Code of conduct

Last updated: 20th October 2024

Introduction

Oneflow is a software-as-a-service (SaaS) company that provides a platform for creating, managing and automating the entire life-cycle of digital contracts. Oneflow believes that business relationships, when built on common values, mutual respect and trust, become valuable and dynamic. Based on those beliefs and our company values, Oneflow makes an effort to seek and collaborate with employees, business partners and other stakeholders that also share a common commitment to similar philosophies.

This Code of Conduct (the “Code”) outlines the ethical guidelines, business practices and expectations for how we conduct ourselves in our interactions internally, with external parties and towards the broader community. The requirements and beliefs stated in this Code are developed and supported by the management of Oneflow, and it is expected that everyone at Oneflow and stakeholders we engage with respect this Code.

Beat Yesterday	We set the bar higher every day. Do you remember a time you made a mistake and thought ‘I’d better not do that again?’. You reflected on it and it’s paved the way for how you do things now. That’s Beat Yesterday.
Show Love	We’re kind, inclusive, and caring about one another. Love makes the world go round, right? We’d like to think so. From brewing the coffee in the morning to wholly supporting your team and the wider company, Show Love is something we see in the smallest of things.
In transparency we trust	We choose transparency over politics. In our books, the key to a transparent work culture is communication. Is it possible to ban micro-management and still have a transparent work culture? You bet it is. How? Because we trust each other. We’re pretty good at that.
Work Wonders	Dream big, challenge the norm, and change the game. Have you ever sat in a meeting with your team and thought ‘These people have some fantastic ideas’? That’s because you’re all curious, innovative and daring people.
Inittogether	We succeed and fail as one team. So inittogether that even the words don’t want to be apart. This one’s all about how we collaborate and help each other, regardless of our job titles.

Compliance with Laws and Regulations

We are committed to conducting our business in compliance with all applicable laws and regulations. This includes but is not limited to:

• Trade Compliance: We adhere to all applicable international and local regulations governing technology transfers, exports, re-exports, and imports.
• Antitrust and Fair Competition: We engage in fair competition and comply with all antitrust laws in the jurisdictions where we operate.
• Anti-Corruption and Bribery: We have zero tolerance for corruption, extortion, or bribery. We do not offer or accept bribes or any other improper incentives.
• Accessibility: We are dedicated to making our products and services accessible to people of all abilities.
• Intellectual Property: We respect the intellectual property rights of others. We use software, content, and other materials only as permitted by their licenses and terms of use.

Business Practices and Ethics

• Business Records and Accounting: We maintain accurate and honest records of all business dealings in accordance with applicable and standard accounting practices.
• Transparent Communication: We are honest, direct, and truthful in all our communications, including those with regulatory agencies and government officials.
• Gifts and Entertainment: We avoid conflicts of interest by not offering or accepting extravagant gifts or entertainment that could influence business decisions.
• Conflicts of Interest: We must avoid situations where personal interests conflict with Oneflow’s interests. Any potential conflicts should be disclosed promptly.
• Insider Trading: We do not use or share non-public information for trading purposes or for any other purpose except conducting Oneflow’s business.
• Travel and Expense Reimbursement: We have implemented and comply with a travel and expense policy ensuring that all expenses are reasonable and properly documented.

Financial Integrity and Accountability

We are committed to maintaining accurate and reliable financial information as part of our business practices:

• Accurate Record-Keeping: All financial transactions must be recorded accurately, completely, and in a timely manner, in compliance with applicable accounting principles and standards.
• Internal Controls: We implement appropriate controls to ensure the accuracy and integrity of financial data, including regular reconciliations and audits.
• Responsibility and Oversight: Employees involved in financial reporting or transaction processing are responsible for ensuring data accuracy and completeness. Any identified discrepancies or errors must be reported and corrected promptly.
• Preventing Fraud and Misuse: We have zero tolerance for financial fraud or the misuse of company assets. Any suspicion of fraudulent activities must be reported immediately through the designated reporting channels.
• Documentation and Retention: Financial documents and records must be maintained in a secure and organized manner, ensuring traceability and availability for audits when required.

