Natural Intelligence Code of Conduct

Introduction

This Code of Business Conduct and Ethics (the “Code”) is specifically designed to provide guidance
regarding the Company’s standards of integrity and business conduct.
This Code applies to all full time, part-time and temporary employees (collectively “Employees”) of
Natural Intelligence Ltd. (“Natural Intelligence” or the “Parent”) and its subsidiaries (the
“Subsidiaries”). The Parent and Subsidiaries are collectively referred to herein as the “Company”.
This Code also applies to engagements with consultants, contractors or any other third-party that will receive
access to the Company data and/or systems (collectively “Consultants”).

The purpose of this Code is to promote:

• Honest and ethical conduct, including fair dealing and the ethical handling of actual or apparent personal
  interest in professional relationships;
• Conducting business with professional competence and integrity;
• Full, fair, accurate, timely and understandable disclosure;
• Compliance with applicable laws, rules and regulations;
• Prompt reporting of violations of this Code; and
• Accountability for adherence to this Code and to deter wrongdoing.

If a law conflicts with a policy in this Code, you must comply with the law. If you have any questions about
these conflicts, you should ask your supervisor how to handle the situation.

Those who violate the standards in this Code will be subject to disciplinary action, including termination of
employment or consultancy.

About Natural Intelligence

Founded in 2009, Natural Intelligence is a leader in online multi-vertical marketplaces. The company’s leading
brands, Top10.com and BestMoney, help millions worldwide make informed decisions every day.

Our proprietary xMatch technology utilizes millions of user interactions in order to help consumers make easier
choices and find the right products and services to fit their needs. For brands, our marketplaces serve as a
starting point for connecting with high-intent consumers, allowing them to build up their customer base and
drive growth on a massive scale.

Natural Intelligence, a privately held Israeli company and one of the world’s leading online comparison
providers, employs today over 400 people out of its Headquarters and R&D Center in Tel Aviv, as well as
additional offices in the United States, The UK, and Australia.

Social Impact

Natural Intelligence takes an active part in the Israeli Tech ecosystem and is a pioneer and a driver of social
impact for the entire industry, especially in issues pertaining to gender equality. Natural Intelligence strives
to promote a fair and equal workplace for the LGBTQ community and works closely with LGBTech and the Israeli
LGBT Association. Moreover, as part of its deep commitment to the issue, the “Maavarim” association operates
from Natural Intelligence’s offices and receives ongoing support in all aspects of its administration. In
addition, Natural Intelligence was the first company to provide a NIS 50k surrogacy grant for those unable to
undergo surrogacy in Israel.

Since its establishment, Natural Intelligence has been working with numerous organizations that promote social
change, including “Gesher El HaNoar,” “Appleseeds,” “Shavot,” and others. Natural Intelligence’s employees and
senior managers participate in various volunteering and mentoring activities. Natural Intelligence has won
awards and recognition both within Israel and abroad for its diverse activities and social involvement.

Natural Intelligence’s Values – DNI

There are six fundamental values of Natural Intelligence, collectively known as our DNI. These company values
demonstrate its culture and guide our day-to-day operations, communications and behavior and determine the way
we conduct our business.

Our success is due primarily to Natural Intelligence’s DNI: they separate us from the competition, strengthen us
as a company, and bring us all together for shared success.

• “Come as You Are” (Nirvana) – Great people, genuine caring, NATURAL vibes.
• “Shine bright like a diamond” (Rihanna) – Be the best version of ourselves.
• “Come together” (The Beatles) – One company, one team, one vision.
• “Imagine” (John Lennon) – Challenge the ordinary, Think big.
• “Whatever it takes” (ImagineDragons) – Own it. Make an impact.
• “Ch Ch Changes”(David Bowie) – With great power comes great social responsibility.

1. Compliance with Laws

The Company’s activities and operations will be carried out in careful compliance with applicable laws. The Company
requires that all employees, officers, directors, or consultants comply with laws and regulations applicable to the
Company. The Company acknowledges that there are differences in local laws and practices between countries.
The Company Employees and Consultants shall not under any circumstances engage on
behalf of the Company with individuals, entities or countries which are located in
territories which are considered enemy states according to Israeli Law, or sanctioned
according to Israeli law or according to any treaties, export control regulations or trade
restrictions which the Company must comply with according to any applicable law.
In some instances, the Code establishes policies and/or requirements that would not otherwise be required in some countries.
In keeping with the Company’s commitment to meet the highest standards of business conduct wherever it does
business, all Employees and Consultants must comply with all aspects of the Code, even if it is not required by
local laws. Conversely, there may be laws in certain countries which may not specifically apply outside of those
countries, and therefore, not specifically be addressed by the Code. Employees and Consultants are expected to use
good judgment and common sense in seeking to comply with applicable laws and regulations and to ask for advice when
uncertain about them. Without derogating from the above responsibility, the Company may add policies applicable to
specific regions as required or appropriate under local laws.

2. Corrupt Practices Prohibited

No Bribery or Payoffs. In its relations with governmental officials, actual and potential purchasers and suppliers,
vendors, subcontractors, business associates, and others, the Company and its Employees and consultants will not,
directly or indirectly, engage in bribery, payoffs, or other corrupt business practices.

