Version: October 2026

This document provides standards for Acronis directors, officers, employees and other Personnel. For standards relating to Acronis’s Suppliers, distributors, resellers, contractors, consultants and other business partners, see the Acronis Supplier Code of Conduct.

Integrity is fundamental to how Acronis earns trust, protects customers and works with partners around the world.

This Code explains the standards we expect in our operations and from our Personnel, and how we expect the same lawful and ethical conduct from our Business Partners.

Trust is built through the decisions we make every day. Acronis is committed to conducting business lawfully, ethically and in accordance with high standards of integrity wherever we operate. Our reputation depends on the conduct of our Personnel and Business Partners.

This Code provides a practical framework for making responsible decisions, protecting the information and interests entrusted to us, treating people fairly, and raising concerns when something does not appear right. It cannot address every situation. When the right course is unclear, we expect people to pause, seek guidance and choose the course that best protects our customers, colleagues, partners and the Company.

Each Supplier is responsible for the conduct of its directors, officers, employees and other individuals who work under its direction in connection with Acronis (“Supplier Personnel”) and is expected to communicate this Acronis Supplier Code of Conduct (this “Code”) to them and take reasonable measures to promote their compliance. Supplier Personnel are not themselves Suppliers, or parties to or bound by this Code, by reason of their position with a Supplier.

We rely on every person who works for or with Acronis to uphold these standards and help us maintain a culture in which concerns can be raised on reasonable grounds without fear of retaliation.

This Code describes the core standards that guide Acronis AG and its affiliates (collectively, “Acronis” or the “Company”). It applies to Acronis’s Personnel.

In this Code, “Personnel” means Acronis’s directors, officers and employees; individuals engaged through employer-of-record, professional employer organization or similar arrangements; and interns. Contractors, consultants, agency and temporary workers, and the Business Partner Personnel (defined below).

“Business Partner” means any person or organization that is a “Supplier” as defined in the Acronis Supplier Code of Conduct, including a company or agency through which an individual provides services to Acronis. An individual engaged directly by Acronis as a contractor or consultant is a Business Partner. “Business Partner Personnel” means individuals who work for a Business Partner in connection with Acronis, referred to as “Supplier Personnel” in the Supplier Code of Conduct. Business Partner Personnel are not Personnel and are not bound by this Code by reason of their position with a Business Partner.

Acronis expects its Business Partners to maintain lawful and ethical business practices consistent with the principles of this Code. The specific obligations of a Business Partner are established by applicable law, its agreement with Acronis, and any Acronis policies or codes incorporated into that agreement, including the Acronis Supplier Code of Conduct as described in Section 14.

The Code is part of Acronis’s global compliance program. It should be read together with applicable laws, contractual commitments and more specific Acronis policies. Personnel must comply with applicable law, this Code, and the Acronis policies and contractual requirements relevant to their responsibilities. If requirements appear to conflict, or if it is unclear which requirement applies, the matter must be escalated to the Legal Department [email protected] or Human Resources before action is taken.

This Code is implemented subject to applicable local law and does not limit statutory employment, labor, consultation, collective-bargaining, privacy, reporting, or other protected rights. Where local law requires consultation, notice, consent, or a different process, Acronis will follow the applicable local requirements.

Our baseline: Act lawfully, honestly, fairly and with integrity. Protect people, information and assets. Avoid improper personal gain. Speak up promptly when something may be wrong.

Acronis expects sound judgment as well as legal compliance. Before acting, consider:

• Do I have the relevant facts and approvals?

• Is the action lawful and consistent with this Code and applicable Acronis policies?

• Could a personal interest, relationship or benefit affect, or appear to affect, my judgment?

• Would I be comfortable if the decision were reviewed by a customer, regulator or the public?

• Does the decision protect the dignity, rights and legitimate interests of affected people?

• If uncertain, have I paused and sought guidance before proceeding?

Acronis encourages Personnel, Business Partners and Business Partner Personnel to raise concerns about suspected misconduct or risks as early as possible. Concerns may include potential violations of law, this Code, Acronis policies, contractual commitments, accounting controls, human rights, information security or data protection requirements.

Nothing in this Code prohibits or restricts any individual from reporting possible violations of law to, communicating with, providing information to, or participating in an investigation or proceeding conducted by a governmental, regulatory, law-enforcement, judicial, or administrative authority. No prior authorization from Acronis is required, and individuals are not required to notify Acronis that they have made such a report or disclosure. Nothing in this Code limits any rights relating to protected disclosures or whistleblower awards under applicable law.