Human Rights and Fair Labor Practices

We are committed to:

• Respecting Individual Rights and Freedom of Association and Collective Bargaining: Upholding the dignity and rights of every individual including employees’ right to join or form (non-violent) assembly or associations of their own choice and to bargain collectively (in accordance with LO Conventions No. 87 and 98). Oneflow ensures to facilitate open communication and direct engagement between personnel and management in those situations in which the right to freedom of association and collective bargaining are restricted under law. No employee shall be subject to dismissal, discrimination, harassment, intimidation, or retaliation for exercising these rights.
• Fair Employment Practices: Complying with all employment laws, agreements, industry standards and providing equal opportunities regarding employees’ contracts, working hours, and compensation. Oneflow offers all employees clear communication stipulating the employment terms and conditions to ensure they are aware of their rights and obligations. Any written contracts shall be in a language understood by the employee.
• Prohibiting Child Labor: Not engage in or condone the unlawful employment or exploitation of children in its workplace, and actively works to prevent the possibility of its occurrence. The view on child labor shall follow the UN Convention on the Rights of the Child, Articie 32.1 and comply with all relevant national and international laws, regulations and provisions applicable in its country of production or operations. We respect that the minimum age for work should not be below the age for finishing compulsory schooling, which is generally 15 years of age, or 14 years of age in accordance with the exceptions for developing countries (in accordance with ILO Convention No. 138). If relevant national legislation has set a higher age, this age will apply. We also recognize all legal limitations on the employment of persons below the age of 18 years (the definition of a child according to the UN Convention on the Rights of the Child). All children should be protected from economic exploitation and from performing any work that is likely to be hazardous or to interfere with the child’s education, or to be harmful to the child’s health or physical, mental, spiritual, moral or social development. Oneflow confirms that it will always make a good faith effort to determine whether forced or indentured child labor has been used to produce, or manufacture any product/service we use or purchase. If child labor, in accordance with the above definitions, is identified by Oneflow or by any of its subcontractors, an action plan with the child’s best interest in focus shall be established.
• Prohibiting Forced Labor: Not engaging in or tolerating any forced labor, or human trafficking such as prison, bonded, debt bonded or compulsory labor (in accordance with LO Conventions No. 29 and 105). Neither Oneflow, nor any entity supplying labor to Oneflow, shall withhold any part of any personnel’s salary, benefits, property, or documents in order to force such personnel to continue working for them.
• Fair Compensation: Providing fair wages and benefits in compliance with local laws. Wages shall be paid in a timely manner together with all other types of legally mandated benefits and compensations. Wage deductions shall not be used as a disciplinary measure. Oneflow recognizes that migrant or seasonal workers shall have entitlements which at a minimum conform to local laws and regulations with regard to contracts, working hours and compensation.
• Reasonable Working Hours: Ensuring working hours do not exceed legal limits, industrial standards or the working hours laid down in current international conventions. Employees entitled to overtime pay shall always receive overtime pay in accordance with applicable legislation.
• Safe Work Environment: Providing a workplace free from harassment and discrimination in compliance with applicable laws and regulations.
• Open Communication: Encouraging employees to voice concerns without fear of retaliation.

Health and Safety

We are dedicated to maintaining a safe, clean, and healthy work environment. We proactively identify and address potential hazards to prevent workplace injuries and illnesses. Oneflow stays up to date with industry specific risks, continuously carry out risk assessments, and take all reasonable precautions to protect the safety and health of employees and contractors. Oneflow ensures that its employees receive necessary and adequate information about safety arrangements such as emergency exits, fire extinguishers, first aid equipment etc., and that the information is accessible in a language understood by the employee. Employees receive appropriate safety training before carrying out potentially hazardous operations, and shall be provided with the protective equipment necessary to carry out their assignments. Oneflow maintains records of non-minor work related incidents and accidents including corrective actions. If required by law, the accidents are reported to the authorities.

Environmental Responsibility

We are committed to environmental sustainability. We comply with all environmental laws applicable to our business and strive to minimize our environmental impact through responsible practices. Oneflow makes efforts to reduce its ecological damage while improving efficiency in its business processes, through for example less use of energy, materials, and water; minimizing hazardous emissions or by-products; as weil as through increased recycling efforts. Any waste and in particular hazardous waste must be taken care of in a responsible manner and in accordance with local law.

Oneflow has been assessed and certified to the provisions of ISO 14001 which is the internationally recognized standard for environmental management systems (EMS). Oneflow’s EMS ensures that we have a good framework for and continually improves our environmental performance.

Data Privacy and Security

We prioritize the privacy and security of personal and confidential information:

• Privacy Notices: Providing clear and accurate information about how we collect and use data.
• Compliance: Adhering to all applicable data protection legislation.
• Data Usage: Using data only for legitimate and agreed-upon purposes.
• Security Measures: Implementing robust security practices to protect data. Oneflow is certified according to SS-EN ISO/IEC 27001:2023 which demonstrates our ongoing commitment to align with globally-recognized best practices and verifies that Oneflow has a system of highly precise security controls in place that are specific to our cloud services.

