Third Party Code of Conduct
Last Updated: October 2026
1. Purpose and Scope
Addepar, Inc. (and its affiliates, collectively “Addepar”) is committed to maintaining a safe, respectful, and professional environment for everyone who works with us or on our behalf. This Third-Party Code of Conduct (this “Code”) sets out the standards of conduct Addepar expects from its clients, vendors, suppliers, contractors, consultants, agency staff, and other external business partners (collectively, “Third Parties” and each, a “Third Party”), as well as their respective employees, agents, representatives, and sub-contractors (collectively, “Third-Party Personnel”).
This Code applies to any Third Party or Third-Party Personnel who interacts with Addepar employees, workers, or contractors (collectively, “Addepar Personnel”), whether in person at an Addepar office or event, at a Third Party's premises, remotely (including by phone, email, videoconference, or messaging platform), or at any other venue in connection with Addepar's business.
2. Our Approach
Addepar does not tolerate harassment, discrimination, bullying, or victimization in its working environment, whether by Addepar Personnel or by Third Parties and Third-Party Personnel, and expects everyone who works with us to share that standard.
This Code sets out the standards of conduct Addepar expects of Third Parties and Third-Party Personnel. It forms part of Addepar's broader approach to fostering a safe and respectful working environment, which also includes our internal policies and procedures. Through this Code, Addepar makes its expectations known to Third Parties in advance: we publish it on our website and, as described in Section 6, may reference it in our agreements. Where a concern is raised under this Code, Addepar will review it and determine what action, if any, is appropriate, as described in Sections 4 and 5.
3. Expected Standards of Conduct
3.1 Respect and Non-Harassment
Third Parties and Third-Party Personnel must treat all Addepar Personnel with courtesy, dignity, and respect. Third Parties and Third-Party Personnel must not engage in harassment of any kind, including sexual harassment.
Sexual harassment means any unwanted conduct of a sexual nature, or other unwanted conduct related to sex or gender reassignment, that has the purpose or effect of violating a person's dignity, or of creating an intimidating, hostile, degrading, humiliating, or offensive environment for them. This includes unwelcome sexual advances, requests for sexual favors, sexual comments or jokes, unwanted physical contact, and the display or circulation of sexually explicit material, whether in person, in writing, electronically, or on social media.
Third Parties and Third-Party Personnel must also not engage in harassment, bullying, discrimination, or victimization related to any other protected characteristic, including age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, or sexual orientation, or any other characteristic protected under applicable law.
3.2 Professional Conduct
Third Parties and Third-Party Personnel are expected to conduct themselves professionally in all dealings with Addepar Personnel, including by communicating respectfully and refraining from conduct that could reasonably be seen as threatening, abusive, or intimidating.
3.3 Other Standards
In addition to the anti-harassment standards above, Addepar expects vendors, suppliers, contractors, consultants and other providers of goods or services to Addepar (“Suppliers”) to:
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Comply with all applicable laws and regulations in the jurisdictions in which they operate, including anti-bribery and anti-corruption laws;
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Respect the confidentiality of Addepar's and its clients' information and comply with applicable data protection and privacy laws;
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Avoid conflicts of interest, and disclose any actual or potential conflict of interest to their Addepar contact promptly;
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Comply with applicable health and safety requirements when on Addepar premises or at Addepar-sponsored events; and
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Not engage in, or knowingly facilitate, modern slavery, forced labor, or human trafficking in their own operations or supply chains.
3.4 Responsibilities of Third Parties
Each Third Party is responsible for making sure that its Third-Party Personnel who deal with Addepar Personnel understand and follow this Code. In particular, each Third Party must:
(a) make Third-Party Personnel who interact with Addepar Personnel aware of this Code and its standards and/or Third Party’s own policy or policies which contain substantially similar rules and responsibilities;
(b) take appropriate action, in accordance with its own policies and applicable law, where its Third-Party Personnel do not meet those standards;
(c) promptly notify Addepar if it becomes aware of conduct by its Third-Party Personnel that may not meet those standards;
(d) cooperate reasonably and in good faith with any review by Addepar of a concern raised under this Code, including by making relevant individuals available where appropriate and preserving relevant records; and
(e) on Addepar's reasonable request, confirm the steps it has taken in response to a concern.
