Code of ethics

Dear All,

We are all aware of how dynamically the world around us—both the business world and our everyday world—is changing. These changes pose numerous challenges to us, such as the need to find our way through a maze of laws and regulations, to keep pace with increasing automation, or to cope with enormous economic, social and geopolitical changes. In these changes, we also see new opportunities and possibilities for deepsense.ai, and thus for each of you—our employees and associates.

Since the very inception of our company, we have emphasized that the way we operate must be not only lawful, but also honest, ethical, and transparent.

With the introduction of this Code, we do not feel as if we were creating some new reality—instead, we are merely collecting and summarizing the values we all share, thus creating a set of principles that are most important to us, which we all identify with and which we all want to be bound by on a daily basis.

I ask you to read the Code and abide by the principles it contains. This is essential for maintaining our position, as well as for our further development.

On a day-to-day basis, some concerns and questions may arise, to which the Code (or our other policies and procedures) does not provide answers. In such cases, both your superiors and the Board of Directors are always there for you. Let us also remember that everyone has the right to report—including anonymously—any abuse of the law and the procedures in place at our company, and each such report will be given due consideration.

With best regards,
________________________
Tomasz Kułakowski
CEO & President of the Management Board
deepsense.ai

I. WHAT IS THE CODE OF ETHICS?

The Code of Ethics is a set of ethical principles and standards that are most important to us and that are key to building a compliance system at deepsense.ai. We apply these principles in our business, especially with regard to public institutions, employees, associates, clients, business partners, local communities, and other external and internal partners.

A compliance system means any documents and mechanisms which help us to ensure that deepsense.ai’s operations comply with the regulations in force as well as other standards of conduct.

The areas mentioned in this Code, or other areas, may all be subject to more detailed internal regulations, depending on, among other things, the requirements under the law or resulting from other needs.

II.ACTING IN ACCORDANCE WITH THE LAW AND INTERNAL RULES

We comply with the law and internal rules in all areas of our business. We act with integrity, honesty and transparency, while taking care of our company’s interests.

We do not tolerate any violations of the law. In case of any misconduct—depending on the severity of the violations—our employees and associates face disciplinary or other consequences.

We are committed to ensuring that everyone is aware of when violations occur, reacts to the violations we encounter, and reports them to the appropriate people. In this way, we will be able to take action to prevent any irregularities in the future.

In this regard, we are taking steps to build awareness of how to conduct ourselves in accordance with the law and our internal regulations.

III. HUMAN RIGHTS AND RESPECT FOR DIVERSITY

We are absolutely committed to respecting the rights of every person.

Everyone has equal opportunities in terms of employment with us. We prohibit any discrimination based on gender, age, customs, membership of a particular ethnic group or nation, health status, religion, political beliefs, sexual orientation, or world view.

Respect for others is at the core of our organizational culture. We believe that our diversity is an important part of our strength, and that all of the differences between us help us build the success of our company.

We support open communication and dialog, and strive to create a workplace that is welcoming to all.

We do not condone any form of modern slavery—human trafficking and forced labor are completely against our principles. Nor do we tolerate any form of child abuse whatsoever.

Apart from that, mobbing/bullying and discrimination are absolutely forbidden. We are all committed to ensuring that mobbing/bullying and discrimination have no place in our company at all.

IV. DEVELOPMENT AND USE OF ARTIFICIAL INTELLIGENCE

We are committed to ensuring that our products and solutions comply with applicable laws, and that they do not violate basic ethical principles and standards.

At our company, we counteract any discrimination, and the protection of privacy and personal data are fundamental values to us. We are committed to ensuring that our solutions are not used to discriminate in any way against individuals or groups, including but not limited to racial or ethnic origin, disability, age, or sexual orientation.

V. BUSINESS SECRETS AND THE HANDLING OF CONFIDENTIAL INFORMATION

Each of us is obligated to protect the business secrets of our company.

A business secret means any data that may have economic value and has not been publicly disclosed, in particular: technical, technological and organizational information, e.g., terms and conditions of cooperation with business partners, employees and associates, prices, costs, financial data, and information concerning intended or ongoing projects. Business secrets also include our clients’ data and all other materials—presentations, reports, documentation, etc.—that we create or to which we gain access during the implementation of projects.

Protecting a business secret means first and foremost that it cannot be disclosed or used in any way other than for the purpose of executing a contract with the Company. Nor will any of us obtain information that is not intended for us. In order to protect our business secrets, access to information at our company depends on the position held, the projects carried out, and the legitimacy of the need for access to information.

