Business Partner Standards of Conduct

BUSINESS PARTNER STANDARDS OF CONDUCT

Snowflake's identity and success is built on our foundation of integrity, honesty, and ethical conduct. Our foundation depends not only on our own employees but also upon our forming relationships with business partners who share our commitment to ethical business practices. These Snowflake Business Partner Standards of Conduct ('Standards') articulate our own commitment and our expectations of our business partners.

Integrity and Compliance with Laws

Anti-Corruption

Snowflake business partners must not permit or engage in any form of corruption, extortion, or bribery - whether they are working with government officials or solely in the private sector. Snowflake business partners must not offer, give, or authorize any gift, loan, fee, reward, bribe, or other advantage to any customer, government official, government employee, or Snowflake employee to improperly influence any action or decision. All Snowflake business partners must follow applicable international anti-corruption laws, including the U.S. Foreign Corrupt Practices Act ('FCPA'), the UK Bribery Act, and the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions.

Fair Competition

While Snowflake competes vigorously in all of its business activities, we are committed to dealing fairly with our customers and competitors. Snowflake business partners must never propose, discuss, exchange information regarding, or enter into an understanding or agreement, with any competitor concerning:

• Costs, prices, discounts or other terms or conditions of sale;
• Profits or profit margins;
• Allocation of product, customers, markets, or territories;
• Limitations on production or supply;
• Boycotts of customers or suppliers; or
• Bids or the intent to bid.

Honest and Accurate Dealings

Snowflake business partners must not make any false representations in connection with any Snowflake transaction including, but not limited to, oral misrepresentations of fact or the promotion or utilization of false documentation such as non-genuine customer purchase orders, fraudulent or forged contracts, forged letters of destruction or any other false or inaccurate records.

Conflicts of Interest

Snowflake business partners must avoid activities that create or appear to create actual or potential conflicts of interest between their own interests and the interests of Snowflake. Snowflake business partners must not offer or provide gifts or excessive hospitality or entertainment to any Snowflake employee or customer or their families to obtain or retain business or to influence a decision. Snowflake employees and their family members may not hold any significant economic interest in any entity that does business with Snowflake, and business partners are required to avoid such relationships with Snowflake employees. Snowflake business partners may not engage in reselling to a government customer when the business partner has already provided consulting services to the government customer advising on the procurement of services that Snowflake provides.

Snowflake business partners must proactively raise actual or potential conflicts of interest with Snowflake so that the situation can be evaluated and addressed appropriately.

Export Controls

U.S. and international trade laws control (a) where Snowflake may send or receive its products and services, and (b) to whom Snowflake may sell its products and services. Snowflake business partners must strictly comply with applicable international trade laws and regulations.