Chainalysis Global Codeof Business Conduct
and Ethics
Effective: November 28, 2023

Table of Contents
Table of Contents

2

Section 1: Introduction to the Code3

1.1 Objective and Scope3

1.2 Applicability and Expectations

4

Section 2: Our Values
Section 3: Our Policies

45

3.1 Integrity

5a. Legal Compliance5b. Conflicts of Interest

5

I. Responsibility and Reporting

6

II. Moonlighting and Side Projects

6c. Confidential Information

6d. Insider Trading7

3.2 Business Ethics

8

a. Fair Dealing

8b. Financial Integrity

8c. Antitrust9

3.3 International, Regulatory, and Government

9a. International Business Laws and Norms

9b. Anti-Money Laundering

10c. Anti-Bribery and Anti-Corruption: Gifts and Entertainment

10d. Trade Restrictions

10

e. Customer Vetting

11

3.4 Corporate Responsibility

11

a. Anti-Harassment and Discrimination

11b. Commitment to Human Rights

12c. Commitment to Sustainability

12d. Use of Company Property

12

Section 4: Code Questions and Reporting

13

4.1 Questions

13

4.2 Reporting Obligation

13

4.3 Commitment to Non-Retaliation

13

4.4 False and Misleading Reports

14

4.5 Contact Methods

14

4.6 Inquiries and Investigations

15

Section 5: General

16

5.1 Consequences of Non-Compliance with this Code16

5.2 Waivers

16

5.3 Annual Training and Acknowledgement

16

5.4 Dissemination and Amendment

162Global Code of Business Conduct and Ethics
Section 1: Introduction to the Code
1.1

Objective and Scope

Chainalysis is committed to maintaining the highest standards of business conduct and ethics. This
Code of Business Conduct and Ethics (this “Code”) reflects our business practices and principles of
behavior that support our commitment. References to “Chainalysis,” “we,” “us,” or “our” in this Coderefer to Chainalysis Inc. and its subsidiaries.
While this Code covers a wide range of topics relating to business conduct and ethics, it does notaddress all of our potential legal, regulatory, or ethical responsibilities, and it is not the only documentthat relates to acceptable conduct at Chainalysis. Rather, it is intended to act as a guideline andminimum requirement that must always be followed. Chainalysis maintains other more detailed
policies, codes, and handbooks related to particular responsibilities, conduct, and other topics,
including those referenced herein, that you should review separately. For instance, such othermaterials include:●

region-specific Employee Handbooks, which include, among other things, policies relating toharassment and discrimination;●

the Anti-Bribery and Anti-Corruption Policy, which supplements this Code and provides
additional responsibilities applicable to all directors, officers, employees, agents,
representatives, joint-venture and teaming partners, re-sellers, prime and subcontractors, andothers working on behalf of or representing Chainalysis; and●the Public Sector Code of Conduct Supplement (the “PubSec Supplement”), which augments
this Code and provides additional responsibilities applicable to employees engaged innegotiating, performing, or supporting contracts, subcontracts, or other agreements related to
Public Sector customers.1

1“Public Sector customers” are any agency, organization, or entity that is within (or is substantiallyowned, funded, managed, or controlled by): the executive, legislative or judicial branches of any
government within the U.S. (federal, state, or local) and its territories, or by any other country’s
government at any level; quasi-governmental entities (such as the World Bank); or international
governing/regulatory bodies (such as European Union institutions); and publicly funded institutions(such as colleges, universities, and hospitals). This definition includes the employees, representatives,
agents, contractors, and subcontractors of the above agencies, organizations, or entities.
3

If you have any questions about this Code, please reach out to the Chainalysis Compliance Team via
the methods described in Section 4.