• Access Control: Restricting access to sensitive information to authorized personnel only, based on role and necessity.
• Data Integrity: Maintaining accurate and consistent data, particularly when it relates to business processes and records, to support reliable decision-making and reporting.
• Retention and Disposal: Ensuring data is retained according to regulatory and business requirements and securely disposed of when no longer necessary.
• Monitoring and Audit Trails: Keeping detailed records of data access and modifications to maintain transparency and accountability.
• Incident Response: Promptly addressing any data breaches or security incidents.

Diversity and Inclusion

We believe that diversity and inclusion are vital to our success. We are committed to:

• Equal Opportunity: Providing equal employment opportunities without discrimination.
• Inclusive Culture: Fostering a workplace where all individuals feel valued and respected.
• Prohibiting Harassment: Maintaining a work environment free from harassment and hate-related or violent speech.
• Fair Treatement: Maintaining an inclusive workplace free from discrimination based on a person’s status such as race, religion, nationality, ethnic origin, political orientation, gender, sexual orientation, marital status, age, union membership, disability or other status (in accordance with ILO Conventions No. 100 and 111), in connection to remuneration, promotions, job assignments, benefits, and/or termination.

Compliance and Reporting

Compliance Framework Alignment

This Oneflow Code of Conduct is developed and maintained for the purpose of aligning with the following internationally recognized standards and compliance frameworks:

• ISO27001: Ensuring robust information security management practices, including data privacy and security.
• ISO9001: Promoting quality management through ethical business practices and transparent communication.
• ISO14001: Upholding environmental responsibility and sustainable practices.
• SOC1 (Type 2): Establishing internal controls relevant to financial reporting to ensure accuracy and integrity.
• SOC2 (Type 2): Implementing and maintaining practices that protect data security, availability, processing integrity, confidentiality, and privacy.

By adhering to this Code, Oneflow demonstrates its commitment to maintaining high ethical standards, regulatory compliance, and responsible business operations as outlined by these frameworks.

Management Responsibilities

Our leadership is responsible for:

• Communicating Standards and Promoting Awareness: Management will ensure that all team members understand this Code and are continuously informed and educated about their responsibilities under related compliance requirements.
• Monitoring Compliance: Implementing measures to monitor adherence to our ethical standards.
• Providing Resources: Offering guidance and resources to help employees make ethical decisions.
• Addressing Violations: Taking appropriate action in response to any violations of this Code.

Employee Responsibilities

Every team member is expected to:

• Uphold the Code: Act in accordance with this Code at all times.
• Seek Guidance: Ask questions if uncertain about any aspect of this Code.
• Report Concerns: Promptly report any suspected violations or unethical behavior.
• Providing Feedback: Employees are encouraged to provide feedback on this Code to help improve our ethical and compliance practices.

How to Raise Concerns

We encourage open communication and the reporting of any concerns regarding unethical or illegal conduct.

• Confidential Reporting: We will handle all reports with the highest possible confidentially level.
• No Retaliation: We do not tolerate retaliation against anyone who reports concerns in good faith.
• Contact Information:
  • Email: support@oneflow.com

We will investigate all reported matters promptly and take appropriate action to address any issues.

Reporting Financial Misconduct or Irregularities:

• What to Report: Employees are encouraged to report any suspected financial misconduct, including but not limited to inaccuracies in financial records, fraudulent reporting, misuse of company assets, or breaches of financial policies.
• How to Report: Reports related to financial misconduct should include as much detail as possible, such as dates, descriptions of the incident, and any supporting documentation. Reports can be made through the confidential reporting channels listed above.
• Handling of Reports: Upon receiving a report, Oneflow will initiate an impartial and thorough investigation, ensuring that any potential impact on financial reporting is assessed and addressed.
• Protection of Reporters: Individuals reporting financial irregularities in good faith will be protected from retaliation, including threats to employment, discrimination, or negative impact on professional standing.
• Follow-Up and Resolution: Once the investigation is complete, appropriate actions will be taken based on the findings, and the reporting individual may be informed of the outcome when permissible.

By adhering to this Code, we affirm our commitment to ethical business practices and integrity in all our interactions. Thank you for being a part of Oneflow’s journey and upholding the values that define us.