Supplier Code of Conduct

1 Introduction and Purpose

Trusted Home Quotes (operated by Yep Ads B.V.) and all of its subsidiaries and affiliates (hereinafter collectively referred to as “Trusted Home Quotes”, “we”, “us”) places great value on integrity and social responsibility — principles that we uphold within our own organization. We expect all Suppliers who provide products and services to us (“Suppliers”) to share in this commitment.

This Supplier Code of Conduct (“Code”) outlines our expectations regarding how Suppliers conduct business. We expect Suppliers to adhere to the Code, comply with all applicable laws and regulations in the regions where they operate, and strive for continuous improvement within the environmental and social domains. Suppliers must also extend similar obligations to their own suppliers, subcontractors, and agents.

2 Scope

We are committed to conducting business in an ethical, legal, and responsible manner. This Code sets out basic requirements on human rights, labor, environment, and business integrity. Trusted Home Quotes, its employees, and shareholders have a duty to comply with applicable laws and regulations and are expected to behave responsibly and ethically.

We expect our Suppliers to work on their corporate social responsibility and comply with the requirements set out in this Code, and to promote these basic requirements actively throughout their supply chain.

This Code is made in accordance with:

• International Labour Organisation (ILO)
• UN Universal Declaration of Human Rights (UDHR)
• UN Global Compact
• UN Conventions on children’s rights and the elimination of all forms of discrimination
• EU Forced Labour Regulation
• OECD Guidelines for Multinational Enterprises

By acknowledging this Code, you confirm your commitment to the social and environmental standards laid down herein and agree to take appropriate measures by securing relevant corporate policies and management systems to ensure the requirements of the Code can be met.

3 Business Integrity and Ethical Practices

Compliance With Applicable Laws

Suppliers must conduct all activities in compliance with applicable international and national laws, rules, and regulations of the jurisdictions in which they operate. This includes laws and regulations relating to environmental, health and safety, ethics, and labor practices. Suppliers must require their own suppliers to follow the same standards.

Competition — Common Forms of Prohibited Conduct

Exchange of Confidential Information
Certain competitive information may be freely used, such as information available in trade publications, obtainable by analysis of marketed products, or disclosed at public meetings. However, it is prohibited to use privately shared information. Prohibited exchanges occur where competing parties engage in discussions that adversely impact competition between them.

Price Fixing and Market Sharing
Price fixing is an agreement among competitors that raises, lowers, or stabilizes prices or competitive terms. Competitors may not agree on raising prices, offering no/more discount, applying minimum prices, or passing on surcharges. Even discussing prices with competitors is forbidden. Market sharing — where competitors agree to divide customers, suppliers, or geographic areas — is equally prohibited.

Abuse of Dominance
Abuse of dominance occurs when a dominant firm substantially prevents or lessens competition by engaging in acts that aim to eliminate or discipline competitors, or to stop potential competitors from entering a market. This includes predatory pricing, tying, unreasonably high prices, and exclusive purchasing. These practices are strictly prohibited.

Corruption and Bribery

Corruption is an umbrella term covering every form of abuse of power for personal gain, including nepotism, trading in influence, and extortion, regardless of whether the recipient or instigator is a public official or a private individual.

Bribery involves prompting someone to act or refrain from acting by offering gifts, services, or hospitality to gain an unfair business advantage. Facilitation payments — small sums paid to low-level public officials for routine actions — are a familiar manifestation of bribery.

• The Supplier shall not engage in or tolerate any form of corruption, bribery, extortion, or embezzlement.
• The Supplier shall not offer or accept any benefits to obtain an undue or improper advantage (including cash, non-monetary gifts, pleasure trips, or services of any nature).
• Gifts may only be given with the permission of Trusted Home Quotes if they are: not intended to influence the recipient; compliant with applicable European Law; not given in the name of an individual; not cash or cash-equivalent; given/received openly; and not offered to a government official, representative, or politician.
• All purchases, sales, and contractual commitments must be based solely on quality, service, price, and efficiency. Only legitimate business reasons should determine whether to enter into a contract and with whom.
• If Suppliers become aware of inside information about Trusted Home Quotes or its clients, they must handle and use that information in line with applicable laws and regulations.
• All business dealings must be transparently performed and accurately reflected in the Supplier’s books and records. Requests for false invoices or unusual, excessive, or inadequately described payments must be rejected and reported. Falsification of records or misrepresentation of conditions in the supply chain is unacceptable.
• Trusted Home Quotes will not make donations to political parties or candidates, and urges Suppliers to adopt similar practices.
• Charitable contributions are permitted but Suppliers must ensure they are not used to facilitate or conceal acts of bribery.

Privacy and Data Security

Trusted Home Quotes is committed to the proper application of the GDPR and other applicable data protection legislation, including fair and transparent processing of data and the protection of data subjects’ rights.

• The Supplier is expected to follow the same approach when dealing with personal data, including data transfers to third countries.
• The Supplier shall comply with all applicable data protection and privacy laws, including but not limited to the GDPR, CCPA/CPRA, CAN-SPAM Act, TCPA, and any applicable U.S. state privacy or telemarketing laws.
• Suppliers engaging in telemarketing, SMS marketing, or call center activities shall obtain and maintain valid prior express written consent where required by applicable law (including under the TCPA), and maintain documented records of consumer consent available upon request.
• The Supplier shall treat any information received from us — including reported data, internal policies, and training documents — as confidential, except where disclosure is required by law or the information has been made publicly available elsewhere.
• The Supplier shall not sell, resell, or reuse consumer lead data obtained through Trusted Home Quotes for any purpose other than fulfilling the specific service request, unless expressly authorized in writing.
• The Supplier is obligated to notify us in the event of an actual or suspected privacy or security breach.