How to raise a concern. Concerns may be raised with a manager, Human Resources or the Legal Department, or through Acronis’s reporting platform, which is operated by an external service provider and available 24 hours a day, seven days a week.

Reports may be submitted online at https://report.syntrio.com/acronis or by email to [email protected]. Reports may be submitted confidentially and, where permitted by applicable law and supported by the platform, anonymously. Acronis will handle reports as confidentially as reasonably possible, consistent with applicable law and the need to review and address the concern. In some countries, local law limits the types of matters that may be reported through the platform or the availability of anonymous reporting. Where that is the case, Acronis will direct the reporter to an appropriate alternative channel.

What happens next. Acronis will acknowledge receipt of a report promptly, and within any period required by applicable local law, review it impartially, and provide feedback within the period that local law requires. In the EU, UK and other jurisdictions with whistleblower protections, individuals may also have the right to report to external authorities, and nothing in this Code limits that right. Personal data contained in reports is processed in accordance with applicable data protection law, as described in Acronis’s privacy statement.

No retaliation. Acronis prohibits retaliation against anyone who raises a concern, seeks advice, reports a suspected violation, or assists with an investigation, provided they have reasonable grounds to believe the information reported was true at the time of reporting. This protection also extends to people who assist a reporter and to colleagues or relatives connected to a reporter. A report made on reasonable grounds that turns out to be mistaken is not misconduct. Knowingly making a false report may be.

Company leaders and managers are expected to model the standards in this Code, make sure their teams understand them, and respond promptly and respectfully to concerns raised with them. They must escalate reported concerns to Human Resources or the Legal Department rather than investigating on their own and must never retaliate or permit retaliation.

Acronis is committed to fair employment practices and equal opportunity. Acronis does not tolerate discrimination, harassment, bullying, intimidation, abusive conduct or retaliation based on any legally protected characteristic or activity. Everyone must be treated with dignity, fairness and respect.

Acronis also works to provide a safe and healthy work environment. Personnel must follow applicable health, safety and environmental requirements, report threats or unsafe conditions, and never perform work while impaired in a way that creates a safety risk. Violence and threats of violence are prohibited. Weapons may not be brought into Acronis workplaces or activities except where expressly authorized by Acronis and permitted by applicable law, including for authorized security or law-enforcement purposes.

Personnel are encouraged to report all threats and acts of violence to their supervisor, local Human Resources representative, or the Company’s Legal Department immediately or to the local authorities if someone is in immediate danger.

Business decisions must be made in Acronis’s best interests and free from improper personal influence. A conflict can arise when personal, family, financial or outside interests interfere, or appear to interfere, with objective judgment on behalf of Acronis.

Potential conflicts must be disclosed promptly and managed through appropriate review. Examples include:

• a material financial interest in a customer, supplier or competitor;

• outside employment, consulting, board service or business activity that competes with or affects Acronis responsibilities;

• supervising, hiring, contracting with or influencing decisions involving a family member or close personal relationship;

• personal financial arrangements with parties doing business with Acronis; or

• using Acronis information, property, position or opportunities for improper personal gain.

Disclosure is protective: A potential conflict is not necessarily a violation. Failing to disclose it, or acting before it is properly reviewed, may be.

Acronis prohibits bribery and corruption in any form. No one may offer, promise, authorize, request or accept anything of value to improperly influence a decision, obtain or retain business, secure an improper advantage, or reward improper conduct. This prohibition applies to commercial dealings and interactions with public officials, directly and through third parties.

Gifts, meals, travel and entertainment must be reasonable, transparent, connected to a legitimate business purpose, accurately recorded and permitted by applicable law and Acronis policies. Cash and cash equivalents are not acceptable gifts. Extra caution and prior review are required for anything involving public officials or government entities.

Facilitation or expediting payments, including small unofficial payments to speed up routine government actions, are prohibited regardless of amount or local custom. Anyone asked for such a payment must decline and report the request to the Legal Department immediately. A lawful, published, official fee paid directly to a government entity (and not to an individual) for an officially available expedited service may be permitted only with the approval of the Legal Department and documentation showing it is the published fee, and must be accurately recorded.

Government and public-sector transactions may be subject to specialized procurement, pricing, disclosure, security, employment, and recordkeeping requirements. Personnel must not improperly obtain non-public procurement information, misrepresent products or contractual compliance, offer prohibited gratuities, or engage current or former public officials without required review.

