Code of Ethical Business Conduct

A Letter from Chris Caldwell

Hi game-changers,

The pace at which technology and our business is changing and evolving grows

faster by the day, and as a company we are always adapting to ensure we conduct

our business with the highest integrity.

Every day we have the privilege of creating epic experiences for our clients and

their customers and they trust us to conduct business on their behalf because they

know how deeply we are committed to doing the right thing, always. We are

constantly working to give you the latest resources, education and information you

need to uphold these standards, because every choice we make both as a

company and as individuals is critical to our joint success.

So, how do we ensure we’re all at the top of our game when it comes to protecting

our business and maintaining that trust? Our Code of Ethical Business Conduct

(COEBC).

Our COEBC is one of the most important tools we use to reinforce our unwavering

commitment to integrity and keep it strong across our entire organization. It is the

overarching set of principles applicable to all staff around the world regardless of

your career level and role, and it sets the gold standard for how we operate,

provides clear expectations for how we conduct ourselves and helps us keep our

ethics present in every interaction we have.

That being said, we have not designed the COEBC as a substitute for good

judgment, and it doesn’t cover every potentially unethical situation you may

encounter. What it does do though is teach us all the basic principles and

standards we need to make the right choices to keep our business safe. If you work

proactively to apply them in your day-to-day duties and commit to the seriousness

of this responsibility, the collective impact we make will create a stronger network of

protection for our business for us, our clients and their customers.

The COEBC exemplifies the promise we make every day to protect each other and

our business, support our clients, and contribute to the communities we call home.

Thank you for doing your part to help make a safer environment for everyone by

completing it and working every day with integrity. We are growing our reputation

as not just a world class customer experience (CX) solutions and technology

leader, but the most trusted CX partner in our entire industry, and it’s all thanks to

your commitment.

If you have questions, please reach out to your People Solutions partner or the

appropriate contact for you from the list below.

Respectfully,

Chris Caldwell

Concentrix Corporation

President & CEO

@CNXPresident

Code of Ethical Business Conduct

Contents

Introduction

1 Culture Statement

3 3Vs

4 Using Our Code

6

Management Responsibilities

7 Consequences for Violating Our Code

Our

Commitment

to

Employees

8 Respecting Diversity

8 Providing Equal Opportunity

10 Forbidding Discrimination and Harassment

12

Prohibiting Substance Abuse

13

Preventing Violence

14

Protecting Privacy

15 Maintaining Product Quality and Safety

Our

Commitment

to

Our

Company

16 Using Technology Appropriately

18 Protecting Intellectual Property

20 Information and Data Security:

Confidentiality

22 Information and data Security:

Confidentiality and Third Parties

23 Social Networking

Our

Commitment

to

Shareholders

25 Avoiding Conflicts of Interest

26

Safeguarding Our Assets

27

Receiving Gifts and Entertainment

28

Prohibiting Insider Trading

30

Maintaining Accurate Records

31 Managing Our Records

Our

Commitment to

Global

Communities

32

Maintaining Fair Competition

33 Respecting Human Rights

33 Political Participation

34 Environment & Sustainability

36 Abiding by Anti-Corruption Laws (Bribes and Kickbacks)

38 Giving

Gifts and Entertainment

39 Trade Controls and Restrictions

40 Global Citizenship

40 Communicating with External Audiences

Code of Ethical Business Conduct

Seeking

Guidance and

Reporting

Concerns

41 Reporting Misconduct

43 Protecting Against Retaliation

43 Health & Safety

INTRODUCTION

1

Code of Ethical Business Conduct

INTRODUCTION

2

Code of Ethical Business Conduct

Ethical

Conduct

is

Part of Our Culture

Concentrix’s culture statement (set out in the previous page) guides

all actions of the Company and its employees.

As part of our culture, we strive to achieve the highest levels of

performance possible in everything we do;

We operate based on the sincere belief that people add value and we

endeavor to always treat others with respect and dignity;

We work together as a team to produce new ideas and delight

our clients;

We work to inspire trust and respect with everyone we work with;

We exercise honesty and sound ethical behavior in all business

transactions and in all interactions with others;

We exhibit a steadfast adherence to strict moral and ethical values;

We respect the environment in which we live and work; and

We support the protection of basic human rights throughout our

worldwide operations

INTRODUCTION

3

Code of Ethical Business Conduct

INTRODUCTION

4

Code of Ethical Business Conduct

Using

Our Code

Our Code serves many purposes. It not only sets forth behavioral expectations and

guidelines for how we should conduct business, but also references the policies and

applicable laws we must follow to uphold these expectations. In addition, our Code

guides us as we make sound, ethical decisions and provides us with the contact

information we should use when we have additional questions or concerns. Not

abiding

by the spirit and the letter of the Code can harm our Company and its

investors. Failure to follow the Code can cost an employee their job, and, if

applicable,

lead to criminal prosecution.

While our Code discusses many areas of potential ethical or legal misconduct, it

cannot possibly address every challenging situation that may occur in our

workplace.

Our operations and employees are subject to the laws of many

countries and other

jurisdictions around the world. Employees and agents acting

on behalf of our Company are expected to comply with the Code and all applicable

laws, rules, and regulations. If a

local law conflicts with our Code, we follow the

law; if a local business practice conflicts

with our Code, we follow our Code.

When in doubt as to whether an activity is proper, you should seek guidance

through one of the avenues discussed in “Seeking Guidance

and Reporting

Concerns.”

Ou

r Code applies to all employees, officers, and directors of Concentrix

Corporation, and its divisions, subsidiaries and affiliates. Collectively, these entities

will be referred to throughout this Code as “our Company” and we refer to our

employees as “game-changers” or “employees” or “staff”. The Code applies to

everything that we do and

reflects our Company’s commitments to our game-

changers, our shareholders, to the global

communities in which we work, and to

our Company itself. Our Code represents our

overall commitment to working

ethically and with integrity in all that we do.

The Regulatory Compliance Function is responsible for the administration of our

Code and reports

to the General Counsel. Any allegation of violation of our Code

must be reported to your

manager, People Solutions, or the Compliance Function,

and it will be investigated and acted upon by

the Company based on the findings

of the investigation.

To demonstrate our commitment to abide by the Code, the Company requires all

employees to certify their acceptance to adhere to the Code of Ethical Business

Conduct upon hire and annually thereafter.

Any employee seeking a waiver to any requirement of the Code may apply to the

Compliance Leader, with a clear explanation and justification for such waiver. Such

waivers may be granted by the Board of Directors of the Company depending on

the

facts of each case.

INTRODUCTION

5

Code of Ethical Business Conduct

Ask Yourself:

•

Does the action reflect our Company’s

commitment to acting with the highest

ethics and integrity?

•

Does the action harm our Company,

clients, suppliers, shareholders, or our

fellow employees?

•

Would I take this action if it were

published on the front page of a

major newspaper?

