Code of Ethics and Business Conduct

Strive To Do What’s Right

At CobbleStone, we understand that not everything is always black and white. Asking yourself a few of the following key questions can help identify situations that may be unethical, inappropriate, or illegal:

• Does what I am doing comply with CobbleStone’s guiding principles, Code of Conduct, and company policies?
• Have I been asked to misrepresent information or deviate from normal procedures?
• Would I feel comfortable describing my decision at a staff meeting?
• How would it look if it made the headlines?
• Am I being loyal to my family, my company, and myself?
• Is this the right thing to do or do I believe that I will be doing something wrong?

Build Trust and Credibility

The success of our business, our employees, and our customers are dependent on the trust and confidence we earn from our employees, customers, and shareholders. We gain credibility by adhering to our commitments, displaying honesty and integrity, and reaching company goals solely through honorable conduct. It is easy to say what we must do, but the proof is in our actions. Ultimately, we will be judged on what we do and not just on what we say.

When considering any action, it is wise to ask: will this build trust and credibility for CobbleStone? Will it help create a working environment in which CobbleStone can succeed over the long term? Is the commitment I am making one with which I can follow through? The only way we will maximize trust and credibility is by answering “yes” to those questions and by working every day to build our trust and credibility.

Respect for the Individual

We all deserve to work in an environment where we are treated with dignity and respect. CobbleStone is committed to creating such an environment because it brings out the full potential in each of us, which, in turn, contributes directly to our business success. We cannot afford to let anyone’s talents go to waste.

Promote Substance Over Form

At times, we are all faced with decisions we would rather not have to make and issues we would prefer to avoid. Sometimes, we hope that if we avoid confronting a problem, it will simply go away.

At CobbleStone, we must have the courage to tackle the tough decisions and make difficult choices, secure in the knowledge that CobbleStone is committed to doing the right thing. At times this will mean doing more than simply what the law requires. Merely because we can pursue a course of action does not mean that we should do so.

Although CobbleStone’s guiding principles cannot address every issue or provide answers to every dilemma, they can define the spirit in which we intend to do business and should guide us in our daily conduct. If you know about a violation of this Code of Ethics and Business Conduct, you must promptly report it to your director.

Use of Company Resources

Company resources, including time, material, equipment, and information, are provided for company business use, with such use subject to the requirements of the employee handbook and company policies. Nonetheless, occasional personal use is permissible so long as it does not affect job performance or cause a disruption to the workplace or is in violation of company procedures.

Employees and those who represent CobbleStone are trusted to behave responsibly and use good judgment to conserve company resources. Directors and managers are responsible for the resources assigned to their departments and are empowered to resolve issues concerning their proper use. CobbleStone employees may not use insider information for personal gain, and any such improper use of this information may be a serious violation of US security laws.

Generally, we will not use company equipment such as computers, copiers, and fax machines in the conduct of an outside business or in support of any religious, political, or other outside daily activity, except for company-requested support to nonprofit organizations. We will not solicit contributions nor distribute non-work-related materials during work hours.

Accountability

Each of us is responsible for knowing and adhering to the values and standards set forth in this Code and for raising questions if we are uncertain about company policy. If we are concerned whether the standards are being met or are aware of violations of the Code, we must contact our director

CobbleStone takes seriously the standards set forth in this Code, and violations are cause for disciplinary action up to and including possible termination of employment.

Data Centers

CobbleStone selects its primary data centers from providers that have a commitment to environmental initiatives inclusive of Google for its leadership with its net-zero carbon commitment, Microsoft Azure, and Amazon AWS for its sustainability goals.

Recycling, Reduce, and Reuse

Additionally, to do our part with reuse and recycling initiatives, CobbleStone promotes recycling at each of its corporate offices with the goal of contributing to reuse, inclusive of landfill diversion and recycling. To reduce waste and promote reuse, recycled paper products are utilized when possible. In key locations, low flow water faucets are implemented to promote reduction in water waste CobbleStone provides reusable cups to its staff to reduce waste where possible.

