrust and competition laws everywhere we do business. We do not discuss our pricing strategy, terms, or marketing plans with our competitors, including at trade association meetings or in informal settings. We avoid all agreements, understandings, and plans with competitors that limit or restrict competition, such as price fixing or allocation of markets. Taking unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair dealing practice is prohibited. Team Members must not misrepresent the quality, features, or availability of our products, nor do anything illegal or unethical to win business.

·If anyone tries to engage you on these topics or if you inadvertently receive another company's confidential or proprietary information, stop the conversation immediately, delete the information that was not intended for you and report the incident to the Legal Ethics and Compliance Team.

·Global Trade Compliance and Anti-Money Laundering

·Fivetran is committed to conducting business in compliance with all applicable trade sanctions, export and import controls, and anti-money laundering laws and regulations that may limit where, how, and to whom we can send, sell or receive products, services and information.

·Fivetran prohibits the procurement of goods or services from and sale of goods or services to any individuals or entities or in territories subject to trade embargoes or economic sanctions. In addition, Fivetran maintains processes and protections to help us remain compliant. For additional information, please refer to our Global Trade Compliance and Anti-Money Laundering Policy.

·Financial Integrity and Recordkeeping

·Maintaining complete and accurate records and reporting of information is critical to ensuring Fivetran can operate a successful business by making appropriate and responsible business decisions in accordance with the law. Team Members must follow Fivetran's recordkeeping and document retention requirements set forth in our Global Record Retention Policy, as well as our financial processes. Fivetran expects that Team Members provide accurate, complete, and appropriately authorized information in our business systems and during financial reviews in accordance with generally accepted accounting principles and in conformity with applicable legal requirements.

·This means that Team Members must never intentionally evade or undermine our processes, whether by altering or falsifying documents, misleading or failing to provide accurate information to Finance, Legal, or company-designated auditors, refusing to cooperate in company audits or investigations, or creating records or communications of any kind that mischaracterize or conceal the truth.

·In addition, Fivetran prohibits the creation of or participation in unofficial or secret funds, making off-the-books payments, side deal agreements or similar improper financial practices, and any requests by a Team Member or third party to do so should be immediately reported to the Legal Ethics and Compliance Team.

·Representing Fivetran

·Our customers and partners trust us to act lawfully, ethically, and with integrity. We make business decisions based on our core values and what is in the best interest of Fivetran and not based on any competing personal, social, or financial interests, and we expect those who work with us to do the same.

·Conflicts of Interest

·As Team Members, we are expected to act in the best interests of Fivetran. This means avoiding situations where your interests conflict, could potentially conflict, or even simply appear to conflict with Fivetran's. Conflicts may exist even when it appears as though Fivetran is or may be benefiting from the situation.

·Because they relate to our business and company interests, Fivetran requires that Team Members disclose any personal, social, or financial interests that fall under the following categories of Conflicts of Interest:

• 1Company Transactions. Any situation where you are in a position to influence a company transaction and the transaction may result in a personal gain to you, your spouse, sibling, parent, in-law, child, a member of your household, or a close personal friend (a "Related Party").
• 2Employment Decisions. Any situation where you are in a position to make or influence an employment decision involving a Related Party; a Related Party is under consideration for a position that you supervise or direct; or you are a manager and you develop a romantic relationship with an employee.
• 3Activities Outside Fivetran. Any situation where outside activities conflict or interfere, or have the potential to conflict or interfere, with your responsibilities to Fivetran including devoting your time to the performance of your job responsibilities and to Fivetran's interests during regular working hours; work for others in a field similar to or in competition with Fivertan; use of Fivetran assets or labor, or proprietary or confidential information for personal gain; and creation or contribution to any intellectual property that is similar to or competes with Fivetran's products or services.

