PUFIN ID CODE OF CONDUCT

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The Code of Conduct outlines what Pufin ID stands for as a company, and it governs how each employee engages with colleagues, customers, suppliers, authorities, the community and other stakeholders. This is the simple, behavioral foundation that all Pufin ID employees must follow.

Pufin ID supports the 10 principles of the United Nations Global Compact within human rights, labor rights, environment and anti‐corruption.

Pufin ID employees work towards achieving, and Pufin ID deliver products that enable customers to achieve, the 17 United Nations Sustainable Development Goals.

The Code of Conduct applies to all employees of Pufin ID. All Pufin ID employees are expected to read, understand and comply with the Code of Conduct and otherwise use their sound judgement to act, at all times and in all ways, in the best interests of Pufin ID and Pufin ID customers, while performing their duties.

Respecting cultural differences and diversity. We treat people equally, independent of gender, race, ethnicity, disability, age, political beliefs, and sexual orientation, as we do not consider this to be of any professional relevance. Harassment or discrimination – no matter the reason – is not acceptable when working or interacting with Pufin ID.

Business ethics. We follow the law and comply with rules and regulations in all countries in which we’re operating, and we support employee rights and environmentally conscious behavior. We are committed to competing in a fair and vigorous manner in compliance with all applicable antitrust and competition laws. Bribery, including donations, lavish gifts, and extravagant entertainment, is not acceptable.

Professional attitude. We interact professionally and politely and dress as the situation, culture and customs requires. Harsh, degrading, and intimidation treatment of others is not acceptable, nor is it acceptable to be under influence of alcohol or other intoxicating substances at work.

Protecting information. We treat items and information with care, maintain full confidentiality and safeguard all data, intellectual property rights, trade secrets and infrastructure to prevent any unauthorized access to proprietary information and to minimize cyber-security threats.

Being trustworthy. We are transparent about any conflicts of interest, and we only undertake work after first having ascertained that we have the required qualifications and resources. We are proud of what we know and of our willingness to learn. We always honor our commitments to the best of our abilities – towards customers, colleagues, the society, and our planet.

Respect for Personal Data and Privacy. We are committed to respecting the right to privacy and process all personally identifiable data in strict compliance with Pufin ID’s Privacy Policy.

Company Communications. All business records and communications (including letters, email, texts, SoMe, contracts and databases) should be clear and accurate to avoid misunderstandings or errors.

Reporting of non-compliance. Pufin ID employees are encouraged to report any non-compliance with the Code of Conduct and other concerns related to misconduct to the management (or to the Chairperson of the Board of Director in case of any misconduct by the management) as soon as possible after becoming aware hereof. Pufin ID does not tolerate retaliations against employees making reports in good faith.  

Enforcing the Code of Conduct. Non-compliance with the Code of Conduct by any employee may result in disciplinary action, including dismissal.

Approved by the Boards of Directors, April 19, 2022

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