Energy Usage Reduction

For energy consumption reduction, CobbleStone has upgraded much of its office lighting to low energy LED lighting has a preference to select electricity providers that has 20% renewal energy standard goals, and purchases Energy-Star appliances for its appliances. CobbleStone has upgraded much of its heating and air conditioning systems to energy efficient equipment to reduce carbon emissions and installed programable thermostats. CobbleStone promotes low energy devices such as laptops and rechargeable batteries to contribute to energy consumption reduction. CobbleStone encourages staff, where possible, to reduce lighting and energy usage during peak energy consumption days by turning off lighting and optimizing indoor temperature.

CobbleStone’s primary source of contribution to carbon emissions is electricity usage at our offices and data centers. For 2024, CobbleStone direct carbon production emitted by electric usage is 8,992.94 CO2e Kg. Google, our primary data center’s carbon report can be found at https://sustainability.google/reports/2021-carbon-free-energy-data-centers/ (third party data centers carbon production is not representative of CobbleStone’s carbon production).

Sustainable Procurement

CobbleStone, when possible, procures from vendors that provide environmentally, socially sourced, conflict free, and recycled materials. When possible, light colored or white roofing materials are selected to offset warming effects of roofing materials and reduce.

Transportation

CobbleStone recognizes that transportation is a large producer of carbon emissions. To help, CobbleStone promotes ridesharing (via mass transportation) with primary offices that are near public transportation routes. For approved positions, work remote is permitted as remote work contributes to reduction in transportation and the carbon emissions associated with transportation.

Leadership

Mark Nastasi, EVP and Cofounder of CobbleStone software, sits on the board of EnvironOne.org and actively participates in clean water, sustainability and environmental initiatives.

Set Tone at the Top

Management has the added responsibility for demonstrating, through their actions, the importance of this Code. In any business, ethical behavior does not simply happen; it is the product of clear and direct communication of behavioral expectations, modeled from the top and demonstrated by example. Again, ultimately, our actions are what matters.

To make our Code work, directors and managers must be responsible for promptly addressing ethical questions or concerns raised by employees and for taking the appropriate steps to deal with such issues. Directors and managers should not consider employees’ ethics concerns as threats or challenges to their authority, but rather as another encouraged form of business communication. At CobbleStone, we want the ethics dialogue to become a natural part of our daily work.

Uphold the Law

Further, each of us must have an understanding of the company policies, laws, rules and regulations that apply to our specific roles. If we are unsure of whether a contemplated action is permitted by law or CobbleStone policy, we should seek the advice from the resource expert. The Legal Team is always available to discuss such questions or concerns. We are responsible for preventing violations of law and for speaking up if we see possible violations.

Confidentiality and Proprietary information

Integral to CobbleStone’s business success is our protection of confidential company information, as well as nonpublic information entrusted to us by employees, customers, and other business partners. Confidential and proprietary information includes but is not limited to such things as pricing and financial data, customer names/addresses or nonpublic information about other companies, including current or potential supplier and vendors. We will not disclose confidential and nonpublic information without a valid business purpose and proper authorization and shall do so only consistent with legal requirements.

It is important that we respect the property rights of others. CobbleStone will not acquire or seek to acquire by improper means of a competitor’s trade secrets or other proprietary or confidential information. We will not engage in unauthorized use, copying, distribution or alteration of software or other intellectual property. Stealing proprietary information and/or possessing unconsented trade secret information is strictly prohibited. No employee, officer, or director of CobbleStone should take unfair advantage of anyone through manipulation, misrepresentation of material facts, or any other intentional unfair dealing practice.

Statement on the Use of AI

CobbleStone believes artificial intelligence (AI) should be used to improve the lives of humankind while protecting our core rights. CobbleStone strives to ensure that our use of AI should:

• Be socially beneficial
• Avoid creating or reinforcing unfair bias
• Be built and tested for safety
• Employ human-in-the-loop processing
• Be accountable to people
• Incorporate privacy design principles
• Uphold high standards of scientific excellence
• Be made available for uses that align with these principles

CobbleStone aims for AI to be used as a foundational and transformational technology that will offer compelling and helpful benefits to individuals, our clients, our staff, and society.