•

How would your family feel if they knew

you took the action?

If the answers to these questions leave you feeling

uncomfortable, it is safe to assume you should not

take the proposed action. Instead, seek

guidance

from either your supervisor, your Senior

Vice

President or country head, or the Legal

Department, or by filing a question with our

Company’s complaint referral website at

www.integritycounts.ca/org/concentrix.

INTRODUCTION

6

Code of Ethical Business Conduct

Management

Responsibilities

Employees in management positions are expected to be good

role models to other employees. As such, managers are

expected to be familiar enough with

our Code to effectively

communicate its guidelines and answer questions to those who

report to them. In addition, managers are encouraged to create

a

comfortable work environment that encourages employees to

come to them

with questions or concerns. Managers have a

responsibility to be alert and

sensitive to situations that could

result in actions that might violate our Code,

company policies

and/or laws and regulations and report them promptly to their

supervisors in order for our Company to be timely notified of

possible violations.

Managers have additional duties under our Code. These

include leading

by example; ensuring that those who work for

them are familiar with the policies that apply to their jobs; and

maintaining a workplace environment in

which employees feel

comfortable raising concerns. At our Company, ethical

leadership is an essential component of effective leadership.

INTRODUCTION

7

Code of Ethical Business Conduct

Consequences

for

Violating Our

Code

Each of us must comply with this

Code,

and with all Company

policies. If we fail

to do so, we may

face disciplinary action, possibly

including termination. Likewise, any

supervisor, manager, officer, or

director who is

aware of any violation

and does not promptly report and

correct it may be subject to similar

consequences. In appropriate

circumstances,

our Company will

consider taking legal action

or

referring matters to public law

enforcement

authorities for possible

prosecution.

Understand

Read, understand, and abide by

the requirements in our Code.

Embrace our Company’s

commitment to integrity.

Do your part in enforcing

compliance with our Code.

Go to your manager, company

legal counsel, or the anonymous

hot line with any questions or

concerns.

Foster a culture that prevents

retaliation against anyone who

reports actual or suspected

violations of our Code.

OUR COMMITMENT TO EMPLOYEES

8

Code of Ethical Business Conduct

Respecting

Diversity

Our Company’s Vision is to be the greatest customer engagement

company in the

world, rich in diversity and talent – powered by

creativity and talent. We respect and value the diversity reflected in

our

various backgrounds, experiences and ideas. We must each be

dedicated to providing an inclusive work environment that fosters

respect for all our coworkers,

clients, and business partners. We are

committed to treating each other fairly and

with respect.

Providing

Equal

Opportunity

Our Company follows the laws that prohibit discrimination in

employment

practices, wherever we do business. It is our

Company’s policy to provide equal

employment opportunities and to

treat applicants and employees without illegal

bias. It is our policy

that no one at our Company should ever be subject to discrimination

on the basis of: race; religion; color; national origin; age; sex;

gender

identity; disability; veteran status; sexual orientation; marital status; or

any other basis protected by law.

We fairly compensate our staff for the hours they work, allow sufficient

rest, and provide generous benefits that often go beyond statutory

minimums. We offer individuals the opportunity to develop their skills

and capabilities. Members of staff are at liberty to exercise their right

to representation, freedom of association, and collective bargaining as

provided by applicable law.

OUR COMMITMENT TO EMPLOYEES

9

Code of Ethical Business Conduct

Basic Rules

•

Make certain that your own decisions

regarding recruitment, selection,

development, and advancement of

employees are based upon merit –

qualifications, demonstrated skills, and

achievements.

•

Do not allow factors such as race, color,

religion, gender, age, national origin,

sexual

orientation, gender identity,

marital status, or disability to influence

your judgment.

•

Document instances of unsatisfactory

performance as they occur and inform

the individual of their shortcomings.

Judge employees under your

supervision based upon performance.

Do not let unrelated considerations form

a part of the performance reviews.

•

Any employee who has cause to feel

they

have not been treated fairly in

accordance with our Company’s policy of

Equal Employment Opportunity should

immediately report the incident to their

supervisor, manager, or the People

Solutions Department.

OUR COMMITMENT TO EMPLOYEES

10

Code of Ethical Business Conduct

Forbidding Discrimination

and

Harassment

Our Company has zero tolerance for

workplace

discrimination or harassment

related to any

basis protected by applicable

law, whether the

behavior is by staff, clients,

contractors,

consultants, or visitors, and

regardless of the

work setting. We are

committed to a safe,

professional, and

positive work environment

that ensures that

everyone is treated with

dignity, respect, and

courtesy.

We believe in treating one other with

respect,

whether it is a co-worker, supplier,

client, or anyone doing business with us. As

a part

of this commitment, our Company

forbids

harassment in the workplace.

Harassment is any conduct that

inappropriately or unreasonably interferes

with work performance, diminishes the

dignity of any

person, or creates an

intimidating, hostile

or otherwise offensive

work environment.

Examples include:

> Sexual advances, requests for sexual

favors, sexually explicit language, off-

color

jokes, or remarks about a

person’s body

or sexual activities.

> Displaying sexually suggestive pictures

or objects, suggestive looks or leering,

or

suggestive communication in any

form.

> Inappropriate touching.

Q. I am being teased by another

employee and I consider it

harassment of a sexual nature.

What should I do?

A. Notify the offending individual

that the conduct is not welcome and

that, if continued, it will

be reported. You should report

complaints to your immediate

supervisor or to any supervisor,

manager, or People Solutions

representative with whom you feel

comfortable. If that is not feasible,

contact.

https://Integritycounts.ca/org/concentrix

Your report can be confidential, and

you may remain anonymous; however,

you must realize that it is difficult and,

in some cases, impossible for our

Company to investigate an anonymous

complaint.

OUR COMMITMENT TO EMPLOYEES

11

Code of Ethical Business Conduct

Our Company prohibits any form of discrimination or

harassment,

including verbal or physical acts, jokes, or

slurs relating to any of the following protected classes:

Ethnicity

Color

Marital Status

Age

Gender Identity

Sexual Orientation

Physical or Mental

Disability

Pregnancy

Veteran Status

Or any other

basis

protected by law

National Origin

OUR COMMITMENT TO EMPLOYEES

12

Code of Ethical Business Conduct

Prohibiting

Substance Abuse

Substance abuse limits our ability to do our work safely, and therefore

puts us all

in jeopardy. We may never work while under the influence of

alcohol, illegal drugs,

misused prescription drugs, or over-the-counter

medications that impair our ability

to perform our jobs safely. In

addition, we may never use, possess, transfer, or sell illegal drugs or

alcohol, or misuse prescription drugs during working hours or

while on

Company premises. Our Company makes an exception to this rule

when

alcohol is transferred in a sealed container for authorized gift

purposes or is used in

moderation at an authorized Company event.

