Extreme : Code of Business Conduct and Ethics Policy (Extreme Code of Business Conduct and Ethics 2025 external)

Published: 2025-07-02 21:29:04 ET EXTR

Published on 07/02/2025 at 21:29

Amended February 12, 2025

At Extreme Networks, Inc., we are committed to conducting our business affairs honestly and in an ethical manner. That goal cannot be achieved unless each of us accepts responsibility to promote integrity and demonstrate the highest level of ethical conduct in all of our activities. Activities that may adversely impact our reputation for integrity should be avoided. The key to achieving our business goal and complying with this Code of Business Conduct and Ethics (the "Code") is exercising good judgment. This Code was adopted to encourage:

Honest and ethical conduct, including fair dealing and the ethical handling of actual or apparent conflicts of interest;

Full, fair, accurate, timely and understandable disclosure;

Compliance with applicable governmental laws, rules and regulations;

Prompt internal reporting of any violations of law or the Code;

Accountability for adherence to the Code, including fair process by which to determine violations;

Consistent enforcement of the Code, including clear and objective standards for compliance;

Protection for persons reporting any such questionable behavior;

The protection of the Company's legitimate business interests, including its assets

and corporate opportunities; and

Confidentiality of information entrusted to directors, officers and employees by the Company and its customers.

This Code applies to all employees (including those employed by professional employment organizations), officers, and members of the Board of Directors (collectively, the "Directors") of Extreme Networks, Inc. and its subsidiaries and branches in all locations (collectively the "Company" or "Extreme Networks"). The parties to whom the Code applies are collectively referred to as the Covered Parties. The Code is based on the Company's core values, good business practices and compliance with applicable law.

Managers set an example for other employees and are often responsible for directing the actions of others. Each manager and supervisor is expected to take necessary actions to ensure compliance with this Code, to provide guidance and assist employees in resolving questions concerning the Code and to permit employees to express any concerns regarding compliance with this Code. No one has the authority to order another employee to act contrary to this Code.

A key prerequisite to conducting business in an ethical and legal manner is to hire the best employees who share this goal and practice it. To this end, the Company will exercise due diligence when hiring and promoting employees. Where legally permitted, the Company will make reasonable inquiries into the background of each individual who is a candidate for such a position. All such inquiries will be made in accordance with applicable law and good business practice.

All Covered Parties are expected to become familiar with and understand the requirements of the Code. Most importantly, each of us must comply with the Code, and support others in their efforts to comply with it as well.

The Company's Chief Executive Officer ("CEO") is responsible for ensuring that the Code is established and effectively communicated to the Covered Parties. Although the day-to-day compliance issues will be the responsibility of the Company's managers, the CEO has ultimate accountability with respect to the overall implementation of and successful compliance with the Code.

The Company will ensure that the Covered Parties have access to the Code on the Company's website and will provide periodic training on the Code to employees and officers.

Extreme Networks is committed to full compliance with the laws and regulations of all jurisdictions in which it operates. Numerous laws and regulations define and establish obligations with which the Company, our employees and agents must comply.

If you violate laws or regulations in performing your duties for the Company, you not only risk individual indictment, prosecution and penalties, in addition to civil actions and penalties from the local authorities, you may also subject the Company to risks and penalties. If you violate laws or regulations in performing your duties for the Company, you may also be subject to immediate disciplinary action, including possible termination of your employment with the Company, as permitted by applicable laws.

Each of us is responsible for ensuring that Extreme Networks and its agents, channel partners, distributors and resellers (collectively, our "Resellers") complies with applicable trade regulations, including U.S. export controls, which are intended to control foreign distribution of

U.S. origin technology to prevent unauthorized access. Under no circumstance should a Covered Party or Reseller engage in marketing, service or sales of Extreme Networks products or technology to embargoed or prohibited countries, end users or uses, or allow products to be exported without proper export documentation or a license when required.

In addition, when importing products, employees must obey the import requirements of any applicable U.S. or foreign government agencies. All questions and inquiries regarding the identity, value or duty due on imported products must be answered truthfully and completely.

Extreme Networks requires its employees to fully comply with the U.S. Foreign Corrupt Practices Act ("FCPA"), the U.K. Bribery Act, as well as all other applicable anti-corruption laws everywhere we do business. Covered Parties, as well as our Resellers, are prohibited from making, offering, authorizing or promising any payment of any money, or offer, gift, promise to give, or authorize the giving of anything of value to any Public Official for the purpose of influencing or inducing that official to affect any government act or decision or to assist the Company in obtaining or retaining business or any other unfair or improper advantage. For the purposes of this Code, "Public Official" includes anyone with any affiliation to a government department, agency, or instrumentality, at any level, including:

Government employees (at any level, whether national, provincial or local);

Directors, officers and employees (regardless of position or level) of entities owned or controlled by, or affiliated with, a foreign government (e.g., state owned enterprises, public universities, public hospitals);

Members of public international organizations;

Members of the military or royal families;

Candidates for political office;

Political party officials;

Anyone acting on behalf of any of the above, such as lobbyists or advisors; and

Journalists of state-owned or controlled media.

The anti-corruption laws prohibit not only improper payments of money (for example, a payment to a Public Official to obtain an operating license, a tax incentive or exemption, or a regulatory change), but also excessive hospitality in the form of lavish gifts, entertainment, travel, accommodations or dining for the purpose of influencing or inducing a benefit from a Public Official. This policy extends to indirect payments made through agents and includes the use of personal funds. Company Directors, officers, and employees are prohibited from doing through a third-party intermediary that which they are prohibited from doing directly. The FCPA prohibits giving anything of value, directly or indirectly, to officials of foreign governments or foreign political candidates to obtain or retain business. It is strictly prohibited to make illegal payments to government officials of any country.

