Our Core Values

We are committed to maintaining the highest ethical standards and conducting our business in full compliance with all applicable laws and regulations. Our Code of Conduct, or Code, reflects the business practices and principles of behavior that support this commitment.

Who must follow this code?

All employees, officers, and directors of SolarWinds and its affiliated companies must abide by this Code. Agents and contractors are also expected to abide by this Code. References in this Code to Solarians are intended to cover employees, officers, directors, agents, and contractors, as applicable. Many of the topics addressed in this Code are also addressed in more detail in other company policies and procedures, such as our Global Handbook, or Employee Handbook. Throughout this Code, we have included references to other relevant company policies and procedures where appropriate. This Code is intended to complement, but not replace, the policies and procedures of the Company. If any policy or procedure of the Company conflicts with this Code, you must comply with this Code. For the avoidance of doubt, nothing in this Code limits in any way the rights granted under the SolarWinds’ certificate of incorporation.

What are our duties and responsibilities?

What are the duties and responsibilities of managers?

Where do I go to ask questions and report concerns? (Whistleblower hotline link)

You are obligated to report violations of the Code, the Law, or any other Company Policy, or Procedure. If you have any questions, concerns, or need to report a known or suspected violation, you should discuss it with your manager, a people team member or legal department representative, or complete a confidential and anonymous online form at Whistleblower Hotline.

Investigations

Once a report is received, SolarWinds will investigate it promptly and thoroughly. SolarWinds expects all Solarians to cooperate in investigations fully and candidly. SolarWinds will take corrective action, as appropriate, based on the findings of the investigation.

Commitment to non-retaliation

We believe it is essential to create an environment in which individuals feel able to raise any matters of genuine concern internally without fear of disciplinary action being taken against them. SolarWinds prohibits retaliation, in any form, against anyone who, in good faith, reports violations or suspected violations of this Code, company policies and procedures, or applicable law, or who assists in the investigation of a reported violation. Acts of retaliation should be reported immediately to your manager.

Integrity & Culture of Inclusion

We trust each other and are committed to building a transparent company standing for equality and personal integrity. We foster a culture of respect and inclusion for our internal and external communities—by listening, learning, and embracing uniqueness.

Waivers

SolarWinds will waive application of the policies set forth in this Code only where circumstances warrant granting a waiver based on the best interests of SolarWinds and its shareholders. Any waiver pertaining to an employee must be submitted to the General Counsel and approved by the Chief Executive Officer or Chief Financial Officer. Waivers of the Code for directors and executive officers may be made only by those members of the Board of Directors not involved in the possible waiver and must be promptly disclosed as required by law or regulation.

Making good decisions

Compliance with laws

SolarWinds and its Solarians must obey all applicable laws and regulations that affect our business. Some of the more common laws and regulations are set forth in this Code. While we do not expect Solarians to be experts in legal matters, each Solarian is responsible for being familiar with the laws governing his or her areas of responsibility. If you have a question concerning the application of any law or regulation to a contemplated action, it is your responsibility to seek guidance.

No tolerance for equal harassment

Every Solarian has a right to a work environment free from harassment, regardless of whether the harasser is a co- worker, supervisor, manager, customer, vendor, or visitor. SolarWinds considers harassment to be any behavior, whether it is verbal, physical, digital, or visual, that is unwelcome and unwanted, that is DEMEANING, INTIMIDATING, THREATENING, or OTHERWISE INAPPROPRIATE, that is based on a person’s protected characteristic or belief, and that creates a work environment that is hostile. In keeping with our policy, SolarWinds strictly prohibits sexual harassment and any harassment based on any protected characteristics or beliefs, such as the ones identified in our EQUAL EMPLOYMENT OPPORTUNITY POLICY, or any other characteristics or beliefs protected under the applicable law. Solarians should be familiar with company policies related to its COMMITMENT TO PRODUCTIVE WORKPLACE RELATIONS, which are found in the Handbook.

Equal Employment Opportunity

SolarWinds is committed to treating all Solarians fairly and with respect. We will provide equal opportunities to all Solarians and applicants. Discrimination based on race, color, religion, national origin, gender, sex, sexual orientation, gender identity, age, physical or mental disability, or veteran or any other protected status is not tolerated. This applies to all terms and conditions of employment including recruiting, hiring, transfers, promotions, terminations, compensation, and benefits. Solarians should be familiar with the company policies related to its COMMITMENT TO PRODUCTIVE WORKPLACE RELATIONS, which are found in the Handbook.

Workplace safety and violence prevention

We are committed to the protection of our Solarians and property. Threats, intimidation, and violence in our workplace will not be tolerated. You may not possess firearms, other weapons, explosive devices, or dangerous materials in the workplace unless you have prior authorization. Solarians should be familiar with SolarWinds’ NO TOLERANCE FOR WORKPLACE VIOLENCE POLICY.