> If you are taking a legally prescribed drug that may be affecting

your

judgment or reaction time, discuss the situation with your

supervisor or a

People Solutions representative to determine if

you should report to work.

> Always follow local laws and customs when they are more

restrictive than

Company policy.

> If you observe that another employee’s performance on the job is

impaired

due to the use of alcohol, drugs, or other substances,

or that another

employee is using illegal substances or abusing

alcohol on the job, notify your supervisor, a member of

management, or the People Solutions

Department.

> Our Company recognizes that substance abuse and alcohol-

Confidential assistance

is available through our Company to all

employees who wish to inquire.

OUR COMMITMENT TO EMPLOYEES

13

Code of Ethical Business Conduct

Preventing

Violence

Our Company prohibits actual or

threatened violence against co-

workers, visitors, or anyone who

is

either on our premises or has

contact with employees in the

course of their

duties. Every

threat of violence is

serious. We

must report any such

event

immediately.

Any actual or threatened violence

should be reported immediately to

security, management, or People

Solutions, who will

determine

appropriate action, including

possible involvement of the local

police

department or other

authorities.

Any employee who ignores or violates

any of our Company’s ethical standards,

and any manager who penalizes a

subordinate for trying to follow these

ethical standards, will be subject to

corrective action, including immediate

dismissal. However, it is not the threat of

discipline that should govern your

actions. Our Company expects you to

share its belief that a dedicated

commitment to ethical behavior is the

right thing to do and is good business, as

well as being the surest way for our

Company to remain a world-class

organization.

OUR COMMITMENT TO EMPLOYEES

14

Code of Ethical Business Conduct

Protecting

Privacy

There are numerous international, federal, and state laws designed to

safeguard

the public from unwarranted dissemination of personal

information. Our Company

respects the confidentiality of our

employees’ personal information. This means

that only employees who

have authorization and a clear business need should have

access to

personal records.

Privacy protection is important. We manage your personal information

consistent

with these guiding principles:

> Keep employee records accurate and up-to-date.

> Permit access and use only for legitimate business purposes, e.g,

payroll

and benefits administration.

> Prevent disclosure to third parties except under circumstances

permitted by

our policies.

> Follow established retention and destruction policies and procedures.

> Promptly respond to any questions or concerns raised by

employees

about their records.

Please note that any records of transactions created in the course of an

employee’s work, including call recordings, that may identify the

employee(s) involved in such transaction(s) are not deemed personal

information and there should be no expectation of privacy as to such

materials.

If you have questions about your information, talk to your supervisor or People Solutions.

OUR COMMITMENT TO EMPLOYEES

15

Code of Ethical Business Conduct

Maintaining

Quality

and

Safety

We maintain our Company’s valuable

reputation by providing safe, quality

products and services. This means that

our products and services must respond

to important

client needs, must

represent superior

value to the user,

and must be reliable. We

ensure this by

following all quality processes

and

safety requirements in place in the

locations where we work. We also

comply with

all applicable standards

and regulations on the

development of

our products and services.

With a disciplined approach,

Company employees work with

great integrity to accomplish:

Customer Satisfaction First

Commitment to the

Highest Quality

Continuous Improvement

of Processes

Can-Do Attitude

Concise Communication

At our Company, we pride

ourselves in offering the highest

levels of quality products

and services. We strive for

excellence in achieving and

optimizing business results,

which reflect total quality

commitment to our customers

and vendors.

OUR COMMITMENT TO OUR COMPANY

16

Code of Ethical Business Conduct

Using Technology

Appropriately

We must use Company technology

appropriately, and we have a responsibility

to use computer, data and

telecommunication resources in a safe,

ethical, lawful, efficient, and productive

manner. Use of Company technology

must not interfere with your job duties.

Unauthorized, inappropriate or unlawful

use, relocation, or transfer of

computer, data, or telecommunication

resources

may result in disciplinary

and

legal action.

Under no circumstances should you

use our Company’s computer and

network systems to communicate,

store, or view inappropriate, sexually

explicit, or offensive statements

or materials. In addition, you may

not use these systems to access

illegal material, send unauthorized

solicitations, or conduct business for

yourself or for another organization.

You should not assume that the

communications or documents you

create, send, or receive via Company

computer, data, or telecommunication

resources are private. To the extent

allowed by applicable law, our Company

has the right to examine and monitor use

of Company assets and

communications

systems to ensure

compliance with

Company policies.

Q. Isn’t it illegal for our Company

to read my email?

A. No, it is not illegal. In fact,

an employer-provided

computer system is the

property of the employer

and, in most cases, our

Company has the right to

monitor all email traffic and

Internet surfing that occurs

on our Company systems.

OUR COMMITMENT TO OUR COMPANY

17

Code of Ethical Business Conduct

Q. What happens if a co-worker

sends me an obscene or

offensive email message? Am I

going to lose my job because of

someone else's action?

Electronic data can also be

“records” which must be

maintained by law.

A. You cannot control other

employees’ actions, but you can

control your own. If you receive

an offensive email message

from another employee, take the

following steps:

•

Do not forward, delete or reply

to the message. Leave it in

your electronic mailbox for

management to review.

•

Report the incident to your

supervisor, manager, or the

People Solutions department.

Management will handle the

situation from there.

OUR COMMITMENT TO OUR COMPANY

18

Code of Ethical Business Conduct

Protecting

Intellectual

Property

Our Company is built upon years of

hard

work and innovation by our

passionate game-changers and

the

intellectual property created by them,

including such things as patents,

trademarks,

copyrights, and trade

secrets Protecting our

intellectual

property is of critical importance,

and

we must all act collectively to ensure

that

it is not misused or

misappropriated. You

should neither

allow our intellectual property to be

used or shared with people outside

of

our Company without appropriate legal

documents in place, nor should you

infringe

the intellectual property rights

of any other companies.

Remember:

Any inventions, designs,

discoveries, ideas, concepts,

works of authorship, and trade

secrets created during the

employment relationship

-- or which arise out of an

employee’s work or are created

using our Company’s time,

materials or assets -- are

owned by our Company. Every

employee is expected to

cooperate with our Company

in documenting the ownership

of all intellectual property

developed by employees

during their employment with

our Company.

OUR COMMITMENT TO OUR COMPANY

19

Code of Ethical Business Conduct

Q. I just got offered a job by another company that

not only operates in the same area of

business

as our Company but is in fact a direct

competitor

of our Company. May I use our Company pricing

information and client contacts I learned while

performing work for our Company to assist my

potential new employer?

A. No. When you became an employee of our

Company you signed a proprietary information

and inventions agreement,” in which you

acknowledged that your employment with our

Company created a relationship of confidence

and trust between our Company and yourself,

respecting private Company information.

Consequently, you are prohibited from sharing

with any other company, any of our Company’s

proprietary information acquired by you during

your employment at our Company. Furthermore,

upon going to work for a different employer, our

Company has the right to notify your new

employer of your rights and obligations to

our

Company.

