N-iX Code of Conduct

Part 1. Introduction

1. Why do we need the Code?

Since 2002, N-iX has been a trusted software development partner for global industry leaders. We are confident that our reputation is the most important asset that help us build long-term and successful partnerships with our clients, associates, suppliers, and communities we operate in. And our reputation and success depend on each N-iX team member.

This document can give clear guidance on our expectations from each team member and other stakeholders.

1.2. Who is this document for?

The Code of Conduct applies to all professionals performing services at N-iX or representing its interests worldwide, including directors, consultants, all our specialists, and other stakeholders, whether their services are performed temporarily or permanently.

1.3. How can this Code help you?

The Code shows clear principles of mutually beneficial cooperation between N-iX, its specialists, and other stakeholders. It is not meant to address each situation that may arise during your work at N-iX. However, it will:

• Give you guidance for everyday decision making.
• Set expectations and requirements for your conduct as an N-iX team member.
• Mark your responsibilities to ensure respectful partnership with all stakeholders.
• Explain where to get assistance or guidance if you have conduct-related questions or any ambiguous situation arises.

1.4. What is expected of you?

• To get acquainted with the Code of Conduct when starting working with N-iX.
• To follow guidelines described in the Code.
• Consult with a direct manager, HR Business Partner, or an appointed responsible person should any questions about interpreting or applying the Code of Conduct arise.
• To raise concerns if any violation occurs.
• To lead by own example and integrate values and principles described in the Code in the team’s everyday life.

1.5. What can you expect of N-iX?

• To ensure equal opportunity, a safe and comfortable working environment for all.
• To conduct a fair investigation and take disciplinary actions towards associates who fail to comply with the Code of Conduct.
• To regularly review and update the Code and communicate the changes to all stakeholders.

Part 2. Our Principles

2.1. We share the same culture and values:

• Entrepreneurship
• Openness
• Flexibility
• Empathy

2.2. We get things done:

• We contribute to a collaborative, inclusive, and transparent working environment.
• We do our best to help our clients achieve their goals and ensure uncompromised success for them.
• We offer help and willingly share knowledge with our colleagues.
• We encourage people to speak up, initiate discussions, ask questions, and share their opinions openly and honestly.

2.3. We respect human rights

• We are committed to ensuring that people are treated equally with dignity and respect.
• We provide a safe and healthy workplace and comply with applicable safety and health laws and regulations.
• We prohibit the use of all forms of forced labour and engagement in human trafficking.
• We do not use child labour and comply with all local laws on the minimum age of employment.

2.4. We communicate respectfully and clearly:

• We highly value transparent, respectful, and professional communications.
• We strongly believe that any inexplicit or unethical communications harm our reputation and partnership with team members and other stakeholders.
• We respect cultural differences, which may have an impact on the way people express their thoughts.

2.5. We do not tolerate any form of discrimination:

• We hire and work with people based only on their professional qualities and merits.
• We respect and value every aspect of diversity among our teammates and other stakeholders.
• We have zero-tolerance for discrimination as any less favourable or differential treatment or violation of people’s dignity based on race, age, gender, marital status, medical condition, religion, political affiliation, citizenship or any other distinctive features.
• We understand that discrimination can be either intentional or unintentional, but both forms could be considered as violations of the Code if they violate another person dignity, put someone at a disadvantage, create a hostile environment or interfere with an individual’s work performance.
• We want everyone to feel confident and comfortable communicating concerns and violations of our Code. We do not tolerate any acts of retaliation against a person who reports an issue or participates in investigating possible violations of our Code of Conduct.

2.6. We do not tolerate harassment or disrespectful behavior, which includes but is not limited to:

• Any offensive, unwelcome or intimidating behavior isolated or repeated, whether it happens in person or remotely (during meetings or calls), in verbal, non-verbal, or physical forms.
• Any deliberate insults, abusive or threatening words even in the form of a joke or compliment.
• Any form of cyberbullying or blackmailing, including exclusion from routine work communication, sending an unsolicited or threatening email with deliberate insults, threats, unsolicited sexual proposals, etc.
• Any offensive or discriminatory displays or publications anywhere in the workspace.
• Any form of sexual harassment including but not limited to unwelcome deliberate physical contact, propositions or subjecting for sexual favors, physical assaults of sexual nature.
• Any decision making on preferential treatment of associates on the ground of individuals’ sex and/or sexual orientation.
• Any form of unsubstantiated complaints with deliberate purpose to insult, bully or intimidate team members or receive any favorable treatment.

Part 3. Business Ethics

3.1. We care about our clients and make sure we provide only top-quality services:

• We care deeply about our customers’ needs and make every effort to help them succeed.
• We provide clear and accurate information to our customers.
• We encourage feedback from our customers, identifying and handling complaints.
• We respect the intellectual property rights of our colleagues and clients and protect our own intellectual property.