All records, reports and information prepared internally and disclosed externally must be truthful, in accordance with correct accounting principles, complete, and correct. As a rule, externally disclosed information is published in a controlled and intended manner by the Company’s management.

The obligations related to the protection of business secrets do not cease upon termination of the contract entered into with the Company.

VI. FIGHT AGAINST CORRUPTION

Any and all corrupt activities are prohibited. We do not demand, accept or offer any benefit in exchange for any preference. This applies to relations with both our business partners and public institutions.

We allow gifts to be given and accepted only if they are small and insignificant gifts. It is important that they are accepted or given occasionally and do not involve an expectation of reciprocity.

We are particularly careful with invitations from business partners—for trips, parties or events which they organize, including training. We can only accept an invitation if the occasion and scope of the invitation justifies it.
We do not make any donations to profit-oriented organizations, or in situations when it could damage our company’s reputation and image. We do not fund any political activities.
We also take a number of measures to minimize the risk of corruption, including:

• making appropriate provisions in contracts with service providers and associates,
• authorized persons (executives and managers) approving all purchase invoices,
• performing monthly verification of costs and expenses,
• controlling employee card expenses,
• keeping cash payments to a minimum.

VII. CONFLICTS OF INTEREST

All of us are obliged to make decisions and undertake actions guided by the interests of the company. Each of us is obliged to avoid any conflicts of interest.

A conflict of interest arises when a decision favorable to the company may be in conflict with the interests of an employee or associate who participates in the decision-making, and the circumstances may affect his or her objective judgment.

Any situation that may constitute a conflict of interest should be immediately reported to a given individual’s superior or to the Company’s Board of Directors. Conflicts of interest should not be resolved on one’s own.

VIII. COUNTERACTING MONEY LAUNDERING

We do not tolerate money laundering in any form; therefore, we maintain business relationships only with reliable and reputable business partners. We do not maintain business relationships with partners whose funds may be derived from criminal activities.

We are all obligated to:

• comply with anti-money laundering and counter-terrorist financing regulations,
• report any suspicious behavior of business partners and Clients to our superiors/management,
• document all financial transactions in detail, and in accordance with accounting regulations.

IX. RELATIONS WITH BUSINESS PARTNERS AND CLIENTS

In all of our business relationships, we comply with the requirements of the law and the highest standards. This also applies to our relationships with business partners and clients; therefore, we are all obligated to comply with the law and other rules of fair competition.

It is strictly forbidden to take any action that would violate fair competition, including entering into agreements that have the purpose or effect of restricting or violating competition. We act transparently, and we do not favor or exclude anyone from cooperation.

We exercise due diligence when entering into contracts with business partners and clients as well as when executing the provisions therein. We promptly clarify any doubts or disputes that may arise during the course of cooperation.

X. VERIFICATION OF BUSINESS PARTNERS; PREVENTION OF FRAUD

We verify our counterparties and business partners and do not undertake or maintain any relationships with them or take additional security measures if:

• there is a reasonable suspicion that the business partner/counterparty’s funds may be derived from criminal activity;
• the business partner or counterparty is on sanctions lists, comes from a country with a high risk of money laundering, terrorist financing or corruption, or there are restrictions on cooperation with such a business partner or counterparty from the perspective of generally applicable sanctions laws;
• the business environment or reputation of the business partner or counterparty indicates that engaging in cooperation with them could damage our company’s image.

XI. CARE OF PROPERTY

The Company’s property is intended to serve each of us and facilitate our daily work. We are obligated to care for it with due diligence and properly safeguard it.

We do not use the Company’s property for purposes other than business-related ones, unless set forth otherwise in contracts or separate regulations. We avoid wasting resources.

In the event of any destruction, theft or other violation of Company property, we are obliged to inform our superiors or the Company’s Board of Directors.

XII. SUSTAINABLE DEVELOPMENT

We feel responsible for the impact of our activities on the environment. We act in such a way as not to destroy the environment with our actions, and we strive to keep it in the same or better condition.

Each of us can contribute to sustainable development, so let us take care to use resources sparingly, both at the Company and in our daily lives—for the sake of ourselves and future generations.

XIII. REPORTING IRREGULARITIES

Each of us has a responsibility to pay attention to any irregularities. We expect our employees and associates to speak openly about them, and in return we promise the necessary confidentiality and security.

Under a separately regulated policy (“Deepsense.ai Whistleblower Procedure”), we provide mechanisms for reporting violations of the law, as well as of our procedures and standards. Every employee and associate can also use them anonymously.