1. Frontify at a glance

1.1 Who we are

Frontify is Where brands live : Our platform unifies assets, templates, and guidelines to simplify brand workflows and transform how marketing teams create on-brand content on a global scale.

1.2 Our mission

Frontify helps global marketing teams orchestrate countless fleeting brand moments to create genuine connections.

1.3 Our vision

We empower brands to own every moment.

2. About this code

“Frontify for Good” serves as our code of ethics and guiding framework for corporate responsibility and sustainability. This document reflects our ongoing commitments and is reviewed regularly to ensure transparent communication with all key stakeholders about our ethical principles and responsible practices.

At Frontify, we’re committed to conducting business with integrity, accountability, and respect for people and the environment. Through strategic initiatives, we actively work to minimize our environmental impact, advance social responsibility across our operations, and uphold the highest ethical standards. By fostering awareness of responsible business practices among our employees and sharing these practices with our business partners, we aim to cultivate relationships built on mutual respect and trustworthiness while advancing sustainable development goals.

This document provides an overview of our initiatives and programs designed to integrate fundamental ethical principles into our daily operations while ensuring full compliance with the law. Our commitment is structured around five key pillars:

1. Human and labor rights
2. Ethics and integrity
3. Privacy and data protection
4. Environmental responsibility
5. Customer's interests

3. The cornerstone of our corporate responsibility

3.1 Our inspiring culture

3.1.1 Our personality

We value authentic connections. This is reflected in the way we communicate with employees and customers. We’re welcoming, supportive, and encouraging. It shows in the way we onboard people and celebrate success. We’re inherently inviting because we seek to always grow and experience more.

We approach problem-solving with optimism and energy. This is reflected in how we share and showcase our differences and personalities with each other and the outside world. This vibrance brings a natural enthusiasm to all we do — from exchanges with customers to our internal events that bring energy and build optimism.

We’re inspired by challenges, eager to learn, and motivated to innovate. We’re lifelong knowledge-seekers, always looking for opportunities to learn and develop as individuals. In turn, we share our findings and impart insights for our collective growth. It’s apparent in how we handle situations where we might say, “I don’t know” when we don’t — but follow through with queries to gain answers. We might also stop by someone’s desk just to see what they’re working on.

3.1.2 Our shared beliefs

We believe in unlocking the full potential of highly engaged, connected, and collaborative teams.
‍By working together, sharing ideas, and supporting each other, we create an environment where innovation thrives. We value openness, participation, and connection, bringing different perspectives together and breaking mental barriers. We ensure every voice is heard — regardless of role or background — through frequent feedback loops.

We believe in staying true to oneself. We’re true to ourselves, always.
We know who we are and why we’re here. We value authenticity, focus, and clarity. We communicate honestly — internally and externally. We don’t sell what we don’t have or what clients don’t need.

We shape the future.
‍Great brands, and the people behind them, have the power to shape the future. We’re eager to challenge the status quo, innovate, and develop sustainably. This means we value growth, adaptability, and innovation.

We act like owners.
We find solutions to problems regardless of our role — always with the company’s long-term success in mind. We anticipate and exceed our customers’ needs and strive to help them create goosebump moments. We aren’t afraid to fail; we set bold goals and continually challenge ourselves.

We’re self-driven and don’t wait to be told.
‍We execute with discipline and pragmatism. We focus on quality and consistency, as we’re not ok with average. We find joy in personal progress and actively participate in the growth of those around us.

We communicate clearly and listen actively.
We ensure effective communication across all levels — company, departments, and teams. We choose positive words, inspire through our actions, and build unity as we work toward our goals.

3.1.3 Our behaviors

We strive for balance.
‍We champion work-life balance through smart working practices that harmonize freedom with responsibility. We cultivate an environment of self-determination by establishing clear expectations and aligned working methods. Our flexible policies support personal autonomy, including adaptable working hours and comprehensive work-life integration. Through regular check-ins, we ensure our employees remain empowered, balanced, and autonomous in their roles.

