GoDaddy : Speak Up Policy

Speak Up Policy

GoDaddy Speak Up Policy

Table of Contents

Introduction Chart	03
Why is Speaking Up important?
What if I just have a question?	04
Why should I get involved?
How do I encourage Speaking Up as a manager?	05
What concerns are covered by this Speak Up policy?
Our Anti-Retaliation Policy	06
Our Reporting Policy & How to Speak Up
Is it possible to report anonymously?	07
What kind of information do I need to provide?
What should I do if I don't have all the facts?
What can I expect after I Speak Up?	08
Who acts on my concerns and how?
Does my report really remain confidential?	09
Will my report be handled fairly and transparently if I Speak Up?
How does an investigation work?	10
Things to remember about investigations
What is expected of me in connection with an investigation?	11
What happens after an investigation is concluded?
What happens if this policy is misused?
What if I have additional questions?	12
External Misconduct Reporting

GoDaddy Speak Up Policy

Harassment,

discrimination, and bullying or hostile workplace

Retaliation

Criminal offenses	Fraud and
or violations of
theft
other regulations

Bribery and corruption, including gifts and entertainment

Concerned

about suspected

misconduct?

Conflicts of

interest

Accounting or		Non-adherence to
financial reporting
irregularities,		company code of
false statements,		business conduct &
deficiencies in		ethics or policies
controls

Who do I talk to?

Any of the following:

Your immediate supervisor or any member of management

People Operations

Compliance [e-mail]

The Ethics Helpline www.godaddy.com/ethicshelpline or 1-800-461-9330

The Audit Committee [e-mail]

What happens when I report?

1. INTAKE
2. ASSESS & ASSIGN
3. INVESTIGATE
4. REPORT
5. ALIGN & ACTION
6. CLOSE

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GoDaddy Speak Up Policy

Why is speaking up important?

Because we always strive to do the right thing. Our customers and employees trust us. We earned that trust because we have high standards, and we expect everyone at GoDaddy1 to uphold them. So, if you hear or see something that conflicts with our policies or values, speak up. "Speak up" means communicating with us in whatever way works best for you. GoDaddy is a safe place. We do not tolerate retaliation for reporting concerns made in good faith.

By reporting suspected misconduct, you give us the opportunity to investigate the matter and address issues. Not raising potential possible misconduct may worsen a situation and undermine trust.

1GoDaddy, or Company, is GoDaddy Inc. and its subsidiaries and affiliates.

What if I just have a question?

This Speak Up policy also covers questions! All reporting channels outlined in this policy can be used to ask for clarification on any GoDaddy policy or whether a situation might constitute misconduct.

Why should I get involved?

We recognize raising concerns may not be easy and it can sometimes feel simpler not to get involved. However, we're all tasked to Be A Guardian and protect the Company, our customers, and each other. We cannot address concerns we don't know about.

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GoDaddy Speak Up Policy

How do I encourage Speaking Up

as a manager?

Building a safe environment also requires managers to Listen Up. Reporting a concern can be a stressful experience and managers should be supportive. That starts with listening and being fully present in conversations. Managers are also expected to act as role models and encourage their teams to act with high integrity and respect at all times.

What concerns are covered by this Speak Up policy?

Any suspected violation of our Code of Business Conduct and Ethics, and Company policies or criminal offenses. Examples include: Discrimination or harassment; conflicts of interest; disclosure of confidential information; improper use of Company resources; health, environmental and safety concerns; inadequate financial or non-financial recordkeeping; violations of competition laws or rules; insider trading; fraud; human rights violations; money laundering or violations of sanctions laws; bribery; retaliation against anyone for speaking up in good faith; or violations of any other GoDaddy policy.

Do not use this policy to:

• Report events presenting an immediate threat to life or property. If you need emergency assistance, please contact your local authorities or call your country's emergency services
  phone number.
• To make accusations that you know are false. Doing so may lead to disciplinary measures.

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GoDaddy Speak Up Policy

Our Anti-Retaliation Policy

GoDaddy prohibits retaliation against any employee for reporting or participating in an investigation of a possible violation of Company policy or unlawful conduct in good faith. "In good faith" means the person making the report actually believes or perceives the information reported to be true. That person does not have to be correct as long as they are acting in good faith.

Prohibited acts of retaliation include, but are not limited to, termination, demotion, suspension, failure to hire or consider for hire, failure to give equal consideration in making employment decisions, failure to make internal employment recommendations impartially, shunning or adversely affecting working conditions or otherwise denying any employment benefit to an employee because they have reported a violation or participated in an investigation into a suspected violation in good faith. If an employee engages in retaliation in violation of this policy, their behavior is not aligned with GoDaddy's values and is deemed not to have taken place within the course and scope of employment with GoDaddy.

Our Reporting Policy & How to Speak Up

How can I Speak Up?

As a general guideline, often the best way to get your concerns addressed quickly and directly is to reach out to your direct manager, leader, or People Operations in person, by telephone, or via electronic communications. You can also reach out to any manager or leader at the Company with your concerns. However, if you don't feel comfortable using these reporting channels or would like to consider reporting anonymously, you can also report through the channels below. If you Speak Up through any of the reporting channels below, we will listen, review your concern, and conduct a prompt, thorough, and impartial investigation, if necessary.

