CyberArk Anti-Corruption Policy Summary

• CyberArk will comply with all applicable anti-corruption laws and regulations in all countries in which we do business.
• CyberArk’s Anti-Corruption Policy applies to all directors, officers and employees of CyberArk, and all contractors, consultants or temporary personnel who devote all or substantially all of their time to CyberArk. For more information regarding our expectations from vendors and business partners, please refer to our Vendor Code of Conduct.
• Our Policy is simple: we have a zero-tolerance policy toward bribery. The Policy prohibits the improper provision (or offering to provide), directly or indirectly, anything of value to anyone (taking particular care with respect to government officials), to obtain or retain business, to obtain a commercial advantage, or to receive favored treatment, anywhere in the world.
• The Policy prohibits facilitation payments, or payments made to a government official for the purpose of expediting or securing the performance of a routine non-discretionary governmental action, directly or indirectly, regardless of local law or custom.
• CyberArk recognizes that providing reasonable and appropriate courtesies is a normal part of business, and our Policy does not prohibit legitimate and appropriate courtesies. CyberArk does prohibit using such courtesies to engage in bribery.
• Any suspected violations of the Policy should be reported to the Company’s Compliance Officer, or in accordance with our Whistleblower Policy.

31 October, 2023