·Fivetran requires Team Members to submit a Conflicts of Interest Disclosure via a Workday Help Case for all personal, social, or financial interests that conflict, could potentially conflict, or even simply appear to conflict with Fivetran's interests and receive approval prior to engaging in the activity. Proper disclosure enables you and Fivetran to proactively safeguard the interests of all parties involved. Meals, Gifts, and Entertainment

·Giving and accepting meals, gifts, and entertainment can help you build and maintain good working relationships with our customers, partners, other third parties, and Team Members. But the exchange of meals, gifts, and entertainment that are excessive, frequent, used to influence or create obligations, or lack a legitimate business purpose can expose Fivetran to legal or reputational risk, as they may create a conflict of interest, improperly influence business decisions, or impair Fivetran's ability to compete openly and fairly.

·Team Members are expected to give and accept only meals, gifts, and entertainment that are reasonable and professional, and comply with our Global Meals, Gifts, and Entertainment and Travel and Expense Policies.

·External Communications and Social Media

·To ensure accuracy, consistency, and compliance with our policies, all external communications on behalf of Fivetran must be conducted by expressly authorized and trained Team Members only. This includes, but is not limited to, responses to inquiries, interactions with the media, public statements, regulatory disclosures, and legal communications.

·If you are approached by a member of the media, or any external party seeking information about Fivetran, please direct the inquiry to Public Relations or Legal to help identify the appropriate authorized team.

·Fivetran recognizes that social media can be a fun and rewarding way to share your life and opinions with family, friends, co-workers, and network around the world. When posting to social media, you should use the same principles and guidelines found in Fivetran policies, including being respectful, honest and accurate. Remember that what you publish externally could reflect on the entire organization. Use your best judgment and exercise personal responsibility when posting online. Any content that Team Members post on social media which could reasonably be viewed as being connected to your employment with Fivetran, or which could impact other Team Members, must be consistent with our mission and values and your obligations under this Code.

·Trust and Safety with Data, Information, and Property

·At Fivetran, trust and safety are foundational to how we do business. We are committed to protecting confidential information, respecting intellectual property, and ensuring data is accessed and used responsibly. Every Team Member is expected to maintain the integrity and security of our data, information, and property.

·Safeguarding Proprietary Information

·We do not disclose non-public, proprietary, or confidential information, including trademarks, patents, copyrights, trade secrets, intellectual property, financial information, business plans and strategies, pricing data, operating processes, sales goals, marketing plans, information about suppliers, contracts, customers, or any other information that by its nature we should know is not public information ("Proprietary Information"). Unless information is made publicly available, Team Members should assume that it is confidential and prevent unauthorized access and use. All Team Members are responsible for properly handling and protecting any non-public or confidential information, including Fivetran's Proprietary Information, from loss or disclosure. Fivetran's records and information are valuable assets and are identified, maintained, and safeguarded as an essential part of the operation of our business. All Proprietary Information created or learned by you during the course of your employment with Fivetran belongs to Fivetran, and your obligation to protect this information continues after your employment ends.

·Similarly, Team Members are prohibited from bringing any Proprietary Information from prior employers to Fivetran, and are expected to abide by any agreements or obligations owed to prior employers. We also protect Proprietary Information in our possession that belongs to customers, partners, competitors, and other third parties. Team Members must follow the terms of our written agreements with all third parties when using their confidential information.

·Using and Protecting Company Assets

·In addition, we must protect Fivetran's physical assets from loss, damage, misuse, theft, waste, and abuse. This includes our everyday business assets, such as telephones, computers, office supplies, furniture, equipment, and company credit cards. All physical assets provided by Fivetran, whether used inside or outside the workplace, are company property and provided for your business use. Personal use of Fivetran's assets, including technology or information resources, should be incidental and should never interfere with your or others' job performance. Any personal use of Fivetran's assets must be consistent with this Code, other Fivetran policies, and the law.

·Team Members should review and be familiar with Fivetran's Information Security and Acceptable Use Policy and Global Employee and Applicant Privacy Notice. If you see suspicious network activity or emails, or suspect that Fivetran assets are being used improperly, contact the Information Security Team or report to one of our Speak Up Resources.