We harness the collective power of our team.
‍Our strength is our unwavering commitment to each other and our unified purpose. We seek out diverse voices and maintain a balanced, empathetic approach. We remain open, humble, tight-knit, and unshakable, no matter what comes our way. By elevating individual potential, we achieve extraordinary results and firmly believe that our shared vision can be realized only through collaborative effort.

We maintain complete transparency in our operations.
We share comprehensive information — from project processes to financial metrics — on a regular basis. We foster collaboration across all stakeholders, including our internal teams, clients, brand partners, and industry experts. Our diverse workforce encompasses varied roles, backgrounds, and experiences that enrich our perspective and deepen our understanding of the global landscape we serve.

We seek new directions.
‍We embrace innovation and strive for excellence. We foster an environment where we challenge established practices, evolve solutions continuously, and welcome unconventional ideas. We celebrate those who question the status quo, who enhance our ways of working, and who drive our product development forward.

3.2 Our five pillars of ethics

3.2.1 Preamble

At Frontify, our inspiring culture and shared values represent an essential framework against which all our business operations are assessed. The same applies to our commitments to corporate responsibility — our policies and procedures in the identified pillars are consequential to an overall commitment to act responsibly toward employees, business partners, customers, society, and the environment.

The following sections outline our approach to key areas of corporate responsibility and provide guiding principles for acting in accordance with our corporate values. Any conduct that contradicts the ethical framework provided herein is inconsistent with our corporate culture and will result in disciplinary action. 

Violations of this code may result in consequences ranging from coaching and training to formal disciplinary measures, including written warnings, suspension, or termination of employment, depending on the severity and nature of the violation. All disciplinary actions will be conducted in accordance with applicable employment laws and our internal policies. Repeated violations or serious breaches that undermine trust, harm colleagues, customers, or the company’s reputation will be addressed through immediate and decisive action, up to and including dismissal.

3.2.2 We uphold human and labor rights

Every person counts, and every voice is heard.
We’re a community of caring and supportive individuals who respect each other in a spirit of collaboration. Everyone has a place in the whole, with their fundamental rights and freedoms being upheld without distinction or limitation of any kind. We believe that every personality can flourish only where the surrounding environment is secure and respectful of its uniqueness. Therefore, we’re committed to fostering an environment free from discrimination and any behavior that may be harmful to the individual.

Everyone is welcomed, valued, and supported in reaching their full potential.
‍We care about our employees and make sure that everyone feels welcome and engaged from day one. We build relationships that are based on trust and make sure everyone receives adequate training and support to achieve their full potential. Our office spaces are designed to suit the needs of every employee and are regularly reviewed to ensure a safe and comfortable working environment. This goes for our remote employees as well — through proper equipment and virtual connectivity that builds confidence, support, and comfort in their roles and as valuable members of the company.

Everyone is supported with care and intention, through initiatives that prioritize physical safety, mental health, and overall well-being.
‍We’re committed to maintaining a healthy and safe working environment through a comprehensive approach to employee well-being. Our commitment starts with full compliance with all applicable laws, regulations, and standards, and it’s reinforced by clear health and safety guidelines for all employees. Our people partners work proactively with leadership to address workload management and workplace health, facilitating workshops on managing energy and stress effectively. We maintain an open-door policy where employees can confidentially discuss concerns with their people partner or lead and provide access to professional support by therapists or coaches via Oliva, our partner for mental well-being services. Regular risk assessments help us identify and address potential hazards and workplace challenges promptly. We support flexible scheduling and encourage employees to take necessary time off to maintain work-life balance. For employees facing health challenges, we offer specialized support programs and facilitate gradual reintegration, with team leads trained to provide appropriate assistance and communication. Our commitment to safety is reinforced through our dedicated reporting system, where employees are encouraged to provide feedback on a variety of topics, including safety-related matters.

