Reporting Hotline Policy

Perforce Software, Inc., a Delaware corporation, on behalf of itself and on behalf of its subsidiary companies and affiliates (“Perforce”), is committed to the highest standards of ethics, integrity, and accountability. To support this commitment, Perforce provides a public-facing reporting hotline for our contractors, suppliers, customers, partners, and other third parties to report concerns regarding suspected misconduct, unethical behavior, policy violations, unlawful activity, or any activity that may damage Perforce’s reputation.

Reporting Violations

Reports can be made anonymously or openly through the channels listed below. We encourage anyone reporting to provide as much detail as possible to allow for thorough investigations.

• Online Reporting System: www.reportit.com, code: PERFORCEHOTLINE
• Text: PERFORCEHOTLINE to 63795
• Direct Reporting: Reports can also be submitted directly to Perforce’s Legal Department: [email protected]

Protection Against Retaliation

Perforce strictly prohibits retaliation against any individual who, in good faith, reports a concern or participates in an investigation.

Confidentiality

Perforce will maintain the confidentiality of all reporters and all individuals involved in the reported issue to the fullest extent possible. Information will only be disclosed on a need-to-know basis, as required for investigation or legal proceedings.

Investigation Process

Upon receiving a report, Perforce’s Legal team will:

1. Acknowledge Receipt: Confirm the report within three (3) business days after its submission.
2. Initial Assessment: Determine if the report falls within the scope of this policy within five (5) business days of submission.
3. Investigation: If the report falls within the scope of this policy, Perforce will conduct a thorough investigation with qualified personnel. Financial matters will be handled by Perforce’s Finance team with Legal oversight, while people-related concerns will be managed by Perforce’s People and Culture team. Outside experts may be involved if necessary.
4. Status Updates: For investigations extending beyond thirty (30) days, Perforce will provide the reporter with bi-weekly status updates (if contact information was provided).
5. Resolution: Perforce aims to complete its investigation within sixty (60) days after the date of submission of the report, and Perforce will take corrective actions if misconduct is confirmed. Results and any corrective actions will be communicated to relevant parties as appropriate, while maintaining necessary confidentiality.

False Reporting

Deliberately providing false or misleading information in a report is prohibited and may result in appropriate consequences, including termination of the business relationship. This policy is intended to encourage good-faith reporting, not to pursue false accusations.

Legal Compliance

Perforce's Reporting Hotline operates in compliance with applicable whistleblower protection laws across its global operations, including:

• Various state-level whistleblower protection laws (United States);
• The EU Whistleblower Protection Directive (European Union);
• The Public Interest Disclosure Act (United Kingdom); and
• Similar protections in other jurisdictions where Perforce operates.

While Perforce is not subject to certain public company requirements (such as those under Sarbanes-Oxley), Perforce voluntarily maintains these reporter protections as part of its commitment to ethical business practices.

All personal information submitted through our reporting channels is handled in accordance with applicable data privacy laws. Perforce only collects and processes the information necessary for investigating reported concerns, and Perforce maintains appropriate security measures to protect this data.

Questions About This Policy

For questions about this reporting policy or reporting process, please contact Perforce’s Legal team at: [email protected].