Extreme Networks also requires that books and records accurately report all payments made by or on behalf of the Company.

The FCPA and other similar laws carry both civil and criminal penalties for noncompliance. Additional guidance regarding compliance with anti-corruption laws is set forth in Extreme Networks' Global Anti-Corruption Compliance Policy.

You may not give or offer or promise to give any excessive entertainment or gifts other than of nominal value to any person or organization to attract or retain business. All decisions

regarding the investing of our assets or the purchasing of goods and services must be made on the basis of applicable investment or acquisition criteria, and in a way that preserves Extreme Networks' integrity. Business-connected gifts, entertainment, meals, hospitality, travel, or other favors may not be extended to any party, including intermediaries, clients or suppliers (current or prospective), unless they:

have a lawful business purpose;

are kept to a reasonable value;

are not intended to improperly influence acts or decisions;

are appropriate to the business relationship and local custom;

are legal in both your country and the country of the recipient;

do not violate the standards of conduct of the recipient's organization or any contractual agreement with a customer;

are properly documented; and

where necessary, proper approval is obtained prior to giving any gift, entertainment, or hospitality.

For any gifts, entertainment, or hospitality for Public Officials or commercial customers with whom Extreme Networks does business under U.S. federally funded contracts, you must obtain advance written approval by Extreme Networks' Legal Department and your manager if the value of such payment, gift, entertainment, or hospitality exceeds USD$20 for a single gift or USD$50 per year (or less, if applicable law has a lower limit). For more information and further details regarding permissible gifts, entertainment and hospitality, please see Extreme Networks' Global Anti-Corruption Compliance Policy.

To avoid even the implication of impropriety, you should also decline any gift, favor, entertainment or anything else of value from current or prospective intermediaries, clients, suppliers or contractors or their representatives except for:

Gifts that do not have substantial monetary value given at holidays or other special occasions.

Covered Parties may not accept any gifts, entertainment, or hospitality with a fair market value in excess of USD$20 per gift or USD$50 per year from suppliers with whom the Company does business under U.S. federally funded contracts, unless the Company's Legal Department has given advance written approval.

Employees who receive gifts, entertainment, or hospitality with a fair market value in excess of USD$200 must report it to their manager promptly. Executive officers or Directors who receive such gifts must promptly report them to the Chief Legal, Administrative & Sustainability Officer (or the Chief Financial Officer, if the executive officer in question is the Chief Legal, Administrative & Sustainability Officer).

Reasonable entertainment at lunch, dinner or business meetings where the return of the expenditure on a reciprocal basis is likely to occur and would be properly chargeable as a business expense.

Ultimately, you must exercise good business judgment in deciding which situations are unacceptable. If you ever have any doubt as to the acceptability of any entertainment activity, consult with the Extreme Networks' Legal Department or Extreme Networks' Chief Legal, Administrative & Sustainability Officer by sending an email to [email protected].

You should not use the Company's funds for political contributions of any kind to any political candidate or person who holds any government office without prior written approval from the Extreme Networks' Legal Department. "Political contributions" include direct and indirect payments, loans, advances, deposits, or gifts of money, or any service. It also includes subscriptions, memberships, tickets, and the purchase of advertising space, payment of expenses, or compensation of employees for a political organization, candidate, or public official. You may participate in trade associations on behalf of the Company that support our industry through lobbying efforts and politically related activities.

The Company strives to make positive contributions in the communities in which it operates and encourages its employees to do the same. The Company's corporate philanthropy is principally directed to educational, scientific and humanitarian endeavors across the globe. Employees wishing to make contributions in the name of Extreme Networks - whether by financial contributions or volunteer activities - must receive prior written approval from the Extreme Networks' Legal Department. Sometimes, customers or suppliers ask that we make a contribution to a charity or nonprofit organization. Charitable contributions may not be given by the Company or requested by an employee, customer, supplier, Public Official, or other business partner as a condition of or to influence a business decision (no "quid pro quo") or be made for the benefit of any one individual.

All Company disclosures in reports and documents that the Company submits to any government authority, and other public communications made by the Company, must be full, fair, accurate, timely and understandable. You must take all steps available to assist Extreme Networks in its disclosure responsibilities, consistent with your role within the Company. In particular, you are required to provide prompt and accurate answers to all inquiries made to you in connection with the Company's preparation of its public reports and disclosures. The Company's CEO and Chief Financial Officer ("CFO") are responsible for designing, establishing, maintaining, reviewing and evaluating the effectiveness of the Company's disclosure controls and procedures (as such term is defined by applicable SEC rules) on a quarterly basis.

The Company's CEO, CFO, and Corporate Controllers (and such other Company officers designated from time to time by the Audit Committee, collectively, the "Senior Officers") will take all steps necessary or advisable to ensure that all Company disclosures in reports and documents filed with or submitted to the SEC, and all disclosures in other public communication made by the Company, are full, fair, accurate, timely and understandable.

Senior Officers are also responsible for establishing and maintaining adequate internal control over financial reporting to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes, in accordance with generally accepted accounting principles ("GAAP"). The Senior Officers will take all necessary steps to ensure compliance with our system of internal controls and GAAP. For example, Senior Officers will ensure that Extreme Networks makes and keeps books, records, and accounts which accurately and fairly reflect the transactions and dispositions of our assets in reasonable

Disclaimer

Extreme Networks Inc. published this content on July 03, 2025, and is solely responsible for the information contained herein. Distributed via Public Technologies (PUBT), unedited and unaltered, on July 03, 2025 at 01:28 UTC.