KnowBe4 Code of Ethical Business Conduct

We take significant efforts to protect data and confidential information against unauthorized use, modification, loss, compromise, destruction, or disclosure of, or access to, such data (“Security Incident”). We have implemented measures, policies and procedures intended for the detection and response to Security Incidents. Such measures take into consideration the nature, scope, context, and purposes of KnowBe4’s data handling policies, practices and procedures.

For more information about our data protection and security practices, see the links below (or other such links that we may provide from time to time on our website - www.knowbe4.com).

knowbe4.com/legal

knowbe4.com/privacy-policy

knowbe4.com/security

Conflicts of Interest

We will declare potential conflicts of interest. We avoid situations where personal interests may interfere with the business interests of KnowBe4. We act in the best interest of KnowBe4 and do not allow outside interests to interfere with our obligations to KnowBe4. Perception matters: we must not only avoid actual and potential conflicts of interest, but also situations where an outsider might assume a conflict. Examples of conflicts of interest may include: transactions with family members, interests in other businesses, gifts or gratuities and personal use of KnowBe4 assets.

Similarly, we do not use our positions or relationship with KnowBe4’s current or potential customers, partners, vendors, suppliers, consultants, or any other party that has a relationship with KnowBe4 for personal gain or to obtain benefits for family members.

Evaluating whether a conflict of interest exists can be difficult and may involve a number of considerations. Before engaging in the activity or accepting something of value, we will obtain the required approvals. Our Conflict of Interest Policy has additional details on our approach to potential conflicts of interest.

Corporate Opportunities

Except as otherwise set forth in KnowBe4’s certificate of incorporation and bylaws, we owe a duty to KnowBe4 to advance KnowBe4’s business interests when the opportunity to do so arises. We are prohibited from taking, or directing to a third party to take, a business opportunity that is discovered through the use of corporate property, information or position, unless KnowBe4 has already been offered the opportunity and turned it down. We are further prohibited from competing with KnowBe4 directly or indirectly during our employment with KnowBe4 and as otherwise provided in any written agreement with KnowBe4.

Fair Dealings

We do not seek competitive advantages through illegal or unethical business practices. We deal fairly with KnowBe4’s customers, service providers, suppliers, competitors, business partners and employees, and do not take unfair advantage of anyone through manipulation, concealment, or any unfair dealing practice.

2. We Strive to Be the Best Place to Work

We foster a culture of fun teamwork, transparency and career growth. We continuously develop the abilities of our employees, and evaluate performance objectively. We show mutual respect as we collaborate across cultures.

Teamwork requires open communication. To strengthen the collaborative nature of our workplace, we offer an open (no door) workplace and foster an environment where everyone feels encouraged to express their ideas and opinions.

Safe and Positive Work Environment

To ensure that we maintain our great work environment, discrimination, harassment, retaliation, and/or violence in any form are strictly forbidden. We treat all colleagues in a respectful manner, forging working relationships that are uniformly free of bias and prejudice.

We comply with applicable national, federal, state, and local laws forbidding discrimination in employment based on protected characteristics, such as on the basis of race, color, religion (including religious dress and grooming practices), age, national origin, ancestry, ethnicity, sex (including pregnancy, childbirth, breastfeeding or related medical conditions), gender (including gender identity, gender expression, transgender status or sexual stereotypes), sexual orientation, marital or family care status, status as a victim of domestic violence, sexual assault or stalking, military/veteran status, physical or mental disability, medical information (including genetic information or characteristics, including those of a family member), immigration status or citizenship status, political affiliation or membership in any other group protected by national, federal, state, or local law as it may vary by jurisdiction. We also comply with applicable national, federal, state, and local laws forbidding retaliation against individuals who engage in protected activity.

No individual will suffer any reprisals or retaliation for making complaints or reporting any incidents of discrimination or perceived discrimination, or for participating in any investigation of incidents of discrimination or perceived discrimination.

We are committed to maintaining a respectful workplace. This includes a working environment that is free from unlawful harassment based on protected characteristics, including sexual harassment. This applies to all work-related settings and activities, whether inside or outside the workplace, and includes business trips and business-related social events.

Human Rights

We conduct our business with respect for human dignity. We support and stand behind the Universal Declaration of Human Rights and comply with all applicable laws, rules and regulations related to anti-human trafficking, anti-slavery, anti-forced labor, and child labor. Equal and inalienable rights of all members of the human family is the foundation of freedom, justice and peace in the world. We believe in the promotion of universal respect for and observance of human rights and fundamental freedoms afforded to everyone. All human beings should be treated with decency, kindness and respect.

Ecological Environment

We understand the importance of implementing sustainable business practices to ensure the world that we are leaving for the next generation is a better one. Our overarching goals are to reduce our carbon footprint, reduce the amount of waste we send to landfills, and increase our use of clean energy. We seek to incorporate sustainability into all aspects of our operations and aim to reach our goals through a combination of energy conservation, waste reduction, environmental stewardship, employee engagement, community engagement, and external partnerships.

