Partner Code of Business Conduct
Gen Digital Inc. ("Gen") is a global company powering Digital Freedom through consumer brands including
Norton, Avast, LifeLock, Avira, AVG, ReputationDefender, and CCleaner. We bring leading technology solutions
in cybersecurity, privacy and identity protection to more than 500 million users so they can live their digital lives
safely, privately, and confidently today and for generations to come. The very nature of our business – assuring
the security and integrity of our customers’ information – requires a global culture of ethical responsibility as thefoundation for our success. We are committed to conducting business with the highest standards of integrity
and in full compliance with applicable laws and regulations around the globe. We expect the same from any
individual or entity we do business with and/or authorize to conduct business on our behalf.
This Gen Partner Code of Business Conduct (“Partner Code”) applies to all business partners involved in thedistribution, resale or commercialization of Gen products and services, whether a direct or indirect partner(“Partners”). Any violation of this Partner Code will constitute grounds for the immediate termination ofany and all agreements between you and Gen.
To that end, our Partners agree to the following principles to govern your conduct:
1. Code of Conduct: Have and enforce written codes of conduct to establish expectations for appropriate
behavior and to communicate these expectations to your respective employees, consultants and otheragents involved in Gen matters. Have means of anonymous communication such as hotlines
in your company to the extent permitted by law, and not to retaliate against whistleblowers in any way.
Establish your own policies, training, and monitoring practices to ensure compliance with the provisions of
this Partner Code and with applicable laws in general.
2. Anti-Corruption: Comply with anti-corruption laws everywhere you do business with Gen and/or on
Gen's behalf, including but not limited to, the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act.
You will not offer money or anything else of value to government officials or commercial entities in orderto obtain or retain business. Any discounts, equipment loans, marketing funds, rebates or other financial
benefits provided by Gen through an authorized program or approved incentive may not be used todisguise or facilitate any improper payment or gift giving. You will not offer or provide gifts, hospitality orentertainment to any Gen employee or family member of the Gen employee, or other Partner orcustomer, which may create an appearance of impropriety or otherwise violate Gen policies, including but
not limited to Gen’s Development Fund Policy guidelines.
3. Competition and Antitrust Law: Comply with applicable competition and antitrust laws and regulations
governing fair business, fair trade, advertising and competition, using appropriate means to safeguardcustomer information everywhere you do business with Gen and/or on Gen's behalf. You will not discuss orenter into any agreement with any competitors, including other Partners, to directly or indirectly fix prices,margins, inventory levels, division of sales territory, products, customers or suppliers.
4. Trade Compliance: Comply with all applicable import and export laws and regulations of the United Statesof America, as well as with all applicable import and export laws of the other countries in which you dobusiness, including economic sanctions and trade embargoes. (For more information, see Gen's ExportPolicy.)
5. Environmental Laws: Conduct business in an environmentally responsible manner, in compliance with allapplicable laws and regulations protecting the environment everywhere you do business on behalf of Gen.
6. Privacy and Data Security: Comply with all applicable laws and regulations governing the protection ofprivacy and data security. (For more information, see Gen's Online Privacy Statement.)

Page 1 of 2

7. Confidentiality and Intellectual Property: Not to disclose non-public information regarding businessactivities, structure, financial situation and performance, relating to Gen or any third party as provided byGen, or disclose such information of a Gen competitor to Gen. Protect and responsibly use the intellectual
assets and confidential information as disclosed to you by Gen, consistent with the authorization granted forsuch use by Gen. Comply with Gen’s requirements and industry best practices relating to confidentiality,security, data privacy and intellectual property protection.
8. Conflicts of Interest: Avoid engaging in any business activity that could create an actual or perceived conflictbetween the Partner’s interests and those of Gen. Note that Gen employees may not hold an economic
interest in any entity that does business with Gen without prior disclosure via EthicsLine.
9. Sales Integrity: Not to enter into any transaction that facilitates improper revenue recognition, expense
treatment, or other accounting improprieties on the part of either the Partner or Gen. Such irregularconduct includes, but is not limited to, placing orders with Gen when there is no firm commitment from
customer to purchase products or services, or handling inventory in any manner not consistent with ethicalbusiness practices. Violation of this section may result in liability to the Partner for which Gen will not beheld responsible, including but not limited to, removal from channel programs, etc.
10. Labor Standards: Uphold the human rights of workers and treat them with dignity and respect as
understood by the international community and proclaimed under the Universal Declaration of HumanRights and the International Labor Organization's core conventions. These rights include freely chosen
employment, avoidance of child labor, implementing fair working hours, wages and benefits, anti-humantrafficking efforts and guarantee of humane treatment, non-discrimination in employment and freedom ofassociation.
11. Lobbying Government Officials: Refrain from lobbying government officials on behalf of Gen (unlessspecifically retained by Gen for lobbying services). Lobbying generally includes activities designed toinfluence laws, regulations and policies.
12. Relations with Channel Partners and Customers: Encourage all channel partners and customers to alsoadhere to these principles.
13. Cooperation and Compliance with the Code: Maintain documents and records and conduct routine audits
to ensure compliance with the Partner Code. Cooperate timely and fully with any reasonable compliance
audit by Gen or request for certification by Gen, including without limitation, providing Gen with documents
related to Gen business and making your representatives available for interviews by Gen and/or Genrepresentatives. Have a corrective and preventative action process in place to address non-compliance withthe Partner Code.
14. Raising Concerns: Inform Gen if any situation develops that creates a risk of causing or actually causes thePartner or its representatives to act in violation of this Partner Code. Promptly contact your Gen contact towork together in resolving the concern. Compliance concerns may also be directed to Gen's EthicsLine or bye-mail. Gen's EthicsLine is available 24 hours a day, seven days a week, is confidential and toll free.
Interpreters are available if needed.

For questions regarding this Partner Code, contact your designated Gen Representative or Gen's Ethics& Compliance team.

Page 2 of 2