OUR COMMITMENT TO OUR COMPANY

20

Code of Ethical Business Conduct

Information and

Data

Security: Confidentiality

One of the ways we protect our intellectual and proprietary information

is by

keeping that information confidential. Thus, every employee is

required to sign a

proprietary information and inventions agreement.

By signing this agreement, each

employee agrees to protect the

confidential information of both our Company and

others with whom

our Company does business. Our Company has substantial

relationships with its clients and vendors, which our Company expends

significant time and resources to acquire and maintain. The particulars

of these

relationships are Company confidential information and

constitute a significant and valuable asset of our Company. Employees

shall not, during or after their

employment with our Company, use their

knowledge of these relationships for any

entity other than our

Company.

Our Company recognizes that, as a result of their prior employment, our

employees

may have entered into a confidentiality agreement with that

employer requiring that

they keep in confidence that company’s

proprietary information. Employees must

ensure that they do not violate

any obligations of confidentiality to a prior employer

in connection with

their employment with the Company. This includes improperly

disclosing or using, in connection with their employment with the

Company, information that is subject to obligations of confidentiality to

the prior employer.

Also, regardless of other restrictions on confidential information, our

employees may

be entitled to immunity, including protection from

retaliation, under the Defend Trade

Secrets Act of 2016 for disclosing a

trade secret or confidential information under

certain circumstances,

such as participating or disclosing as part of a government

investigation

of a suspected violation.

OUR COMMITMENT TO OUR COMPANY

21

Code of Ethical Business Conduct

Q. I just joined our Company as a new employee. My

prior employer is one of our Company’s largest

competitors. Can I share some important

confidential marketing information that I

developed while working for this competitor?

A. No. This would breach the Code, your

obligations to your previous employer, and

might break the law as well. You are obliged

to protect your past employer's confidential

information just as Company employees are

obligated to protect our Company’s

confidential information. The general

knowledge and skills that you learned at a

prior employer may certainly be used at your

new job with our Company, but you must not

bring to our Company any confidential (or

otherwise protected materials) that you, or

others, produced for your prior employer. If

you have

any questions about the status of

any specific information you may have,

check with our Company’s Legal Department

before using it or disclosing it.

OUR COMMITMENT TO OUR COMPANY

22

Code of Ethical Business Conduct

Information and

Data

Security: Confidentiality

and

Third

Parties

In the course of our business activities, we

may have a requirement to receive

information

that others deem to be

confidential. We

should not receive or

disclose any such

information unless we

have a written

confidentiality agreement

in place that has

been approved by Legal.

We should ensure

that we treat the

information in accordance

with the terms

of the agreement, including

avoiding any

disclosure or use that is

prohibited by the

terms of the agreement.

In general, information about our clients

or our clients’ customers that we access

in connection with our provision of

services

will be subject to confidentiality

restrictions

in our agreement with the

client. Such

information should not be

disclosed or used other than as required

in connection with our

provision of

services to the clients’ customer.

Employees are also advised to refrain from

using names and/or logos of our clients

anywhere outside the company (including

pictures or verbal or written statements

that

can result in identification of our

clients or their

products), especially on

social media.

Always protect and never disclose

any confidential Company

intellectual property or any other

confidential information to third

parties.

On occasion, we may need to

share Company intellectual

property with people outside of

our Company. However, you must

never disclose

such information

without Management’s prior

approval and then only under a

written confidentiality agreement

approved by the Legal

Department.

You may not disclose, or induce

our Company to use, any

confidential or proprietary

information belonging to any

previous employer or others.

OUR COMMITMENT TO OUR COMPANY

23

Code of Ethical Business Conduct

Social

Networking

As part of our commitment to protecting confidential information, we must

exercise caution when using social media, including chat rooms, message

forums, and social networking sites. While our Company does not seek to

limit our personal

or professional interactions on such sites, we are

expected to conduct ourselves

appropriately in accordance with Company

standards. This means that we must

never disclose confidential

information of the Company, our clients or any of their clients, or other

business partners through our use of these sites. Such information also

includes names or logos of our clients or any statement that could identify

the client or its product(s) or service(s) including merely stating that we

render

services to such clients. We must also ensure that we do not

attribute our personal opinions to our Company. Never post inappropriate

or offensive materials

or material that violates our Company policies while

representing our Company. The Company may require that an employee

take down offensive or inappropriate

material or posts, and employees are

also requested to bring to our notice any such

posts that they may come

across on social media.

Our Company understands how the use of Internet social network sites and

blogs

can shape the way the public views our products, services,

employees, suppliers,

and clients. Our Company respects your right to

maintain your own blog(s) or post personal comments on social networking

sites. However, our Company is

committed to ensuring that the use of such

communications serves the needs of

our business by maintaining our

Company’s identity, integrity, and reputation in a

manner consistent with

our values and policies.

In case of any posts that could be connected with the Company, (such as

your

picture with the company name or logo taken at a company event or

sharing a

news item or video clip of the Company), please ensure that you

mention that the

comments posted by you are your personal opinions and

not that of the Company. In the event that the company finds such a post

to be inappropriate, you may still

be required to take it down.

OUR COMMITMENT TO OUR COMPANY

24

Code of Ethical Business Conduct

Q. I recently landed a large contract with a client who

I have been trying to secure for several

months.

Last night I was so excited about the new contract

that I posted the information, including the new

client’s name, on Facebook. Is this a

violation of

our Company’s policy?

A. Yes. We understand your right to engage in social

networking, such as posting information on

Facebook. However, our policy specifically

prohibits the posting of confidential Company

information on these social networking sites. By

identifying yourself as an employee of our

Company and disclosing a contract that may not

have been made public yet and the name of our

client, you have put yourself and our Company at

risk. You should delete your posting immediately

and report the violation to

your supervisor or to

the Legal Department.

OUR COMMITMENT TO SHAREHOLDERS

25

Code of Ethical Business Conduct

Avoiding Conflicts

of

Interest

We are expected to act in the best interest of our

Company at all times. This means that business

decisions should be made free from any actual or

apparent conflict of interest. We must make our

decisions based on sound business reasoning.

As a result, we need to watch for potential

conflicts

of interest.

For example, there is a likely conflict of interest if you:

> Cause our Company to engage in business

transactions with relatives or friends;

> Use nonpublic Company, client, or vendor

information for personal gain by you,

relatives,

or friends (including securities

transactions

based on such information);

> Have more than a modest financial

interest

in our Company's vendors,

clients, or competitors;

> Receive a loan, or guarantee of any

obligation,

from our Company or a third

party as a result

of your position at our

Company;

> Compete, or prepare to compete, with our

Company while still employed by our Company;

or

> Receive a loan, or guarantee of any

obligation,

from any third party as a result of

your position

at our Company.