Our resolve is to not only fulfill our environmental commitments but to inspire collective action within our workforce, fostering a culture of sustainability that extends beyond our corporate objectives.

Paying it Forward

Our commitment to corporate responsibility extends to creating a meaningful and positive influence within our community. We embrace a holistic approach, acknowledging our responsibility toward our employees, the environment, and the broader community we serve.

We take pride in forging strong alliances with esteemed organizations in our community. Such partnerships reflect our unwavering dedication to social stewardship and engagement. Through these initiatives, we reinforce our pledge to serve and uplift our community, fostering a culture of generosity and purpose within KnowBe4.

Continuous Learning and Professional Development

We are dedicated to promoting an environment where continuous learning and professional development are not only supported but actively encouraged. By investing in the growth of our employees, we are investing in the future of our company.

By sustaining a workplace culture that values continuous learning and professional development (we encourage a minimum 5 hours a week), we not only enhance our employees' job satisfaction and career prospects but also bolster our company's innovative and competitive edge.

We are committed to providing our employees with ample resources and support to engage in professional development activities. This encompasses obtaining professional certifications that align with our organizational goals. In doing so, we lay a foundation of ethical behavior underscoring the principle that a well-informed and educated workforce is key to fair, transparent, and honorable business practices.

Physical Security and Safety

We are dedicated to the security and safety of all our employees and physical premises. Our physical security team thrives to create a distraction free environment where employees can dedicate their time and energy to achieving the goals set for their production.

We achieve these objectives by implementing and monitoring various security tools and protocols at our physical premises. We also conduct regular risk assessments to identify, evaluate and address potential vulnerabilities, threats and impacts to our workplace, employees, data, assets, and operations.

3. We Protect KnowBe4’s Assets

Knowsters must work together to protect and prevent misuse of our assets from loss, misuse, theft, embezzlement, damage or destruction at all times. Our assets should be used solely for the benefit of KnowBe4 and never to promote an employee’s own interests or those of another person or company. In addition to observing our physical and protective security measures, any improper downloading, copying or sharing of our assets is strictly prohibited and may result in the loss of its value and be deemed a misappropriation of our assets, which include both KnowBe4’s proprietary and confidential information.

KnowBe4’s proprietary information refers to information owned by the company that gives KnowBe4 a competitive advantage. Proprietary information includes our intellectual property (IP) and may come in the form of patents, copyrights, trademarks, specialized know-how, designs, software code, or unique processes. This information is considered an asset of the company and is often legally protected through intellectual property laws.

KnowBe4’s confidential information generally includes any nonpublic information we wish to keep secret that might be of use to competitors or others, or that might be harmful to KnowBe4 or third parties that entrust their confidential information to us, if disclosed. This may include a wide variety of information such as trade secrets, business plans, financial records, contracts, customer lists, and other data that, if disclosed, would harm KnowBe4’s competitiveness or operations. Confidential information may only be shared with people who need to know the information for business purposes and who are bound by obligations of confidentiality.

We must never allow unauthorized access to these assets. We must take care not to lose, misplace, or leave any assets (or technologies containing such information, including computers, laptops, cell phones, mobile devices and software) unattended. Any theft, loss or unauthorized disclosure of KnowBe4’s assets must be reported immediately in accordance with our policies.

4. Financial Reports and Other Records – Disclosure

We are responsible for the accurate and complete reporting of financial and operating information and for the timely notification to management of financial and non-financial information that may be material to KnowBe4 to ensure full, fair, accurate, timely and understandable disclosure in reports and documents that KnowBe4 files with government agencies or releases to the general public.

We have familiarized ourselves with the disclosure requirements applicable to KnowBe4 and the business and financial operations of KnowBe4, and will not knowingly misrepresent, or cause others to misrepresent, facts about KnowBe4 to others, whether within or outside KnowBe4, including to KnowBe4’s independent auditors, governmental regulators and self-regulatory organizations.

We maintain all of KnowBe4’s books, records, accounts and financial statements in reasonable detail, and reflect the matters to which they relate accurately, fairly and completely. Furthermore, we will ensure that all books, records, accounts and financial statements conform both to applicable legal requirements and to KnowBe4’s system of internal controls. We carefully and properly account for all assets of KnowBe4. We will not establish any undisclosed or unrecorded account or fund for any purpose. We will not make any false or misleading entries in KnowBe4’s books or records for any reason, or disburse any corporate funds or other corporate property without adequate supporting documentation and authorization. We will not misclassify transactions related to accounts, business units or accounting periods. We bear responsibility for ensuring that we are not party to a false or misleading accounting entry. We cooperate with all requests made to preserve or produce any documents, records, information, devices, computers, hardware, cell phones or other media. If a legal hold is placed on certain records, we must preserve and protect those records in accordance with instructions from the Legal Department. Records or supporting documents that are subject to a legal hold must not be destroyed, altered or modified under any circumstance. A legal hold remains effective until it is officially released in writing by the Legal Department.