Code of Business Conduct & Ethics Our Code of Business Conduct & Ethics (the “Code”) is at the center of everything we do. It goes beyond policies, rules, and laws to provide guidance for behaving ethically and responsibly. Behaving ethically and responsibly means doing the right thing in accordance with our values in all situations. Each section of the Code provides examples of real situations and practical guidelines that help us make the right decisions based on good judgment. As we all come from different backgrounds and cultures, the Code provides a consistent ethical compass to guide our judgment and behavior as PayPal employees. Our Code applies to every employee at every level of PayPal Holdings, Inc. and its subsidiaries (collectively, the “Company”), as well as our directors. In addition, we expect third parties, including contingent workers, to act in a way that is consistent with the values outlined in our Code when they are conducting business with or on behalf of the Company. While the Code doesn’t offer an answer to every situation, the Code provides helpful contacts and resources that can advise you when the right decision is not clear. 2 Table of Contents MESSAGE FROM OUR WE RESPECT AND VALUE EACH OTHER 14 WE DO THE RIGHT THING 25 WE INTERACT OPENLY AND HONESTLY 4 39 CHIEF EXECUTIVE OFFICER Harassment, Bullying and Discrimination-Free WITH GOVERNMENTS 16 Conflicts of Interest 26 Workplace Bribery and Corruption 40 Engaging with Family and Friends 27 Appropriate Decorations And Dress for the OUR MISSION, VISION & VALUES 5 16 Gifts and Entertainment 40 Workplace Working with Family and Friends 27 Engaging in Political Activities 41 Prohibited Activities for Work-related Socializing Investments and Business Interests 28 ONE TEAM BEHAVIORS 6 16 Trade Compliance 41 and Business Travel Corporate Opportunities 28 Lobbying 42 Reporting Discrimination or Harassment 17 Business Opportunities with the Company 28 SPEAK UP – VOICING CONCERNS Requests from Government Officials & 7 Workplace Safety 18 Expert Network Firms 28 42 OR MISCONDUCT Agencies Emergency Preparedness 18 Board and Advisory Board Memberships 29 Workplace Violence 18 Outside Employment 29 WE LIVE OUR CODE 8 WE CONNECT RESPONSIBLY 43 Drugs and Alcohol 18 Bribery and Corruption 30 WITH THE PUBLIC Know Your Responsibilities 9 Mental Health and Well-Being 18 Third Party Responsibility 30 Advertising and Marketing 44 Responsibilities of Employees 10 Limits on Solicitation and Distribution 19 Money Laundering 30 Public Speaking and Statements 45 Responsibilities of People Managers 11 Gifts and Entertainment 31 Personal Use of Social Media & Guidelines 46 Speak Up! 12 WE PROTECT OUR COMPANY 20 Privacy 33 Environmental Sustainability 47 Resources 13 Company Assets and Information 21 Community Involvement & Charitable Insider Trading 34 47 Use of Company Assets 21 Contributions WE RESPECT AND VALUE EACH OTHER 14 Protecting Company Assets While Working WE DEAL FAIRLY WITH OTHERS 35 Commitment to Diversity and Inclusion 15 21 Remotely ADMINISTRATION AND RESOURCES 48 Competition and Fair Dealing 36 Open and Honest Environment 15 Return of Company Property 21 Administration of our Code 49 Competitive Intelligence 37 Equal Opportunity 15 Maintaining Business Records 21 Where to Find More Information 50 Intellectual Property of Others 38 Pay Equity 15 Accurate Accounts and Records 22 Industry Associations 38 Confidential and Proprietary Information 23 Employee Personal Data 24 3 Message from our Chief Executive Officer We have an ambitious and inclusive mission at PayPal – to democratize financial services. Together as one team, we work every day to improve the financial health of individuals and families, and to create economic opportunity for nonprofits, small businesses and merchants of all sizes. To continue to succeed in achieving this impact, we must consistently deliver world-class experiences for our customers while living our values each and every day. Our success is the cumulative result of the trust we have built with our community of stakeholders around the world. And maintaining this reputation requires us to always operate with our highest ethical standards and to do what’s right–for our customers and each other. This is the guiding light for how we function and the foundation for our Code of Business Conduct & Ethics. Think of our Code as a roadmap for navigating the decisions we face every day–to make the right choices for the various stakeholders we serve and for the purpose-driven colleagues with whom we work alongside every day. It’s critical that we always operate with the highest level of integrity. Not just because the Code says we should, but because that’s just how we do things at PayPal. Thanks for everything you do to fulfill our mission and vision, and to live our values. Dan Schulman 4 OUR MISSION, VISION & VALUES INCLUSION