• On child labor: We prohibit child labor and protect the right of young employees to schooling and education in general. We observe the applicable national regulations regarding the minimum age for admission to employment, and where no such national regulation exists, we refer to the relevant guidelines of Convention C138 of the International Labor Organization (ILO). According to this Convention, on no occasion, except under the specific circumstances set out in Articles 6 and 7 of the Convention, a child under 15 years of age may be employed. Additionally, we ensure that the health, safety, and development of our employees under 18 years of age are safeguarded through employment agreements approved by the competent national authority. This specifically applies to our apprenticeship programs.
• On forced labor. We reject all forms of forced and compulsory labor, as well as all forms of modern slavery and human trafficking. We refuse the practice of bonded labor, including the use of employment bonds to recover costs incurred for employee trainings or other educational activities. There are no restrictions on employees regarding the use of the office space: Everyone is encouraged to organize their weekly plan between days to be spent at the office and days of remote work. Lastly, every employment relationship is concluded on a voluntary basis, and employees are entitled by contract to terminate at their own discretion and within a reasonable notice period.
• On freedom of association. We acknowledge every employee’s freedom to form trade unions and employee representations; to join or not to join them, as well as the employee’s right to collective bargaining. In consequence of any such free choice, we don’t penalize, discriminate, or harass employees and use our best efforts to foster an environment where no such discriminatory behavior is ever held and/or tolerated among employees themselves.

Everyone’s efforts and motivation are rewarded fairly.

Additionally, great focus is on guaranteeing fair incomes, protection, and security in the workplace, support for personal and family development, employee engagement, equality of opportunity and anti-discrimination practices, and working time flexibility. For each area, we set clear goals and relevant strategies, most of which are detailed in the different sections of this code.

‍Every employee’s rights and freedoms are guaranteed and protected.We endorse all universally recognized labor standards and guarantee full respect for the employee’s fundamental rights. Specifically:

Salary
‍Our salary system is designed to retain exceptional talent and attract new, inspiring individuals through a competitive and fair compensation framework. It ensures consistency by applying clear principles and boundaries across all roles, promoting fairness and equity. Our philosophy is grounded in flexibility and scalability, allowing us to adapt to changing market conditions and unique situations while staying true to our core values. We use a cost-of-labor approach, supported by reliable market data, to define salary bands by role, country, and level. Through our annual performance and reward cycle, we conduct regular, structured reviews of both performance and compensation. This setup supports meaningful growth by encouraging open conversations about expectations at each seniority level and helps individuals understand how to move forward in their careers.

Bonus and other benefits

1. Company-wide bonus: All employees, excluding those whose compensation includes a variable component (such as commercial teams with commission-based pay), are eligible for the company-wide bonus program. This bonus is tied to the achievement of our business goals and is designed to allow employees to share in the company’s success. Participation in the bonus program is subject to the company’s discretion and may be adjusted based on business performance or financial circumstances.
2. Personal development benefits: We offer our employees tailored support for professional growth through access to educational programs, courses, coaching, and conference attendance. Any additional support is assessed on a case-by-case basis.
3. Quarterly well-being allowance: All permanent employees (including those who work in a hybrid or remote setup) receive a quarterly allowance to spend across different buckets. The categories below summarize a variety of possibilities to use this allowance:
   
   1. Lifestyle spending account: Health and wellness benefits including mental health support (e.g., therapy, counseling, and mindfulness app subscriptions), physical health (e.g., fitness apps, gym memberships, and yoga classes), wellness services (e.g., meditation classes, spa treatments, and massages), and support services (e.g., nutritional counseling and financial literacy programs)
   2. Travel expenses: Employees in a hybrid work setup can use this allowance to help with travel expenses to and from their local Frontify office.
4. ‍Additional benefits according to the employee location:
   
   1. For the employees in St.Gallen, Switzerland:
      
      • Accident insurance (occupational accidents covered fully by Frontify; non-occupational accident insurance premiums split 50/50)
      • Time off:
        
        • Minimum 25 days (5 weeks) of annual paid time off
        • 11 cantonal holidays observed
      • Parental leave:
        
        • Maternity leave: 16 weeks paid leave at 100% salary
        • Paternity leave: 4 weeks paid leave at 100% salary, and possibility of an unpaid extension
        • Pension fund (premiums split 60/40 between Frontify and the employee)
   2. For employees in New York, United States:
      
      • Comprehensive healthcare benefits that include the following:
        