Acronis competes through the quality and value of its products and services. We treat customers, suppliers, partners and competitors honestly and fairly. Communications about Acronis or third-party products and services must be accurate, factual and not misleading or exaggerated.

Competition laws prohibit agreements and conduct that improperly restrict competition. Personnel must not coordinate with competitors on prices, bids, customers, markets, output or other competitively sensitive matters, and must seek legal guidance before participating in conduct that could raise competition concerns.

Acronis corporate funds, assets, systems, premises, or working time may not be used for political contributions or partisan political activity unless expressly authorized and lawful. Personnel may engage in lawful political activity in a personal capacity, using their own resources and without representing that their views are those of Acronis. Political contributions, lobbying, and interactions with public officials on behalf of Acronis must follow applicable law and Acronis approval requirements.

Acronis books, records, accounts, reports and public communications must be complete, accurate, timely and understandable. Transactions and expenses must be properly authorized, documented and recorded. No one may create or preserve records intended to mislead, conceal misconduct or circumvent controls.

Records relevant to an anticipated or actual investigation, audit, dispute or legal proceeding must not be destroyed, concealed, falsified, altered or made unavailable. Acronis property, systems, funds and services must be used responsibly, protected from loss or misuse, and used only for legitimate purposes, subject to any permitted limited personal use.

Acronis protects confidential and proprietary information belonging to the Company, its customers, partners, suppliers and other third parties. Personal data must be handled lawfully, fairly, securely and only for legitimate purposes.

Personnel must:

• access and share information only on a need-to-know basis and for an authorized purpose;

• use Company-approved systems, tools and security controls;

• apply appropriate passwords, multi-factor authentication, encryption and access restrictions;

• avoid discussing or reviewing sensitive information where unauthorized people may see or hear it;

• comply with applicable privacy, data-transfer, retention and deletion requirements; and

• promptly report suspected loss, misuse, unauthorized access or disclosure.

Obligations to protect confidential information continue after an engagement with Acronis ends.

Confidential information does not include information that is publicly available or that an individual is legally entitled to disclose. Nothing in this Code restricts Personnel from discussing or disclosing their own wages, hours, benefits or other terms and conditions of employment or engagement; from disclosing information about conduct they reasonably believe to be unlawful, including harassment or discrimination; from making disclosures protected by law, including those described in Section 4; or from engaging in other activity protected by applicable law, including concerted activity protected under applicable labor law. This paragraph does not authorize the disclosure of information protected by attorney-client privilege or attorney work product, except where disclosure is expressly permitted or required by law. Personnel who are lawyers remain subject to their professional obligations.

Acronis respects intellectual property rights and expects others to do the same. Third-party software, content, data and other protected materials may be used only with appropriate authorization and in accordance with applicable license terms.

Artificial intelligence tools may support innovation and efficiency, but must be used responsibly, lawfully and in accordance with Acronis policies and requirements, including applicable AI, automated decision-making, employment, privacy and intellectual-property laws. Personnel using AI for Acronis business must use tools approved for the intended use and comply with applicable Acronis AI, security, privacy, intellectual-property and records-management requirements. AI tools must not be used to make or support decisions about individuals, such as hiring, evaluation, promotion or discipline, in a way that is unlawful or discriminatory, or to circumvent required human review, notice or consent.

Social media use must not disclose confidential information or trade secrets of Acronis, its customers or its partners. Only authorized individuals may speak on behalf of Acronis, and personal views must not be presented as Company positions. This section does not restrict the protected activity described in Section 11.

Under the U.S. Defend Trade Secrets Act (18 U.S.C. § 1833(b)), an individual will not be held criminally or civilly liable under any federal or state trade secret law for disclosing a trade secret (a) in confidence to a federal, state or local government official or to an attorney, solely for the purpose of reporting or investigating a suspected violation of law, or (b) in a complaint or other document filed under seal in a lawsuit or other proceeding. An individual who files a lawsuit for retaliation for reporting a suspected violation of law may disclose the trade secret to their attorney and use it in the court proceeding, if the individual files any document containing the trade secret under seal and does not disclose it except by court order.

Acronis conducts business globally and complies with applicable sanctions, export controls, import and customs rules, anti-boycott requirements and other international trade laws. These rules may restrict transactions involving particular countries, territories, persons, entities, products, software, technology, services, end uses or access arrangements.

Personnel involved in sales, procurement, contracting, payments, product access, service delivery, distribution or other cross-border activity must follow applicable screening, classification, due-diligence, approval, escalation and recordkeeping requirements. Transactions must not be structured, redirected, concealed or facilitated to evade legal restrictions or Acronis controls (Business Partners follow the Supplier Code of Conduct and their agreements).

