Business Partner Code of Conduct

Purpose and General Responsibilities

It is the general policy of Cerebras Systems, Inc., and its affiliates (the "Company") to conduct its business activities and transactions with the highest level of integrity and ethical standards and in accordance with all applicable laws, rules and regulations. Obeying the law both in letter and in spirit is the foundation on which the Company's ethical standards are built. This Business Partner Code of Conduct (this "Code") sets the Company's expectations and standards for doing business and applies to agents, distributors, dealers, contractors, intermediaries, and suppliers ("Business Partners"). The following policy applies to you, our Business Partner.

The highest legal, moral, and ethical standards of honesty, integrity, and fairness are to be practiced in the conduct of the Company's affairs. In order to meet this standard, each Business Partner is expected (i) to read and understand this Code and its application to the performance of their business responsibilities and (ii) to conduct themselves in accordance with this Code and to seek to avoid even the appearance of wrongdoing or improper behavior. Those who violate the standards in this Code may be subject to a cessation of business dealings and/or the reporting of violative conduct to appropriate regulatory and criminal authorities.

This Code may be amended from time to time, and all updates are effective immediately upon posting. Other policies that govern the conduct of Business Partners may be established by the Company from time to time that supplement and are in addition to this Code.

Core Values

• Environmental Responsibility
• Integrity
• Respect
• Partnership
• Excellence in Performance
• Ethical Business Practices

Business Partners are expected to adhere to the following requirements:

Ethical Business Practices

Legal and Regulatory Compliance

• Comply with the letter and spirit of all applicable national, state or regional, and local laws and regulations in the countries in which you operate.

Freedom of Association

• Respect employees' rights to join or not join any lawful organization, and shall comply with all applicable laws pertaining to freedom of association and collective bargaining.
• Recognize employees’ freedom of association, and not to discriminate, either in favor of or against, members of employee organizations or trade unions.

Limitations on Gifts and Gratuities

• Neither accept nor give payments or gifts to the Company's employees, directors, officers, or third parties with an explicit or implicit suggestion of "quid pro quo."

Antitrust and Competition Laws

• Comply with all applicable antitrust and competition laws that prohibit agreements or actions that unreasonably restrain trade, are deceptive or misleading, or unreasonably reduce competition without providing beneficial effects to consumers.

Anti-Corruption and Bribery

• Under the U.S. Foreign Corrupt Practices Act and other applicable anti-corruption laws in the countries where we do business, must not give or offer "anything of value" to a foreign government official or employee of a state-owned enterprise, including gifts and hospitality. "Anything of value" can include bribes, kickbacks, gifts, entertainment, and even contributions to a foreign government official's favorite charity.

Anti-Money Laundering and Terrorist Financing

• Cerebras unequivocally opposes money laundering and terrorist financing. To align with our stance, we expect our Business Partner to adhere to all applicable money-laundering laws and regulations, and to refrain from engaging in any money-laundering activities, or any other activities that may aid, result in, or be perceived to constitute money laundering in any form.

No Retaliation / Reporting

• Employ a no-retaliation policy that permits workers to speak with the Company’s staff regarding violations of this Code or applicable law without fear of retaiation by management.

Conflicts of Interest

• Disclose to the Company all actual or potential conflicts of interest and make decisions impartially and based on sound business reasoning.

Work Conditions and Human Rights

Wages and Benefits

Comply with all applicable national minimum wage and hour laws and regulations and provide legally mandated benefits.

Health and Safety

Provide a safe work environment and conduct yourself in a manner consistent with all applicable safety standards, including governmental requirements, operations- and facility- specific safety requirements, and contractual requirements.

Identify and respond to any public health impacts of your operations and use of your products and services.

Non-discrimination

Must not discriminate on the basis of race, gender, religion, ethnicity, nationality, sexual orientation, and/or political beliefs.

Human Rights

• Cerebras values the human rights of workers and only conducts business with partners who share in our values. As such our Business Partners are expected to practice and adhere to the following standards related to labor and employment:
• The Business Partners must not violate basic human rights of life, liberty, and security. There shall be no harsh or inhumane treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, intimidation, threatening, abusive, exploitative, or harassment behavior (including gestures, language or physical contact) or verbal abuse of workers.
• The Business Partners must not use child labor, and each partner is expected to abide by the applicable laws and regulations of their jurisdiction as it relates to workers who have not reached the age of majority.
• The Business Partners must provide equal opportunities for its employees, contractors, and suppliers, regardless of their race, ethnicity, nationality, social background, any disability, sexual orientation, political or religious convictions, age, or gender and not engage in discrimination on any basis prohibited by applicable law.
• The Business Partners must comply with all applicable wage laws, including those related to minimum wages, maximum working time and overtime, and legally required benefits.
• The Business Partner will never under any circumstances employ anyone against their will, force them to work, exploit anyone, or tolerate human trafficking. In addition, we expect the business partner to have in place internal measures to ensure modern slavery, involuntary servitude or forced labor is not taking place within its complete value and supply chain.

Records

• By purchasing from Cerebras or by accepting any purchase order from Cerebras you agree to maintaining accurate books and records of all transactions with Cerebras and maintaining records sufficient to demonstrate your compliance with this Code of Conduct.
• Business Partners must maintain all valid licenses, permits, authorizations or registrations required under the applicable laws and regulations of the territories where you conduct business.

Privacy and Confidentiality

Privacy

• Abide by all regulations pertaining to the privacy of individuals and never disclose personal information to anyone outside the Company except as permitted by law and in the proper conduct of our business.

Confidentiality

• Protect the Company's confidential or proprietary information from any unauthorized access or disclosure.
• Comply with all applicable laws and regulations governing the protection, use, and disclosure of the Company's proprietary, confidential, and personal information.

Responsibility

Assets of the Company

• Protect the assets of the Company, as well as the assets of its customers, employees, and other Business Partners in accordance with the highest ethical standards, from theft, waste, or other types of loss.

Environmental Stewardship

• Abide by the letter and spirit of all federal, state, and local environmental laws, as well as all applicable Company policies and procedures.

Global Trade Compliance

Cerebras Business Partners shall not violate applicable trade laws, including but not limited to:

• Compliance with, restrictions on dealing with entities and individuals located in countries that are subject to trade embargoes or economic sanctions imposed by the United States and other countries where we do business;
• Not exporting products and services to embargoed countries;
• Not providing products for prohibited end uses (i.e. uses related to nuclear materials, nuclear facilities, or nuclear weapons);
• Not providing products to prohibited end users (i.e. individuals or organizations listed on the “Entity List” or “Denied Persons List” maintained by the U.S. Department of Commerce); and
• Not shipping, transferring or releasing products, technology or software requiring an export license without obtaining the appropriate authorization.
• Never seek to mislead or improperly or illegally avoid the payment of import duties, taxes and fees, and never engage in activities meant to evade the legal requirements of international traffic and trade.

Additional Obligations

Cerebras may be under an obligation with vendors to abide by such vendor’s code of conduct and to apply it to its business dealings with you. In such case, Cerebras will inform you accordingly and, by accepting or placing any purchase order from Cerebras, you agree to be bound by such Cerebras vendor’s code of conduct.

Resolving Code of Conduct or Ethics Issues

Employees of Business Partners are encouraged to work through their own company to resolve internal ethics issues. However, Business Partners should promptly report violations of this Code or any unethical behavior by an employee of the Company to the Company's Chief Legal Officer at legal@cerebras.ai.

Revised 5-1-25