Protecting
our Jamfs
Jamf Code of Conduct

“Our best chance to succeed is tobe consumed with serving.”“Jamfs know that our journeyis never done and that a lot of
people are depending on us to
get a little better every day.”— Dean Hager, Former CEO

A Message from Leadership
Our values, as well as this Code of Conduct are intended to establish
boundaries in our choices and actions. The guidelines contained
here are the framework outlining our interactions with each other andour customers; a boundary system that contributes to our culture.
Every Jamf deserves to be treated in such a manner and not accept
behaviors outside the boundaries.
As individuals, we have just as much ability to impact the culture of
Jamf as the culture has the ability to impact us. You are part of thisteam because we believe your values are aligned with the organizationand you will act in ways that are in the best interest of Jamf, yourcoworkers, and our customers. While Jamf has evolved over time, ourcommitment will always remain the same - employees and customers
are the reason why we do the things we do. Keep this in mind forevery decision you make!
It would be impossible to address every potential issue that comes up,
so we ask that you would use your conscience and common sense. If
something you witness or experience doesn't align with our boundary
system, it probably isn't right. When you are unsure, seek guidance.
Please speak up about your concerns so that we have the opportunity
to fix it. After all, we can’t fix what we don’t know about.
Finally, this document isn't just a “read-it-once and you're done” typething. It's about the daily choices we make, how we behave and how
we act towards each other and our customers. If we want this…thevalues, the culture, the organization…to continue, we all have theresponsibility to protect what’s important.

Table of Contents
I

V

VII

Our Values

Compliance

Disciplinary Action

II
Ethical Decision Making

III
Speak Up

i
ii
iii
iv
v
vi
vii
viiI

Protecting our Assets
Business Partners

Trade and Export

i
ii
iii
iv
v
vi
vii

VIII
Review and Acknowledgment

Anti-Boycott
Conflicts of Interest
Financial Records
Government Contracting

Respect

Trust
Privacy and Confidentiality

Gifts and Entertainment

VI

IV
i
ii
iii

Insider Trading
Anti-Corruption

Anti-Harassment
Inclusion and Diversity
Anti-Discrimination
Human Rights
Safe Workplace
Environment
Social MediaIX
Resources

I

OUR VALUES
Selflessness
Considering customers' needs before our own
Sacrificing for betterment of team
Lead by helping others become more powerful

Relentless Self-Improvement
Humility
Constantly learning and growing
Get a little better every day“The most important thing to theachievement of our goals is our Values.”— Dean Hager, Former CEO

1

II

ETHICAL DECISION
MAKING
Everything we do, and don't do, is a reflection of our values and culture.
If you're ever unsure about what you should do, consider the following:

Is it consistent with our boundary system, and any applicable law
or regulation?

Is it good for Jamf, your coworkers, and our customers?
How would you feel if everyone knew about your decision?
Would you be comfortable with the example it sets for
future decisions?

If you can answer yes toeach of these, you areprobably good to move
forward.
If you’re still unsure,seek guidance! Your
manager, Legal, andCompliance are resources
for you!
2

WHEN IT COMESTO EMPLOYEEBEHAVIOR,WHAT ARE YOUREXPECTATIONS?
"They aren't expectations for just employees, they are
expectations for the human race. We just want to seethem in practice in the organization.
B asic elements… tell the truth, own your mistakes, beaware of the impact you have on others, and do theright things. If you have questions about what is right,
seek help from others."— Jason Wudi, Chief Strategy Officer

3

III

SPEAK UPWe all have a responsibility to speak up when we believe something isn't right. This
responsibility is critical to ensuring Jamf remains a great work environment and to protect ourcustomers, our culture, and our brand.
If you see anything you believe is illegal, unethical, or simply doesn’t live up to our values,
please voice your concerns by contacting any of the following resources:

Your manager

Legal and Compliance

Human Resources

If you don't feel comfortable withany of those reporting resources,

You may leave a message using any one of two methods:

Jamf provides confidential reporting methods for all employees tothe confidentiality of your identity.

report issues directly to the Audit Committee. When you report an issue,

Secure web form: www.whistleblowerservices.com/JAMF

you’ll be able to remain anonymous if you choose.
Jamf will act quickly on all reports received. Because we may need toshare information as part of the investigation, complete confidentiality is
not guaranteed. However, we will handle reports and investigations asconfidentially as possible. This means we will share confidential
information only on a need-to-know basis and will instruct recipients toSecure Hotline: 833-976-2075
All voicemail messages will be electronically altered/disguised to ensure

When you send a message using any of these methods, you will receive
back a 14 to 16-digit code that can be used to access the status ofyour message. The Audit Committee may also use this to ask you, withcomplete confidentiality, for additional information regarding this issue.
To anonymously follow up on your message, please click here.

handle that information confidentially.