As an employee, director, or officer of our Company, it is imperative that you avoid any interest or association that

interferes, or appears to interfere, with your independent exercise of judgment in our Company's best interests. You

should not exploit your position or relationship with our Company for personal gain.

It is our responsibility to report actual or

apparent conflicts between our work

with our Company and our family,

business, personal, or financial interests

as they develop.

In most cases, potential conflicts can be

easily resolved once they are brought

into the open and discussed. Early

disclosure and discussion facilitates the

resolution of potential conflicts before

they affect our work or our reputation.

Our Company may ask you to excuse

yourself from some relevant decisions or

add an approval step in the process if

there is a possible conflict of interest

between yourself and the matter being

discussed or approved.

OUR COMMITMENT TO SHAREHOLDERS

26

Code of Ethical Business Conduct

Safeguarding

Our

Assets

Every employee must safeguard our

Company’s property from loss or theft and

may not take such property for personal

use. Company property includes

confidential

information and other

intellectual property, software, computers,

office equipment, and

supplies. You must

appropriately secure all

Company

property within your control to prevent its

unauthorized use. Employees

may make

limited non- business use of our

Company’s electronic communications

systems, provided that such use:1) is

occasional; 2) does not interfere with your

professional responsibilities; 3) does not

diminish productivity; and 4) does not

violate

this Code or our Company’s

electronic

communications system policy

then in effect.

At our Company’s request, or upon

termination of employment, all employees

are

required to deliver to our Company all

items

that belong to our Company,

including any

data or intellectual property.

At our Company, we regularly produce

valuable, non-public ideas, strategies,

and

other kinds of business information –

“intellectual property” -- which we own and

need to protect just as we do other kinds of

property. Because it is the product of our

Company’s own hard work, various laws

allow

us to protect this information from

use by outsiders.

All employees should

protect our Company’s

property and ensure its

efficient use.

All property should

be used for legitimate

Company business

purposes.

Take care to prevent waste,

loss, damage, misuse,

theft, misappropriation, or

infringement of Company

property.

OUR COMMITMENT TO SHAREHOLDERS

27

Code of Ethical Business Conduct

Receiving

Gifts

and Entertainment

Our Company’s commitment to integrity

requires us to adhere to the highest ethical

standards, including avoiding situations that

have even the appearance of impropriety.

Business gifts and entertainment can create

goodwill in our business relationships but can

also make it hard to be objective about

the

person providing them. Our choice of

suppliers, vendors, and partners must be

based on objective factors like cost, quality,

value, service, and ability to deliver. We must

avoid the appearance of making business

decisions based on gifts received through

these relationships.

Gifts, hospitality and business amenities may

be accepted, but only if they are not given

with

an expectation of preferential treatment

in

return and are of nominal value and not

prohibited by law or known practices of the

giver. This includes promotional discounts and

programs offered by various businesses such

as those in travel, hospitality, restaurant, retail

and such other industries in the regular course

of their business to individual clients,

which

may be accepted.

Any gift, business amenity or hospitality that

is

not acceptable as above, even if received

by a

family member of the employee, whether

solicited or otherwise, shall be promptly

returned or received on behalf of the company

or otherwise reasonably handled by the

manager. Infrequent business entertainment is

appropriate provided it isn’t excessive, and it

does not create the appearance of

impropriety.

All gifts given to individuals or small groups

of

individuals (i.e, not gifts to an entire team

or

business unit) should be reported to the

manager of the most senior employee receiving

the gift(s).

Are cash or a cash equivalent

Are illegal or violate the law

Cause you to feel an obligation

Influence, or give the appearance

of influencing, business judgment

Are given as part of an agreement

to do something in return

Would violate the gift and

entertainment policy of the

giver’s employer

Are for entertainment that

is unsavory or otherwise

OUR COMMITMENT TO SHAREHOLDERS

28

Code of Ethical Business Conduct

Prohibiting

Insider

Trading

You may become aware of material information about our Company or

other companies we do business with (e.g., clients or vendors)

that is not

publicly available to all investors. It is illegal to purchase or sell securities

in a company (including stock, debt, or equity, options, and shares held

in retirement

plans) based upon “material non-public information” – this

is commonly referred to as “insider trading” -- If you engage in insider

trading, you could lose your job and

be subject to significant civil and

criminal penalties.

We must never use material non-public information about our Company

or other companies we do business with, for personal gain. In addition,

we must never pass material non-public information on to others who

may trade on

it. If you provide a “tip” to someone who then buys or sells

securities, both of you

can be convicted of insider trading.

“Non-public information” is information that is known within our

Company and has

not been publicly released. “Material information” is

information that a reasonable

investor would consider important when

deciding to buy or sell securities.

Employees w

ho are in possession of material, non-public information

may not

complete a security transaction until the first business day that

is at least 48 hours

after the time that the information is publicly released.

You should contact Legal if

you have any questions regarding what

constitutes “material non-public information”

and associated

restrictions with regard to insider trading.

OUR COMMITMENT TO SHAREHOLDERS

29

Code of Ethical Business Conduct

The following types of (positive or negative)

information, if non-public, are examples of what

might be “material,” in which case their use and

disclosure can lead to insider-trading violations:

•

Gains or losses of substantial clients

or suppliers, or significant pricing

changes;

•

New service or product offering

announcements or research results of

a significant nature;

•

Significant product defects, recalls

or modifications;

•

Major changes in senior management;

•

Significant litigation exposure due to

actual or threatened lawsuits;

•

Financial results, or projections of future

earnings or losses;

•

News of pending or proposed mergers,

acquisitions, and disposition of

subsidiaries, stock splits, new equity, or

debt offerings;

•

Impending bankruptcy or financial

liquidity problems.

Both the U.S. Securities and

Exchange Commission and

Congress are very concerned

about

maintaining the fairness

of the U.S.

securities markets.

These laws

require publicly

traded companies

to have

clear policies on

insider

trading.

OUR COMMITMENT TO SHAREHOLDERS

30

Code of Ethical Business Conduct

Maintaining

Accurate Records

Full, fair, accurate, timely, and understandable disclosures in our Company’s

periodic

reports, disclosures and regulatory filings are essential to the

success of our Company’s

business. Each of us has a duty to ensure that all

entries in our Company’s financial

records give an honest picture of the

results of our operations and our financial position.

We do this by complying

not only with our Company’s policies, but also with the laws,

rules and

regulations that govern our financial accounting and reporting.

