Code of Conduct Policy

1. Introduction

At Nordicwise Limited (hereinafter referred to as 'Nordicwise,' 'Lingvanex,' 'we,' 'us,' or 'our'), our Code of Conduct is integral to our business ethics, applicable to all employees, contractors, and affiliates. This Code guides professional decisions and behavior, aligning with our commitment to integrity, trust, and respect in all business dealings. It serves as a standard for internal conduct and shapes our interactions externally with clients, partners, and the public. The Code establishes clear professional and ethical standards, crucial for maintaining our reputation, developing innovative products, and building lasting customer relations, both within and outside our workplace.

2. Scope and Applicability

This Privacy Policy is applicable to all users of Lingvanex services. We prioritize user consent in our data collection practices, focusing solely on analytical data. This approach ensures that users are thoroughly informed and have expressly agreed to the rules governing the use of their data. Our commitment lies in maintaining transparency and respecting user preferences in all data interactions.

3. Information Collection and Nature of Personal Data

Policy Coverage:

• This policy applies universally across the organization, encompassing all individuals in various employment capacities, including:

• Permanent Employees.
• Part-Time Employees.
• Contract Workers.
• Temporary Staff.

• In addition, this policy extends to individuals employed by our:

• Business Partners.
• Vendors.

Applicability of the Policy:

All employees and contractors are expected to be familiar with and adhere to the Code of Conduct, as mandated by their Employment Contract or Service Agreement.Similarly, contractors, consultants, and others temporarily engaged to perform work or services are required to comply with the Code during their association with the organization. Any breach of this policy by such external parties may result in the termination of their contractual relationship.

4. Core values

1. Integrity and Honesty:

• Maintain the utmost honesty and ethical standards in all business activities, both internal and external.

2. Fairness, Respect, and Equality:

• Ensure fair treatment, respect, and equal opportunities, embracing diversity in all operations.

3. Professionalism and Objectivity:

• Execute duties with impartiality and professionalism, prioritizing organizational and stakeholder benefits while avoiding conflicts of interest and external.

4. Accountability and Transparency:

• Be responsible for actions and transparent in communication, accountable for decision impacts.

5. Sustainability and Compliance:

• Comply with legal and regulatory requirements and commit to sustainable, socially responsible operations.

6. Hosting and Backend Infrastructure:

• Amazon Web Services (AWS), Hetzher, OVHcloud, Linode, Genezis Cloud, Scaleway: Manages diverse data types.

5. Principles of Professional Standards and Job Duties at Lingvanex

1. Organizational Loyalty:

• Uphold Lingvanex’s objectives and values in all actions and decisions.

2. Client-Centric Excellence:

• Exceed client expectations through professional, transparent, and quality-driven service.

3. Privacy and Security:

• Safeguard sensitive information and comply with legal standards in confidentiality and organizational security.

4. Professional Integrity:

• Maintain integrity by avoiding conflicts of interest and ensuring impartial decisions without personal gain.

5. Positive Work Environment:

• Foster a professional, respectful atmosphere, free from discrimination and harassment.

6. Employee Accountability:

• Embrace personal responsibility, report ethical concerns, and commit to high-quality product and service delivery.

6. Compliance with Law and Regulations at Lingvanex

1. Legal and Ethical Compliance:

• Mandatory adherence to all relevant environmental, safety, and fair dealing laws, as well as industry-specific regulations, is expected. Ethical management of the company’s products, finances, and public image is crucial.

2. International and Domestic Law Adherence:

• Follow all applicable laws and regulations in every territory of operation, aligning actions with our Code of Conduct's ethical and professional standards.

3. Guidance and Reporting:

• Employees should seek advice on legal or policy compliance from designated teams when in doubt and are encouraged to report any potential legal or ethical violations.

7. Conflict of Interest Policy at Lingvanex

1. Conflict Avoidance:

• Employees must avoid conflicts between personal interests and Lingvanex duties, including compromising relationships or activities.

2. Conflict Disclosure:

• Prompt disclosure of any actual or potential conflicts, including financial stakes or personal relationships affecting business decisions, is required.

3. Conflict Management:

• Address arising conflicts with necessary actions, seeking guidance from Compliance

4. Prohibited Activities:

• Engaging in conflicting business relations, gaining personal benefits from business decisions, and accepting inappropriate gifts from partners or competitors are forbidden.

5. Reporting Responsibility:

• Report conflicts in writing to supervisors for appropriate escalation. Non-compliance may result in disciplinary actions.

6. Guidance for Uncertainties:

• Consult Compliance or Legal teams for advice on potential conflict situations.

8. Confidentiality Policy at Lingvanex

1. Confidentiality Protection:

• Essential to protect Lingvanex’s confidential data, including client information and intellectual property. Misuse by employees or their families is prohibited.

2. Data Confidentiality:

• Our company maintains a strict policy on data confidentiality, adhering to all legal and contractual obligations. Details of how we treat client data can be found in our company’s Privacy Policy. Under no circumstances do we share or disclose this information.

3. Security Compliance:

• Secure management of non-public information is mandatory, under no circumstances do we store, share or have access to our client’s private translation data.

4. Information Security Duty:

• Employees must adhere to Lingvanex’s information security policies to prevent unauthorized access to sensitive data.