4

FAQ

What if I suspect, but I'm not certain, that someone has
acted in an inappropriate manner?
Speak up! It’s better to say something and elevate your concern rather than
waiting and potentially increasing the risk of harm or damage to our customers,
the organization, or your coworkers.

ANTI-RETALIATION
It can take courage to speak up, so know that wehave your back.
We are grateful when you raise concerns because then we can do the work tolook into and address them. Jamf does not tolerate retaliation against anyone
who raises concerns or questions regarding illegal, unethical, or inappropriate
behavior that they reasonably believe to have occurred. Jamf also does nottolerate any negative action taken against you as a result of your participation in
an investigation or other protected activity.

5

IV

TRUST

i Privacy and Confidentiality

Jamf needs to obtain and process certain information about
individuals during our course of business. This can include customers,
vendors, business partners, employees and other people Jamf has arelationship with or may need to contact. Always remember that weare asking these individuals to trust us with their personal information.
Keeping that trust requires that each of us respect and protect theprivacy and security of that information.

Employees are obligated to protect Jamf’s
confidential information at all times.
Do not disclose confidential information to anyone outside of Jamf except
when disclosure is required for business purposes. Even then, takeappropriate steps, such as execution of a non-disclosure agreement, toprevent misuse of the information.
In addition, we have self-reporting obligations in some global jurisdictions
which require Jamf to identify any data loss or security breach and proactively report to, and work with, local agencies to mitigate risks andlosses. Accordingly, it is the responsibility of each of us to notify Legal,
Compliance, or Information Security immediately upon suspecting or
identifying any such breach or loss. Further details can be found in the
Personal Data Breach Policy.

6Your Responsibilities:
Understand our Data Classification Policy and what is considered confidential.
Follow all relevant privacy laws and regulations.
Safeguard confidential and personal information from unauthorized use and disclosure.
Report any breaches immediately to Legal, Compliance, and Information Security.

FAQ“I sent an email containing sensitive information to thewrong recipient, what should I do?”It’s ok, accidents happen. Send a follow up email requesting them not to disseminate theinformation and to delete the email immediately. Notify Legal, Compliance, and Information
Security of the incident so they can evaluate and determine any additional steps.

7

ii Protecting our Assets

Jamf provides a broad array of resources for us to do our jobs, including computer equipment,
mobile devices, software, operating systems, storage media, network resources and network
accounts. We ask that you be responsible; care for the resources entrusted to you and use them inthe “right way” - with good judgment and in the best interests of the company and our customers.

Our assets take various forms, but can include:
Physical Property Our facilities, equipment, office supplies, hardware, and tools.
Intangible Property Our information, email and voicemail.
Personal Data Personal information about our customers, vendors, business
partners, and employees.
Intellectual Property (IP) Our name, logos, trademarks, patents, creative ideas and copyrights.
It also includes anything you create or design while employed at Jamf.

It's our responsibility to safeguard our assets and protect them from theft,misuse or loss. Know our security policies, including those regarding
protection of equipment and physical security of our facilities, andfollow them.

8

iii Business Partners

Our business partners play an important role
representing our efforts to help organizations succeed
with Apple.
That’s why we are committed to choosing and working with partners whoshare our values and understand the importance of conducting businessethically. Business partners include joint venture partners, vendors, integrators,
resellers, contractors, consultants and agents.
If you are involved in selecting business partners, look for organizations andpeople that share our high ethical standards. The trust our customers havein us is passed on to these relationships. Monitor their performance to makesure they uphold our Partner Code of Conduct and the laws that apply to
our businesses. If you become aware of potential violations committed by abusiness partner working with Jamf or on our behalf, speak up.

9

DID YOU KNOW?
While business partners can be a major risk to anorganization’s data, in the mind of the customer, it is
the organization that owns responsibility for a breachor violation.
Help reduce this risk by ensuring that Finance, Legal, Compliance, and Information
Security conduct proper due diligence for all new business partners.

10

V

COMPLIANCE
i Insider Trading

Jamfs must comply with applicable insider trading restrictions
Such restrictions prohibit Jamfs from trading in Jamf stock while in possessionof material non-public information (MNPI) or sharing Jamf confidential information
with unauthorized third parties. In addition, Jamfs who are on the “covered
persons” list are required to comply with applicable trading window and preclearance processes.