        • Medical insurance: Choice between EPO (Exclusive Provider Organization) and POS (Point of Service) plans with open-gated access (no PCP, Primary Care Physician selection or specialist referrals required)
        • Dental insurance: Comprehensive coverage offering discounted dental services
        • Vision insurance: Coverage for optical needs
        • Wellness program: Access to wellness dollars for healthy lifestyle choice.
        • Life and disability insurance: Short-term and long-term disability insurance to protect against financial hardship if unable to work
        • Flexible spending account (FSA) through Optum on Justworks for pre-tax healthcare expenses
        • Health advocate service providing personalized health care navigation assistance
        • Pre-tax transit benefits for commuting expenses
        • 401(k) retirement plan through Empower with Frontify matching up to 5% of monthly base salary
      • Time off:
        
        • Minimum 25 days (5 weeks) of annual paid time off
        • 12 federal holidays observed
      • Parental leave:
        
        • Maternity leave: 16 weeks paid leave at 100% salary (employees are eligible after 6 months of employment)
        • Paternity leave: 6 weeks paid leave at 100% salary (employees are eligible after 6 months of employment)
        • 20 hours paid prenatal personal leave annually for pregnancy-related appointments
      • Employee assistance program and additional life management resources
   3. For employees in London, United Kingdom:
      
      • Healthcare: Private medical insurance provided through Vitality and a cashback health plan through Medicash. The Vitality program rewards healthy lifestyle choices with points that can elevate the employee membership status from bronze to platinum, unlocking additional discounts. The Medicash plan reimburses costs for routine medical expenses and covers Vitality excess fees on certain treatments.
      • Time off: Minimum 25 days (5 weeks) of annual paid time off
      • Pension scheme: Automatic enrolment with Royal London, featuring a 5% employee contribution matched with a 5% contribution from Frontify
      • Life insurance: Through Canada Life, providing 4x annual salary paid to nominated beneficiaries
      • Employee assistance program: Access to confidential counseling and specialist advice through Canada Life
      • Parental leave:
        
        • Enhanced maternity benefits: 12 weeks paid leave at 100% pay, followed by 12 weeks at 50% pay, and statutory maternity pay (SMP) until week 39, with the option for up to 52 weeks of leave. 10 optional Keep in Touch (KIT) days are available during leave.
          
        • Enhanced paternity leave: 4 weeks of paid leave (compared to the statutory 1-2 weeks)
   4. For employees in Paris, France:
      
      • Meal vouchers: We cover 60% of the cost (EUR 9.25/day) of employees’ meal vouchers. The number of meal vouchers provided depends on the number of working days (excluding vacation days, sick days, or any other leaves).
      • Public transport: We cover 50% of the cost of employees' public transport subscriptions.
      • Teleworking allowance: We contribute EUR 41.6 for hybrid and EUR 52 for remote.
      • Remote working: Remote employees also get EUR 100 extra for working from home.
      • RTT days: Reduction of working time (RTT days)
      • Time off: Employees are entitled to 25 days of paid vacation per year, in addition to 8–10 RTT days depending on annual accrual. RTT (Réduction du Temps de Travail) compensates employees working more than 35 hours per week, in compliance with French labor law. It provides additional paid days off to ensure the legal working time limits are respected.
      • Parental leave:
        
        • Maternity leave: Entitled to 16 weeks of paid maternity leave (typically 6 weeks before and 10 weeks after birth
          
        • Paternity leave (including second parents in same-sex couples): Entitled to 28 days of paternity leave; 7 of which are mandatory
          
      • These leaves are job-protected and paid through French social security, not the employer.
      • Health insurance and life and disability insurance according to mandatory requirements
   5. For remote employees: Additional benefits depending on the type of contract and working location.
5. ‍Lactation policy
   We support breastfeeding parents by providing the following:
   
   1. Reasonable break times during the workday to express milk, coordinated in a way that works for both the individual and their manager
   2. A clean, private, and secure room that’s shielded from view and free from interruption
   3. Access to these accommodations at all Frontify office locations, in compliance with applicable local laws

Any form of discrimination, harassment, or retaliation related to breastfeeding or lactation needs is strictly prohibited.

