1. Introduction

This Code outlines our commitment to ethical business practices and serves as a guide for everyone at Criipto. It applies to all staff, including employees, contractors, and consultants, and sets clear expectations for professional and personal conduct.

We value transparency, fairness, and respect in all interactions. This Code also ensures employees can report concerns without fear of retaliation.

2. Ethical Principles

These core values guide our decisions:

- Dignity: Respect for everyone we interact with.

- Integrity: Upholding the highest ethical standards.

- Reliability: Delivering on our commitments.

3. Ethical Decision-Making

Ask yourself these questions when facing ethical dilemmas:

- Is it legal?

- Does it reflect our values?

- Would I feel comfortable if this became public?

If unsure, seek guidance.

4. Compliance with laws and regulations

We comply with all applicable laws, contracts, and policies. Non-compliance is not tolerated and may result in disciplinary action.

5. Sustainability: People + Profit + Planet

We are committed to sustainable practices that balance economic growth with environmental responsibility and social equity.

6. Human Rights

We respect and uphold human rights in all our actions, treating everyone with dignity and fairness. In particular, we are committed to upholding communities’ civil and political rights, the rights of indigenous peoples, the rights of workers in the value chain and the rights of end-users. We are committed to prevent discrimination of end-users and ensure accessibility of our products and services.

7. Working conditions

Our working conditions are fair and we commit to

• Adequate scheduling of night and weekend work
• Flexible working time
• Entitlement to parental leave

8. Equal treatment and opportunities for all

We commit to gender equality and equal pay for work of equal value and accessibility of workplaces for persons with disabilities.

9. Fair Labor Practices

We support fair employment practices and strictly oppose forced labor, child labor, and any form of exploitation. We practice non-interference in trade union formation and recruitment.

10. Anti-Discrimination and Harassment

Criipto is an inclusive workplace. Discrimination, harassment, or bullying is not tolerated.
In particular, Criipto does not tolerate discrimination on grounds of racial and ethnic origin, colour, sex, sexual orientation, gender identity, disability, age, religion, political opinion, national extraction or social origin. Violence in any form is a non-tolerated practice.

11. Health, Safety, and Environment

We provide a safe, clean, and healthy work environment and comply with all relevant safety regulations.

12. Business practice

We commit to responsible marketing practices, and avoid dark patterns at all times.

We do not hold back maliciously, unlawfully or unduly payments towards our partners.

13. Fair Competition and Business Conduct

We conduct business fairly and ethically, competing based on quality, not unethical practices.

14. Anti-Corruption

We reject all forms of bribery and corruption. Acceptable business courtesies must be modest, infrequent, and aligned with local customs. We commit to the United Nations Convention against Corruption.

15. Protection of whistle-blowers

Employees, former employees, interns, business partners, family members of employees, and persons involved or formerly involved in a recruitment process are neither prohibited nor restricted from disclosing confidential information in the public interest regarding fraud, corruption, hazardous behaviour, sexual harassment, breaches of regulations or illegal activities when voluntarily contacting or responding to inquiries from any government entity or self-regulatory organisation, or as required by law.

16. Gifts and Hospitality

Avoid gifts or hospitality that could influence or appear to influence decisions. When in doubt, consult your manager.

17. Use of Company Assets

Use company resources responsibly and only for legitimate business purposes.

18. Confidentiality and Data Security

Safeguard all confidential information and comply with data protection laws. Unauthorized disclosure or misuse is prohibited.

19. Financial Integrity

Maintain accurate financial records and report any discrepancies. We strictly oppose fraud and tax evasion.

20. Anti-Fraud

Fraud in any form is unethical and illegal. Report suspected fraud immediately.

21. Conflicts of Interest

Avoid situations where personal interests conflict with Criipto’s. Disclose any potential conflicts to management.

22. Privacy and Data Protection

We handle personal data responsibly and in compliance with all applicable laws, ensuring transparency and security.

23. Political engagement and lobbying activities

Criipto only engages in the political process for legitimate business objectives and in compliance with applicable laws. We engage transparently and do not seek to influence the political process by improper means.

We don't contribute to any political campaign, party, candidate, or their affiliated organisations.

Commitment to the Code of Conduct

Adherence to this Code is mandatory. Let’s work together to uphold Criipto’s values and reputation.

Copenhagen, November 2024