Insider trading violations are pursued vigorously by applicable authorities.
Punishment for insider trading can be severe, and could include significant
fines or imprisonment.
Find out more!
Detailed information about insider trading can be found in the
Company’s Insider Trading Policy.

11

ii

Anti-Corruption
In an effort to fight corruption, most countries have laws that prohibit bribery.
Violation of these laws may result in fines for Jamf and in personal penalties
for individuals.
Bribery occurs when anyone authorizes, offers, solicits, gives, receives or accepts
anything of value, or any financial or other advantage, in exchange for favorable
treatment by a company, government authority, official, or employee. Bribes can
include cash payments, facilitation payments, unreasonable gifts, unreasonable
entertainment or hospitality, favors, loans, free use of Jamf services, unexplained
or excessive discounts, job offers, any item or service of value, or any otherpayment made or offered.

Jamf strictly prohibits paying bribes or making any other improper paymentsin the course of any of its business operations. The laws in some countries
are stricter when dealing with government officials, but at Jamf, bribery isalways unacceptable.
12ii Gifts and Entertainment
Business courtesies, such as gifts, meals, and entertainment,
are a well-established practice which can help strengthen
existing relationships, cultivate new opportunities, and express
appreciation for partners.
Unfortunately, companies run the risk of violating anti-corruption laws if these
expenditures cross a line into conduct that could be characterized as bribery. It isnever permissible to provide any business courtesy for a corrupt or improper purpose.
When giving or receiving a gift always consider the intention, value, and timing. As
documented in Jamf's Anti-Corruption Policy, a gift that is valued at USD $200 or lessis generally acceptable, subject to other concerns regarding context, purpose andfrequency. Gifts in excess of $250 should be reviewed by Legal and Compliance.

FAQ“May I accept a business meal from a vendor?”In most circumstances, modest and infrequent business meals may be accepted.
However, always consider the intent and potential appearance of impropriety. Talk withyour manager if you are unsure.

13

iii Trade and Export
Jamf must comply with all applicable trade
restrictions imposed by the U.S. government.
Such restrictions prohibit Jamf from engaging in certain businessactivities in specified countries and with specified individuals andentities. Penalties for non-compliance can be severe, including fines andimprisonment for responsible individuals, and Jamf may be prohibitedfrom further participation in certain trade.

Find out more!
Detailed information on export restrictions that may be in effect at any given time areposted on the Export Compliance Confluence page. If you have any questions or concerns
regarding export compliance, please seek clarification from the Legal and Complianceteam at export@jamf.com.

14

iv Anti-Boycott

The United States has laws that forbid U.S.
companies, or their foreign affiliates or agents,from participating in non-United Nations
sanctioned boycotts of countries friendly to theUnited States.

In certain countries, companies are encouraged or mandated torequire an agreement from customers and suppliers that they do
not do business with particular companies, nations or groups ofpeople based on race, religion or national origin. Boycott-related
requests can be verbal or included in a request for proposal,
supplier questionnaire, contract, purchase order, letter of credit
or shipping documents. Agreeing to such provisions is against
our business practices and applicable laws.

15

v Conflicts of Interest

We must all use our best judgment to avoid any
activities or associations that conflict with our duties
and responsibilities at Jamf.
A conflict of interest arises when your personal activities and relationships interfere, or appear tointerfere, with your ability to act in the best interest of Jamf or our customers. For example, a conflictof interest may occur when you or a family member receive a personal benefit as a result of yourposition with Jamf. Other examples of potential conflict of interest include outside employment, serving
on boards, personal investments, gifts, and entertainment. If you discover that a personal activity or
association could interfere with your objectivity or your ability to make impartial business decisions,disclose it immediately to your manager, Human Resources, or Legal and Compliance.

Determining Conflicts of Interest
In any potential conflict of interest situation, ask yourself:“Could my personal interests“Might it appear that way to others,interfere with those of Jamf?”

either inside or outside of Jamf?”

If you answer yes to either question, you should disclose the situation.
When unsure, seek guidance.
16

vi Financial Records

Everyone at Jamf is responsible for ensuring that we spend money
appropriately, we keep complete and accurate financial records, andwe comply with internal controls.