INNOVATION We believe that now is the time to reimagine money, to democratize financial services, because we believe that managing and moving money is a right for all citizens, not just the affluent. We believe that full participation in the global economy is a right, not a privilege. We have an obligation to empower people to exercise this right and improve financial health. As a leader in Financial Technology, we believe in providing simple, affordable, secure and reliable financial services and digital payments that enable the hopes, dreams and ambitions of millions of people around the world. It is our duty and privilege to be Customer Champions. We have a COLLABORATION WELLNESS fundamental commitment to put our customers at the center of everything we do. We must be bold and innovative and execute flawlessly against our immediate goals, with our eyes always on the future. We are One Team, valuing inclusion and collaboration, demonstrating integrity, trust, respect and empathy. We take care of ourselves, each other, and our community. 5 One Team Behaviors As One Team, our behaviors are rooted in the aspirations of our mission, vision and values, which demand a high standard for how we will lead, work and treat each other. Our One Team behaviors are designed to help us unite as a team to fulfill our extraordinary potential as a company and demonstrate how each of us can live up to being true Customer Champions. EXECUTE AND WIN CARE FOR YOURSELF RESPECT AND CREATE AMAZING AS ONE TEAM AND EACH OTHER VALUE UNIQUENESS CUSTOMER EXPERIENCES Think end-to-end beyond silos Know what recharges you and make Balance action with empathy Solve with empathy for the customer time for it Assume best intentions Be the voice of fairness and respect Think big but start small Create the space you need to do your Be transparent and accountable best work Stand up for the potential of people Fail fast to learn Support each other Treat each other with respect, kindness Actively listen and seek diversity of Be data-driven and outcome-focused and empathy thought Find common ground Persevere but know when to change course Put company first, group second, individual last 6 We’re all empowered to SPEAK UP WHEN TO SPEAK UP: CULTURE WORKPLACE SAFETY MISCONDUCT HOW TO SPEAK UP: PayPal has a strict non- retaliation policy. This means you will not be punished for reporting a violation in good faith. Good faith doesn’t mean you have to be right. It simply means you believe you are Call Escalate Email Engage providing truthful and accurate PayPal Integrity Helpline Concerns/Questions ‘SPEAK UP’ Business Ethics Officer (BEO) information about the concern http://paypal.ethicspoint.com Always remember that you can Need guidance on a question or to Reach out to your local BEO to you are raising. Available 24/7 in multiple languages, discuss concerns with your Manager, raise a concern? Email the discuss any Code of Conduct reports may be anonymous, and you HR Business Partner, or by raising a Ombuds/Ethics team at questions or issues of concern. Find can even set up an informal call with ticket to Employee Central. [email protected] the current list of BEOs at http://beo. the Ombuds/Ethics team if you have Every PayPal location has an assigned questions or need guidance. BEO. 7 We Live Our Code KNOW YOUR RESPONSIBILITIES RESPONSIBILITIES OF EMPLOYEES RESPONSIBILITIES OF PEOPLE MANAGERS SPEAK UP! RESOURCES 8 Know Your Responsibilities UNDERSTAND OUR CODE Q&A You are responsible for understanding and following the spirit and letter of the Code, as well as the Company policies and laws that apply to the work that you do. Consult the Code regularly and incorporate the principles of the Code into your work. QUESTION: What should I do when I’m faced with a business decision CONFLICTS that does not feel right to me? We are committed to ensuring that every action we take is in full compliance with the law. If there is a conflict between the Code ANSWER: or a Company policy and the law, making it impossible for you to comply with both, the law prevails. In many cases, the Code’s standards will be stricter than applicable legal requirements. In these instances, follow the Code. If you have specific questions, Follow these 3 steps if a situation makes you feel uneasy or talk to a Business Ethics Officer (BEO) or email the Ombuds/Ethics team at [email protected]. your instincts are telling you something is not quite right. • Pause before you act and consider how to approach the SEEK GUIDANCE situation. Making good decisions and ethical choices builds trust between each of us and the people we interact with. Not all situations we • Consider whether your approach is consistent with our encounter are straightforward. The Code doesn’t offer an answer to every situation. It serves as a guide to help you mission, vision and values and this Code of Conduct.