‍Every employee's needs are different, therefore, flexibility is key.We believe that a healthy and productive work environment only exists where employees have enough autonomy to identify their work-life integration. As a result, a great part of our internal policies and processes is aimed at fostering everyone’s self-determination in a context of mutual respect within the team and toward customers and the company. Thus, every employee has the freedom to organize their working schedules according to their specific life needs and role requirements (such as alignment with customer time zones for customer-facing roles) and coordinate with their team on expectations and ways of working.

Everyone feels engaged and contributes to the company’s growth.
We believe in the potential of highly engaged, connected, and collaborative teams. Thus, we communicate openly with employees on the company’s goals and strategies and encourage them to share their thoughts, ideas, and concerns. We use a third-party tool to run internal surveys and collect anonymous feedback on how the Frontify employees feel about the company culture, their roles, the teams, and the overall company direction. The results are then discussed within the relevant teams — or, where more appropriate, also in the management — and help define effective action plans.

Every employee’s growth journey is supported by our comprehensive skills development framework and growth plans. Our skills development framework serves as a roadmap that combines role competencies, which are tailored to specific job families, and company competencies that foster our unified organizational culture. Each role has three defined sub-skills, while our company-wide competencies encompass four key areas that drive collective success.

To support continuous development, we implement growth plans that help employees navigate from their current position to their career goals. These plans act as a compass for making informed decisions and guiding development conversations, ensuring personal growth aligns with team objectives.

We maintain a strong feedback culture through our performance cycles in Lattice, where employees can give and receive real-time feedback from peers and leaders. Each person can also actively request or offer feedback at any time, making development an ongoing, shared responsibility. This feedback system helps identify strengths and areas for development, records significant milestones, and steers individual growth plans. Our performance evaluations provide employees with comprehensive written feedback and foster a culture of trust, collaboration, and continuous learning.

Being a fast-growing company, we regularly create new positions that allow employees to explore new interests or take on leadership roles. We actively support inter-departmental transitions and career path changes, ensuring an objective internal application process supported by the People Team. Team leads conduct regular development conversations with team members, and we use OKRs (objectives and key results) to define and measure company and team goals.

Some of our diversity, equity, inclusion, and belonging (DEIB) initiatives include:

3.2.3 We enforce ethics and integrity

• We use an objective recruiting process with diverse interviewers.
• We provide unconscious-bias training for all hiring managers.
• We collect data in monthly surveys around inclusiveness and engagement.
• We provide opportunities to comment on challenges and opportunities anonymously in Lattice and in the bi-weekly all-hands meetings.
• We use globally recognized compensation tools and market-based standardized benchmarks to ensure we're not differentiating based on gender, race, or any other non-performance-related factors.
• We analyze workforce, leadership, and applicant diversity.
• We conduct structured strengths assessments and review sessions with individuals and teams to identify and leverage differences.
• We support apprentices and employees with difficulties integrating into the primary labor market. We work with an agency, Förderraum, that helps people with disabilities and difficulties to integrate into the primary labor market in Switzerland.

Going forward, we’ll focus on the following initiatives:

• We’ll expand data analysis across the recruitment process, workforce diversity and experience, and pay equity.
• We’ll continue to implement engagement and inclusion surveys to monitor progress and identify opportunities for improvement.
• We’ll develop targeted action plans based on the DEIB audit conducted in partnership with Inklusiiv.

A more detailed overview of our efforts in the DEIB area is provided in the following document: Frontify DEIB initiatives.

‍Every employee’s goals and expectations are backed up by career paths and directions.Our teams bring together a wide range of roles, backgrounds, and experiences, which makes us more creative and innovative. Through mutual respect and appreciation for individual points of view, alongside an open ear and consideration for others, we contribute to a healthy and exciting work environment.

We comply with the law.
We’re committed to the highest standards of integrity and responsibility toward all our stakeholders. We abide by applicable laws and regulations in force in the countries we operate. Additionally, we perform internal awareness trainings to ensure every employee takes compliance seriously and follows the relevant internal policies and procedures. We communicate frequently and transparently about regulatory changes that require adapting our daily operations. We monitor compliance with applicable laws and regulations constantly and take immediate action to remedy any violations.