This includes records such as time reports, expense reports, sales opportunities, and benefitsclaim forms. Always record and classify transactions in the proper accounting period and in theappropriate account and department. Do not delay or accelerate the recording of revenue or
expenses to meet budgetary or sales goals.
When spending money on Jamf’s behalf, make sure that the cost is reasonable, directly related tocompany business, and supported by appropriate documentation. If you’re uncertain about whether
you should spend money or submit an expense for reimbursement, check with your manager.
Managers are responsible for all money spent and expenses incurred by their direct reports andshould carefully review such spend and expenses before approving.

17

vii Government Contracting

Jamf and its employees may deal withgovernment officials in the course of
our business.

It is important that the responsible employees be thoroughlyfamiliar with and comply with laws and regulations applicable todealing with government officials. Employees should be awarethat business practices which are acceptable in a commercial
environment may not be acceptable — and in fact could beillegal — when dealing with government officials. The penalties
for failing to follow the laws when dealing with government
officials can be severe and include substantial civil and criminalfines, imprisonment, and debarment of Jamf from doing
business with the government. Employees should follow Jamf
policies and guidelines in their relationships with government
officials, and should direct questions about particular situations
to Legal and Compliance.
18

VI

RESPECTi Anti-Harassment

Harassment in any form is unlawful and will not be tolerated
at Jamf. Jamf will take appropriate and immediate action
in response to reports of harassment, including cases ofsuspected harassment.
Jamf does not tolerate harassment by third parties, such as
vendors, customers, or partners.
Harassment is any unwelcome conduct that denigrates orshows hostility or aversion toward an individual becauseof their gender, gender identity or expression, family status, age,disability, race, color, religion, pregnancy, national origin, sexual
orientation, or any other characteristic protected by law.
Harassment creates a work environment that a reasonable
person would consider intimidating, hostile, or offensive.

It is not considered harassment
if interactions between
employees are:Mutually respectful, courteous, and non-coercive;
Appropriate for the workplace; andWelcomed and accepted by involved parties.
19

Sexual Harassment
Sexual harassment is a specific form of harassment thatencompasses unwelcome sexual advances, unwelcomedphysical contact or communications of a sexual nature, or any
offensive remarks about a person’s sex, gender identity or
expression, or sexual orientation.
Sexual harassment occurs when unsolicited and unwelcome sexual
advances, requests for sexual favors, or other verbal or physicalconduct of a sexual nature:
Is made explicitly or implicitly a term or condition of employment;
Is used as a basis for employment decisions; and nreasonably interferes with an employee’s work performance, orUcreates an intimidating, hostile, or offensive environment.

Employees who witness harassment are empowered to speak up in the momentthat such conduct is inappropriate and must stop. If you do not feel comfortableinterrupting in the moment, please report the incident immediately.
20

RESPECT AT JAMF
Treat others the way you’d like to be treated.
Celebrate our diversity. Listen and be receptive to different points of view.
 peak up if you see or suspect discrimination or harassment based onS
someone’s race, color, national origin, age, religion, disability, gender,
gender identity or expression, sexual orientation, pregnancy, genetic
information, familial status, marital status, military status, or any othercharacteristics protected by federal, state, and local applicable fair
employment practices laws.

“You don’t come to Jamf to just work, you come to be
together with people and work towards common goals.
All of us connecting with one another in an effort tohelp others.”— Sam Johnson, Chief Customer Officer21

ii Inclusion and Diversity
We can only be our best selves when given
the freedom to be ourselves.
At Jamf, we inspire people to let their individuality shine and encourage ourJamfs to be their whole selves both inside and outside of Jamf. Our commitment
to create an environment that embraces and celebrates unique perspectives
while ensuring equality and fairness in the workplace is unwavering.
Our Employee Resource Groups provide employees a safe space for
empowerment and cultural education. We encourage employees to use their
voice to make real, actionable differences to ensure Jamf is a place where
everyone feels comfortable and can be successful both in the office andworking remotely.
In the spirit of selflessness and relentless self-improvement, we are actively
working every day to get better; our commitment on becoming a more inclusiveand diverse workplace is never done. We believe differences in opinions
and ways of thinking are essential in order to achieve global impact for ourcustomers, our communities and our Jamfs. Our products enable people of allages, cultures and genders to use technology to educate, care and prosper. We
believe in putting the human experience first, supporting and actively promoting
inclusion and diversity helps us to better understand that human experience andthe different perspectives of every person.
We, as one Jamf, pledge to be leaders and allies of change by taking intentional
action for all Jamfs and our communities at large.