Each of us needs to exercise the highest standard of care in contributing to

or preparing

such reports in accordance with the following guidelines:

> All our Company accounting records, as well as reports produced from

those

records, must be in accordance with the laws of each applicable

jurisdiction;

> All records must fairly and accurately reflect the transactions or

occurrences to which they relate;

> All records must fairly and accurately reflect, in reasonable detail, our

Company’s

assets, liabilities, revenues, and expenses;

> Our Company’s accounting records must not contain any false or

intentionally

misleading entries;

> No transactions should be intentionally misclassified as to accounts,

departments,

or accounting periods;

> All transactions must be supported by accurate documentation in

reasonable detail

and recorded in the proper account and in the proper

accounting period;

> You should cooperate fully with internal and external auditors to gather

information

as requested, explain processes, and suggest possible

improvements; and

> You must comply with our Company’s system of internal accounting

controls.

OUR COMMITMENT TO SHAREHOLDERS

31

Code of Ethical Business Conduct

Managing Our

Records

Various laws and good-business

practices require our Company to keep

certain business records, including

electronic records, for specific periods

of time. In addition, we may not destroy

certain relevant records when litigation,

subpoenas, audits, or investigations are

pending or anticipated. Storing

business

records longer than

necessary, however, incurs needless

costs for our Company

and prevents

the efficient retrieval and

accessibility of relevant records. We

must

all strictly comply with Company

policies

on management of company

records. For

specific information

regarding how long

to keep and how to

dispose of business

records, consult

our Records Retention

Policy or ask the

Legal Department.

The Legal Department may issue a

Legal

Hold on certain documents, in

certain

circumstances such as

litigation, and

documents subject to a

Legal Hold shall not be tampered with

or destroyed

except with the prior

written authorization

of the Legal

Department. Under such

circumstances, all instructions of the

Legal Department are to be complied

with.

The Record Retention Policy covers both

electronic (soft copy) and hard-copy

materials. They apply to ALL record types

regardless of the medium in which they

exist, including paper; email; video; hard

drive; thumb drive; and compact disc or

other electronic-storage device.

You should give special care to ensure that

records containing confidential information

are retained and disposed of in accordance

with both the Record Retention Policy and

our Company’s information-protection

policies and practices.

Q.

The accounting department receives a

letter from a customer’s attorney,

demanding that our Company fulfill

certain oral promises that our Company

allegedly made. Your manager asks you

to review your email to determine whether

you have any email messages that would

support such a promise. You identify one

email that could be construed as

constituting a promise to a person who

was unfamiliar with the customer

relationship but you believe, in good faith,

that no such promise was ever made to

the customer. Should you delete the

email?

A.

No. Our Company’s Records

Retention

Policy requires employees to preserve

all

records that may be relevant to a matter

in

which our Company reasonably

anticipates

litigation. You should immediately

contact

the Legal Department to help

determine

whether, under the circumstances, there

is

a reasonable anticipation of litigation.

OUR COMMITMENT TO GLOBAL COMMUNITIES

32

Code of Ethical Business Conduct

Maintaining

Fair

Competition

Our Company is a staunch supporter

of

free and fair competition. Our

actions in the marketplace define

who we are as a Company. By

competing based strictly on the

quality of

our services and

deliverables, and never in an

unethical manner, we uphold our

Company’s

reputation as an ethical

leader in our industry. No Company

employee, director, or officer

should

take unfair advantage of anyone

through manipulation, concealment,

or abuse

of privileged information,

misrepresentation

of material facts, or

any other unfair practice.

We

concentrate on delighting our clients,

and we will not seek to limit the

competitive

opportunities of our

rivals in deceitful or

fraudulent ways.

We must exercise caution when

interacting with competitors. We must

avoid cooperating, or even appearing to

cooperate, with competitors. We must

never discuss any of the following topics

with our Company’s competitors without

prior permission from the Legal

Department:

Pricing or pricing policies, costs,

marketing or strategic plans

Proprietary or confidential information

Technological improvements

Promotions we will conduct

with customers

Division of customers, markets,

territories, or countries

Boycotts of certain customers,

suppliers, or competitors

Joint behavior towards customers

OUR COMMITMENT TO GLOBAL COMMUNITIES

33

Code of Ethical Business Conduct

Respecting

Human Rights

Our Company supports the protection of basic human rights throughout its

worldwide operations. Our employees work with clients, suppliers, and

partners

in every region of the globe. We are truly a global enterprise and

with that comes

the responsibility to behave responsibly as a corporate

citizen in every town, in

every country, with every employee engagement,

every partner relationship, and

every client. We do this by running our

global business with great respect for

human rights. In support of this

commitment, we adhere to applicable laws relating

to working hours,

wages, human trafficking, modern slavery, child labor, and

working

conditions that are a threat to life or health. Our support for these principles

is embedded in this Code, in our position on labor relations, in our

employment

practices, and in our relationships with suppliers.

Political

Participation

Concentrix is an apolitical company and does not have the practice of

making

political contributions with respect to any party, candidate, or

issue. Employees

are free to participate in political processes, including

making contributions, in their

personal capacity. They must not,

however, do anything to create a perception

that their activity is on behalf

of the Company, and all other Company policies with relation to conduct

of personal activities using Company assets or on Company time

apply

to the conduct of political activity. The Company will not reimburse

employees

for any time spent in political activity, except to the extent

required by law.

OUR COMMITMENT TO GLOBAL COMMUNITIES

34

Code of Ethical Business Conduct

Environment &

Sustainability

We respect the environment in which we live and work. This means, in

part, that we

comply with all applicable environmental laws in all countries

in which we operate.

Our Company is also committed to protecting the

environment by minimizing the

impact of our operations.

We have a responsibility to improve the lives of our people and the health of

our planet. It’s a responsibility we take very seriously. The way we see it, we

have an incredible opportunity to use our scale as a force for good. The power

of one—amplified across our entire family of 270,000+ staff, our clients, our

suppliers, and our partners—translates to world-sized impact.

We are committed to three key areas of action:

Environmental: To care for the environment to leave it better than we found it.

Social: To create a better place for people to work and live in the

communities where we operate.

Governance: To act with integrity and do the right thing. Always.

We invite you to read our latest Sustainability Report for more detailed

information: https://www.concentrix.com/esg/

OUR COMMITMENT TO GLOBAL COMMUNITIES

35

Code of Ethical Business Conduct

We recognize and accept our

responsibility to be a good steward of the

environment and to help achieve a state

of sustainable development. In support of

these responsibilities, our Company has

established the following commitments:

•

Prevention of pollution in all its forms

•

Conservation of natural resources,

including energy, through source

reduction, reuse, and recycling

wherever practical

•

Continual environmental

performance improvement through

the involvement of all employees,

subcontractors, suppliers, and

through partnerships with

local communities

•

Integrate environmental

c onsiderations into our

business activities

OUR COMMITMENT TO GLOBAL COMMUNITIES

36

Code of Ethical Business Conduct

Abiding by Anti-Corruption

Laws (Bribes and Kickbacks)

Our Company has a zero tolerance policy

for

bribery. As such, we may never make,

accept, or offer any form of improper payment

while conducting business on our Company’s

behalf. We abide by all international laws,

treaties, and regulations that forbid bribery

of government officials, including the U.S.