5. Insider Information Handling:

• Insider information must not be exploited for personal gain or unlawfully disclosed.

6. Reporting and Adherence:

• Report breaches of confidentiality immediately. Non-compliance can lead to disciplinary actions, including potential termination.

The policy underlines the critical responsibility of maintaining confidentiality of client, partner, and internal information, with disclosure allowed only through proper channels or legal requirements.

9. Workplace Conduct Policy at Lingvanex

1. Anti-Harassment and Discrimination:

• Firm commitment to a workplace free from harassment and discrimination based on any legally protected characteristic.

2. Health and Safety Compliance:

• Prioritizing employee health and safety, adhering to relevant occupational and environmental health regulations.

3. Professional and Ethical Behavior:

• At Lingvanex, upholding ethical standards and integrity is imperative, and all employees, contractors, and affiliates are responsible for reporting any breaches of our Code of Conduct.

Reporting Unethical Behavior and Violations Policy at Lingvanex

At Lingvanex, upholding ethical standards and integrity is imperative, and all employees, contractors, and affiliates are responsible for reporting any breaches of our Code of Conduct.

Reporting Guidelines

• Confidential Reporting: A confidential system is in place for raising concerns without fear of retaliation, safeguarding the reporter's identity and the information's confidentiality.
• Encouragement to Report: All staff are urged to report any suspected Code violations, regardless of perceived severity, to protect the company's business and reputation.
• Objective Investigation: Reports are promptly and impartially investigated to ensure thorough understanding and appropriate response.

10. Disciplinary Actions for Code of Conduct Violations at Lingvanex

Disciplinary Actions Include:

• Formal reprimand.
• Demotion.
• Suspension.
• Termination.
• Benefit reduction or removal.
• Legal action for serious offenses like corruption or theft.

Violation Examples:

• Gross misconduct.
• Conflict of interest non-disclosure.
• Insubordination or illegal strike participation.
• Aggressive behavior towards colleagues.
• Damage to company property.
• Criminal behavior.
• Confidentiality breaches.
• Employment checks non-compliance.
• Persistent tardiness or neglect of duties.

Violation Examples:

• Mandatory reporting of Code violations.
• Objective investigations of reports.
• Confirmed violations result in corresponding disciplinary actions.

11. Confidentiality Policy at Lingvanex

Stewardship of Company Assets and Financial Responsibility

At Lingvanex, our commitment to excellence is reflected in our policies governing both the use of company property and the management of financial resources. This comprehensive policy encompasses:

1. Purpose of Data Collection:

• Employees and contractors are expected to treat all company property, tangible and intangible, with the utmost care. This includes:

• Avoiding the misuse of company equipment.
• Respecting intangible assets such as trademarks, copyrights, information, reports, and other proprietary materials, using them responsibly and strictly for designated job duties.
• Protecting company facilities and physical assets against damage and vandalism.

2. Financial Integrity and Accountability:

• The integrity of financial dealings is paramount, requiring:

• Commitment to accurate, comprehensive financial reporting, adhering to accepted accounting principles and legal regulations.
• Responsible management of company funds and resources, ensuring all expenditures and financial records maintain the highest level of integrity.
• Diligent internal auditing processes to accurately reflect financial transactions. Any willful misrepresentation in financial reports is a serious violation, carrying potential legal consequences.
• Employees are expected to uphold Lingvanex’s financial ethics in all aspects of their work, including vendor hiring, expenses, and contractual agreements, ensuring decisions made are in the company's best financial interest.

12. Responsible Use of Social Media

• Employees must positively reflect Lingvanex’s values on social media, ensuring their online conduct upholds the company's image.
• Strictly avoid sharing any confidential Lingvanex information on social platforms.
• Be mindful of how online activities could affect the company’s reputation.
• Only authorized personnel are permitted to engage in public communications on behalf of Lingvanex on social media.

13. Gifts and Anti-Bribery Standards

• Strict prohibition against any form of bribery, including offering, receiving, or facilitating bribes in any manner.
• Careful consideration required in accepting gifts, ensuring they do not influence or appear to influence business decisions.
• Immediate reporting of any bribe offers or inappropriate gift proposals is mandatory to uphold transparency and ethical standards.

14. Ethical Utilization of Employment Benefits

• Employees are encouraged to use their benefits, including time off, responsibly and ethically, supporting their well-being and productivity.
• Abuse or misuse of any employment benefits, like fraudulent claims or exploiting benefits, is strictly prohibited.
• For any queries or clarifications regarding benefit usage, employees should consult with the Human Resources team or their managers.

15. Dual Employment at Lingvanex

• Lingvanex employees must obtain prior approval from the company head before accepting external employment or freelance roles.
• The company head is required to seek approval from the Board of Directors for any external commitments, ensuring transparency and conflict avoidance.
• Employees uncertain about potential external roles should consult their supervisors or HR for guidance.

16. Regular Updates and Training

• Employees must thoroughly understand and comply with the Code of Conduct as a foundational employment responsibility.
• Regular training sessions are provided to reinforce ethical standards and inform about policy or legal updates.
• The Code of Conduct is periodically reviewed and updated to stay in line with industry and legal changes.