“Diversity in our
teams or our people
equals diversity in our
thinking, diversity in
our performance, and aworkforce that reflects
the diversity of thecommunity that we’reactually serving.”–M elissa Antoine, Senior Manager,
Customer Success22

iii Anti-Discrimination
Jamf is committed to the principles of equal employment and providing
equal employment opportunities. It is our duty to maintain a work
environment that is free from discrimination.
Jamf is an equal opportunity employer and does not discriminate with regard
to race, color, national origin, age, religion, disability, gender, gender identity or
expression, sexual orientation, pregnancy, genetic information, familial status,
marital status, military status, or any other characteristics protected by federal,state, and local applicable fair employment practices laws.
We are all responsible for maintaining a work environment free of discriminationand preventing discrimination against others. If you believe you have been
subjected to any form of discrimination, or if you witness or are made awareof an incident of discrimination involving another employee, you should report
immediately to your manager and/or HR in compliance with the Workplace
Issues Escalation Policy.
23

FAQ

“One of my coworkers is making insulting, agerelated remarks to another coworker. Should I say
something?”
Yes. If you’re comfortable doing so, ask them to stop. If you prefer, shareyour concerns with your manager immediately. We do not tolerate any
forms of discrimination or harassment, whether the action is initiated by—or directed at—an employee, a customer, a supplier or anyone else in our
workplace (or at a work related event).

24

iv Human Rights
Everything we do at Jamf must be done with respect
for individuals’ internationally recognized humanrights, and we must seek to prevent our businessactivities from impeding those rights.
This includes treating employees fairly and in accordance with applicable laws andregulations regarding employment. Jamf is also committed to complying with modern
slavery and human trafficking laws wherever we do business. We expect our business
partners to share our commitment to the same high standards.

It's simple, treat others with dignity and respect. Treatothers how you want to be treated.

25

v Safe Workplace
To work effectively, all of us need a healthy and safe work
environment. All of us should be safe at our place of work.
Should you observe any unsafe situations at work, notify your manager.
Please also take the time to familiarize yourselves with emergency
procedures and the safety manuals applicable to your location.
Jamf is committed to a violence-free work environment, and we will not
tolerate any level of violence or the threat of violence in the workplace.
If you become aware of a violation of this policy, you should report it to
Human Resources and/or Workplace Services immediately.

26

vi

Environment

Jamf is committed to conducting our business in anenvironmentally responsible manner and we are committed
to compliance with all applicable environmental laws andregulations.
We all play a role in this commitment whether it be through waste
minimization, efficient resource use, or other measures relevant to ourbusiness. Be proactive and always thinking about ways to address theenvironmental impacts of our operations and daily activities. In addition,
we must ensure that Jamf business partners share this commitment toenvironmental protection.
Jamf employees are encouraged to eliminate or limit the use of toxic
materials and single-use plastics, avoid the use of conflict materials,
conserve natural resources, reduce greenhouse gas emissions (GHG),
and implement circular economy practices.
If you become aware of any violation of environmental law you should
immediately report the matter to your manager or Legal and Compliance.
27

vii

Social MediaSocial media can be a fun way to share your life and opinions withfamily, friends, and co-workers around the world.
As Jamfs we value our freedom to express ourselves and our opinions whenusing personal social media accounts. Jamf has no intention of creating
an environment where we feel limited in the ability to express ourselves,
however, the use of social media presents certain risks and carries with itcertain responsibilities.
Ultimately, you are solely responsible for what you post online. The views
and opinions you express are your own. Before creating online content,
consider some of the risks and rewards that are involved. Customers,
colleagues, managers, suppliers, competitors and others may have access toyour posts. Offensive or inappropriate remarks are as out-of-place online asthey are offline. Use the same set of standards and boundary system as you
do in the physical workplace.
Jamf social media accounts must only be used and created by authorizedindividuals for the purpose of meeting defined company goals.

“With great power comes great responsibility”
Inappropriate or unlawful conduct will not be tolerated.
Never reveal non-public company information on social media.
When in doubt, do not post.

28

VII

DISCIPLINARYACTIONAny employee found to have violated this Code of
Conduct, any of Jamf's policies, applicable laws,or ethical standards may be subject to disciplinary
action, up to and including, termination of
employment. We also hold vendors and business
partners accountable to our ethical standards.

29

VIII

REVIEW AND
ACKNOWLEDGMENT

All new employees must acknowledge that they
have read this Code of Conduct and agree toabide by its provisions.
All employees will be required to make similar
acknowledgments on an annual basis. Failure to read theCode or sign the acknowledgment form does not excuse an
employee from compliance with the provisions.

30