Drug-free workplace

SolarWinds strives to maintain a workplace that is free from illegal use, possession, sale, or distribution of alcohol or controlled substances. Legal or illegal substances shall not be used in a manner that impairs a person’s performance of assigned tasks. Solarians should be familiar with SolarWinds’ DRUG AND ALCOHOL ABUSE AND MISUSE POLICY, which is found in the Handbook.

Employee privacy

SolarWinds respects the confidentiality of personal information of employees and is committed to complying with all applicable laws to maintain employee’s privacy. Personal information includes employee medical and personnel records. Access to personal information is only authorized when there is a legitimate and lawful reason, and access is only granted CONFIDENTIAL — FOR INTERNAL USE ONLY © 2025 SolarWinds Worldwide, LLC. All rights reserved. 8 to appropriate personnel. Requests for confidential employee information from anyone outside SolarWinds under any circumstances must be approved in accordance with our policies and with applicable law. It is important to remember, however, that employees should have no expectation of privacy with regard to information and communications stored or sent on company technology systems. employees should be familiar with company policies related to its COMMITMENT TO EMPLOYEES’ PRIVACY, which are found in the Handbook.

Protecting proprietary and confidential information

Protecting customer and third-party information

Keeping customer information secure and using it appropriately is a top priority. We must safeguard any confidential information customers, or third parties share with us. We must also ensure that such information is used only for the reasons for which it was provided. Customer or third-party information includes any information about a specific customer or third party, including such things as name, address, phone numbers, and business or financial information.

Protecting classified information

All national security classified information must be handled and safeguarded in strict compliance with U.S. (or the relevant) Government mandated procedures.

Protection and proper use of company assets

Protecting intellectual property rights

Using the internet and technology systems

SolarWinds provides computers, devices, e-mail systems, voicemail systems, access to the Internet, and other technology systems to assist Solarians in conducting our business. Access and use of the Internet and these systems is permitted and encouraged, but Solarians must adhere to all company policies regarding EMPLOYEE USE OF COMPANY PROPERTY, and SOCIAL MEDIA USE which are found in the Handbook. Occasional, limited personal use of these resources is permitted, but cannot interfere with your work performance, or the work performance of your colleagues. Further, as these resources are intended for legitimate business purposes, you should not have any expectation of privacy related to your access and use of these resources. Further, SolarWinds does not tolerate inappropriate or illegal use of these resources and reserves the right to take appropriate disciplinary actions, up to and including termination of employment, for inappropriate or illegal use.

Using software

Any software used or installed on company technology systems, or used in conducting our business, must be used in accordance with company policies and procedures regarding the USE OF EXTERNAL SOFTWARE, which are found in the Handbook. Appropriate licensing is required for all software installed on company devices or systems or used in conducting company business. Each Solarian is directly responsible for the ongoing integrity of the software they use.

Avoiding conflicts of interest

Fair purchasing

Integrity and fair dealing are core components of our business practices. All vendors, suppliers, and other business partners should be treated fairly and uniformly in accordance with our established purchasing policies and procedures, including seeking opportunities to increase spending with diverse or historically disadvantaged businesses where possible. Further, all Solarians must comply with our established purchasing policies and procedures in connection with engaging or hiring any vendor, supplier, or service provider. Solarians should be familiar with the company policies related to SPENDING AUTHORIZATION and CORPORATE CONTRACTING SIGNATURE AUTHORITY.

Maintaining accurate financial records and internal controls

Managing records properly

Our records are our corporate memory, providing evidence of actions and decisions and containing data and information critical to the continuity of our business. Records consist of all forms of information created or received by SolarWinds, whether originals or copies, regardless of media. Examples of company records include paper documents, e-mail, electronic files stored on any medium (CD, DVD, USB data storage devices, etc.) that contain information about our company or our business activities. All records are the property of SolarWinds and should be retained in accordance with applicable law and company policies. Further, each Solarian is responsible for properly labeling and carefully handling confidential, sensitive, and proprietary information, and securing it when not in use.

Anti-money laundering

Money laundering is conduct designed to disguise proceeds of criminal activity by individuals or entities. Our company will not condone, facilitate, or support money laundering. Two areas that deserve special awareness are unusual ways in which payments may be requested and customers who appear to lack integrity in their operations.

Antitrust and fair competition

Export controls

We comply with all United States federal import and export laws and regulations. These laws restrict transfers, exports, and sales of products or technical data from the United States to certain prescribed countries and persons as well, as re-export of certain such items from one non-U.S. location to another. Many countries in which we operate have similar laws and regulations. We have implemented export control procedures designed to ensure compliance with applicable export laws and regulations. If you are involved in order entry or processing, you are responsible for knowing and following all applicable company procedures related to EXPORT COMPLIANCE, which are found in the Handbook.