1.2

Applicability and Expectations

Compliance with this Code is mandatory for all employees, employees of record, officers, members of
the Chainalysis board of directors (the “Board”), and others working on behalf of or representing
Chainalysis. Chainalysis also requires its business partners to comply with this Code or to haveadopted a code of business conduct and ethics of equivalent scope. All persons and entities to whom
this Code applies are collectively referred to herein as “providers” or “you.”
When acting for or on behalf of Chainalysis, you are at all times expected to:●

conduct yourself in a legally and ethically compliant manner and consistent with this Codeand other Chainalysis policies, procedures, guidelines, and practices;●

apply good judgment, common sense and the highest personal ethical standards when
making business decisions; and●be familiar with applicable laws and regulations in your area of operation. Any questions
about laws and regulations should be addressed to the Chainalysis Legal Team via themethods described in Section 4.

Section 2: Our Values
Chainalysis observes the following company values:●

Build Trust - take every chance to build trust in your team, Chainalysis, and the industry●

Earn the Right - don’t rest on your laurels, we re-earn our rights every day●

Rigor - question everything, be data-driven and deliver high quality work●

Team First - success comes through collaboration●

Strong Convictions/Loosely Held - act on today’s information, not yesterday’s

Further information on company values can be found here.

4Section 3: Our Policies
At Chainalysis, we promote the highest standards of integrity by conducting our affairs in an honest
and ethical manner. Our integrity and reputation depends on the honesty, fairness, and integrity
brought to their jobs everyday by all employees. This also includes respect and integrity wheninteracting with each other and other third parties.

3.1

Integritya. Legal ComplianceObeying the law is the foundation of this Code. Our success depends upon all of you operating within
legal guidelines and cooperating with national, state, and local authorities in the U.S., and around theworld. We expect all of you to understand the legal and regulatory requirements applicable to yourbusiness units and areas of responsibility. You also are expected to use good judgment, common
sense, and the highest personal ethical standards in seeking to comply with all applicable laws, rules,
and regulations. If you have a question in the area of legal compliance, it is important that you not
hesitate to seek answers from your manager, or the Legal Team via the methods described in Section
4.

b. Conflicts of Interest
We expect our providers to act in the best interests of Chainalysis and to refrain from engaging in any
other employment, occupation, consulting relationship, commitment, or activity or having a personal
interest that presents–or even gives the appearance of–a “conflict of interest.” A “conflict of interest”
occurs when your personal interest (including interests of a member of your family) hinders yourability to perform your Chainalysis duties and responsibilities honestly, objectively, and/or effectively,or otherwise interferes with the interests of Chainalysis.
Whether or not a conflict of interest exists depends on the circumstances, but some situations that
could be considered conflicts of interest include:●

soliciting or accepting gifts, favors, loans, benefits, or preferential treatment from any personor entity that does business or seeks to do business with us;●

selecting vendors, customers, other business partners, and new hire candidates based on any
considerations other than the best interest of Chainalysis;●

owning a significant financial interest in an entity that does business, seeks to do business orcompetes with Chainalysis; for the avoidance of doubt, an investment by a professional5

investment fund affiliated with a member of our Board shall not, by itself, be considered aconflict of interest;●

using Chainalysis assets for personal purposes;●

engaging in other employment, occupation, consulting relationships, or commitments (a)directly related to Chainalysis’s business or (b) for or on behalf of a competitor, customer, orvendor of Chainalysis;●

allowing a member of your family to receive improper benefits as a result of your position with
Chainalysis; and●certain types of “moonlighting” (see below for additional detail).

Government Contracts Supplement: For additional information regarding preventing conflicts ofinterest in compliance with the U.S. Federal Acquisition Regulation (FAR) and in connection with
Chainalysis’s performance of government contracts, please refer to the Employee Handbook for U.S.
employees.

I.

Responsibility and Reporting

It is the responsibility of each provider to avoid not only any situation that is a conflict of interest, butalso to be aware of situations that might appear to be a conflict, as they might not be in the bestinterest of Chainalysis. Also, you must fully cooperate in the remediation of any situation in which a
conflict exists or may arise.
If you have any questions about a potential conflict of interest, or wish to report a potential conflict ofinterest, please reach out to the Compliance Team via the prescribed methods described in Section 4.

