Supplier Code of Conduct

Gerson Lehrman Group, Inc. (“GLG”) has prepared this Supplier Code of Conduct (“Code”) to communicate GLG’s expectations of all suppliers providing goods and services to GLG, our subsidiaries and affiliates.

We expect our suppliers to monitor compliance with this Code and to take reasonable steps to address, remedy and avoid any failure to comply with this Code.

Compliance with our Code may be used as part of our supplier evaluation, selection and vendor management process. We reserve the right to verify your compliance with this Code and expect your cooperation as may reasonably be required to make this assessment. When a supplier does not meet our requirements, or refuses to take corrective action after violating this Code, we may terminate our relationship with such supplier without further liability or penalty.

Supplier Responsibilities

All new and existing suppliers are required to comply with this Code and meet the standards and principles set out herein.

1. Legal compliance; Supply Chain; Ongoing Evaluation

a. Our suppliers must comply with the laws and regulations of the applicable legal systems in which they operate or conduct business; and

b. Our suppliers must use reasonable efforts to make their own suppliers comply with the principles of this Code and check their compliance on a risk-based approach.

c. As reasonably requested by GLG, taking into consideration the nature of services provided, suppliers may be asked to complete due diligence questionnaires from time to time. Such questionnaires must be completed as promptly as practicable and the supplier must make appropriate resources available for follow-up information requests and address points for remediation within a reasonable, mutually-agreed timeframe, or GLG may terminate its relationship with the supplier without further liability or penalty

2. Ethics, anti-bribery, anti-money laundering and corruption, and sanctions; Privacy and Data Protection

a. Our suppliers must comply with all applicable laws and regulations relating to the prevention of bribery, corruption, fraud, money laundering, tax evasion or similar activities;

b. Our suppliers must avoid any conflicts of interest that may influence or appear to influence the business relationship between GLG and the supplier;

c. Our suppliers must respect, and take reasonable steps to protect, our intellectual property rights, as well as the intellectual property rights of third parties;

d. Our suppliers must comply with all applicable laws and regulations with respect to sanctions, export control and customs. In all dealings with GLG, our suppliers must not engage, directly or indirectly, in trade activities or include in their supply chain any goods or services sourced from sanctioned persons, countries, or organizations; and

e. Our suppliers must comply with applicable laws and regulations respecting privacy and personally identifiable information to the extent suppliers access any such information in the course of providing services to GLG.

3. Human rights and labor practices

a. Our suppliers, whether directly or through their supply chain, must comply with all applicable laws and regulations regarding collective bargaining, compensation for work performed and human rights in respect of their workers;

b. Our suppliers must refuse to tolerate unacceptable treatment of their employees (i.e., mental cruelty, sexual harassment, abuse, corporal punishment, or any other action or inhumane treatment that is sexual, coercive, threatening, abusive or exploitative);

c. Our suppliers must comply with all applicable discrimination laws and regulations and strive to promote equal opportunities and treatment of their employees, irrespective of skin color, race, nationality, ethnicity, political affiliation, social background, disabilities, gender, sexual identity and orientation, marital status, religious conviction, or age;

d. Our suppliers must provide their workers with access to a reasonable method to direct grievances of work-related issues (as well as issues related to services provided to GLG) and ensure protection of whistleblowers and other workers against retaliation and provide notice to GLG where applicable;

e. Our suppliers must conduct their business activities in a manner which respects human rights and must not hold another person in slavery or servitude, employ, engage, or otherwise use, forced or compulsory labor, trafficked labor or child labor; and

f. Our suppliers must source raw minerals and other raw materials in a manner that complies with applicable law and ethical business practices.

4. Health and Safety

a. Our suppliers must comply with all applicable and relevant health and safety laws and regulations.

5. Environmental and Sustainability

a. Our suppliers must comply with all applicable environmental laws and regulations, and

b. To the extent material to the services provided, suppliers must evaluate ways to reduce energy usage, greenhouse gas emissions and waste and make reasonable efforts to do so within their own supply chain.

6. Miscellaneous

a. Our suppliers must adopt and maintain a business continuity plan that is reasonably designed taking into account the nature of the services provided.

If you have any questions or concerns regarding this Code, please contact GLG’s legal department at legal@glgroup.com.