Selective Disclosure

We will not selectively disclose (whether in one-onone or small discussions, meetings, presentations, proposals or otherwise) any material nonpublic information with respect to CobbleStone, its securities, business operations, plans, financial condition, results of operations or any development plan. We should be particularly vigilant when making presentations or proposals to customers to ensure that our presentations do not contain material nonpublic information.

Modern Slavery and Human Trafficking

CobbleStone has zero-tolerance of modern slavery and human trafficking. CobbleStone repudiates sex trafficking, forced labor, bonded labor, debt bondage, domestic servitude, forced child labor, and all other related practices which violate fundamental human rights. We are committed to operating an ethical, transparent, and socially responsible business to ensure modern slavery is prevented in our workforce.

CobbleStone is not aware of any allegations of modern slavery or human trafficking activities against any of our partners. Should CobbleStone become aware of any such allegations, it will immediately investigate and report those claims to the proper authority where required

Americans with Disabilities Act (ADA)

Discrimination against individuals with disabilities or individuals with perceived disabilities is unlawful and will not be tolerated by CobbleStone. It is unlawful to discriminate in employment against a qualified individual with a disability (or perceived disability) in all employment practices such as inter alia: recruitment, pay, hiring, firing, promotion, job assignments, training, leave, lay-off, and benefits.

To ensure equal employment opportunities to qualified individuals with a disability, CobbleStone will make reasonable accommodations for the known disability of an otherwise qualified individual, unless undue hardship on the operation of the business would result or were doing so could give rise to a direct threat of harm.

Employees who may require a reasonable accommodation should contact the Human Resources Department.

Competition

We seek competitive advantages through superior performance – never through unethical or illegal business practices. We are dedicated to ethical, fair, and vigorous competition. We offer CobbleStone products and services based on superior quality, functionality, and competitive pricing. We make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our competitors. We will not offer or solicit improper payments or gratuities in connection with the purchase of CobbleStone’s goods or services nor will we engage or assist in unlawful boycotts of particular customers.

Conflicts of Interest

We must avoid any relationship or activity that might impair, or even appear to impair, our ability to make objective and fair decisions when performing our jobs. At times, we may be faced with situations where the business actions we take on behalf of CobbleStone may conflict with our own personal or family interests. We owe a duty to CobbleStone to advance its legitimate interests when the opportunity to do so arises. We must never use CobbleStone property or information for personal gain or personally take for ourselves any opportunity that is discovered through our position with CobbleStone, and violate the duty of loyalty owed to Cobblestone as your employer.

Here are some ways in which conflicts of interest could arise:

1. Being employed (you or a close family member) by, or acting as a consultant to, a competitor or potential competitor, supplier or contractor, regardless of the nature of the employment, while you are employed with CobbleStone.
2. Hiring or supervising family members or closely related persons in violation of the CobbleStone company policies or handbook.
3. Serving as a board member for an outside commercial company or organization that is a client, or competitor of CobbleStone
4. Involvement in transactions, or owning or having a substantial interest in a competitor, supplier or contractor.
5. Having a personal interest, financial interest or potential gain in any CobbleStone transaction.
6. Placing company business with a firm owned or controlled by a CobbleStone employee or his or her family.
7. Accepting gifts, discounts, favors or services from a customer/potential customer, competitor or supplier, unless equally available to all CobbleStone employees.

Determining whether a conflict of interest exists is not always easy to do. Employees with a potential conflict of interest or question should seek advice from Executive Management. Before engaging in any activity, transaction or relationship that might give rise to a conflict of interest, employees must seek review from their director.

Accepting Business Courtesies

Most business courtesies offered to us in the course of our employment are offered because of our positions at CobbleStone. We should not feel any entitlement to accept and keep a business courtesy. Although we may not use our position at CobbleStone to obtain business courtesies, and we must never ask for them, we may accept unsolicited business courtesies that promote successful working relationships and good will with the firms that CobbleStone maintains or with whom we may establish a business relationship. Employees who award contracts or who can influence the allocation of business, who create specifications that result in the placement of business, or who participate in negotiation of contracts must be particularly careful to avoid actions that create the appearance of favoritism or that may adversely affect the company’s reputation for impartiality and fair dealing. The prudent course is to refuse a courtesy from a supplier when CobbleStone is involved in choosing or reconfirming a supplier or under circumstances that would create an impression that offering courtesies is the way to obtain CobbleStone business.