·Data Privacy

·We respect the privacy of our Team Members, partners, and customers, and we must properly safeguard all confidential or personally identifiable information entrusted to us. When we collect, store, or transfer personal information, we must abide by all applicable legal requirements, and Team Members are required to follow Fivetran's internal privacy policies. This includes confidential and personal information disclosed by both our Team Members and our customers and partners, such as identification information, physical and email addresses, communications records, and employment records. Accessing, using, or sharing business, customer, or personnel data is strictly prohibited without a legitimate business purpose and in a manner consistent with the performance of your responsibilities to Fivetran.

·As Team Members, you are expected to abide by the expectations for accessing and handling People Data, as outlined in the People Data Access Policy. If a Team Member has access to personal data of our team members, whether because of their job or as a manager, it is their responsibility to treat it as confidential and access it only for legitimate business purposes. Team Members may not access, use, or disclose personal data of our Team Members for personal use or gain, or any unauthorized purpose.

·Our Community

·We view our community of Fivetranners as our greatest strength. We strive to create a diverse and inclusive work environment where Team Members can learn and grow through authenticity and open communication. We also strive to support local, national, and global efforts through our partners, customers, and community engagement to foster those same values.

·Equal Employment Opportunity

·Employment decisions are based on merit, business needs, and other valid job requirements and are free from discrimination based on any characteristic protected by applicable local law, such as race, color, religion, sex, national origin, age, disability, and genetic information. Fivetran also makes reasonable accommodations for qualified applicants and Team Members with disabilities and for religious practices in accordance with applicable law. For further information, consult our Global Employee Handbook, regional Handbooks, and specific policies applicable to you.

·Safe Workplace, Anti-Harassment and Discrimination

·Fivetran is committed to a respectful work environment free of harassment, discrimination, abusive conduct, and retaliation, including based on legally protected characteristics. This policy applies to all work-related settings and activities, inside or outside Fivetran offices, including business trips and social events.

·Conduct that may foster a disrespectful, intimidating, degrading, discriminatory or hostile work environment is strictly prohibited, including but not limited to unwelcome sexual advances, slurs, inappropriate remarks or jokes, or other conduct that interferes with an employee's work performance. Such conduct is prohibited both of or by Team Members, and of or by non-Fivetran personnel.

·If you experience, witness, or hear about a concern or potential violation of Fivetran's Anti-Harassment, Discrimination, Abusive Conduct, and Retaliation Policies, you are expected to report the conduct so Fivetran may promptly, effectively, thoroughly, and objectively investigate. Concerns may be reported to any of our Speak Up Resources. Managers are required to immediately escalate concerns of harassment, discrimination, abusive conduct, or retaliation to the People Team or one of Fivetran's Speak Up resources.

·For further information, consult our Global Employee Handbook, as well as all applicable regional Handbooks and Policies.

·Human Rights and Fair Labor Practices

·Fivetran firmly believes in treating everyone with dignity, fairness, and respect. We comply with labor and employment standards, laws, rules, regulations, and policies everywhere we operate, and all individuals and organizations that work with Fivetran must do the same. Fivetran does not permit use of forced labor or human trafficking - and expects all third parties with whom we do business to uphold the same ethical standards. Fivetran's position on Modern Slavery can be found in our Modern Slavery Act Statement.

·Diversity, Equity, Inclusion and Belonging

·Fivetran is committed to fostering a diverse, equitable, and inclusive workplace where every Team Member is valued and respected. We believe that the collective strength of our individual differences, experiences, and talents helps us build a world-class company to better serve our customers, partners, Team Members, and communities.

·Charitable and Political Activities

·Fivetran encourages Team Members to participate in their communities through charitable and/or political activities. All such activities must comply with the law and be done on Team Members' own time with their own resources, and as an individual private citizen and not as a representative of Fivetran, unless Fivetran is hosting or organizing the activity. Team Members may not utilize Fivetran's resources to support charitable or political activities unless explicitly authorized in writing to do so by the Legal Ethics and Compliance Team and Finance Team.

·Environment

·Safeguarding and preserving our environment for future generations is important to Fivetran, and we are continually striving to conduct our business in an environmentally responsible manner. Team Members are encouraged to consider the environmental impacts of their actions and those of the vendors they employ and to take efforts to reduce their footprints when completing work for Fivetran. Need help? legal@fivetran.com

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