Code of Conduct

Introduction

Integrity, entrepreneurial responsibility and the environment have been important to Bizplay's company culture from the start over 10 years ago. Since then the world has changed, more and more companies want to contribute to a "better world". That is why a growing number of our business partners and customers have published a code of conduct or have asked us to sign a code of conduct agreement. That is why we decided to put in writing the guidelines according to which we have acted for many years and that we have agreed upon to a number of our partner companies and customers. The following is a list of these guidelines; this is our Code of Conduct.

Basic requirements

Compliance with the law

• Compliance with all applicable laws and regulations is a matter of course for us and critically important to the success of our company. Any violation of laws or regulations can have severe consequences for both the company and its employees, such as criminal convictions, disciplinary actions, fines, and reputational damage.
• We investigate all reports of misconduct. Violations are stopped and appropriate measures are taken.
• Managers (employees with budget or personnel responsibilities) in particular must be familiar with the fundamental laws, regulations, and corporate policies that are relevant to their areas of responsibility.
• In specific countries, industries, or markets, as well as with specific business partners, stricter rules than those described in this Code of Conduct may exist. In such cases, employees shall apply the stricter standard.
• If there is any doubt whether a decision is legally sound, the relevant legal department or another appropriate person shall be consulted for assistance and clarification.

Freedom to speak up

• Being able to speak up freely helps to prevent misconduct, and to detect and correct it, should it occur. We encourage critical and imaginative thinking and value an open work environment where employees can approach their supervisors or senior management to raise issues or voice criticism without any concerns. Managers encourage open dialogue, support their employees and address their concerns in a fair and impartial manner.
• Intimidation or retaliation against employees who report suspected or actual misconduct in good faith will not be tolerated. "In good faith" means that an individual believes that what he or she asserts is true, whether or not a subsequent investigation proves that report to be true.
• Knowingly making an untruthful report of misconduct with the aim of wilfully and falsely accusing another person constitutes a compliance violation and will result in appropriate measures being taken.
• If employees feel uncomfortable raising concerns with a contact person in their local working environment, or if doing so has been ineffective, they are encouraged to contact senior management.

Mutual respect and trust

• Every individual shall be treated fairly, respectfully and with dignity. We are committed to diversity, inclusion, and equal opportunities and encourage a respectful and tolerant workplace in which everyone's unique value is recognized. Sexual harassment, discrimination, racism, bullying, abuse of power, intimidation, threats, or any other form of harassment are not tolerated.
• We do not allow discrimination on the basis of race, national or ethnic origin, gender, gender identity or gender expression, sexual orientation, pregnancy, marital or parental status, age, disability, religion or belief, or any other characteristic specified under applicable anti-discrimination law or company policy.

Conflicts of interest

• In our day-to-day work we may be faced with situations in which a business decision that is in the best interest of the company is in conflict with our personal interests.
• A conflict of interest can make it difficult to make impartial decisions that are in the best interest of the company.
• Employees with a potential or actual conflict of interest must quickly disclose it to their supervisor or their company's senior management for prompt resolution.

Protection of company assets

• We treat company assets of all kinds, such as products, work materials, IT equipment, or intellectual property, carefully and responsibly.
• Company assets are used for their intended business purposes and not for unreasonable or improper personal purposes.
• Every form of fraud, embezzlement, theft, misappropriation, or tax evasion is prohibited, regardless of whether company assets or third-party assets are affected.

Corporate responsibility

Human rights

• We respect the human rights, individual rights, and dignity of employees and all third parties.
• We uphold both the right to freedom of association and the right to engage in collective bargaining in accordance with applicable laws and regulations.
• Forced or child labour, all forms of modern slavery and human trafficking, and any form of exploitation are prohibited at Bizplay, and we strictly comply with applicable laws.

Fair and healthy working conditions

• We comply with regulations that ensure fair working conditions, including those regulating compensation, working hours, and privacy.
• Our compensation systems are consistent and transparent. They ensure remuneration that reflects the market, function and performance, while also considering conditions that are specific to the business.
• We comply with all applicable health and safety laws and standards and provide a healthy and safe workplace for our employees.

Environment

Environment and climate protection

• We comply with all applicable environmental regulations and with our internal environmental guidelines, for example regarding climate protection.
• We strive to increase our resource and energy efficiency in the production and distribution of our products and services, to minimize negative impacts on the environment, and to achieve climate neutrality by 2030.
• We procure and use resources such as energy and water responsibly.

Business partners and third parties

Dealings with business partners

• Our business partners (such as customers, clients, suppliers, agents, and consultants) expect to be able to rely on Bizplay as a business partner that complies with the law. This also requires us to be well informed about our contractual obligations towards our business partners.
• We carefully check the identity and integrity of potential business partners (due diligence). If in this process, or later in the course of collaboration, we find that the business partner engages in inappropriate or illegal business practices, we will take appropriate measures.
• We make fair and unbiased procurement decisions based on objective criteria such as quality, price, service, reliability, availability, technical performance, contract fulfilment, resource and energy efficiency, and environmental impact.
• We take adequate measures to ensure that transactions with third parties do not violate current economic embargos, sanction lists, or regulations of trade, import or export controls, or regulations for the prevention of terrorism financing.
• We comply with our obligations regarding the prevention of money laundering and minimize general money laundering risk by conducting adequate due diligence of third parties.