II.

Moonlighting and Side Projects

Chainalysis recognizes that employees may want to engage in outside activities and projects, and it
supports its employees when those activities and projects do not conflict or interfere with their ability
to perform their duties or act in the best interest of Chainalysis. However, you may not take personaladvantage of opportunities for Chainalysis that are presented to you or discovered by you as a resultof your position with us (or services provided to us) or through your use of corporate property or
information. Even opportunities that are acquired privately by you may be questionable if they are
related to our existing or proposed lines of business. All moonlighting opportunities are subject toreview and approval by the People Team, your executive leader and the Legal Team.
Further details on moonlighting and side projects and the required approval process can be found in
the applicable regional Employee Handbook.

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c. Confidential Information
While working for Chainalysis, you will be privy to confidential information of Chainalysis and otherthird-parties. All non-public information of or about Chainalysis, our products, services, plans, trade
secrets, customers, employees, partners, or other third-parties with which we do business is
considered “confidential information.” Importantly, all customer information is confidential
information. Unauthorized disclosure of any confidential information is prohibited, and providers musttake appropriate precautions to safeguard confidential information and ensure that it iscommunicated within Chainalysis only to those who have a need to know such information to
perform their responsibilities.
All Chainalysis emails, voicemails, slacks, and other communications are presumed confidential toChainalysis and should not be forwarded or otherwise disseminated to individuals outside ofChainalysis, except where required for Chainalysis-related business reasons.
Failure to safeguard such information may significantly harm Chainalysis and its competitive position,and the use of such confidential information for any purpose except to conduct our business isunlawful and may lead to civil and/or criminal liability.
Your obligation to treat certain information as confidential does not end when you leave Chainalysis,
and you will be prohibited from disclosing any confidential information to a new employer or to others
after leaving. All employees are required to sign either a Confidential Information, At-Will
Employment, Arbitration and Invention Assignment Agreement, or an employment agreement, with
Chainalysis which provides additional detail on your confidentiality obligations that are not containedin this Code.

d. Insider Trading
Providers who have access to confidential information are not permitted to use or share that
information for purposes of trading in Chainalysis securities or in securities or digital assets of anothercompany. All material, non-public information about Chainalysis or about companies with which we
do business is considered confidential information. You may also have access to material, non-public
information about other third-parties in the course of your services to Chainalysis. To use material,
non-public information in connection with buying or selling securities or digital assets, including“tipping” others who might make an investment decision on the basis of this information, is bothunethical and illegal, and may be subject to disciplinary action. You must exercise the utmost carewhen handling material non-public information.

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3.2

Business Ethics

a. Fair Dealing
Chainalysis strives to outperform our competition fairly and honestly. Advantages over ourcompetitors are to be obtained through superior performance of our solutions and services, notthrough unethical or illegal business practices. Providers are expected to deal honestly, ethically andfairly with customers, partners, vendors, competitors, and other third parties. This includes:●

ensuring clear and precise communication in our contracts, advertising, literature, and otherpublic statements, and attempting to eliminate misstatements of fact or misleading
impressions;●reflecting accurately on all invoices to customers the sale price and terms of sale for products
and services sold or rendered;●protecting all proprietary data that is provided to us by customers, partners, vendors,
employees, or developed by us as reflected in our agreements and policies or as compelled bylaw; and●prohibiting our representatives from otherwise taking unfair advantage of our customers,
partners or vendors, or other third parties, through manipulation, concealment, abuse ofprivileged information, or any other unfair-dealing practice.

