Resideo Technologies : Code of Business Conduct

Published: 2025-02-25 17:08:11 ET REZI

RESIDEO CODE OF BUSINESS CONDUCT

RESIDEO'S COMMITMENT TO INTEGRITY

At Resideo, we have the tremendous privilege of simplifying the connected world so people can have peace of mind and focus on what matters most. We have earned a presence in 150 million homes globally, and with that trust comes

a responsibility to act with the highest levels of integrity. We strive to live our Values -- Start with the Customer, Act As One Team, Pioneer the Future, and Make a Difference. These Values, along with our Code of Business Conduct, set the standard for ethical business practices across our company. We cannot and will not compromise on integrity and compliance at Resideo because, at the end of the day, we want to create a rewarding, respectful, and ethical brand for our customers and employees.

You will see that the Code includes guidelines for appropriate interactions and communications with our customers, fellow employees and other stakeholders, as well as our fundamental rules for doing business. The Code also represents our unwavering commitment to always act ethically and in compliance with the law.

We encourage you to speak up if you have a question about whether conduct is ethical or if you observe behavior that concerns you, even if you are not certain that a violation has occurred. All stakeholders are encouraged to escalate issues, concerns, and questions so we can resolve potential compliance issues early.

Please take some time to familiarize yourself with the Code and our company Values and reach out to our Integrity and Compliance function if you have questions, concerns, or suggestions about anything covered in the Code.

Our success depends on our ability to deliver best-in-class products and services, and outstanding financial performance, while operating from a strong foundation of integrity. It is up to each employee to live this Code every day at Resideo.

TABLE OF CONTENTS

INTRODUCTION TO OUR CODE

Why Have a Code?

What's Expected

A Manager's Role

When to Speak Up

What Does Resideo Do with Reports?

Will Resideo Protect Me if I Speak Up?

HOW WE TREAT ONE ANOTHER

Dignity and Respect, Always

Protecting Personal Data

Keep Facilities Free of Substance Abuse

Keep Facilities Free of Violence

Promoting a Safe and Healthy Workplace

ACT IN THE BEST INTERESTS OF RESIDEO

Avoid Conflicts of Interest

PROTECTING COMPANY INFORMATION AND PROPERTY 13

Keep Confidential and Proprietary Information Safe

Protect Company Resources

Protect and Respect IP Rights

Use Resideo IT Systems Responsibly

Use Social Media and Networks Responsibly No Insider Trading and Tipping

CONDUCTING BUSINESS GLOBALLY

Be Open and Honest

No Bribes or Corrupt Activities Compete Fiercely, But Fairly Market Truthfully Compliance Across Borders

Combatting Trafficking in Persons and Child Labor Don't Participate in Unsanctioned Boycotts Political Activity and Contact with Government

Officials Must Comply With All Laws

PROTECT OUR SHAREHOLDERS' INTERESTS

Keep Honest, Accurate Records

Let Lawyers Handle Legal Proceedings and Investigations

Let the Communications Team Handle Media Inquiries Community Support

Actively Protect the Environment

Build Strong Partnerships with Suppliers

HELP WITH QUESTIONS OR CONCERNS

Don't Hesitate to Reach Out

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01INTRODUCTION TO OUR CODE

WHY HAVE A CODE?

Integrity and Compliance are central to everything we do here at Resideo. Acting with the highest standards of ethical conduct is essential to creating and maintaining trust between the company and its employees, customers, shareholders and suppliers. We recognize that we cannot achieve our business objectives and continue to be invited into customer homes, nor can we show that we are invested in our people, unless we operate from an unwavering foundation of integrity and compliance. We created the Code to provide our employees with an overview of the Company's expectations for acting with the highest ethical standards and in compliance with the law.

Code of Business Conduct | 4

WHAT'S EXPECTED

We expect our employees to adhere to both the letter and spirit of this Code. You will learn more as you read through it, but the key takeaways are that when you are acting on Resideo's behalf, we expect you to:

Resideo operates in many countries around the world and local customs and social standards often differ from place to place. We expect our employees to follow national and local laws and regulations unless these violate U.S. law. When you have questions about which law to follow, aren't sure if a certain law applies to you, or have concerns that a local custom may be inconsistent with Resideo's Code, we expect you to seek help from the Integrity and Compliance Team.

A MANAGER'S ROLE

Our managers, supervisors, and leaders should serve as role models for ethical business conduct. The bigger the role an employee occupies, the more we expect of them when it comes to modeling the right behavior and promoting compliance with our values and policies. We expect our managers to drive our culture of integrity, including:

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WHEN TO SPEAK UP

WHAT DOES RESIDEO DO

WITH REPORTS?

We encourage you to speak up if you have a question about whether conduct is ethical or if you observe behavior that concerns you, even if you are not certain that a violation has occurred. All employees are encouraged to escalate issues, concerns and questions so we can resolve potential compliance issues early.

Many avenues are available to our employees to raise concerns, including:

•1 via an email to [email protected]

The helpline provides employees with a resource to seek advice, ask questions or report issues, including those related to fraud, business practices and compliance or suspected violations of our Code. The helpline is available 24 hours a day, 7 days a week.

Employees who choose to use the helpline - administered by a well-regarded independent vendor - have the option to remain anonymous (as permitted under applicable law). The helpline is available in English or in local languages where Resideo has operations. If you choose to identify yourself when contacting the helpline, your identity and the information you provide will be treated confidentially to the greatest extent possible and will only be shared on a "need-to-know" basis. For additional information, please review the policy on Raising or Reporting an Integrity or Compliance Concern.