Nothing in this Section requires a Third Party to act contrary to applicable law, or to disclose confidential personnel information or legally privileged material.
4. Speaking Up, Reporting, and No Retaliation
Addepar encourages anyone — including Third Parties and Third-Party Personnel — to speak up if they experience or witness conduct that may violate this Code. Concerns may be raised with the relevant Addepar business contact, or directly and confidentially with Addepar's Legal Team or via Addepar's anonymous reporting channels.
Reports may be sent to the Legal Team (“Legal”) at legal@addepar.com, or by mail to Addepar, Inc., Attention: Legal Department, 335 Madison Avenue, 25th Floor, New York, New York 10017 USA. Reports that do not identify the sender, or that state a wish to remain anonymous, will be treated as anonymous.
Alternatively, concerns may be reported through Addepar's anonymous hotline:
Website: www.lighthouse-services.com/addepar
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Telephone — English (USA & Canada): 844-420-0044
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Telephone — Spanish (North America): 800-216-1288
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Email: standard-reports@mitratech.com (must include company name)
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Fax: (215) 689-3885 (must include company name)
Addepar will review concerns raised under this Code and determine what action, if any, is appropriate. Addepar does not tolerate retaliation against anyone who raises a concern in good faith or participates in a review. Personal data provided in connection with a concern will be processed in accordance with applicable data protection law and Addepar’s Privacy Policy.
5. Consequences of Non-Compliance
Addepar expects Third Parties and Third-Party Personnel to comply with this Code. Where Addepar determines, acting in good faith, that a Third Party or any Third-Party Personnel has not met the standards in this Code, Addepar may take the action it considers appropriate in the circumstances. This may include requesting that different individuals manage the relationship; ending or declining meetings or events; restricting or removing an individual's access to Addepar Personnel, premises, or systems; requiring additional training or a corrective action plan; and suspending or terminating the relevant contract or business relationship, in each case subject to the terms of any applicable agreement and applicable law.
6. Relationship to Contracts
Addepar publishes this Code on its website and incorporates it into its contracts with Third Parties where the applicable Order, Master Terms of Use, Supplemental Terms, or other written agreement expressly references this Code. Where this Code is incorporated into an agreement in this way, a Third Party's and its personnel's compliance with this Code forms part of that Third Party's contractual obligations to Addepar, and Addepar may exercise the contractual rights and remedies available to it under that agreement in addition to the actions described in Section 5. Addepar may also ask Third Parties to acknowledge this Code.
7. Interpretation and Legal Effect
This Code applies across every jurisdiction in which Addepar operates. Legal obligations relating to harassment and to the conduct of third parties vary by jurisdiction. Where applicable law imposes a stricter requirement than this Code, that requirement applies, and Addepar may issue local supplements to this Code.
The standards and definitions in Section 3 describe the conduct Addepar expects of Third Parties and Third-Party Personnel. They may be broader than the legal definitions in any particular jurisdiction and do not define or extend the legal obligations of Addepar or any Addepar entity. This Code does not create or assume any duty or standard of care owed by Addepar to any person beyond those imposed by applicable law, and does not create any private right of action.
This Code does not form part of any contract of employment or engagement with Addepar Personnel. Nothing in it creates contractual rights for any Third Party, Third-Party Personnel, or Addepar Personnel, except where an agreement entered into with Addepar expressly provides otherwise. This Code does not set a governing law, jurisdiction, or dispute resolution forum. Where it is incorporated into an agreement, the relevant provisions of that agreement apply.
8. Contacting Us
If you have any questions or comments about this Code, please contact us using the following contact information:
Addepar, Inc.
335 Madison Avenue, 25th Floor
New York, NY 10017