ExtraHop Networks, Inc.
Supplier Anti-Bribery and Anti-Corruption Policy
ExtraHop Networks, Inc. (“ExtraHop,” “we” or “us”) does not tolerate bribery or corruption in any form. Suppliers and those acting on their behalf may not offer, promise, authorize, recommend, give or receive, directly or indirectly, anything of value to any person or entity if it is intended, or could reasonably appear as intended, to influence improper action, obtain or retain business, or secure an improper advantage for ExtraHop.
For purposes of this Policy, “Supplier” (or “you”) means an individual or entity that provides us services and/or goods, that provides services and/or goods to others on our behalf or that has a business partnership with us. “Supplier Personnel” means any director, employee, agent, affiliate, contractor, subcontractor or any other individual or entity engaged by or acting on behalf of Supplier in conducting any and all business activities with us or on our behalf. Any reference to Supplier includes all Supplier Personnel.
We expect Suppliers to support ExtraHop’s compliance with applicable anti-corruption laws and policies. We also expect Suppliers to uphold these same values in their business.
General Directives
ExtraHop requires compliance with all relevant anti-corruption laws including, but not limited to, the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act. Accordingly, ExtraHop prohibits Supplier or anyone acting on behalf of the Company, directly or indirectly, from making or receiving improper payments.
“Improper payments” means receiving or paying bribes or kickbacks or giving, offering, or promising to give money or anything else of value to any person, including any government official, in order to improperly influence any act or decision of a person or to otherwise gain an improper benefit for the company.
A “government official” may include, but is not limited to, any officer or employee of a foreign government, a public international organization, a member of a political party, a candidate for foreign political office, any foreign government department or agency thereof, or any official or employee of a state-owned business enterprise.
The use of ExtraHop funds or assets for any illegal, improper, or unethical purpose is strictly prohibited.
Never Engage in Bribery
Never offer, pay or receive a bribe or kickback. Do not give, offer, authorize or promise to give money or anything else of value to any person – including any government official – in order to improperly influence any act or decision or to otherwise gain an improper benefit. Comply with all relevant anti-corruption laws. These may include the United States Foreign Corrupt Practices Act (FCPA) and the United Kingdom Bribery Act. Report bribery to ExtraHop, even if the attempted bribe was not successful.
Compliance
Supplier and Supplier Personnel must comply with this Policy. Supplier is responsible for ensuring that third parties with whom it interacts fully understand and follow the Policy and associated procedures in their activities related to ExtraHop business.
Supplier shall have its own written anti-bribery and anti-corruption policies, maintain these and enforce them with the intent to avoid breaches of national and international, cross-border anti-bribery and anti-corruption laws. Supplier’s policies shall include an annual review of the same with its personnel. Where requested by ExtraHop, Supplier shall respond to reasonable inquiries regarding these guidelines. ExtraHop at its discretion, may periodically require Suppliers to execute and deliver certifications attesting to Suppliers’ continued compliance with applicable anti-corruption laws, the provisions of this Policy and other contractual terms relating to anti-corruption compliance.
Supplier shall ensure that all Supplier Personnel who provide services or supply goods in connection with any agreement between Supplier and ExtraHop will be subject to binding obligations to comply with anti-corruption laws, whether via a written agreement or otherwise.
Supplier must conduct risk-based integrity due diligence on individuals or entities it engages who may interact with government officials in connection with their business relationship with ExtraHop. Supplier must also require such third parties to comply with anti-corruption principles equivalent to those contained in this Policy.
Cooperation
Supplier must cooperate fully with ExtraHop at its own expense in connection with any internal or government-led investigation, review into their compliance with this Policy or any potential bribery or corruption issues relating to its supply or performance of services for ExtraHop, including by appointing a representative with sufficient seniority and authority to respond to requests.
Training
Supplier must provide appropriate training to Supplier Personnel, and conduct sufficient monitoring of their activities, to secure their compliance with this Policy. If Supplier needs assistance with such training, ExtraHop may be able to assist. Supplier must distribute this Policy to all Supplier Personnel who work on ExtraHop matters.
Policy Violations
Any Supplier who violates this policy in connection with ExtraHop business will be subject to disciplinary measures, up to and including restriction or termination of business relations, suspension of the making or reimbursement of any payments and, where appropriate, referral of the matter to relevant law enforcement authorities. Supplier’s violation of this Policy is deemed a material and uncurable breach of its contract with ExtraHop.
Reporting Violations
Any Supplier or Supplier Personnel who has information or belief that this Policy or related procedures may have been violated, or believes that they are being asked to pay a bribe or receive a bribe or otherwise act in contravention of this Policy, shall immediately report the event directly to ExtraHop Legal using the information below. All reports are treated as confidentially as possible. It helps with follow-up if you identify yourself. If you are not comfortable identifying yourself, you can make anonymous reports to the extent allowed by law.
To report violations or solicitations, contact ExtraHop Legal at:
legal@extrahop.com
or
ExtraHop Networks, Inc., Attention: Legal Department, 520 Pike Street, Suite 1600, Seattle, WA 98101, United States
ExtraHop undertakes to promptly investigate reports and to pursue reasonable and appropriate action to remediate any violations substantiated by an investigation.
Whistleblowing
ExtraHop does not allow retaliation for reports of misconduct by others made in good faith. Supplier shall have policies and procedures in place to support Supplier Personnel raising genuine concerns about legal or ethical issues. Whistleblowers shall be provided with all requisite support, including anonymity if requested and shall not be subject to harassment or retribution.
Nothing in this Policy grants or is intended to grant any additional rights or remedies to any Supplier or in any way limits any of ExtraHop’s contractual or legal rights or remedies. ExtraHop may modify this Policy at any time in its sole discretion consistent with applicable law and effective upon posting.
Last updated March, 2023.