Unity Vendor Code of Conduct

Unity Technologies Vendor Code of Conduct

At Unity Technologies (“Unity”), we believe the world is a better place with more creators in it. This mission shapes the way we do business internally and how we engage with our Vendors.

I. Introduction - Unity Values and Expectations

Unity’s Vendors and their employees, agents, and subcontractors (collectively referred to as “Vendors”) serve our customers in collaboration with Unity. It is paramount to Unity that our Vendors embrace and continually build on Unity’s values. When engaging with existing or prospective customers, Unity requires its Vendors to operate in compliance with all applicable laws and regulations, and to comply with the principles outlined in this Vendor Code of Conduct.

Our values reflect the company we are and that we aspire to be. We use these guiding principles to inform how we do our jobs, and how we treat each other every day. Underpinning a commitment to ethical and responsible business practices, these values include:

• Empathy: We recognize and validate the perspectives and experiences of others, even without connecting ourselves to those experiences. It’s about listening to understand, not to respond.

• Respect: We take everyday actions that acknowledge individual experiences and perspectives.

• Opportunity: We recognize the knowledge and experience of others by empowering them to contribute, create, or lead based on their knowledge and experience.

This Vendor Code of Conduct is not intended to replace, supersede, or conflict with any applicable law, regulation, or contractual obligation with Unity.

II. Integrity and Compliance with Laws

A. Anti-Corruption: Vendors will comply with all applicable anti-corruption and anti-money laundering laws. All forms of bribery, kickbacks and other forms of corruption are prohibited. No Vendor will improperly influence any act or decision of any person, including any Public Sector person, including, without limitation, through the direct or indirect offer, promise, authorization, or provision of any improper or unlawful gifts, meals, travel, entertainment, or any other thing of value. If a Vendor is a Public Sector entity, or a Public Sector entity or person owns 15% or more of Vendor, or is any Vendor director or senior officer a Public Sector person, Vendor shall provide Transparency (as defined in this document) into such matters and contact Unity’s legal department promptly.

B. Business Records and Accounting: The business records of Vendors will be complete and accurate and conform with applicable legal, accounting, and regulatory requirements. Vendors will not place any orders for Unity, products, support, or services without the existence of a corresponding customer order or agreement in writing.

C. Third Parties Engaged: Unity Vendors should only do business with third parties that share Unity and Unity Vendors’ high ethical standards. Unity Vendors may comply with this requirement by conducting appropriate risk-based diligence on any third party that the Unity Vendor may engage regarding Unity-related business. Unity Vendors will not engage any third party in connection with any Unity-related business if the Unity Vendor knows or suspects that the third party pays bribes or otherwise acts unlawfully. Unity Vendors are responsible for ensuring that all parties engaged by a Unity Vendor in connection with Unity-related business will agree to comply with the ethics and compliance standards that are no less strict than those of this Vendor Code of Conduct.

D. Fair Competition and Antitrust laws: Unity Vendors will conduct their business in full compliance with all applicable fair competition and antitrust laws. Unity Vendors will support fair and open competition by complying with all laws and regulations related to government or other procurement, tenders, and bids. Unity Vendors will not conspire with other Vendors, including but not limited to, bid rigging, placing orders prior to tender finalization, price fixing, or other forms of collusion. In specific jurisdictions where such conduct is unlawful, Unity Vendors may not interfere with the right of other resellers to freely determine their resale price of products, limit a reseller’s right to sell products, or condition the sale of products on an agreement to buy other products. Unity Vendors may only use legal means to gather information about manufacturers or sellers of products that compete with Unity’s products.

E. Disclosure of Fees to Governmental and State-Owned Entities: If required by law or under a contract, Vendors will disclose to the applicable governmental entity customer or state-owned entity customer, the potential fees, commissions, or other compensation that Vendor will receive from Unity in connection with the products or services being procured.

F. International Trade Laws: Vendors will adhere to all applicable trade laws, including with Section 889 of the National Defense Authorization Act (2019), laws that control the import, export, and re-export of Unity products and information and laws that restrict dealings with entities and individuals located in countries subject to trade embargoes or economic sanctions.

