Code of Conduct

Equality, diversity, and inclusion

When it comes to recruitment, promotion, and training, what counts is competence, experience, attitude, ambition, and performance. We believe that successful teams are diverse teams. We understand, respect and value each other’s differences. We do not tolerate discrimination, bullying, victimisation or any kind of harassment.

We provide a professional and fair working environment in line with universal human and labour rights standards, applicable laws, and agreements on working hours and compensation. These universal standards and applicable laws are a minimum standard for us that we strive to exceed. Child labour, or forced labour at any age, is not tolerated in our business or supply chain.

At Cludo, employees’ wellbeing, health, and safety form an integral part of our values and daily operations. We provide a safe working environment that promotes a healthy physical and psychosocial working environment and wellbeing. Our offices comply with all applicable health and safety regulations. We have established a hybrid working model that allows for greater employee flexibility and provides us the ability to better serve customers around the world. When our employees come to the office or travel for business, we want them to be always supported and safe. We have therefore implemented processes and programs that aim to keep our people informed and secure, when working from our offices, when travelling for business or working remotely. Our aim is that everyone enjoys and has a healthy work-life balance, so we discourage work outside office hours.

Human rights and interacting with business partners and suppliers

We respect human rights and the interests of Cludo’s employees and third parties – and we only work with business partners and suppliers who do the same. We have a policy and due diligence processes in place to identify, prevent, mitigate and account for adverse human rights impacts we might cause, contribute to or be linked with. Acting upon human rights impacts includes taking appropriate steps to avoid, minimize and/or mitigate them. We follow our Code of Conduct when interacting with current and prospective business partners and suppliers. We are following the practices on antibribery and corruption, fair competition, and representation in relation to any contacts and cooperation with government officials, civil servants, trade associations as well as in regard to other lobbying activities, and we avoid conflicts of interest.

Anti-bribery and corruption

A bribe is not just cash in an envelope. It can be the provision of anything of value – including cash or equivalents, gifts, paid expenses, entertainment, kickbacks, favours or loans – in return for certain actions or benefits. We do not tolerate any form of bribery, corruption or inducement to act improperly. Everyone working for – and on behalf of – Cludo is expressly prohibited from giving, receiving, offering or promising anything of value to influence business decisions or to gain an improper business advantage. The same goes for requesting, accepting or receiving a bribe. Employees must abide by Cludo Anti-bribery and Corruption Policy and obtain all necessary approvals in relation to gifts and hospitality beforehand. Nobody at Cludo will ever face punishment of any kind for refusing to pay a bribe or for highlighting corruption – we expect honesty and integrity from each other and from our business partners.

Taxation

Cludo’s business is based on commercial considerations and our tax approach is based on our values. We conduct our business in compliance with applicable tax and accounting laws and regulations, as well as guidelines issued by relevant tax authorities including international guidelines and principles set by the Organisation for Economic Cooperation and Development and the United Nations. All our employees must comply with the above when carrying out business in the name of, or on behalf of Cludo. Hence we do not tolerate engagement in the performance of, or facilitation of tax evasion, nor in committing tax fraud.

Terrorism and Illicit Activities

Cludo strictly prohibits any involvement in or support for terrorism, illegal arms trade, money laundering, or any other illicit activities that violate national or international laws.

Trade with Sanctioned Countries

Our employees are cautious when conducting business transactions and stay informed about any potential restrictions imposed by governmental bodies or international organizations that might be of relevance to Cludo.

Implementation

By implementing and enforcing this policy, Cludo aims to maintain the highest standards of integrity, legal compliance, and ethical conduct in all aspects of its business operations.