Prohibited Payments. Payments to consultants, attorneys, suppliers, distributors, purchasers, and others are
strictly prohibited if it is known or believed (or there is reason to believe) that all or a portion of such
payments will be offered, given, or promised to a government employee, a member of a political party, a candidate
for political office, or to an employee, officer, director, business associate, or family member of an actual or
potential purchaser of Company products. Facilitation payments are not permitted.

Political Contributions Prohibited. The use, directly or indirectly, of Company funds for political contributions to
any organization or to any candidate for public office is strictly prohibited.

3. Permitted Tips and Gratuities.

Employees and consultants are solely permitted to offer nominal tips, gratuities, gifts and promotions (e.g. Natural
Intelligence’s pens; branded merchandise; etc.) of a custom amount or value for routine services or courtesies or as
part of Natural Intelligence’s customary promotional and marketing efforts. “Nominal” value is defined as a gift of
not more than $150 per annum per business contact and in any event not more than $500 per annum per business
associate (Partner). Hospitality expenses (such as lunch or dinner at a restaurant) shall be as set forth in the
Company’s Travel Policy.

Any other tips, gratuities, hospitality, gifts and promotions that are not standard or customary require advance
written approval by the Company’s CFO, with a copy of the approval to be attached to the expense report or expense
receipt. All receipts for such expenditures must be submitted to the Company finance department and must be recorded
in the Company’s books of account.

4. Permitted Receipt of Gifts

In connection with their business activities, Employees may receive gifts of nominal value or accept invitations
only if such gifts or invitations have no undue influence on their decision-making and are not illegal under
applicable law. Gifts below the nominal value of $75 do not require reporting. For any benefit valued over $75,
Company CFO must be updated, who, in consultation with the Chief People Officer will determine how to make use of
the benefit (Company use, donation, retention by the employee etc.). For the avoidance of doubt, reasonable expenses
on business meals shall not be considered a breach of this policy.

This policy is limited during tenders – an Employee shall not receive a bonus or gift from a service provider or
customer, during a tender process, rather only after an agreement is signed.

5. Proper Use of Corporate Funds and Property

Corporate funds and assets must be utilized solely for lawful and proper corporate purposes. Transfer or expenditure
of such funds or assets will be undertaken only if the stated purpose is in fact the actual purpose. The transfer or
expenditure of such funds and assets must be authorized in writing in accordance with procedures established by the
Company. Company equipment or other property should be handled and cared for properly and should be used only for
business purposes. It should not be used for personal benefit, sold, loaned, given away, or otherwise disposed of,
regardless of its condition or value, without proper authorization. Fraud, theft, embezzlement or misappropriation
of Company property is prohibited.

6. Written Employment/Consultancy Agreements Required

Employees and consultants will be retained and paid only pursuant to a written agreement supplied or approved by the
Company’s authorized representatives. Employees shall be permitted to work with the Company only if they operate in
conformity with their written contracts, applicable laws and regulations, this Code and  the Company policies as
shall be in effect from time to time.

7. Accounting and Auditing Matters

The Company is committed to providing accurate and reliable information to its shareholders, governmental agencies,
and other entities who rely on the veracity of the Company’s financial records. No false, misleading or artificial
entries shall be made in the Company’s books and records for any reason, and all accounting, internal accounting
controls or auditing matters shall be conducted in accordance with all applicable laws. Any concerns regarding
questionable accounting, internal accounting controls or auditing matters should be directed to the CFO, on either
an anonymous or non-anonymous basis by calling the following telephone number or sending a letter by mail or email
to the CFO.

8. Avoid Conflicts of Interest

All Employees and consultants must avoid conflict of interest situations between their direct or indirect (including
members of immediate family) personal interests and the interest of the Company. Typical conflict situations include
providing services to or owning stock (or stock options) in business entities, which are competitors, purchasers or
suppliers of the Company (minor shareholdings of up to 2%  in listed companies are generally not considered to be a
conflict of interest situations).

It is against our Code, unethical for our Employees and consultants, and under certain circumstances also
illegal, to use material nonpublic information, regarding the Company or other companies with whom we do business,
in order to gain profit and/or “tip” others who might make an investment decision on the basis of that information.

Company Employees involved in the process of purchasing goods and services should be extremely careful in exercising
their judgment in purchasing decisions. Objectivity and impartiality should be exercised when making
purchasing-related decisions, and any potential conflict of interests, including any existence of prior acquaintance
or family connections with any vendor, should be reported to the Company’s Chief People Officer. The Company will
put in place a process to ensure this clause is adhered to.

Employees and Consultants must notify their direct supervisor of any actual or potential conflict of interest
situation. The direct supervisor will advise the Chief People Officer or the relevant VP, who both in turn will
consult with the CEO to provide a considered and confidential response.

