Code of conduct

Paligo is committed to being a competitive, fair, respectful and trusted partner to our customers, our current and future colleagues, our suppliers and other stakeholders. We strive to be good corporate citizens wherever we conduct business.

• We believe in fair working terms and conditions
• We are committed to a healthy workplace and work/life balance
• We believe in diversity and inclusion
• We keep accurate and complete records
• We protect our company’s and our customers’ assets
• We are committed to quality and continuous improvements
• We have zero tolerance for bribery and corruption
• We ensure protection of personal and business-critical information
• We are committed to environmental responsibility
• We communicate honestly, transparently and in a timely manner

Paligo’s Code of Conduct (‘Code’) describes how we do business and sets the principles for how we interact with our stakeholders, customers, and the world. In addition to our company’s core values, as well as local laws and regulations in each of the countries where we operate, this serves as a set of principles we apply to our daily work and common culture worldwide. We are committed to high ethical standards and practices to create long-term value that is beneficial for our customers, the company and society.

The Code of Conduct applies to all Paligo employees, Board of Directors and contractors globally, regardless of role. In the case of conflict between this Code and mandatory local laws or regulations, the local laws or regulations shall prevail.

As a manager/supervisor or leader, you have a particular responsibility to lead by example and conduct our business in accordance with this Code, making sure your team is provided with the training necessary to understand the Code and any policies related to it.

The continued long-term success of our company depends on everyone to act accordingly, be accountable, and follow these principles in our daily work. Therefore, it is important to read this Code, apply it consistently, and ask questions if needed. Failure to follow the principles outlined in our Code of Conduct will be taken seriously and could result in disciplinary action, ranging up to and including dismissal.

The foundation of our Code of Conduct is built on our core values and on the International Bill of Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, and the United Nations Convention against Corruption as outlined in the ten principles of the United Nations Global Compact. We are committed to adhering to these principles in order to provide a solid foundation that supports a more sustainable future for Paligo and for our stakeholders.

Working terms and conditions cover a broad range of topics, from schedules to earnings, as well as physical conditions and psychological safety in the workplace. Paligo strives for a fair, safe, and inclusive working environment that allows everyone to thrive.

• As a company, we feel it is our responsibility to promote safe and healthy labor practices. We have zero tolerance for any form of child, forced, or compulsory labor. Working hours that are not in compliance with national laws and industry standards will not be permitted. Earnings and benefits are market competitive and consistent with industry standards in the
  countries in which we operate.
• We recognize and respect our employees’ right to freedom of association and collective bargaining.

• You have a responsibility to understand your own employment conditions.
• Managers/supervisors have a particular responsibility to lead by example and promote fair working conditions.
• Regular communication regarding wages and benefits should be clear.
• All employees are entitled to a written employment contract or offer of employment stating the terms and conditions of employment.
• You have the right to appoint worker representatives and form workers’ associations or join trade unions of your own choosing.
• Your decision on whether to join a trade union or form workers’ associations or appoint worker representatives is an individual choice; you will be respected regardless of your choice.
• Everyone shall be treated with respect and will not be subjected to physical, verbal or financial punishment.

A healthy workplace and work/life balance means the provision of leadership, workplace environments and work practices that result in a culture where every person has a psychologically safe and healthy work environment.

• When conducting business, we are committed to providing candid and respectful communication.
• We support a fully embedded health and safety culture, by integrating both physical and psychological health and safety into every aspect of our daily business. Importance is placed on recognizing, promoting and sharing good health and safety practices throughout the organization.

• Take the time to understand the health and safety risks present in your daily work as well as the actions you can take to prevent them.
• Comply with Paligo policies and the Paligo Employee handbook on health and safety aspects, as well as local health and safety legislation, rules and procedures.
• Demonstrate proactive and visible leadership in health and safety matters, regardless of your role.
• Take personal actions to ensure your psychological and physical health are not negatively affected by your work.
• Take advantage of the health and safety activities/programs offered at your location.
• Exercise sound judgment and safe conduct when conducting company business and during business travel.
• Make sure you are always “fit for work”. This means you are free from any adverse effects due to medical or physical conditions, drug or alcohol use, fatigue or stress.

Diversity encompasses personal, cultural and cognitive differences, as well as different work and life experiences. Inclusion is how we allow all employees and contractors to contribute and reach their full potential. We believe the combination of diversity and inclusion leads to innovation, motivation and high performance.

• We believe diversity and inclusion helps to attract, develop and retain talent, generate innovation, and help fulfill and exceed customer expectations.
• Working together as a team to utilize everyone’s unique competencies and knowledge is crucial to our success. We feel having diverse perspectives is beneficial to our workplace.
• Therefore, we provide equal opportunities regardless of race, ethnicity, national origin, religion or belief, gender, sexual orientation, gender identity or expression, age, disability, marital or family status, or any other characteristic.
• We do not accept any form of intimidating or disrespectful behavior, bullying, harassment, unwanted sexual advances or unlawful discrimination.