Be aware that the Federal Trade Commission Act provides that “unfair methods of competition incommerce, and unfair or deceptive acts or practices in commerce, are declared unlawful.” It isunlawful to engage in deceptive, unfair, or unethical practices, and to make misrepresentations inconnection with sales activities.

b. Financial Integrity
The integrity of our records, reports, presentations, and other materials that we use internally andshare with third parties (collectively, our “financial records”) depends upon the validity, accuracy, andcompleteness of the information supporting the entries to our books of account. Therefore, ourcorporate and business records should be completed accurately and honestly. The making of false or
misleading entries is strictly prohibited. Our records serve as a basis for managing our business andare important in meeting our obligations to customers, suppliers, creditors, employees, and others.
We also rely upon our accounting and other business and corporate departments in preparing ourfinancial records. Our financial records must provide full, fair, accurate, and understandable
disclosure. Employees and other providers who contribute in any way in preparing or verifying thesereports should strive to ensure that our financial records are complete, accurate, and transparent. Any

8employee or other provider who becomes aware of any departure from these standards has a
responsibility to report his or her knowledge promptly to a supervisor or to the Compliance Team via
the methods described in Section 4.

c. Antitrust
Antitrust laws are designed to protect the competitive process and impose severe penalties forcertain types of violations, including criminal penalties. These laws are based on the premise that the
public interest is best served by vigorous competition and will suffer from illegal agreements orcollusion among competitors. When representing Chainalysis in the community, you are expected tocompete energetically by promoting Chainalysis on the merits, not by disparaging competitors.
Product or service comparisons should be fair and accurate. Please also keep in mind that outside theU.S. there are further constraints under comparative advertising regulations.
Competitive information must be gathered with care. We must conduct all interactions withcompetitors, including social activities, as if they were completely in the public view, because they
may later be subject to examination and unfavorable interpretation. Certain kinds of information, suchas our strategies, business plans, budgets, forecasts, financial and operating information, pricing,production, and inventory, should not be exchanged with competitors, regardless of how innocent or
casual the exchange may be.
If you have any doubt about the legality or impropriety of a situation, please reach out to theCompliance Team via the methods described in Section 4.

3.3

International, Regulatory, and Governmenta. International Business Laws and Norms
Providers are expected to comply with the applicable laws in all countries to which they travel, in
which they operate and where otherwise do business, including laws prohibiting bribery, and/or
corruption or governing the conduct of business with specified individuals, companies, or countries.
The fact that, in some countries, certain laws are not enforced or that violation of those laws is not
subject to public criticism will not be accepted as an excuse for noncompliance.
Many countries and cultures also have unique customs, norms, and traditions including with respect
to business transactions. Providers are encouraged to become familiar with the customs, norms, andtraditions of the countries that they do business with.
For more information, please consult the Anti-Bribery and Anti-Corruption Policy and the Travel
Policy, or contact the applicable members of the Legal Team via the methods described in Section 4.
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b. Anti-Money Laundering
Providers are prohibited from engaging in any activity that facilitates money laundering or thefunding of terrorist or criminal activities in connection with our business. Money laundering is the actof concealing or disguising the existence, illegal origins, and/or illegal application of criminally derived
income so that such income appears to have legitimate origins or constitute legitimate assets. Whilemoney laundering involves giving “dirty” money, terrorist, or criminal financing often involves using
legally earned income to finance illegal activities through means that appear legitimate. Chainalysis
expects all providers to comply with all applicable anti-money laundering laws and regulations.

c. Anti-Bribery and Anti-Corruption: Gifts and Entertainment
Providers must always use good judgment and moderation when offering or receiving business gifts,
meals, entertainment, or travel. While there may be times when it is appropriate to provide
reasonable business courtesies in the context of a business relationship, we must avoid potential
conflicts of interest and the appearance of impropriety.
Chainalysis prohibits bribery of any kind and requires full compliance with all anti-bribery andanti-corruption laws that apply in the United States and/or internationally. Violation of these laws canlead to civil and/or criminal prosecution of Chainalysis and/or the individuals involved.
All providers are prohibited from offering, promising, authorizing, or receiving an improper payment oranything of value to or from (as applicable) any person, entity, government official, or third party toobtain or retain business or a business advantage; and must comply fully with all applicable U.S.
local, state, federal, and/or national and international anti-bribery and anti-corruption laws.
For questions, please consult the Anti-Bribery and Anti-Corruption Policy and the Quick Reference
Guide: Gifts and Government Employees in the United States, or contact the applicable members of
the Legal Team via the methods described in Section 4.