Reports may be made through GoDaddy's third-party helpline provider online at www.godaddy.com/ethicshelpline or by phone at 1-800-461-9330 in the U.S. or the applicable country telephone number as instructed by the helpline. If local country laws prohibit certain reports via a helpline, the helpline provider will give instructions on how and to whom to report a particular concern. The helpline is available 24 hours a day, 7 days a week and accommodates multiple languages.

EMAIL

You can also send an email directly to the Compliance department at [e-mail].

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GoDaddy Speak Up Policy

Is it possible to report anonymously?

When using our ethics helpline or submitting an online report, you always have the option of remaining anonymous (where permitted by the laws of your country). We do, however, encourage reports to include identities because

it is much more difficult, and in some circumstances even impossible,

to properly or thoroughly investigate anonymous reports.

Information reported through these channels is, to the extent possible, kept confidential and only shared on a need-to-know basis with Compliance, People Operations, or Legal.

What kind of information do

I need to provide?

A report can only be thoroughly investigated if it contains sufficient information. When you report suspected misconduct, please provide as much information as possible, including details such as: the background, history, and reason for the concern; names/witnesses, dates, places, times, and other relevant information; and any documents that may support your report.

Note that some countries have their own rules on 'speaking up' and 'whistleblowing'. In those locations you have the choice of speaking up through this policy or any other channel which may be specified in your local handbook or policies. Please check the handbook or policies in your country to determine if there are additional options or approaches in your home country and, in the event of doubt, please check with [e-mail]

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GoDaddy Speak Up Policy

What should I do if I don't have all the facts?

We encourage you to Speak Up as soon as possible. It is always better to discuss a situation upfront than to report afterwards. Memories also fade over time. If you know about or suspect misconduct, Speak Up with the information you have. We do not expect you to have all the answers. Our investigations teams will look into the matter to determine if there is a reason for concern. Never investigate the matter yourself and do not seek evidence yourself in an effort to build a case. No disciplinary measures or other steps will be taken against you if your good faith concern later turns out to be mistaken.

What can I expect after I Speak Up?

GoDaddy takes every report of possible misconduct seriously. If you submit a report, you will receive confirmation of receipt within 1 to 3 business days. Unless the circumstances of your report require immediate intervention, your report will undergo an initial review, and if appropriate, it will be investigated. You will be informed of the progress and contacted once the issue has been resolved. Please note that we will not be able to give you full details of the outcome of a case (or related actions taken) for reasons of confidentiality, privacy, and the legal rights of all

parties involved.

Who acts on my concerns and how?

Based on the nature of your concerns, specific departments such as People Operations, Legal, Internal Audit, and Information Security may be assigned to conduct an investigation. Depending on the seriousness of the allegation, level at which it may have occurred, and internal departments' bandwidth, external parties (for example, law firms) may be retained to conduct the investigation.

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GoDaddy Speak Up Policy

Does my report really remain confidential?

When you Speak Up, your concern is treated with confidentiality. This means that any information you provide will only be shared with a limited number of people on a strict need-to-know basis in order to properly investigate the report or to take remedial actions. Information, including the identities of reporters and witnesses, will only be disclosed outside this small group of people if we are required to do so by law or an important public interest is at stake.

Will my report be handled fairly and transparently if

I Speak Up?

All suspected misconduct reports and resulting investigations will be conducted in an independent, fair, and unbiased manner with respect to all parties involved and in accordance with relevant laws and principles. Details of the case, your identity, and the identity of anyone else mentioned in the report are kept confidential throughout and after the investigation and are only shared on a need-to-know basis. For certain types of concerns, including retaliation, discrimination, harassment, and hostile workplace, we take other steps to ensure the safety, health, emotional well-being, and the ability to work of all involved, but especially those that Speak Up on these concerns. You can also request that investigators provide an update at any time during the investigation.

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GoDaddy Speak Up Policy

How does an investigation work?

Our investigation process typically follows six main steps, unless circumstances require otherwise:

1. INTAKE

Questions or concerns come in through any of the reporting channels outlined in this policy.

2. ASSESS & ASSIGN

The People Operations, Legal or Compliance Department will review the report to determine if an investigation is necessary and if applicable, assign the matter to an investigator.

3. INVESTIGATE

The assigned investigator will conduct background research and interview participant(s) with empathy and care. Reporters and subjects of the investigation will be able to discuss the matter with the investigator and provide information or documentation separately. Investigators may request additional information, but there is no obligation to do so.

4. REPORT

The investigator will analyze their findings and determine if a violation of policy or Code of Business Conduct & Ethics has occurred.

5. ALIGN & ACTION

The investigator will share the investigation report findings and recommendations with need-to-know partners for any necessary remedial actions.

6. CLOSE

The investigator will close the case and inform the reporter that the case is closed.

Things to remember about investigations

• To maintain the integrity of the investigative process, we ask that you keep the details of the investigation confidential.
• You should not attempt to influence the investigation by trying to persuade others to support a particular viewpoint.

• You are also prohibited from altering, destroying or removing any information or documentation relating to the issues that you know or believe may be relevant.
• At the conclusion of the investigation, you may or may not be included in any review of the findings. What we share is limited and may vary by your involvement.

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