Anti-corruption and anti-bribery

• We do not tolerate offering or accepting bribes, in any form, whether to or from public officials or business partners.
• Gifts and hospitality are permissible under certain conditions, provided that they are either associated with promotional measures or are intended to foster business relations or present products or services.
• Such advantages may only be given or accepted if they serve a legitimate business purpose and are not intended as compensation in exchange for an unlawful or improper advantage. The advantage must not have an unreasonably high value and must not exceed the limits of customary business practice or the recipient's normal standard of living. When accepting or offering gifts or entertainment, the internal rules, in particular the approval requirements, must be observed.
• Donations and sponsoring activities are generally permitted but must not be used to obtain an unlawful business advantage. We do not conceal any benefits or advantages that could lead to corruption risks.

Fair competition

• In virtually all countries, laws prohibit relationships or arrangements with competitors, suppliers, distributors, or dealers that may interfere with competition in the marketplace. These laws apply to a wide range of activities, including price fixing, allocations of customers or sales territories between competitors, anti-competitive boycotts, and other unfair methods of competition.
• We put a stop to any infractions without delay.

Governmental and regulatory relations

• Business relationships with governmental bodies are often subject to particularly strict requirements. In all our dealings with government and regulatory authorities and officials, we conduct ourselves honestly and transparently and comply with applicable laws and our internal rules. Dealings with governmental entities may occur, for example, in the ordinary course of business (obtaining necessary licenses or approvals or entering into contracts), while engaging in political lobbying, or when responding to governmental or regulatory requests or inquiries (including subpoenas, investigations and legal proceedings).
• We do not offer gifts to public officials. We limit invitations to public officials to low-priced hospitality and obtain the necessary guidance and approvals in advance.
• In the event of governmental inquiries of any kind, the company's senior management and the relevant legal department must be contacted immediately.
• If an official license is required (either for the entity or for an employee) we do not conduct any business activity in the respective business area until we have obtained this license. If a license is revoked or expires (including applicable grace periods, where applicable), we will stop the business activity until it has been reissued.

Product safety

• We are committed to providing our customers with safe, high-quality products and services.
• Our products must not contain defects or unsafe features that could have adverse effects on health or property.

Content and information

Content responsibility

• We place a great importance on complying with local laws in the distribution of content when it comes to discrimination or inappropriate content, and we comply with the relevant restrictions.
• We place a great importance on the protection of children and youth in the distribution of content, and we comply with the relevant restrictions.

Protection of intellectual property

• Protection of intellectual property is of particular importance for our business.
• Protected intellectual property includes any products of the human mind irrespective of their commercial value. This includes, but is not limited to, literary and journalistic works, music, films, TV programs, visual works, and software and its components. Intellectual property is protected under relevant laws (copyright, trademark, or patent rights) or as a trade secret.
• Intellectual property infringement includes, but is not limited to, the display, distribution, or performance of copyrighted material without permission and the unauthorized creation and distribution of copies of protected intellectual property.
• We point our customers to their responsibilities in protecting intellectual property and adhering to the applicable local laws in our terms of service.

Data privacy and protection

• When we collect, retain, process, or transmit personal data (such as names and addresses) relating to employees, customers, or other third parties, we do so with great care and strict confidentiality and in compliance with applicable law and policy, see our privacy policy.
• Employees involved in the collection, retention, processing, or transmission of personal data receive advice and support from the legal department.

Information technology use and security

• In our daily business, we use information technology and process data on a regular basis. This requires appropriate security practices (password protection, approved technology, and licensed software) to protect intellectual property and personal data. Ignoring appropriate security practices can lead to serious consequences, such as data loss, theft of personal data, or copyright infringement.
• Because digital information can be distributed rapidly, and is easily replicated and practically indestructible, we exercise care in the content of any e-mails, recorded voice-mails, attachments, or downloaded information that we receive or send.
• We commit to using company-provided IT systems for legitimate business purposes and not for unreasonable or improper personal use.

Confidentiality and communication

• Confidential information is non-public information that is intended for specific recipients only, not for internal dissemination or external release. It may involve records, reports, contracts, financial and personnel data, investigations, disputes, court records, creative work, intellectual property, or plans relating to business or products.
• Discussing confidential information in public places or engaging in unauthorized sharing of company or customer information with third parties constitutes a breach of confidentiality obligations and may constitute a violation of applicable antitrust laws.
• In particular, employees with access to especially sensitive information (including information relating to the areas of finance, human resources, employee representation, legal, mergers and acquisitions, corporate communications, corporate development, and insider information on other companies) must observe strict confidentiality, even with colleagues.
• When using social media we are aware of our responsibility to our company's reputation. We do not share confidential or sensitive company information and we respect the privacy of our colleagues and business partners.
• Employees are provided with comprehensive, transparent, and up-to-date information about the company in accordance with our rules concerning confidentiality.

Finance

Financial integrity

• All transactions and records relating to our business must be maintained accurately and properly. All transactions, assets and liabilities must be properly documented and, recorded in accordance with legal requirements.
• Proper record keeping requires high standards of accuracy, completeness, and accountability in all business dealings.
• Financial accounts, documents, contracts, and other company information may not knowingly include incorrect or misleading entries.
• We comply with tax regulations and fulfil our tax obligations.

Insider trading

• The law prohibits the use of insider information when trading in securities or other tradable financial instruments as well as the disclosure of insider information to others for such purposes.
• Insider information is information about any circumstance that is not publicly known which, if made public, could significantly influence the price of, or market for, any securities or similar financial instruments. Examples of such circumstances include higher/lower earnings, major contracts, plans to merge with or acquire a company, important new products, or significant personnel changes in company management.
• The scope of the regulations on insider trading may vary from country to country. Employees faced with such a situation should seek the advice and support of the legal department.

Statements regarding products and services

• We always make truthful statements about our products and services.
• Misleading or false information regarding products or services can harm our customers as well as our reputation. This violates our principles and is prohibited

Version history

10 October 2023: First edition