d. Trade Restrictions
Chainalysis has a global reach, and the privilege of doing business globally also comes with export
control obligations. Some of the strictest export controls are maintained by the United States against
countries that the U.S. government considers unfriendly, adverse to U.S. foreign policy interests, or tobe supporting international terrorism. These controls include the trade and economic sanctions
administered by the Office of Foreign Assets Control (“OFAC”). The U.S. regulations are complex andapply to certain transfers of goods and technology to foreign companies and foreign persons,whether in the United States or abroad. Thus, even an oral presentation containing technical10

information made to foreign nationals in the United States or access by foreign nationals to certain
technology may constitute a deemed export. Chainalysis is currently prohibited from exporting its
products and services to certain countries, as addressed in the Chainalysis Customer Vetting Policy
and Process. The consequences for not complying with the export control and economic sanctions
laws could be severe for Chainalysis and the individuals involved, with administrative, criminal, andreputational repercussions. If you have any questions regarding the potential export of any products
or services, please reach out to the Compliance Team via the methods described in Section 4.

e. Customer Vetting
Chainalysis is committed to working with customers spanning many jurisdictions, sectors, andindustries. Working with a diverse customer base offers many benefits, it also means we have a
responsibility to make sure we are minimizing risk and that our customer engagements reflect our
mission of building trust in the cryptocurrency ecosystem.
All prospective and current customers are evaluated pursuant to the Customer Vetting Policy andProcess must go through appropriate evaluations with the vetting committee to ensure we mitigate
potential risk of U.S. and international sanctions violations (ranging from significant fines to criminal
penalties), reputational damage, and/or fractured customer relationships.
For further information on customer vetting, including contact information if you have any questions,please refer to the Customer Vetting Policy and Process.

3.4

Corporate Responsibility

a. Anti-Harassment and Discrimination
Chainalysis prohibits harassment of any kind, including sexual harassment and harassment based onother characteristics, such as actual or perceived race, color, age, religion, creed, sex, gender, gender
identity, gender expression, sexual orientation, marital status, partnership status, alienage, citizenshipstatus, national origin, ancestry, medical condition (cancer/genetic characteristics and information),pregnancy, physical or mental disability, military or veteran status, request for family care leave, or
any other category protected by applicable law.
Chainalysis takes allegations of discrimination, intimidation, and harassment very seriously and willpromptly conduct an investigation and take appropriate corrective action when warranted, which
may include disciplinary action, up to and including termination of employment or contract. For details
regarding Chainalysis’s policy regarding harassment and discrimination, please refer to the Employee
Handbook for your region. You can also contact us via the methods described in Section 4.

11

b. Commitment to Human Rights
Chainalysis strives to comply with all applicable laws and respect internationally recognized humanrights where we operate, and expects the same of our partners. All labor must be voluntary. We don’t
engage in child labor, forced, bonded, or indentured labor, involuntary prison labor, slavery, traffickingof persons, or physical punishment. We pay applicable legal wages under humane conditions. We
comply with all applicable environmental laws and regulations.

c. Commitment to Sustainability
Chainalysis is committed to promoting environmentally conscious behaviors in our day-to-day
interactions and to taking steps to minimize our impact on the environment. We strive to create ahealthier and more sustainable future by supporting the development of innovative solutions that
address environmental challenges both at Chainalysis and with our customers.

d. Use of Company Property
Company assets should only be used for the legitimate business purposes allowed by Chainalysis. All
employees and other providers have an obligation to use Chainalysis property efficiently and toreport any theft or damage to Chainalysis property to appropriate Chainalysis management
personnel. This includes both electronic and non-electronic equipment, and/or systems.
Further information on baseline requirements for electronic equipment can be found in IT Security
Best Practices for User Devices Policy and other security policies.
For employees, further information on expected use of company property can be found in theapplicable regional Employee Handbook and in your Confidential Information, At-Will Employment,
Arbitration and Invention Assignment Agreement or employment agreement.