Foreign Corrupt Practices Act (FCPA).

Almost every country prohibits the bribery

of

its government officials. In addition, some

countries have laws that make it illegal to bribe

officials of other countries. To be responsible

members of our business communities,

we must follow these laws wherever we do

business, regardless of local law or custom.

This means we may never offer, attempt to

offer, authorize, or promise any sort of bribe

or kickback or facilitation payments to a

government official for the

purpose of

obtaining or retaining business

or an unfair

business advantage or influencing their

official actions. Moreover, we may never

solicit or accept a bribe or

kickback. Anti-

corruption laws are complex, and the

consequences for violating these laws

are

severe. For this reason, you should avoid

any

activity that could be construed as bribery.

It is also important to note that we may

not

hire a third party to do something that

we

cannot ethically or legally do ourselves.

Engaging a third party to indirectly make an

improper payment violates this Code and anti-

corruption laws. We must carefully screen all

third parties before retaining them.

A “bribe” is anything of value,

including cash payments, gifts,

entertainment, or other business

courtesies, given in an attempt to

affect a person’s business

actions or decisions in order to

obtain a business advantage.

A “kickback” is the return of a

sum already paid or due to be

paid as a reward for awarding or

fostering business.

A “government official” can be a

national or local government

official or employee, a political

candidate, a representative of

an organization like the World

Bank, or an official or employee

of government-owned or

-controlled entities, such as

state-owned oil companies.

OUR COMMITMENT TO GLOBAL COMMUNITIES

37

Code of Ethical Business Conduct

Employees with

duties involving

transactions or

travel outside of

the

United States

must

be familiar

with the

FCPA,

the UK Anti-

Bribery Act, and

similar local laws.

Management

approval is

required

before

any gift or

payment can be

made to a

government or

public official. All

employees must

immediately

report

any

demand for a

bribe or kickback

to

the Legal

Department.

Q. I recently met an agent who can assist our

Company in obtaining business in a country

where it has been particularly difficult for us to

become established. May I engage this agent on

behalf of our Company?

A. Speak with your supervisor or the Legal

Department to ensure that the agent’s contacts

and methods are aligned with both local and

U.S.

laws. Due diligence on this agent is critical

because our Company may face legal liability

if we consciously avoid learning relevant facts.

If the agent clears due diligence, internal

procedures for obtaining business approval,

purchase orders, and legal approval must be

followed.

Q. Susan needs to obtain approval for a project

as quickly as possible. The government

employee Susan contacted offers to speed up

the approval process for a “small fee.” Can

Susan make a small payment to a government

employee to speed up the approval process?

A. No. This is known as a “facilitation payment”

and is prohibited by law as well as against

our

Company policy. Susan

may not offer or pay

any amount to facilitate government approvals,

even if it will speed up a project. Susan should

notify her manager

and the Legal Department

of this request for a

facilitation payment.

OUR COMMITMENT TO GLOBAL COMMUNITIES

38

Code of Ethical Business Conduct

Giving Gifts

and

Entertainment

We sometimes entertain our clients and suppliers in order to build or strengthen good working

relationships with them. Good judgment, discretion, and moderation should

always serve as

our guides in these situations. Providing entertainment is not appropriate

if doing so makes

us appear biased or as if we are attempting to influence a business

decision. You may offer

entertainment when it fits all of the following guidelines:

> It is incidental to a discussion of business

> It is in a setting that is appropriate for a discussion about business

> Its cost is reasonable

> The entertainment was not solicited by a client or supplier

Our Company defines “gifts” as things of value, goods and services, and meals or

entertainment that you, as the one who offers, do not attend. Gifts of cash or cash

equivalents, such as gift certificates, are never permitted. You may give gifts that meet

all

of the following criteria:

> Are of modest value;

> Will not be viewed as a bribe or payoff or a facilitation payment;

> Are consistent with generally accepted business practices and ethical standards;

> Would not embarrass our Company if publicly disclosed; and

> Are not cash or cash equivalent (including gift certificates and vouchers).

The giving of gifts and entertainment to government officials, including employees of

government-owned or -controlled companies, is also subject to the requirements of

this

Code. When giving gifts or offering to entertain a business partner, ensure that

your offer

does not violate the recipient’s own policies. If you work with public officials,

be aware that

even simple offers, such as purchasing a meal or refreshments, may be

unacceptable or

even against the law.

In some locations it is customary to provide items of nominal value (e.g. sweets or Concentrix

logoed mugs and similar items) to government officials. However, providing gifts of even

nominal value to a government official requires special consideration to ensure compliance

with applicable laws. You should consult with Compliance prior to providing anything of

value to a government official.

Note that government officers and employees of government-controlled companies, both in the U.S. and

abroad, are subject to strict government standards. Violation of these standards can result in civil and

criminal

penalties for individuals, our Company, and the officers in question. Please refer to Abiding by

Anti-Corruption

Laws in the section titled “Our Commitment to Global Communities” in this Code.

OUR COMMITMENT TO GLOBAL COMMUNITIES

39

Code of Ethical Business Conduct

Trade

Controls and

Restrictions

As a global company, we may deliver

goods,

services, software, and technology

all over

the world crossing national

borders. It is

therefore critical that we

carefully comply with all national and

international rules and

regulations that

apply to our cross-border

trade activity,

which includes our imports,

exports, and

re-exports. Many countries have

laws that restrict or otherwise require

licensing

for the export and/or import of

certain goods

and services to other

countries and to certain

parties. Countries

may also impose various

kinds of trade

sanctions or embargoes against

other

countries or people. These sanctions or

embargoes typically focus on national

security, foreign policy, or humanitarian

concerns.

To maintain compliance with these

requirements when applicable to our

Company, we must screen our

international

transactions to ensure we

see no evidence

of any prohibited end-

destination, end-user, or end-use, and

watch for “red flags” that suggest a

counterpart may be trying to evade

applicable laws.

Due to the complexities of the legal

requirements under many of these

international trade laws, we must seek

guidance from the Legal Department before

exporting or importing goods or services or

engaging in transactions that might be

affected by trade sanctions.

An “export” occurs when a good,

service, software, or item of

technology is shipped or otherwise

delivered in tangible or intangible

form, to a person in another country.

An export also occurs when we

provide technology or software to

someone who is not a national of the

country where they are located (e.g.,

someone in the U.S. who is not a U.S.

citizen or U.S. permanent resident).

A re-export is the movement of the

good, software, or technology from

one foreign country to another

foreign country.

OUR COMMITMENT TO GLOBAL COMMUNITIES

40

Code of Ethical Business Conduct

Global Citizenship

Charitable activities, contributions and donations are part of the Company’s

Global Citizenship efforts and policy. Such contributions are made without

any demand or expectation of a

business return No such payment shall be

made to an individual or organization

whose goals and values are

incompatible with that of the Company. Beneficiaries of

any such

contribution shall not be related to any of the directors or the Company.