We handle our supply chain responsibly.
‍When engaging with external third parties, we apply objective criteria, such as competitiveness, quality, objectivity, correctness, and respectability. We do business exclusively with external parties that can ensure the high standards of compliance, ethics, and integrity that are substantially equivalent to our own standards; this is an essential condition for establishing and maintaining any business relationship. We keep records of all our existing contractors, monitor our business relationships, and instruct employees to abide by the internal processes for the engagement of any new contractor. Any engagement may be finalized only once the legal, financial, and security assessments have been successfully completed, and key contractual provisions have been negotiated and secured. At a minimum, these provisions must include the right to audit the contractor’s compliance with applicable laws and contractual obligations, as well as the right to terminate the contractual relationship at any time. Furthermore, all third-party service providers with whom we collaborate are required to review and formally accept our supplier code of conduct, which sets forth our expectations regarding integrity, ethical behavior, and sustainability standards.

We take a firm and principled stand against all forms of corruption. We don’t knowingly engage in or tolerate any corrupt practices — including kickbacks, facilitation payments, political donations or sponsorship, travel and promotional expenses, conflicts of interest, or collusion — regardless of where our operations take place and of any local established practices. We comply with all applicable national and international legal standards and regulations.
We set high standards of transparency and ethical behavior as the norm, ensuring that incidents of non-compliance are minimized and can be effectively identified and corrected. This commitment includes maintaining accurate books and records that properly and fairly document all our financial transactions and provide a clear audit trail for all business activities.

We promote employee awareness of our anti-corruption policy through regular training. All employees are aware of and expected to abide by certain fundamental ethical principles and to comply with our internal procedures. In particular, they shall:

1. Avoid situations where private interests are in conflict or could come into conflict with the interests of Frontify as a company. Where employees find themselves in such circumstances, they should disclose the situation to their direct manager and the management. Eventually, they can refer to the legal team for counseling. Since not all circumstances where private interests are involved in a business situation qualify as a conflict of interest, documenting the private interests and showing transparently why there is no conflict can help to resolve most of these cases.Not be involved in the offering, giving, or receiving of benefits whenever they could influence or reasonably be perceived to influence improperly the outcome of a business decision process. On the other hand, the employee shall be allowed to offer, give, or receive reasonable and good-faith gifts, hospitality expenditures, or other benefits that may be strictly driven by local customs, traditions, and morals, making sure to comply at all times with our anti-corruption and gift policy and respect our stakeholders’ internal policies. In every case, the benefit must be legal, appropriate, proportional, and transparent. If uncertain, employees should consult the legal team for advice.
2. Not be involved in the offering or making of facilitation payments.
3. Register every financial transaction performed on behalf of the company by using approved company-wide tools.

We accompany these guiding principles with regular training sessions and reviews to ensure our ethical culture is maintained and evolves as we grow. We use company communication channels to raise awareness of the topic, and we provide all employees with secure and confidential avenues to raise concerns and report potential violations. Employees are encouraged and supported in speaking up, reinforcing our commitment to integrity across the organization.

3.2.4. We prioritize privacy and data protection

Frontify is committed to data minimization and collecting and processing only the minimum amount of information necessary for our services.
We firmly oppose any misuse of provided information. We comply with domestic data privacy laws, in parallel with, and additionally to, the EU’s General Data Protection Regulation (GDPR) 2016/679. This means, at a minimum, that in our capacity as processors, we process personal data according to the specific instructions of the data controller and only to the extent strictly necessary to provide our services; whereas, in our capacity as controllers, we make sure that the processing is always justifiable on one of the lawful bases recognized by art. 6 GDPR.

We guarantee the privacy of personal data.
‍Protecting the personal information we collect during our operations is our core responsibility; therefore, we uphold the highest standards of security and transparency. Our comprehensive, publicly available privacy notice and cookie policy clearly outline the categories of personal data we collect, as well as how this data is used, stored, and accessed. These policies also provide an overview of the fundamental principles — such as the principle of least privilege — and responsibilities embedded in our daily practices across the organization. In doing so, we ensure full compliance with all applicable legal and regulatory requirements.