• Always encourage a positive work environment, where everyone is appreciated, respected and valued for their differences.
• Be open-minded, promote team spirit, encourage new ideas, and learn from others.
• Include and consider all people in opportunities for development, discussion or employment within your organization.
• Encourage and promote the development of diverse teams at all levels and functions.

This includes both financial and non-financial records such as meeting minutes, memoranda, contracts, financial statements, payrolls, expenditures, human resource records, and other records containing personal data, safety and environmental records, product information, and accounting source documents.

• We believe the integrity and accuracy of our business records are of the utmost importance.
• We maintain well-managed, accurate and transparent records consistent with all applicable legal requirements and industry standards for every detail of our business.
• We prepare our financial records in a timely manner. They are fact-based and accurately reflect our business dealings.
• We maintain a system of control of the business records’ accuracy at all times.

• Maintain accurate records of your business dealings every day.
• Retain and maintain documents and records in accordance with applicable customer and legal requirements.
• Comply with the delegated authority levels for approval of financial and other business decisions.
• Ensure that every entry in all reports or records is accurate and is not false or misleading.
• Record your working hours and business expenditures accurately and according to local procedures.
• Use the correct security classification, for example, when sending emails.

Assets can be tangible or intangible. Examples of tangible assets are real estate, office or personal equipment, including our computers and other mobile devices, that store important and confidential company information and personal data of our employees and stakeholders. Examples of intangible assets are: brands, patents, trademarks, know how, trade secrets, copyrights, goodwill, and information.

Fraud includes any intentional or deliberate act to deprive a company of property or money by deception or other unfair means. Theft occurs when property belonging to a company is taken without the required approval.

• We are mindful and protect our company’s and our customers’ assets from damage, loss and criminal acts, as they are vital to our business.
• We comply with internal controls designed to safeguard and protect such assets.
• We only use assets for business purposes unless otherwise authorized by appropriate management.
• We never use company or customer assets for personal gain or illegal activities.

• Use appropriate means to safeguard our company’s and our customers’ assets from loss, theft, damage and/or misuse.
• Comply with and adhere to the company’s internal controls and procedures.
• Use our and our customers’ brands, patents, trademarks, know-how, and copyrights responsibly and as instructed.
• Never use our company’s computers, phones or IT systems to view materials that are inappropriate, illegal, sexually explicit, or otherwise offensive.
• Report suspicions or concerns of fraudulent behavior, theft, money laundering, or other irregular activity.
• If you become aware of theft, damage and/or misuse of company or customers assets, or have any questions about appropriate use of them, speak with your manager.

Our quality and continuous improvement culture is based on our attitude and commitment to meet or exceed customer expectations and to continually develop and improve all aspects of our solution and our operations, every hour and every day.

• Continuous improvements and an understanding of our customers and their business needs drive our efforts and activities.
• We are committed to providing our customers with software and services that meet or exceed their expectations.
• Leadership, attitudes, relentless efforts to improve, and a service mindset are crucial for building long-term relationships with our customers.
• Our technology leadership and innovative mindset strengthens our brand reputation as a trusted business partner that supplies superior software and services.

• Continuously strive to meet or exceed requirements and improve your processes through your attitude and mindset.
• Understand our quality principles, objectives and key performance indicators (KPIs), while clearly supporting our business needs and strengthening customer focus.
• Listen to our customers (both internal and external) and understanding their needs and challenges before agreeing on requirements.
• Take action if you discover unclear requirements, suspected deficiencies or non conforming products or services.
• Be proactive in learning and improving every day and sharing what you learn.
• Embrace new technology and innovation when needed and appropriate, always with the intention to enhance the product and increase the customer value provided.

Bribery is the offering, giving, receiving, or soliciting of something of value for the purpose of influencing the action of an official or private company in the discharge of their duties. Corruption means abuse of entrusted power for private gain, which could include conflicts of interest, embezzlement, kickbacks, extortion, or nepotism/cronyism.

• We are committed to conducting our business with integrity. We have zero tolerance for all forms of bribery and corruption.
• We do not directly, or indirectly through third-parties acting on our behalf, pay or offer to pay bribes.
• We do not offer or accept gifts that will improperly influence our business decisions or those of our partners.
• We always make business decisions in the best interest of our company.
• We disclose conflict of interest situations in accordance with applicable policies, procedures, and guidelines.
• We are committed to and comply with all anti-money laundering legislation, including reporting obligations.
• We train our employees and contractors to ensure they are knowledgeable about anti bribery and anti-corruption, including making sure they can identify situations where anti corruption considerations are relevant.

• Understand the company’s position regarding bribery and corruption.
• Never make facilitation payments or permit others to make them on your behalf.
• Do not engage in activities that create any type of conflict between your personal interest and the interest of our company.
• When using third parties, such as distributors or agents, you require that they conduct business with the same level of integrity and honesty that is consistent with our high ethical values.
• Avoid activities that limit the ability to compete fairly or that could influence you or your counterpart’s judgment (such as excessive gifts or entertainment) in all relationships with customers, competitors, suppliers and distributors.
• Always contact the company legal team if you are exposed to, become aware of, or suspect corruption.
• If you are in a position where you may be exposed to corruption risks (especially if you work within sales or marketing, or engage in procurement on behalf of the company), you must attend and complete training.