3.2. We take information confidentiality very seriously and thus:

• We collect, store, and process associates’ personal and customer data securely, lawfully and transparently for legitimate business purposes only.
• We do not disclose or share private information regarding our colleagues, customers, and other stakeholders with anyone outside N-iX.
• We understand that our commitment to privacy remains effective after relationships with stakeholders have been discontinued.
• We are careful about not infringing any legal limitations when copying, reproducing, or transmitting protected materials, including writing, artwork, video or photo artefacts, and software (whole or in parts) unless we have permission or a license.

3.3. We carefully choose our suppliers and expect them to:

• Operate fairly, ethically, and responsibly in line with our Anti-corruption Policy and the Code of Conduct.
• Ensure compliance with the obligations and applicable local laws.

3.4. We avoid conflict of interest:

• We actively identify situations where a conflict of interest might occur and proactively prevent them.
• We do not use our position, corporate property or company information for personal gain.
• We act with honesty and integrity to avoid any relationship or activity that might create, or appear to create, a conflict between our personal interests and the interests of other stakeholders.
• We avoid situations when our associates, other stakeholders, their family members, or another person in a personal or professional relationship gain improper benefits as a result of their position in the company.
• We ensure that no close personal relationships negatively influence our work responsibilities or our capacity to make unbiased and objective decisions.

3.5. We avoid situations that can damage our reputation or create a conflict of interest, and thus all gifts from N-iX or any third party acting as an intermediary on behalf of N-iX must:

• Be reasonable in value and presented for a legitimate reason, such as to validly promote or demonstrate N-iX services, products, or policies.
• Comply with applicable local anti-corruption laws and best international anti-corruption practices.
• Be given or received in an open and transparent manner.
• Be appropriate to the business relationship and local customs.

3.7. We can accept the following gifts:

• Invitations to certain events and entertainment such as conventions, conferences or product training seminars, or business-related meetings outside the ordinary course of business.
• Nominal gifts, such as branded items, pens, calendars, caps, shirts and mugs, are generally acceptable.

3.8. We do not accept any gift or hospitality in the following situations:

• Gifts from suppliers during a pitch, tender, contract renewal or dispute.
• Gifts that could improperly impact N-iX’s Code of Conduct, relationship with a customer or supplier, or create an obligation to them.
• Gifts or other benefits that by their nature or amount, would create a potential conflict of interest or be considered a bribe.
• Cash gifts should never be accepted or given. Ƚ Should there be any doubt whether the gift is acceptable, N-iX representatives are required to follow established approval procedures.

Part 4. Our responsibilities towards communities

4.1. We recognize our impact on the local communities where we operate:

• We are committed to engaging with stakeholders in the communities where we operate to ensure that we take into account their views as we conduct our business.
• We expect our specialists to share our commitment to integrity and understand the importance of building trust with our customers, governments, representatives, and each other.
• We know and follow local rules, requirements, and processes that apply to our business.
• We recognise and comply not only with the letter of the law but also with the spirit of the law.

4.2. We have zero tolerance for bribery and corruption:

• We do not offer or take bribes, kickbacks, improper profit-sharing arrangements, illegal gratuities etc., to obtain or keep business or to secure some other improper advantage.
• We do not offer or make “gifts,” whether directly or indirectly on N-iX’s behalf, to government officials to get favourable business treatment.
• We clearly understand that restrictions in this section apply to all N-iX business activities around the world, even where such practices might be locally considered acceptable.
• We report any potential, suspected or actual violations of local AntiCorruption Laws.

4.3. We separate personal political activity and our work with N-iX:

• N-iX associates and representatives may participate in the political process as private citizens.
• We separate personal political activity and our work to comply with the appropriate rules and regulations and not to harm N-iX business interests.
• We do not work on behalf of the candidate’s campaign while at work or at any time use N-iX’s facilities or that purpose unless approved by the relevant company stakeholder.

4.4. We are committed to running a sustainable business and care for the environment:

• We recognize the impact we make on the world where we live and work and strive to reduce the environmental footprint of our operations.
• We support the use of environmentally friendly technologies, products, and services and work on building a sustainable business.
• We take specific actions in our everyday work to reduce our environmental impact, such as recycling and managing waste more effectively, improving the energy efficiency of our facilities and extending the life cycle of our IT equipment, etc.

Part 5. Code in Practice

5.1 How to complain

If you have any queries or concerns about code of conduct violations or want to report potential case, please contact us confidentially via conductcompliance@n-ix.com. All reports will be kept confidential with details shared only with the Corporate Compliance Committee.

You may also report the incident anonymously through the form below. Please notice that if you would like to receive a follow-up about the progress of your incident report, you would need to provide contact information.