G. Conflicts of Interest: Unity Vendors must avoid engaging in any business activity that could create a conflict between their interests as a Unity Vendor and any separate duty or obligation to provide independent advice to a customer regarding the products or services being procured. In order to avoid actual, potential, or apparent conflict of interest situations, Unity Vendors are not authorized to operate as an agent Vendor or to collect an agent commission or fee, or other type of compensation from Unity, where the Unity Vendor is under a separate duty or obligation to provide independent, unbiased advice to a customer regarding the products or services being procured.

H. Technology Fraud: Vendors are prohibited from engaging in false or deceptive business practices, including any activities which may mislead customers or consumers. These prohibited practices include engaging in technology fraud and activities which may mislead seniors, children, or other vulnerable consumers to purchase or subscribe for unneeded technical support or services. In order to better protect these vulnerable consumers, Vendors should also not engage in the “cold-calling” of such consumers for the purpose of engaging in any of those prohibited practices.

I. Sales, Advertising, and Marketing: Vendors’ sales, advertising and marketing activities will be conducted truthfully, accurately and in accordance with applicable law, rules, and regulations. Vendors will ensure that all communications to their customers are truthful, accurate, and not misleading. Unity may, at its discretion, require you to utilize Unity-approved marketing materials and reserves the right to review and approve any marketing collateral at any time during the term.

J. Insider Trading: Vendors acknowledge that Unity is a publicly traded company, and that Vendors may learn of material, non-public information regarding Unity or other companies in the course of their relationship as a Unity Vendor. Vendors will ensure that any material, non-public information obtained as a result of the Vendorship is not used for the personal gain of the Vendor, its employees, or other individuals, including by purchasing or selling Unity securities while in possession of any material non-public information. Vendors must comply with all applicable confidentiality obligations.

K. Privacy: Vendors will comply with applicable data protection laws and executed data protection provisions. Insofar as permitted by applicable data protection laws and/or such provisions, Vendor will assist Unity in demonstrating its compliance. Vendors will implement and maintain appropriate measures to ensure the security of data.

L. Intellectual Property Laws: Vendors must not infringe Unity’s trademarks and other intellectual property rights, or the intellectual property rights of third parties in any manner related to Unity-related business.

M. Transparency: If Vendor, its directors, senior officers or shareholders with 15% or more Company ownership has been (a) the subject of an internal, government, or regulatory investigation (including any involving fraud, bribery, corruption, export/sanctions compliance, or money laundering-related issues), or (b) ever been found by a court or government agency of any country to have violated a law prohibiting fraud, bribery, corruption, money laundering-related issues, sanctions/export control violations, or any other criminal or securities laws, Vendor shall promptly provide Unity’s legal department with detailed information about the incident.

III. Labor Practices & Human Rights

Vendors will provide a fair, safe, and healthy work environment compliant with all employment, health, and safety laws.

A. No Human Trafficking; No Child Labor: Human trafficking and modern slavery exist in many forms, including but not limited to slavery, domestic servitude, human trafficking, forced child labor, or forced or bonded labor. Vendors will abide by local minimum wage and maximum working hour requirements, will not use forced, compulsory, or trafficked labor, or use labor contracts that impose unreasonable limitations on a worker’s ability to leave the Vendor’s employment. The use of child labor is strictly prohibited.

B. Non-Discrimination: Vendors will not illegally discriminate in hiring, compensation, access to training, promotion, termination and/or retirement decisions based on race, color, sex, national origin, religion, age, disability, gender, gender identity or expression, marital status, parental status, medical condition, physical or mental disability, pregnancy, sexual orientation, political affiliation, union membership, military or veteran status, citizenship, genetic predisposition or carrier status, ancestry or other protected characteristic or status.