Acronis expects its Business Partners to operate lawfully and ethically. Business Partners must not do or be used to do anything that Acronis could not lawfully or ethically do itself.

Risk-based due diligence, approvals, contracting and monitoring must be completed when required. Warning signs of bribery, sanctions evasion, fraud, human-rights abuse, security risk or other misconduct must not be ignored and must be escalated promptly.

Acronis is committed to preventing fraud, theft, embezzlement, money laundering, tax-evasion facilitation, false invoicing, off-book arrangements, or the concealment of the source, destination, ownership, or purpose of funds. Suspicious payment instructions, unusual commission arrangements, requests for payment to unrelated parties or jurisdictions, and other financial red flags must be escalated before a transaction proceeds.

Acronis is committed to preventing forced labor, child labor, human trafficking or modern slavery in its operations or supply chain. Acronis supports internationally recognized human rights, including the principles reflected in the United Nations Guiding Principles on Business and Human Rights and the International Labour Organization’s fundamental principles and rights at work, to the extent reflected in Acronis’s applicable policies and compliance program.

Supplier standards. Acronis’s expectations for suppliers are further described in the Acronis Supplier Code of Conduct. Business Partners must comply with the Supplier Code of Conduct to the extent it is incorporated into, or otherwise made applicable to, their agreements. The Supplier Code of Conduct addresses standards including ethical business practices, compliance with applicable laws, respect for human rights, responsible labor and environmental practices, information protection, and cooperation with appropriate due diligence and monitoring.

Contractors and consultants. Contractors, consultants, and the companies through which they are engaged, are subject to the Acronis Supplier Code of Conduct to the extent provided in or made applicable by their agreements. Acronis may also require individuals who work on Acronis premises or systems to follow workplace, security and conduct rules identified in their agreements or onboarding terms. Nothing in this Code or the Supplier Code of Conduct creates an employment, joint-employment, agency or partnership relationship, or gives Acronis control over the manner and means of a contractor’s work beyond what is permitted by the applicable agreement and law.

Acronis seeks to conduct business in a manner that supports responsible environmental, social and governance practices. Relevant decisions should consider applicable environmental, human-rights, responsible-sourcing and governance requirements. Environmental, sustainability and social-impact statements must be accurate, supportable and not misleading. Public environmental, sustainability, governance, and social-impact statements must be based on appropriate evidence, use approved methodologies where applicable, and receive required internal review before publication. More information may be found here: Acronis Sustainability & Governance.

Acronis may review and audit compliance with this Code, applicable laws and related policies. Personnel are expected to cooperate honestly with authorized reviews and investigations, preserve relevant information and avoid interfering with or retaliating against participants.

Substantiated violations may result in proportionate corrective or disciplinary action, up to and including termination of employment or a business relationship, subject to applicable law, contractual rights, and required procedures. Acronis may also seek recovery of losses or refer matters to governmental or regulatory authorities where appropriate.

This Code is maintained under Acronis’s compliance governance framework and may be amended through the applicable Company approval process. It may be updated as Acronis’s business, risk environment and legal obligations evolve.

This Code is a statement of Acronis’s conduct expectations and governance principles. Acronis expects Personnel to comply with it and, subject to applicable law and any required notice, consultation or approval, compliance is a condition of employment or engagement. Acronis may enforce this Code against Personnel in accordance with applicable law and the terms of their employment or engagement.

This Code does not create contractual rights, private rights of action or third-party beneficiary rights for any other person, and it does not amend any agreement unless that agreement expressly incorporates the Code. Individuals who work for a Business Partner have no rights or obligations under this Code by reason of that work. Any obligations on them arise through the Business Partner’s own policies and agreements, and they may raise concerns under Section 4. Where local law requires that a policy be notified to, agreed with, or approved by employees or their representatives before it can be enforced, Acronis will follow those requirements, and this Code will apply in that jurisdiction to the extent permitted.

Questions about this Code may be directed to the Company’s Legal Department: [email protected].

This Code is written in English. Translations may be published for convenience and to support understanding by Personnel and Business Partners worldwide. If there is any inconsistency or ambiguity between the English version and a translation, the English version prevails and governs interpretation, except where applicable law, a collective agreement or another binding local requirement provides that a local-language version prevails or must be provided. Translations may be published after the English version; the version date shown on the English version at https://www.acronis.com/en/legal/ identifies the current Code.