Privacy and security are fundamental principles embedded in our product development lifecycle through privacy by design and by default approaches.
‍We apply comprehensive privacy and security standards at every stage of development. These include data minimization, anonymization techniques, and rigorous manual and automated testing protocols. Our commitment to privacy and security is regularly validated through independent third-party assessments and audits to ensure compliance with industry best practices and regulatory requirements.

We actively participate in industry initiatives and collaborations.
Earning and maintaining our customers’ trust is at the core of Frontify. Since day one, IT and information security have been included in every aspect of our system development, internal operations, and handling of customer data. Our efforts go beyond just legal requirements: We follow recognized industry standards and have obtained ISO 27001:2013 certification. Because information security is a company-wide responsibility, the scope of the Frontify Information Management Security System (FISMS) covers all essential assets, processes, and services connected to the Frontify application and business operations, regardless of where these processes or services are carried out. In addition, we regularly participate in industry initiatives and communities to stay informed on the latest developments and to actively exchange knowledge.

Privacy and data protection are fundamental to Frontify’s culture.
‍We’re committed to fostering a strong culture of privacy, data protection, and information security supported by a dedicated team that drives key initiatives, including comprehensive awareness training programs. All employees, regardless of role or seniority, are required to participate in regular training and to formally acknowledge their compliance through a statement of acceptance.

We engage only with trustworthy third parties.
To provide certain services on our platform and website, we engage with trusted third parties. To ensure that our standards are upheld, we have implemented a vendor management process that requires all third parties to demonstrate their commitment and compliance with our guidelines.

3.2.5 We promote environmental responsibility

We encourage environmentally friendly behaviors.
‍Besides complying with domestic and international environmental protection laws, we strive to minimize our impact on the environment and continuously seek better practices. Current key initiatives include:

• Regular monitoring of our carbon footprints through external climate service providers.
• Partnering with external climate experts to develop an emission-reduction path aligned with the Science-Based Targets initiative (SBTi).
• Promoting efficient energy use.
• Implementing waste separation and recycling whenever possible.
• Encouraging sustainable commuting by promoting public transport and offering opportunities to work from home.
• Prioritizing local suppliers and vendors whenever quality and cost are aligned. At each facility, employees are encouraged to choose local options for food, supplies, and services to help us reduce emissions, support local economies, and strengthen community ties.

3.2.6 We respect customers’ interests

We provide transparent information and adopt fair business practices.
‍In full respect of consumers’ fundamental rights to make informed purchasing decisions, we ensure that our marketing practices are fair, and our services meet the highest quality standards. We provide our customers with accurate information about our services, including details on pricing, content, potential risks, and available support. Additionally, we remain at our customers’ disposal for any further information they might need according to their specific business needs, and we ensure they can easily contact us for questions or complaints. We always do our best to make sure customers’ requests are handled promptly and efficiently.

We ensure the confidentiality of information.
During our operations, we may receive or gain access to information that is confidential and/or proprietary to our customers. Regardless of the form in which the information is received — whether in writing, electronically, or verbally — we protect such information from unauthorized disclosure. All employees are made aware that any information they receive concerning the company or its customers is confidential and must be safeguarded. Additionally, employees are bound by internal confidentiality agreements to protect such information, whether generated internally or acquired externally, and to use it only in the performance of their professional responsibilities. The handling of confidential information with employees and contractors is guided by one core principle: Confidential information may only be shared with individuals who have a legitimate business need to know.

4. Looking ahead: A sneak peek at our future commitments

We dedicate significant time and resources to monitoring and enhancing our existing programs and initiatives with the goal of continuous improvement. We’ll continue to research key topics, remain aligned with industry best practices, and integrate new approaches in a way that reflects our culture.
We’re committed to identifying and addressing any gaps or inefficiencies swiftly and thoroughly. This document will be reviewed and updated regularly, with the purpose of communicating any new initiatives related to our five pillars of ethics.