Meals, Refreshments and Entertainment

We may accept occasional meals, refreshments, entertainment and similar business courtesies that are shared with the person who has offered to pay for the meal, refreshments, or entertainment, provided that:

• they are in accordance with CobbleStone’s policies
• they do not violate a customer’s or lead’s policies. state or federal regulations; or can be construed as or constitute a bribe;
• they are not over $20.00 without director approval;
• the courtesies are infrequent and do not reflect a pattern of frequent acceptance of courtesies from the same person or entity
• the courtesy does not create the appearance of an attempt to influence business decisions, such as accepting courtesies or entertainment from a supplier whose contract is expiring in the near future; and the employee accepting the business courtesy would not feel uncomfortable discussing the courtesy with his or her director or co-worker or having the courtesies known by the public.

Gifts

Employees may accept unsolicited gifts, other than money, that conform to the reasonable ethical business practices, Company policies, does not violate the law, regulations, or client’s policies and that are under $20.00 in value from any one source (unless approved by a director), including:

• Flowers, fruit baskets and other modest presents that commemorate a special occasion.
• Gifts of nominal value, such as calendars, pens, mugs, caps and t-shirts;
• Other minor novelty, advertising, or promotional items.

Generally, employees may not accept compensation, honoraria or money of any amount from entities with whom CobbleStone does or may do business. Tangible gifts (including tickets to a sporting or entertainment event) that have a market value greater than $20.00 may not be accepted unless approval is obtained from management.

Employees with questions about accepting business courtesies should talk to their director.

Offering Business Courtesies

Any employee who offers a business courtesy must assure that it cannot reasonably be interpreted as an attempt to gain an unfair business advantage or otherwise reflect negatively upon CobbleStone or be done for personal gain. An employee may never use personal funds or resources to do something that cannot be done with CobbleStone resources. Accounting for business courtesies must be documented in accordance with approved company procedures.

Other than to our government customers, for whom special rules apply, we may provide nonmonetary gifts (i.e., company logo apparel or similar promotional items) to our customers. Further, management may approve other courtesies, including meals, refreshments or entertainment of reasonable value, provided that:

• The practice does not violate any law or regulation or the standards of conduct of the recipient’s organization;
• The business courtesy is consistent with industry practice, is infrequent in nature, and is not lavish; and
• The business courtesy is properly reflected on the books and records of CobbleStone.

Accurate Public Disclosures

We will make certain that all disclosures made in financial reports and public documents are full, fair, accurate, timely and understandable. This obligation applies to all employees, including all financial executives, with any responsibility for the preparation of such reports, including drafting, reviewing and signing or certifying the information contained therein. No business objective or goal of any kind is ever an excuse for misrepresenting facts or falsifying records.

Employees should inform Executive Management and the HR department if they learn that information in any filing or public communication was untrue or misleading at the time it was made or if subsequent information would affect a similar future filing or public communication.

Corporate Recordkeeping

We create, retain and dispose of our company records as part of our normal course of business in compliance with all CobbleStone policies and guidelines, as well as all regulatory and legal requirements.

All corporate records must be true, accurate and complete, and company data must be promptly and accurately entered in our books in accordance with CobbleStone’s and other applicable accounting principles.

We must not improperly influence, manipulate or mislead any audit, nor interfere with any auditor engaged to perform an internal independent audit of CobbleStone books, records, processes or internal controls

Each invoice that CobbleStone submits for payment must be truthful, accurate, and reflect the item(s) or service(s) that CobbleStone has delivered. We only bill for items and services we provide. We timely correct any billing errors, and make timely refunds of any amount determined to be due. CobbleStone requires honest and accurate recording and reporting of information. All employees of CobbleStone are responsible for reporting any questionable accounting matters that may come to their attention. Records should not be destroyed before the expiration of any obligation to maintain such documentation or as legally compelled.

Media Inquiries

CobbleStone is a high-profile company in our community, and from time to time, employees may be approached by reporters and other members of the media. In order to ensure that we speak with one voice and provide accurate information about the company, we should direct all media inquiries to the marketing department. No one may issue a press release without first consulting with the Director of Marketing.