Section 4: Code Questions and Reporting
4.1

Questions

Every provider has the responsibility to ask questions, seek guidance, and express concerns regarding
this Code. If you have any questions about this Code, please contact the Compliance Team via one of
the methods described in Section 4.5.

12

4.2

Reporting Obligation

Chainalysis is a workplace where employees and third parties can express concerns about its
business practices and are protected from unlawful retaliation or discrimination if they properly reportillegal or unethical conduct.
If you become aware of any circumstances that are–or that you suspect are–inconsistent with or in
violation of this Code, any other Chainalysis policy, or applicable law, it is your right and responsibility
to report such information to the appropriate Chainalysis personnel via one of the methods describedin Section 4.5. If you are unsure, you can also contact the Compliance Team to answer any questions
and advise of any next steps.
Because our ability to investigate depends on the quality and specificity of the information provided,
when reporting a suspected inconsistency or violation, we encourage you to provide as much detailas possible about the complaint or concern, including names, a description of the alleged conduct, thedates of the alleged conduct, and the policy or law that you suspect was violated. To the extent
possible, all complaints and concerns will be kept confidential.

4.3

Commitment to Non-Retaliation

No retaliation will be taken against you for reporting irregularities with, voicing concerns under, or
suspected violations of this Code, any other Chainalysis policy, or applicable law that you believe ingood faith to be true, or for participating in an investigation. Examples of retaliation can include
harassment, intimidation, threats, coercion, discrimination, or negative performance feedback that is
not reflective of actual performance. Any provider who feels that he or she has been subjected toretaliation should immediately report such behavior to his or her manager or primary Chainalysis
contact, unless the conduct at issue concerns that manager or primary Chainalysis contact. In thatcase, the provider should speak to their HR Business Partner or the People Team at
hrbp@chainalysis.com, or reach out to the appropriate personnel via one of the methods described in
Section 4.5. All reports will be investigated and anyone who is found to have engaged in retaliatory
behavior may be subject to disciplinary action, up to and including termination of employment orcontract.

4.4

False and Misleading Reports

13

Employees who knowingly file misleading or false reports, or without a reasonable belief as to theirtruth or accuracy, will not be protected by this Code and may be subject to disciplinary action,
including potential termination of employment or contract, subject to applicable law.

4.5

Contact Methods

Please use one of the methods below to ask questions regarding, or report suspected inconsistencies
with or violations of, this Code, any other Chainalysis policy, or applicable law:●

Compliance Reporting Portal: The centralized reporting portal can be found via the Legal
Intake Service Desk under “Compliance.” The intake will provide you with options to submit aquestion about, or report any suspected noncompliance with, the Code, another policy, or
applicable law. For information on how to use the Compliance Reporting hub, please see theCompliance Hub User Guide.

●

Email: Alternatively, you may contact the appropriate Chainalysis groups by email:○ Code: Please contact the Compliance Team at compliance@chainalysis.com○ Other Chainalysis policies: Please contact (a) the appropriate team listed in suchpolicy or (b) if no team is listed, the Compliance Team at compliance@chainalysis.com○ Applicable law: Please contact the Legal Team at legal@chainalysis.com●

Oral Reports: You may also report suspected inconsistencies with or violations of, this Code,any other Chainalysis policy, or applicable law to your manager or to a member of the LegalTeam. Managers must promptly report any such complaints or observations of inconsistencies
or violations using one of the methods described above or to a member of the Legal Team.
The person receiving an oral complaint should encourage the individual making the complaint
to prepare a written complaint or, if he or she refuses, the person receiving the complaint
should prepare a written complaint based on the oral reporting.

