Page 46 - Footprint Employee Handbook 2021

We are committed to conducting our business affairs with honesty and integrity and in full compliance with all
applicable laws, rules, and regulations. No officer, director, or employee of Footprint shall commit an illegal or
unethical act, or instruct others to do so, for any reason. This includes, but is not limited to, bribery and corruption
of U.S. and foreign officials, corporate representatives, and health care professionals. In addition, if you supervise
others, you should create an environment where the employee understands the Code, the policies, laws, and
regulations that affect the workplace, their responsibilities and feels comfortable raising issues and concerns without
fear of retaliation.

If you believe that any practice raises questions as to
compliance with this Code or applicable law, rule, or regulation
or if you otherwise have questions regarding any law, rule, or
regulation, please contact the CPO or the CLO.

For more detailed information concerning Footprint’s policies
on bribery and anti-corruption, please review the Company’s
Global Anti-Corruption Policy.

TRADING ON INSIDE INFORMATION
Using non-public information to trade in securities, or providing a family member, friend or any other person with a
“tip” is illegal. This prohibition applies to you, all family members and any friend or acquaintance of yours. All non-
public information concerning any of our customers, suppliers, vendors, contractors, subcontractors and any other
entity or person with whom we do business (collectively, “Constituent Third Parties”) should be considered inside
information and should never be used for personal gain.

PROTECTION OF CONFIDENTIAL PROPRIETARY INFORMATION

Confidential proprietary information generated and gathered in our business is a valuable Footprint asset. Protecting
this information plays a vital role in our continued growth and ability to compete. All proprietary information should
be maintained in strict confidence, except when disclosure is authorized by Footprint or required by law. This means
that you should not discuss internal Footprint matters with anyone outside Footprint, except as required in the
performance of your employment duties or by law. This prohibition also means that you should not post any
information of any kind or nature concerning Footprint, its business or any officer, employee, director or agent of
Footprint, or any Constituent Third Parties to an electronic message board, “chat room” or through the use of any
other types of social media, even on an anonymous basis or in an attempt to defend Footprint.
Proprietary information includes all non-public information that might be useful to competitors or that could be harmful
to Footprint or its Constituent Third Parties if disclosed. Intellectual property such as trade secrets, patents,
trademarks, and copyrights, as well as business, research and plans, objectives and strategies, records, databases,
salary and benefits data, employee medical information, customer, employee, and suppliers lists and any
unpublished financial or pricing information must also be protected.

In addition, Footprint employees must not use or disclose confidential information concerning Constituent Third
Parties to any third-party. All Footprint employees must be respectful of proprietary information of others and should
not take any actions that would directly or indirectly infringe upon or use the patents, trademarks, copyrights,
intellectual property rights or trade secrets of others.

UPON THE COMMENCEMENT OF YOUR EMPLOYMENT WITH THE FOOTPRINT, YOU EXECUTED AN AGREEMENT TO KEEP ALL
INFORMATION IN YOUR POSSESSION CONFIDENTIAL. Unauthorized use or distribution of proprietary information violates
Footprint policy and could be illegal. Such use or distribution could result in negative consequences for both Footprint
and the individuals involved, including potential legal and disciplinary actions. We respect the property rights of other
companies and their proprietary information and require our employees, officers, and directors to observe such
rights. Your obligation to protect Footprint’s proprietary and confidential information continues even after you leave
Footprint, and you must return all proprietary and confidential information in your possession immediately upon
leaving Footprint, and not retain any such information, whether in tangible or intangible form, or any copies, extracts
or derivations thereof.

CONFLICTS OF INTEREST

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