Personal information (or data) is any information that directly or indirectly identifies an individual. Business-critical information is information such as business plans, strategic documents, planned mergers and acquisitions, sales information, sourcing information, intellectual property, research and development information and financial information. Personal and business-critical information exists in many forms, such as paper-based or on digital devices. The unauthorized use or dissemination of personal and/or business-critical information can cause significant harm to our company’s business or reputation, in addition to the individuals whose personal data we are responsible for safeguarding.

• We make sure that information is reliable and available to those who need it, when they need it.
• We are committed to ensuring the protection of the personal information of our employees and stakeholders with whom we engage.
• We handle personal information responsibly and in compliance with laws and regulations in the countries where we operate.
• We handle information about our company and related parties with caution and take measures needed to ensure the protection of business-critical information.

• Make sure information is trustworthy, reliable and available for those who need it, when they need it, but only on a need-to-know basis.
• Do not access, collect, store, use, or share personal or business-critical information without proper authorization.
• If you have been authorized to share personal or business-critical information with anyone inside or outside the organization, make sure it is in line with company policies and procedures, as well as applicable laws of the country in which you operate.
• Ensure the protection of personal or business-critical information related to our employees, customers, suppliers, joint ventures and any other individuals whose data we process.
• Use only the minimum amount of personal data or business-critical information necessary to fulfill your legitimate business purpose or legal requirement.
  Implement technical and organizational measures proportionate to the sensitivity of the personal and business-critical information.
• Store personal data only as long as necessary to fulfill a legitimate business purpose or legal obligation.

At Paligo, environmental responsibility means operating our business and providing services in a way that limits environmental impact and contributes to a more sustainable future.

• In our daily activities, we strive to act in a manner that considers ways to lessen our impact on the environment.
• We measure our carbon footprint annually and set environmental ambitions to improve it.
• We take positive, precautionary actions if we identify that our operational activities may harm the environment.

• Understand any environmental requirements of your role.
• Understand and identify any negative environmental impact present in your daily work and take proactive measures to eliminate or reduce it.
• Be aware of the environmental effects of the resources you use while working, and make improvements where you can.
• Follow local waste separation guidelines and try to re-use and/or recycle materials to minimize environmental harm.
• When making business travel decisions, try to make the most environmentally friendly choices possible.

Communication is about increasing engagement for our company, building a strong brand and managing our reputation to help achieve our business objectives. This includes both internal and external communication that is verbal, written or visual, and can occur in multiple channels; internet, intranet, internal collaboration platforms, meetings, social media, publications, and news media in any form.

• We build trust for our brand at all times by behaving in a way that reflects our core values.
• We keep our customers and stakeholders well-informed in a timely manner, assisting them in understanding our business developments.
• We keep confidential information to ourselves at all times, but openly share other information, best practices and feedback throughout the whole organization to promote engagement and transparency.
• We always make sure that information is accurate and not misleading.
• We take a neutral view on politics and religion. Employees are free to participate in public, religious and political matters in their free time in their capacity as private citizens.
• We communicate in an inclusive way that encourages diversity.

• Only speak to the media or investors, or engage in social media on behalf of our company, with the proper authorization.
• Do not share non-public information with unauthorized persons.
• Act with care and integrity when using social media, and in all your communication on behalf of our company. Stay consistent with our core values and Code of Conduct.
• Make sure to maintain a clear distinction between you and the company when you communicate about Paligo. Keep content consistent with our Code of Conduct when presenting yourself to colleagues and customers.
• Promote an open and constructive dialogue while avoiding rumors and unconfirmed information.
  If you have concerns about possible violations of this Code of Conduct, you have a responsibility to report it.

The Code applies to everyone. As an employee or contractor, it is your responsibility to read the Code of Conduct, use it for reference, and react if you witness a breach. You are also responsible for following any company policies relevant to your position and work. Paligo’s policies and procedures can be found on the intranet.

If you have questions about specific situations not covered in the Code, reach out to us for help. We’re happy to provide guidance and assistance.

If you are in a situation and unsure of how to act, ask yourself the following questions:

• Is the decision or action considered legal?
• Is the decision or action in compliance with company policies and this Code?
• If my family, friends and others outside Paligo became aware of this, would I feel comfortable?
• If my action was reported on the front page of the newspaper, would I still feel comfortable with my decision or action?

If you have concerns about possible violations of this Code of Conduct, you have a responsibility to:

Discuss your concern with your immediate manager as soon as possible.
If you are uncomfortable doing that, speak to another manager or contact someone on the People Growth team.
If you are uncomfortable doing that, report it via our whistleblowing function.

Being an ethical and sustainable company is important to Paligo, so be sure to raise concerns or report any possible breaches of our Code of Conduct so that we can take corrective action, improve our work environment, and reduce risks.

Paligo’s commitment to its Code of Conduct as per above is hereby confirmed.