9. Protection of Intellectual Property

The Company recognizes intellectual property rights as well as proprietary confidential information (collectively
“IP”) as of utmost importance that lies at the heart of the Company’s business. Employees and Consultants shall take
appropriate actions to preserve and enhance the Company’s IP and not infringe the IP rights of other persons and
entities, and must comply with their obligations contained in their employment/consulting agreements during and
following their engagement by the Company.

10. Non-Disclosure Requirements

The written employment and retention agreements with all Employees and consultants shall contain provisions
regarding the non-disclosure and non-use of proprietary and/or confidential information received by such Employees
and Consultants during the term of the relationship with the Company.

11. Personal Behavior and Respect for Individuals

A. Respect, consideration and non discrimination

The Company strives, on a personal level, to treat each individual with dignity, consideration and respect. The
Company has no tolerance for discrimination or harassment. All employment decisions are to be made without regard to
race, color, age, gender, sexual orientation, religion, marital status, pregnancy, national origin/ancestry,
citizenship, physical/mental disability, military status or any other basis prohibited by law. For purposes of this
Code, harassment includes slurs and any other offensive remarks, jokes and other verbal, graphic, or physical
conduct that could create an intimidating, hostile or offensive work environment. In addition to the above, “sexual
harassment” includes unwelcome sexual advances, requests for sexual favors, and other visual, verbal, electronic, or
physical conduct of a sexual nature.

The use, sale, possession or transferring of illegal drugs at the Company’s premises, in company vehicles, during
hours of work or during Company events, including social functions organized within the framework of team building
events for teams and departments, as well as parties,  is strictly prohibited. Reasonable drinking which does not
cause intoxication is allowed at company events approved by Company management.

B. Online posts and opinions

Employees are held responsible for the content they post on social media, including in a personal capacity, while
they should take into account that such a post may be attributed to the Company. Employees are expected to act in a
respectful and responsible manner, and should not make any post, on social media or on any other public platform,
within the workplace or outside of it, and including via a support (“like”) or share, of any statement, expression,
content, song, video, quote, and the like (a “Statement” or “Statements”) that are considered unacceptable or that
may incite, intimidate, hurt, threaten, support illegal activities or illegal organizations, discriminate, or damage
the work environment and interface with teams in Israel or abroad.

12. Enforcement and Compliance with Code

All officers, executives, and managers of the Company are responsible for the enforcement of, and compliance with,
this Code, including necessary distribution of this Code to ensure Employee and consultant knowledge and compliance.
Non-compliance with this Code will result in disciplinary measures up to and including termination of the
relationship with the Company.

13. Distribution of Code

All current Employees and Consultants shall be provided with a copy of this Code at the earliest possible date. All
new Employees and consultants shall be provided with a copy of this Code within thirty (30) days of joining the
Company, or will receive it together with the consulting agreement, as the case may be . The Code and any amendments
thereof shall be available to the Company’s Employees and consultants. Any questions on this Code should be
addressed to the Human Resources department.

This Code may be amended from time to time with or without notice by the Company.

14. Reporting Code Violations

Any Employee who knows or believes that another Employee or consultant of the Company has engaged or is engaging in
conduct related to the Company that violates applicable law, this Code or any other code or practice standard
applicable to such an individual, should report this information either personally or anonymously to a supervisor or
the Chief People Officer or one of the Company’s executive officers. Any supervisor or officer who receives a report
of a violation of this Code must immediately inform the Chief People Officer by email. The Chief People Officer will
ensure that the CFO is informed of reports received and the action being taken.

Employees concerned about matters involving accounting, internal accounting controls or auditing matters should
report their complaints immediately as follows: (1) by email or telephone, to CFO; or (2) by postal mail, to Natural
Intelligence, 6 Totseret HaArets Street, Tel Aviv, Attention: Chief Financial Officer.

This Code should not be construed to prohibit you from testifying, participating, or otherwise assisting in any
state or federal administrative, judicial, or legislative proceeding or investigation.

15. Investigating and Resolving Concerns

All reports of possible violations will be investigated by the Chief People Officer. The Chief People Officer may,
in his or her discretion, assume responsibility for evaluating any possible violation and directing or conducting
any investigation or may delegate any portion of such responsibility to another person or entity within or outside
the Company.

All reports of possible violations will be handled with the utmost care and receive a thorough review.

After conducting the investigation, the results will be evaluated and the Company will authorize such swift
response, follow-up and preventive actions, if any, as are deemed necessary and appropriate to address the substance
of the reported possible violation. The Company reserves the right to take whatever action it believes appropriate,
up to and including the discharge of any Employee determined to have engaged in improper conduct. The Company will
strive to keep all reports of possible violations and the identity of those who submit them and participate in any
investigation as confidential as possible. Neither the Company nor any person associated with the Company shall
discharge, demote, suspend, threaten, harass or in any other manner discipline, discriminate or retaliate against
any person or entity because he or she reports any violations or cooperates in any investigation or inquiry
regarding violations of applicable law or this Code using the methods outlined above. However, the Company may take
disciplinary action against an Employee or consultant who provides an incorrect report on violations of the Code if
the report was not made in good faith.

Any waiver of the Code for executive officers and directors and any other Employee of the Company may be made only
by the CEO.

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