Upholding Business Ethics Our Code of Business Conduct & Ethics (Code of Our Speak Up culture is espoused by our leadership and appropriate next steps, which may range from control Conduct), available in 14 languages, provides guidance actively promoted by the Ombuds/Ethics team through 100% environment enhancements to termination. for our employees, directors and everyone working for outreach and awareness sessions. Our Chief Risk and In 2022, we continued to build awareness of ESG PayPal and its subsidiaries on ethical and responsible Compliance Officer provides periodic updates to the employee completion of considerations with internal stakeholders across behavior. We refresh the Code of Conduct at least ARC Committee on significant program metrics and 2022 annual training19 the vendor lifecycle. We also conducted one-on- annually to reflect our latest programs, policies and investigations. one engagements with high-impact suppliers on expectations. Our most recent update incorporated We require every employee and contractor to complete Managing Our Supply Chain climate change and continued our efforts to support our new Leadership Principles. our annual training, which covers areas such as our supplier diversity. Read more about how we engage Code of Conduct, anti-money laundering, information Responsibly our vendors on diversity and climate change in security awareness, data privacy, anti-bribery and Due to the digital nature of our business, our supply Employees & Culture and Environmental Sustainability, Our Code of Conduct reinforces that we are all corruption, safety and security and sexual harassment chain consists primarily of the procurement of various respectively. empowered to speak up or seek advice without awareness and prevention. In addition, upon joining direct and indirect goods and services (such as IT fear of retaliation. Employees have multiple PayPal and annually thereafter, our employees must infrastructure, marketing, real estate, consulting and Committing to Political Transparency avenues to share their concerns or ask questions certify that they understand and will comply with the labor) and corporate partnerships. We work with a anonymously. Code of Conduct. small number of third parties to manufacture goods PayPal’s commitment to pursuing transparent (e.g., Zettle card readers) and do not manufacture disclosure and strong governance extends to our WHEN to speak up: Beyond our Code of Conduct, we require all employees, anything directly. lobbying and political transparency policies and third parties and other stakeholders such as contingent practices. We adopted many of the best practices Culture Workplace Safety Misconduct workers to abide by our enterprise policies, including Across our value chain, we seek to partner with third put forth by the Center for Political Accountability in our Conflict of Interest, Ethics Reporting and parties who share our commitment to business ethics. their Zicklin Index and in 2022, we maintained our Whistleblower and Anti-Bribery and Corruption All third parties and subcontractors are expected to 20 HOW to speak up: comply with our Third Party Code of Conduct & Ethics, “Trendsetter” categorization. policies. Call the confidential Integrity Helpline which sets forth our expectations regarding human and The Governance Committee oversees our political available 24/7 in multiple languages Respecting Human Rights labor rights, environmental responsibility, anti-bribery contributions, lobbying expenditures and interactions Escalate concerns or questions and improper payments, occupational health and safety, with government officials. To provide consistency with with their manager or HR business partner Our Code of Conduct outlines our commitment to consumer protection, financial crimes compliance and the Company’s business objectives and public policy managing potential human rights risks and opportunities other requirements. priorities, at least annually the committee reviews and Email the Ombuds/Ethics team across the Company, which is informed by our initial discusses with management our political activities directly using the dedicated Speak Up human rights impact assessment completed in 2021. Our third-party risk management program works to and expenditures, including those of the PayPal email alias Additionally, our Joint U.K. and Australia Modern Slavery establish appropriate risk-based due diligence for new Political Action Committee, as well as Company- Statement highlights the steps we have taken to mitigate and existing suppliers based on the potential risks and related guidelines and policies. To find out more Engage a Business Ethics Officer and prevent modern slavery and human trafficking impacts of their product or service to our business. We about PayPal’s lobbying disclosures and political in their local office practices across our Company and value chain. aim to hold our third-party partners to high standards transparency practices, please visit our Government of risk management and ethical behavior, and review Relations website. and investigate potential noncompliance to determine 19 Does not include exempt employees that are on leave during the due date of trainings. All training is tracked internally through PayPal’s Learning Management System. 20 Companies that receive a score of 90 or above indicating robust disclosure and oversight are identified as “Trendsetters” in the CPA Zicklin Index.