JFROG SUPPLIER CODE OF CONDUCT

JFrog Ltd. and its affiliates (collectively, “JFrog”) are committed to conducting business ethically and with integrity. This Supplier Code of Conduct (“Code”) describes JFrog’s expectations of how our vendors, consultants, resellers and other business partners (each a “Supplier”) must act when conducting business with or on behalf of JFrog. We expect our Suppliers, including any staff, directors, agents, subcontractors and other representatives (collectively, “Representatives”), to embrace our commitment to our core values and adhere to the principles in this Code.

This Code serves as a guide, and JFrog expects each Supplier and its Representatives to use good judgment and adhere to the high ethical standards to which JFrog is committed. To ensure awareness of the Code, Suppliers are responsible for communicating and training their Representatives about these principles. JFrog reserves the right, and shall have full discretion, to take any action which it deems appropriate against Supplier if Supplier or any Representative of Supplier does not comply with the Code.

In addition, Suppliers must:

1. SAFEGUARD INFORMATION AND ASSETS
   1. Use of JFrog Assets. Use JFrog assets only for authorized business-related purposes and comply with all applicable JFrog policies and requirements when using JFrog assets, both tangible and intangible (including equipment, software, hardware, computers, servers, networks, facilities, and intellectual property).
   2. Protect Confidential and Personal Information. Maintain the confidentiality of all confidential information and comply with all applicable privacy rules and regulations.
   3. Background Checks. Conduct background checks of all personnel as required by local law and regulations.
   4. Trade Controls. Comply with trade control laws and export, re-export and import requirements.
   5. Intellectual Property. Respect intellectual property rights and conduct technology and know-how transfers in a manner protecting intellectual property rights.
2. ENSURE INTEGRITY AND TRANSPARENCY
   1. Conflicts of Interest. Avoid apparent or actual impropriety or conflict of interest.
   2. Honesty. Deal honestly in all transactions.
   3. Anti-Corruption. Comply with all applicable anti-bribery, anti-money laundering, and anti-corruption laws (including the United States Foreign Corrupt Practices Act) and not improperly influence any act or decision of any government official, employee, or political candidate, including, without limitation, through the provision of any improper or unlawful gifts, meals, travel, or entertainment.
   4. Fair Dealing. Refrain from promising anything of value to influence a business decision or engage in unfair methods of competition and unfair or deceptive acts and practices.
   5. Improper Payments. Not offer any bribe, kickback, improper gratuity, bartering arrangement for goods or services or any other incentive to a JFrog employee in order to obtain or retain JFrog business.
   6. Gifts. Only provide or receive gifts or entertainment in compliance with applicable law and Supplier’s and Frog’s policies, and otherwise only as consistent with local custom and practice. Refrain from giving JFrog employees an individual gift with a value significant enough to cause the employee to make a purchase or take or forego other action that is beneficial to Supplier and which the employee would not otherwise have taken.
   7. Insider Trading. Suppliers may have access to material non-public information about JFrog or other companies. Suppliers must comply with all insider trading and securities laws, including refraining from purchasing or selling stock on the basis of material non-public information, and recommending a stock to (i.e. “tip”) a third-party based on any such information.
   8. Responsible Sourcing. Comply with all legal requirements regarding conflict minerals, exercise proper due diligence, and maintain evidence that Supplier is in compliance.
   9. Business Records and Permits. Maintain accurate records and provide accurate disclosures regarding Supplier’s compliance with applicable law, business activities, structure, financial situation and performance, including keeping current all required operational and environmental permits, approvals and registrations, and follow all applicable reporting requirements.
3. HAVE RESPECT
   1. Diversity and Non-Discrimination. promote JFrog’s commitment to diversity, equity, and inclusion, and maintain a workforce free of harassment and unlawful discrimination, including discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste or socioeconomic circumstance, national origin, religion, age, disability, gender or gender identity, marital status, sexual orientation, union membership or political affiliation. This includes efforts to source diverse suppliers (for example, women-owned, minority-owned, LGBTQ-owned and veteran-owned businesses), regular engagement with company executives on diversity measures and efforts to reflect a diverse range of perspectives among leadership and company personnel. To the extent applicable, Supplier and its Representatives shall comply with all Federal equal employment opportunity obligations in accordance with Federal Labor Law.
   2. Health and Safety. Provide a safe and healthy work environment in compliance with all applicable occupational health, safety and environmental laws.
   3. Freedom of Association. Permit employees to associate freely, bargain collectively and seek representation in accordance with applicable law.
   4. Human Rights. Share JFrog’s commitment to human rights and act in accordance with all applicable labor and employment laws and regulations.
   5. Labor Standards. Not utilize child labor or employ any individual under the applicable legal minimum working age. Not use forced labor whether in the form of indentured, bonded or prison labor, and all workers must be free to terminate their employment at any time in compliance with applicable law.
   6. Compensation. Compensate employees fairly with a living wage and abide by local minimum wage and maximum working hours requirements.
   7. Environmental Responsibility. Comply with applicable environmental laws, regulations, and standards, including requirements for waste management, recycling, and emissions. JFrog seeks to work with Suppliers who care about their communities, and we encourage Suppliers to prioritize sustainable activities that make a positive impact on the people and the environment around us.
4. ESTABLISH COMPLIANCE PROCEDURES
   1. Communication. Supplier will communicate this Code to its Representatives who perform work for JFrog, and report any known or suspected violation of this Code (by Supplier or its Representatives) to JFrog. If there is any actual or potential conflict between this Code and your contract with JFrog, report the concern as specified below.
   2. Cooperation. JFrog is committed to maintaining a high standard on human rights and fair labor practices in its supply chain. When requested by JFrog, Supplier will provide necessary information and supporting documentation to enable JFrog to perform and complete supply chain due diligence, including disclosure of certain information from Representatives as may be required.
   3. Questions and Reporting Concerns. To report questionable behavior or a possible violation of the Code, Suppliers are encouraged to work with their primary JFrog contact in resolving their concern. If that is not possible or appropriate, please contact JFrog by email at businessconduct@jfrog.com. JFrog will maintain confidentiality to the extent possible and will not tolerate any retribution or retaliation taken against any individual who has, in good faith, sought out advice or reported questionable behavior or a possible violation of the Code.