C. Anti-Harassment: Vendors will not harass Unity employees, its own employees, or the customers the Vendors serve because of race, color, sex, national origin, religion, age, disability, gender, gender identity or expression, marital status, parental status, medical condition, physical or mental disability, pregnancy, sexual orientation, political affiliation, union membership, military or veteran status, citizenship, genetic predisposition or carrier status, ancestry or other protected characteristic or status.

D. Freedom of Association: Vendors will respect the legal rights of employees to join or refrain from joining worker organizations, including trade unions. Vendors have the right to establish favorable employment conditions and to maintain effective employee communication programs as a means of promoting positive employee relations and mitigating the need for third party representation.

E. Environmental Registrations & Permits: Unity expects its Vendors to align with our commitment to environmental stewardship. Vendors are required to adhere to all relevant environmental laws and regulations, maintain active status(es) as necessary for environmental registrations and permits for their business operations, and actively implement suitable conservation measures.

F. Transparency: If Vendor had been involved in any Environmental Social Governance-related breaches that resulted in fines or penalties, litigations, or sanctions, including but not limited to issues related to human trafficking or modern slavery, Vendor shall promptly provide Unity’s legal department with detailed information about the incident.

IV. Environmental Sustainability

Vendors must comply with all applicable environmental laws, regulations, and standards in their operating regions.

A. Consumption: Vendors are expected to optimize resources used by minimizing the consumption of water, energy, and raw materials in their operations. Vendors should implement processes that enhance efficiency and reduce waste while striving for sustainable manufacturing and operational best practices. Wherever feasible, Vendors are encouraged to adopt innovative solutions and technologies that promote resource conservation and contribute to reducing environmental impact.

B. Sourced Material: Vendors are required to ensure that all materials sourced are ethically and sustainably produced, with a focus on minimizing harm to the environment and supporting responsible supply chains. This includes prioritizing materials certified by recognized sustainability standards (e.g., FSC for timber, RSPO for palm oil, etc.), and avoiding practices that contribute to deforestation, pollution, or other environmental degradation. Vendors must also ensure transparency in sourcing practices and collaborate with their own supply chains to uphold these principles.

C. Reporting: Vendors are encouraged to monitor and report key environmental metrics, including energy consumption, greenhouse gas emissions, and waste management practices. Transparent reporting on these metrics demonstrates accountability and supports continuous improvement in environmental sustainability.

V. Governance

Vendors are expected to develop a culture of compliance with a view for continuous improvement.

A. Risk Management: Vendors will maintain or establish effective business controls that are capable of preventing and detecting unlawful conduct by their employees, agents, subcontractors, and counterparties. These business controls should be adequately resourced and be periodically reviewed and updated to consider the current risk environment.

B. Training: Vendors will ensure that they have an adequate training program that achieves the appropriate levels of knowledge and skills to maintain compliance with applicable laws, regulations, and standards.

C. Cooperation: Vendors will provide reasonable assistance to Unity in connection with any investigation by Unity of a violation of this Vendor Code of Conduct or applicable law. Unity Vendors will permit Unity reasonable access to all records and other applicable documentation concerning Vendors’ compliance with this Vendor Code of Conduct and applicable laws relevant to their Vendor status and to Vendor’s sale and distribution of Unity products and services.

D. Reporting & Assistance: Vendors should contact Unity if they have any questions about this Vendor Code of Conduct or compliance concerns. Vendors also will promptly report to Unity any conduct of their employees and representatives, as well as any conduct of Unity’s employees and representatives, that is believed in good faith to be an actual, apparent, or potential violation of this Vendor Code of Conduct or applicable laws relating to the sale or distribution of Unity products and services. Reports should be directed to Unity’s Legal Compliance Team (legal_compliance@unity3d.com) or Unity’s anonymous hotline (1-855-754-3236 or www.unity3d.ethicspoint.com). Reports will be handled as confidentially as possible. Unity may enforce violations of this Vendor Code of Conduct by taking such action(s) as it deems appropriate, including suspension or termination of the Vendor’s relationship with Unity in the manner described in the applicable agreement(s) between Unity and Vendor.