Whistleblower Policy

• The Supplier must promote an environment supportive of open communication, encouraging employees and external stakeholders to come forward with concerns or observations of possible or actual misconduct.
• The Supplier shall ensure accessible, effective reporting channels are available to all employees, contractors, and other stakeholders, enabling confidential reporting of concerns or incidents of misconduct. Where legally permitted or required, anonymous reporting must also be allowed.
• The Supplier is encouraged to establish policies and procedures that protect the confidentiality of both the reporter and the details of the reported issue, and a structured process for reviewing, investigating, and addressing reported concerns or violations.
• The Supplier must have safeguards in place to protect individuals who report misconduct in good faith from retaliation, unfair treatment, harassment, or any negative repercussions.

Supplier Obligations

• The Supplier must not take or appear to take any action that could unfairly exclude or reduce competition in any market.
• The Supplier must not misrepresent, manipulate, or conceal confidential information, engage in disparaging discourse against competitors, or impersonate Trusted Home Quotes or represent themselves as insurance providers, contractors, or licensed professionals unless legally authorized to do so.
• The Supplier must only obtain information about competitors through legal and ethical means.
• The Supplier must not enter Trusted Home Quotes into any business arrangement or cartel conduct to eliminate or discourage competition. Prohibited activities include price fixing, illegal boycotting, bid rigging, cartel conduct, predatory practices, exclusive dealing, misuse of market power, market division agreements, and exchanging confidential information.
• The Supplier must comply with all applicable advertising laws and FTC guidance regarding endorsements, disclosures, and unfair or deceptive acts or practices.

4 Labor Practices and Human Rights

Forced and Child Labor

We expect our Suppliers to respect and protect internationally recognized human rights both in the workplace and in general business practices. All employees working under the Supplier — whether directly or indirectly — shall be treated with honesty, respect, and dignity.

All employment shall be freely chosen. Workers shall be free to leave their employment at any time and shall not be subject to any coercion or restriction.

Any form of exploitation of children or working conditions resembling slavery, or that are harmful to children’s health, are forbidden under ILO and UN Conventions. The Supplier is obligated to protect the rights of young workers. In the event that children are found to be working in situations fitting the definition of child labor, the Supplier shall establish and document policies and procedures for remediation.

Working Conditions

• Working hours must be limited in accordance with national or local law, including breaks. Overtime should be voluntary, should not replace regular employment, and must be fairly compensated.
• The Supplier shall comply with all applicable laws relating to wages and benefits, including minimum wages, overtime pay, equal remuneration, and legally mandated benefits. Suppliers must not use wage deductions as a disciplinary measure and must pay workers in a timely manner.
• The Supplier must acknowledge the freedom and rights of workers to organize themselves in order to promote their interests.
• The Supplier shall ensure a safe and healthy workplace or any other location where work is undertaken, taking adequate precautionary measures to prevent accidents and damage to health.
• All work shall be preceded by documented, adequate risk management with implemented controls, covering physical, social, and organizational health risks.

Discrimination and Harassment

• The Supplier shall treat all workers with respect and dignity.
• The Supplier is obligated to ensure that employees are protected from harsh or inhumane treatment, including violence, gender-based violence, sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying, public shaming, or verbal abuse. The threat of any such treatment is equally prohibited.
• The Supplier shall not engage in or support harassment or discrimination based on race, color, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, protected genetic information, or marital status in hiring and employment practices.

5 Environmental Practices

• We have ambitious goals on environmental sustainability and expect our Suppliers to contribute to these goals.
• The Supplier shall comply with all environmental laws and regulations, including those relating to the use and handling of hazardous waste, whether international or national. In line with applicable legislation, Suppliers shall report transparently on the environmental impact of their activities.
• The Supplier should endeavor to make continuous improvements in environmental performance through practicable measures and employ leading practices where possible.
• The Supplier shall take responsibility by using production techniques that have a minimum negative impact on the environment and shall make maximum efforts to limit the negative impact on biodiversity throughout their chain — including at their own suppliers and partners.
• Suppliers shall make continuous efforts to optimize their business in accordance with circular economy principles, such as reducing the use of virgin raw materials, optimizing product duration, increasing recycling, and minimizing landfill waste.
• We expect the Supplier to measure, manage, and reduce energy usage and Greenhouse Gas (GHG) emissions.

6 Compliance With the Code

• Suppliers should have adequate management systems and controls in place to ensure compliance with this Code or equivalent standards.
• Suppliers are required to promptly report to us any legal violations or violations of this Code or any other Trusted Home Quotes policy. All reports should be sent to: [email protected]
• We may monitor compliance with this Code and may audit the Supplier. When an audit is requested, the Supplier should respond and cooperate promptly.
• In case of a violation of law, we may suspend or terminate the relationship with the Supplier and may disclose the matter to relevant authorities.

✓ Supplier’s Acknowledgement

For questions or to report a concern, contact us at [email protected].