Benchling Business Partner Code of Conduct

Benchling, Inc. (“Benchling”) is committed to maintaining the highest standards of business conduct and ethics when serving our customers, including upholding fundamental human rights and fair labor practices, respecting the environment, maintaining proper compliance and controls systems, and conducting business in an ethical manner. This Business Partner Code of Conduct (the “Code of Conduct”) reflects the business practices and principles of behavior that support this commitment. We expect our vendors, distributors, technology partners, service providers, and any other party providing goods or services to or on behalf of Benchling (collectively, the “Partners”) to do the same, and to adhere to the principles outlined in this Code of Conduct while conducting business with Benchling and Benchling’s customers.

Partners are expected to report any suspected or actual violations of this Code of Conduct or related laws to their primary Benchling contact. Any Benchling employee who receives a report of a violation must immediately inform Benchling’s compliance team at Benchling may enforce violations of this Code of Conduct by taking such action(s) as it deems appropriate, including suspension or termination of the Partner’s relationship with Benchling.

Benchling may, from time to time, update this Code of Conduct to take into account changes in applicable law, or for any other reasons. This Code of Conduct does not reduce or limit other obligations Partners may have under local law and regulations or contractual obligations Partners have with Benchling or Benchling’s customers. Partners will follow all applicable laws, rules and regulations in the jurisdictions where they operate.

  1. Compliance with Laws and Regulations

    Partners will comply with all applicable laws and regulations and behave in an ethical manner, in addition to acting in compliance with this Code of Conduct, while conducting business with Benchling and Benchling’s customers.

  2. Anti-Bribery, Anti-Corruption and Ethical Business Conduct

    Partners must comply with all applicable laws and regulations on bribery, corruption, money laundering, and other prohibited business practices, including the U.S. Foreign Corrupt Practices Act, the UK Bribery Act, and other anti-corruption laws. All forms of bribery, kickbacks and other corruption are prohibited. Partners shall not offer, pay, promise, authorize, or accept any payments or anything of value for the purpose of (a) causing a person to act or fail to act in violation of a legal duty, (b) causing a person to abuse or misuse their position, or (c) securing any improper advantage in obtaining or retaining business for or with, or directing business to, any person. This prohibition on improper activities applies to interactions with government officials, political party officials and candidates for political office, as well as individuals doing business in the private sector.

  3. Export Control Laws

    Partners agree to comply with all relevant U.S. and foreign export and import laws that apply to their business and when working with Benchling and Benchling’s customers. Partners represent that they are not, and do not do any business with any entity that is, listed on any U.S. government list of prohibited or restricted parties or located in a country that is subject to a U.S. government embargo or comprehensive sanctions, or that has been designated by the U.S. government as a “terrorist supporting” country.

  4. Antitrust and Fair Competition

    Partners will conduct their business consistent with all applicable laws and regulations regarding fair competition, and should avoid any actions that violate, or create an appearance of violating, antitrust and competition laws. Partners must not make false, misleading, deceptive or fraudulent statements regarding Benchling’s products and services.

  5. Human Rights and Fair Labor Practices

    Partners are expected to provide a work environment that is free of unlawful discrimination and harassment and fully compliant with all employment, health and safety laws. Benchling will not tolerate any type of discrimination or harassment on the basis of race, color, religious creed, sex (including gender, pregnancy, childbirth, or related medical conditions), national origin, ancestry, age, physical disability, mental disability, medical condition, marital status, domestic partner status, sexual orientation, gender identity, gender expression, genetic information, military or veteran status, or any other basis protected under applicable federal, state, or local laws.

    Partners are required to comply with all applicable laws supporting fair labor and antislavery practices, as well as the UK Modern Slavery Act of 2015. Benchling prohibits the use of forced, compulsory or trafficked labor, or anyone held in slavery or servitude, whether adults or children. Partners are also expected to comply with applicable labor laws including hours, wages, and working conditions.

  6. Data Privacy

    Partners must comply with all applicable data protection laws and regulations. Any personal data provided by Benchling must be processed in accordance with these laws and any data processing agreements established between Benchling and the Partner. Partners are required to implement and maintain robust technical and organizational security measures to protect the confidentiality and integrity of personal data, aligning with industry-standard practices.

  7. Environmental Protections

    We expect Partners to comply with all applicable environmental laws and conduct its business in an environmentally responsible way that minimizes environmental impacts, such as using resources responsibly; promoting recycling, reuse, and waste reduction; and conservation of natural resources.

  8. Conflicts of Interest

    Partners must refrain from engaging in any activity or having any interest that presents – or even appears to present – a conflict of interest. In addition, Partners must disclose any transaction or relationship that reasonably could be expected to give rise to a conflict of interest, or the appearance of a conflict of interest, to the Partner’s primary Benchling contact.

  9. Confidentiality Partners may learn of information about Benchling that is confidential and proprietary. Partners who have received or have access to confidential information may only use Benchling’s confidential information for purposes of the business relationship with Benchling and should take care to keep such information confidential, including through confidentiality agreements with its employees, contractors, and other agents.

  10. Insider Trading In addition to confidential information about Benchling, Partners may have access to non-public (or “inside”) information about other companies, including other Partners and Benchling customers, as a result of their business relationship with Benchling. Partners are prohibited from using or sharing Benchling’s or other companies’ non-public information for stock trading purposes or for any other purpose except to conduct their business. Using material non-public information in connection with buying or selling securities, including “tipping” others who might make an investment decision on the basis of this information, is not only unethical, it is illegal. Partners must exercise the utmost care when handling material inside information.

  11. Reporting Violations of this Code of Conduct If Partner believes that someone associated with Benchling or one of our Partners has violated any laws, regulations, or this Code of Conduct, that Partner has a responsibility to report it. Please report these concerns to your primary Benchling contact or directly to Benchling’s compliance team ( When reporting, Partners should provide as much information as possible so we can fully investigate your report.

  12. Partner Accountability Partners are expected to cooperate with Benchling’s periodic requests for documents and/or information made in connection with Benchling’s due diligence processes and any investigation or audit by Benchling relating to any suspected or alleged violation of this Code of Conduct or applicable law.

  13. Consequences of Violation Benchling may enforce violations of this Code of Conduct by taking such action(s) as it deems appropriate, including suspension or termination of the Partner’s relationship with Benchling and cancellation of any pending fees and/or benefits due to the Partner pursuant to applicable laws and without any liability to Benchling. Certain violations of this Code of Conduct may require Benchling to refer the matter to law enforcement authorities for investigation or prosecution.