Resideo takes all reports of possible misconduct seriously and will investigate them. We ask that you report concerns as promptly as possible to ensure a thorough investigation and timely resolution.

During the investigation process, Resideo will:

Employees who become involved in an integrity investi- gation, should cooperate fully and answer all questions completely and honestly. Interference with an integrity investigation is itself an integrity violation.

¹The list of Helpline phone numbers for international locations is available in the policy on Raising or Reporting an Integrity or Compliance Concern and on the Integrity & Compliance page of the Resideo intranet.

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WILL RESIDEO PROTECT

ME IF I SPEAK UP?

Yes. Resideo strictly prohibits retaliation against anyone who raises a good faith concern about Resideo's business practices. Our Integrity and Compliance Program will not succeed unless employees trust they can raise concerns and ask questions without fear of retaliation. Resideo will act swiftly against retaliatory behavior. Any individual who feels that they have been the victim of actual or threatened retaliation should immediately notify Human Resources or the Integrity and Compliance Team for help.

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DIGNITY AND RESPECT, ALWAYS

We believe our diverse, talented global workforce is the key to our success. Resideo does not discriminate against employees, applicants or anyone else with whom it does business. We also want all our employees to feel comfortable coming to work each day and believe that harassment is toxic to a productive and pleasant work environment.

Our prohibition of discrimination and harassment applies to all the characteristics protected by law, including but not limited to, discrimination or harassment based on the employee's race, color, gender, religion, national origin, age, marital status, citizenship status, political belief, disability, pregnancy, military service, veteran status, sexual orientation, gender identity, genetic information or medical condition.

02HOW WE TREAT ONE ANOTHER

Some examples of prohibited conduct are:

•

verbal: repeated unwanted requests for dates, sexual

innuendoes, racial or sexual epithets, derogatory slurs,

foul or obscene language, off-color jokes, questions

about another's sexual experiences, or suggestive or

PROTECTING PERSONAL DATA

insulting remarks or sounds

•

visual/non-verbal: inappropriate written materials

(including email and online content), racially or

sexually derogatory posters, cartoons or drawings,

suggestive objects or pictures, leering, or obscene

gestures

•

physical: interference or assault ranging from

intentionally blocking someone's way to unwanted

physical contact (for example, touching or rubbing

someone)

•

other: making or threatening reprisals because of a

negative response to harassment

We encourage our employees to speak up whenever they witness or suspect discrimination or harassment. Additional guidance can be found in Resideo's Global Workplace Harassment Policy.

All Personally Identifiable Information ("PII") that Resideo maintains about its employees, customers, prospects, vendors, or partners will be collected and used only for its intended and lawful purpose and with the appropriate notice to and consent of the individual, as required by local law. PII will be kept up-to-date, accurate and secure, and will not be kept for longer than is necessary. PII maintained by Resideo will not be transferred to other employees unless they have a legitimate business need for that information and transfers to third parties will comply with our policies. We maintain detailed policies which govern how PII should be used and secured. See Employee Privacy Notice (Data Practices). Any misuse or security breach involving PII must be reported immediately via the established incident management process, the helpline or directly to Resideo's Privacy Team (see https://resideoinc.sharepoint.com/ teams/privacy for more information).

Special care will be taken with respect to sensitive personal or financial information maintained by the company, including social security or tax ID numbers, bank account numbers, credit/debit card numbers, driver's license information, maiden names, racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union memberships, sexual life, criminal activity, physical and mental health-related information or any information that can be used to access a person's financial resources. Employees must consult with Resideo's Privacy Team

if they wish to use or collect sensitive information in the course of their job in a way that has not been previously reviewed and approved by the Privacy Team.

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KEEP FACILITIES FREE

OF SUBSTANCE ABUSE

Resideo wants to provide a safe workplace for all its employees. Substance abuse, in all forms, increases the risk of injury, illness and even death occurring in the workplace. For this reason, Resideo strictly prohibits employees from working under the influence of alcohol or illegal drugs as well as misused legal drugs and over-the- counter medications. Alcohol may be used in moderation at an authorized company event. If you suspect a co-worker is under the influence while at work, please report the issue.

PROMOTING A SAFE AND HEALTHY WORKPLACE

We are committed to providing a safe workplace by integrating safety into our daily business decisions and eliminating hazards in a proactive manner. We have established procedures and processes that are designed to make our workplace healthier and safer. If you believe that an unsafe or unhealthy condition exists in any Resideo facility, you should stop working and immediately report your concern to the Health and Safety Team.

KEEP FACILITIES

FREE OF VIOLENCE

Resideo will not tolerate violence or threats of violence. We are counting on all our employees to promptly report any concerns they have about workplace violence or the threat of such violence to the Health and Safety Team or Human Resources. We expect employees to help keep our facilities secure by ensuring that only authorized individuals have access to our workplace. If you have concerns that an unauthorized person is in a Resideo facility, please promptly notify your manager or a member of the Health and Safety Team. If you believe there is immediate danger, you should contact local law enforcement. Please also see our policy on Safety and Security at Work.

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Disclaimer

Resideo Technologies Inc. published this content on February 25, 2025, and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on February 25, 2025 at 22:07:30.962.