prevention, detection, and investigation program to identify and control credit, fraud, and operational risks and protect our customers, their employees, and our partners from bad actors. Customer identity verification Risk mitigation and fraud prevention start with customer onboarding. At Rippling, customers are required to provide critical KYC information at onboarding. Rippling utilizes this information, internal tools, and leading providers of authentication and verification services to manage Automated Clearing House (ACH), credit, and fraud exposure, including through the establishment of limits and other appropriate controls. Transaction monitoring Rippling maintains a robust detection program to systematically monitor daily payroll run activity for anomalous or inconsistent data and outliers for both credit and fraud purposes. Additionally, Rippling leverages custom transaction monitoring rules based on known money laundering typologies targeted at payments processors with a particular emphasis on payroll. Risk teams follow defined investigation procedures and standards for transactions flagged by these controls to facilitate a timely response and report suspicious activity when necessary. Office of Foreign Asset Controls sanctions program Rippling maintains robust policies and procedures to ensure that com- pany services are not utilized by, or on behalf of, sanctioned parties as defined by the United States Office of Foreign Assets Control (OFAC). Rippling’s OFAC policy is reviewed annually and approved by the Board. As part of this program, Rippling maintains a continuous monitoring system to ensure that changes to the Specially Designated Nationals and Blocked Person List (SDN List) are updated on a daily basis, and that customers, employees, and contractors are screened against this list at onboarding and in advance of payments transactions. Rippling also utilizes technical controls and blocks product to prohibit payments to countries that are under a comprehensive sanctions program. rippling.com | Payments Compliance and Risk Programs 3