Anti-corruption and anti-bribery

The United States and many other countries have laws that prohibit bribery, kickbacks, and other improper payments. No Solarian, officer, agent, or independent contractor acting on our behalf may offer or provide bribes or other improper benefits in order to obtain business or an unfair advantage. A bribe is defined as directly or indirectly offering anything of value (e.g., gifts, money, or promises) to influence or induce action, or to secure an improper advantage. The Foreign Corrupt Practices Act and other U.S. laws prohibit payment of any money or anything of value to a foreign official, foreign political party (or official thereof), or any candidate for foreign political office for the purposes of obtaining, retaining, or directing of business. We expect all Solarians, officers, agents, and independent contractors acting on behalf of SolarWinds to strictly abide by these laws.

Gifts and entertainment

Solarians should not accept gifts, gratuities, or entertainment from any customer, competitor or supplier of goods or services to the company, unless they are lawful and reasonable (e.g., consistent with marketplace practices, infrequent, and not lavish or extravagant) and are not offered in consideration for an improper action or in a manner that could hurt SolarWinds’ reputation for impartiality and fair dealing.

Restrictive trade and boycotts

A request to participate in any activity that could have the effect of promoting a boycott or restrictive trade practice fostered by a foreign country against customers or suppliers located in a country friendly to the United States or against a U.S. person, firm, or SolarWinds may be a violation of law and must be reported promptly to your immediate supervisor.

International business

It is always important that Solarians conducting international business know and abide by the laws of the United States and the countries that are involved in the activities or transactions. These laws govern the conduct of Solarians throughout the world. If you participate in these business activities, you should know, understand, and strictly comply with these laws and regulations, including those relating to fair competition, export controls, anti- corruption, anti-bribery, and restrictive trade practices discussed above. If you are not familiar with these laws and regulations, seek guidance prior to negotiating any foreign transaction.

Government customers and contracting

Obtaining competitive information fairly

Insider Trading

Honest advertising and marketing

It is our responsibility to accurately represent SolarWinds and our products in our marketing, advertising, and sales materials. Deliberately misleading messages, omissions of important facts, or false claims about our products, individuals, competitors or their products, services, or employees are inconsistent with our values. Sometimes it is necessary to make comparisons between our products and our competitors. When we do, we will make factual and accurate statements that can be easily verified or reasonably relied upon.

Social responsibility and environmental stewardship

We pride ourselves on being a company that operates with integrity, makes good choices, and does the right thing in every aspect of our business. We will continually challenge ourselves to define what being a responsible company means to us, and work to translate our definition into behavior and improvements at SolarWinds. We seek to align our social and environmental efforts with our business goals and continue to develop both qualitative and quantitative metrics to assess our progress. We take opportunities, as a company and as individuals, to respect and protect natural resources where possible. From doing our part to recycle to being aware of our individual carbon footprint, we recognize that together these small efforts can have a larger impact.

Political activities and contributions

SolarWinds strives not to become involved in political process. However, SolarWinds respects the right of Solarians to be involved in the political process through personal contributions or by volunteering your personal time to the candidates or organizations of your choice. These activities, however, must not be conducted on company time or involve the use of any company resources such as telephones, computers, or supplies. You may not make or commit to political contributions on behalf of SolarWinds.

Charitable contributions

SolarWinds supports community development throughout the world. Solarians may contribute to these efforts or may choose to contribute to organizations of their own choice. However, as with political activities, you may not use company resources to personally support charitable or other non-profit institutions. You should consult the Legal department if you have questions about permissible use of company resources.

Human rights

Human rights are valued throughout our organization, regardless of location. We follow all international labor and immigration laws wherever we conduct business and where applicable. We have a zero-tolerance approach to modern slavery and human trafficking and are committed to acting with integrity in all our business dealings, and with our supply chain, including business partners, suppliers, contractors and other third parties who provide or deliver any goods or services to us. We will not support or deal with any business that is knowingly involved in any form of slavery and/ or human trafficking and will take steps to ensure transparency within our business and supply chain. Please consult the Legal Department if you have questions or need assistance regarding this statement.

Communicating with external parties

Only specifically authorized Solarians may speak with the media, investors, and analysts on behalf of SolarWinds. Unless specifically authorized, do not give the impression that you are speaking on behalf of SolarWinds in any communication that may become public. This includes posts to online forums, social media sites, blogs, chat rooms, and bulletin boards. Solarians should be familiar with company policies regarding EXTERNAL COMMUNICATIONS and SOCIAL MEDIA USE.

Full, fair and accurate disclosure in communications

The Company is committed to providing full, fair, accurate, timely and understandable disclosure in its public communications. Although certain personnel are more directly involved in the preparation of such communications than others, the Company expects all members of our community to accept this responsibility. Accordingly, all employees, officers, directors, and consultants have an ethical responsibility to provide prompt, complete and accurate information in response to inquiries related to preparation of the Company’s public communications. In addition, and in order to ensure accurate financial reporting, those personnel who participate in the maintenance and preparation of the Company’s books, records and accounts must ensure that the transactions and events recorded therein are done so in an accurate and complete manner in compliance with required accounting principles and Company policies.