Employees are encouraged to engage in charitable activities in their

personal time

and at their personal cost, in order to give back to the

community they belong to. Such activities shall not be undertaken or

performed on behalf of the Company, and the Company will not reimburse

employees for any time and cost incurred on

account of any charitable

activity, unless the employee was acting on behalf of the

Company, with

prior written authorization to do so.

Communicating with

External

Audiences

It is important that our Company provides fair, accurate, timely, and

understandable

disclosures to the public and to governmental authorities,

both verbally and in

writing. For this reason, only designated spokespeople

are approved to respond to or communicate with outside parties -- namely

members of the media, industry

analysts, financial analysts, and investors.

By having these spokespeople on hand,

we avoid having our words taken

out of context by reporters or other members of

the media or other external

organizations. If you receive a request from the media for information, for

an interview, or to author a technical article or present a paper, you should

forward the request to a member of our Marketing team, who will handle

the

request or provide support and guidance. Similarly, requests from financial

analysts and shareholders should be forwarded to Investor Relations. If you

have

any doubt about a request, you can also contact the Legal Department

before responding to the request.

Please check with the marketing team for applicable guidelines and rules regarding brand usage

and corporate communications.

SEEKING GUIDANCE AND REPORTING CONCERNS

41

Code of Ethical Business Conduct

Reporting

Misconduct

Each of us is responsible to report any

misconduct, including violations of

this

Code, that we become aware of

multiple

channels are available for this

purpose.

We encourage employees to help

maintain

the integrity of our

Company by reporting

any

misconduct. To assist in these

efforts,

any employee of our

Company may

submit a complaint

regarding questionable

accounting

or auditing matters, instances of

corporate fraud, or violation of

applicable

laws to the management

of our Company.

If you prefer to report a question or

concern

anonymously, an

anonymous hot line is

available 24

hours a day, 365 days a year

to

respond to questions or concerns

about

ethical or legal issues, including

potential

violations of our Company’s

Code and other

policies. All questions

and/or reports will be investigated

promptly and thoroughly, consistent

with applicable law. Appropriate

answers and/or corrective or

disciplinary

action for violations of our

Code will be

applied whenever

necessary.

If you become aware of a situation that may involve

a

violation of our Code, Company policy, or any applicable

law

or regulation, you are encouraged to report it by

contacting

your manager or People Solutions. If you

pr

efer, you can also go directly to your Senior Vice

President,

country head or the Legal Department.

Alternatively,

you can also follow our Company’s Whistle-

blower

Policy and report any violations to one of the

following:

Teh

-Chien Chou Allison Leopold Tilley

Chairperson of the Audit

Committee

Pillsbury Winthrop LLP

Concentrix

Corporation 2475 Hanover Street 44201

audit@concentrix.com

Palo Alto, California

+1 94304-1114

Telephone: 650.233.4537

Company’s complaint

referral

website at:

www.integritycounts.ca/

org/concentrix

SEEKING GUIDANCE AND REPORTING CONCERNS

42

Code of Ethical Business Conduct

How Will I Know If There

Is A Problem?

Our Code attempts to address the most-common legal and

ethical issues we might encounter. It cannot, however, address

every question that arises. When you face an ethical dilemma,

think through the issue and reference available resources, such

as Company policies and procedures.

You can assess the situation by asking yourself the

following questions:

•

Do I think my action complies with the law?

•

Does it feel like the right thing to do?

•

Does it follow our Code and all other Company policies?

•

Would I feel comfortable if others knew about it?

If you cannot answer “yes” to all of these questions, do not take

the action. Seek guidance if you have any additional questions

about the situation.

You may also come across situations that pose ethical

dilemmas while conducting business internationally. If

another country’s local laws, customs, or practices conflict

with U.S. law, Company policy, or this Code, seek guidance

from the Regulatory Compliance Department or write to

coebc@concentrix.com. In such circumstances, we must

always adhere to the law, custom, or practice that is most

stringent.

SEEKING GUIDANCE AND REPORTING CONCERNS

43

Code of Ethical Business Conduct

Protecting

Against

Retaliation

Even companies with the highest ethical

standards occasionally have issues that may

arise. When they do, we want them to be

reported to us so that they can be addressed.

It is not always easy to report a question or

concern that is or even has the appearance

of

being contrary to the requirements set forth

in

our Code, Company policy or applicable

law or

regulation. Our pledge to you is that

our

Company will not retaliate against any

employee for good faith reporting of ethical

concerns or cooperating in a company

investigation. Disciplinary action may be taken

against anyone who retaliates against such

employees.

Health and Safety

Our Company strives to ensure that we provide healthy and safe conditions on our premises by

complying with applicable regulations and best practices. We aim to provide an environment with

no risk to our employees’ health and safety and provide access to care, minimizing noise, dust,

odors, particles and other sources of location pollution.

Q.

I’m concerned about

reporting a suspected fraud.

What if I am wrong and it gets

me in trouble, or I hurt

someone’s reputation?

A.

We do not hold employees

accountable for reports made in

good faith, even if they turn out

to be incorrect or unable to be

proven. We are careful when

looking into alleged wrongdoing

to ensure that employees’

reputations are protected.

Investigations are conducted in

an objective, fair and

confidential way.

RECEIPT AND ACKNOWLEDGMENT

44

Code of Ethical Business Conduct

Receipt and Acknowledgment

I have received a copy of our Company’s Code of Ethical Business

Conduct and

have read it carefully. I understand all of the guidelines,

practices, and policies

and agree to abide by them.

I understand and agree that if I violate the guidelines, practices,

and policies

in the Code of Ethical Business Conduct that I can be

disciplined for my

conduct and may even be terminated.

I understand that our Company reserves the right to change, amend,

or delete

any or all of the information contained in this Code of Ethical

Business Conduct

at any time as dictated by circumstances of

the business.

I further understand that signing this Receipt and Acknowledgment

form does

not, nor is it intended to, confer any rights or benefits or

employment, or

constitute an assurance of continued employment or

employment other than as

provided in the terms and conditions of my employment.

Signature:

Date:

Printed Name:

Employee Number:

Locations:

Waivers of any provision of the Code are generally not permitted and,

in any

event, may be granted only by the Board of Directors in writing

and must be

disclosed in accordance with applicable law. This Code

of Ethical Business

Conduct may be amended from time to time at

our Company’s discretion. The

current version of the Code will be

posted and maintained on our Company’s

intranet sites and can be

obtained from People Solutions or the Legal

Department.

CONCENTRIX Corporation

1.800.747.0583

www.concentrix.com

Version 2.4 September 2023

company, product and services names and slogans are trademarks or registered trademarks of Concentrix Corporation.

Concentrix and the Concentrix Logos Reg. U.S.