For General Questions: In addition to the above, you can submit questions regarding this Code or any
other Chainalysis policy, you can submit questions to the Compliance Team via Slack at#help-compliance. If the question is sensitive in nature or if you prefer for it to remain confidential,
please use one of the other methods identified above.
While it is Chainalysis’s desire to address matters internally, nothing in this Code should discourage
you from reporting any illegal activity, including any violation of the securities laws, antitrust laws or
any other federal, state or foreign law, rule or regulation, to the appropriate regulatory authority. This
Code should not be construed to prohibit you from testifying, participating, or otherwise assisting inany state or federal administrative, judicial, or legislative proceeding or investigation.

14

4.6

Inquiries and Investigations

Chainalysis takes seriously all properly reported suspected inconsistencies with, or violations of, thisCode, any other Chainalysis policy, and applicable law. Chainalysis will review all such reports
promptly and determine whether it is necessary to conduct an informal inquiry or formal investigation
and, if so, initiate such inquiry or investigation. Chainalysis will determine the appropriate scope andnature of all investigations, but will endeavor to keep the reporter informed where possible andappropriate. Chainalysis will also endeavor to avoid any actual or potential conflicts of interest when
conducting such inquiries or investigations, including by restricting persons from taking part in any
investigation regarding a grievance in which they are named as an alleged wrongdoer or witness.
The results of any such inquiries and investigations, together with a recommendation as todisposition of the matter, shall be reported to the Chief Legal Officer for action.
Results and any reports will be treated as confidential to the largest extent possible, however, that
may not always be feasible based on the nature of the allegation and/or Chainalysis’s reporting andcompliance obligations.
All providers are required to cooperate in such investigations. If the result of the investigation
indicates corrective action is required, Chainalysis will decide what steps it should take, including,when appropriate, legal proceedings to rectify the problem and avoid the likelihood of its recurrence.
Where required, violations of law will be brought to the attention of the appropriate law enforcement
authorities and/or disclosed to any impacted third parties.
Executive Officers and Board Members: For reports relating to alleged conduct of an executive officer
or member of the Board, the Chief Legal Officer shall determine whether to report the alleged conduct
and/or the results of any such inquiry or investigation to the Chief Executive Officer and/or Board or its
delegate(s).
Accounting Matters: All alleged violations regarding matters involving accounting, internal
accounting controls, and financial audits shall be reported to the Board or its delegate(s) by the Chief
Legal Officer.

Section 5: General
5.1

Consequences of Non-Compliance with this Code

Depending on the nature of the violation, the action may result in disciplinary action, up to andincluding termination of employment with or service to Chainalysis. As noted herein, certain conduct
in violation of this Code may also violate the law and involve civil and/or criminal penalties, and may
require Chainalysis to refer the matter to the appropriate governmental or regulatory authorities for15

investigation or prosecution. Moreover, any manager who directs or approves of any conduct inviolation of this Code, or who has knowledge of such conduct and does not immediately report it, also
will be subject to disciplinary action, up to and including termination of employment or contract.

5.2

Waivers

Any waiver of any provision of this Code by executive officers or members of the Board must be
approved in writing by the Board or its delegate(s), and any waiver by other providers must be
approved in writing by the Chief Legal Officer.

5.3

Annual Training and Acknowledgement

All providers must review and acknowledge that you have received, read, understand, and agree tocomply with this Code on an annual basis, or more often if otherwise directed by Chainalysis. Thisacknowledgement will generally occur as part of mandatory annual training provided related to this
Code.

5.4

Dissemination and Amendment

Chainalysis reserves the right to amend, alter or terminate this Code at any time for any reason,
subject to written approval by the Board or its delegate(s). The most current version of this Code canbe found on Confluence.
This document is not an employment contract between Chainalysis and any of its employees, officers
or directors and does not alter Chainalysis’s at-will employment policy in jurisdictions where suchpolicy applies.

16