Code of Conduct

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This Code of Conduct sets the minimum standards of professional, ethical, lawful, and secure conduct expected from everyone working for or on behalf of ZeroPact.

It supports ZeroPact’s commitment to responsible business, trustworthy technology, customer confidence, and compliance with applicable legal, regulatory, contractual, and data-protection obligations.

This policy applies to all ZeroPact founders, directors, employees, contractors, temporary staff, consultants, and third parties acting on ZeroPact’s behalf.

It applies whenever personnel are performing ZeroPact work, representing ZeroPact, handling ZeroPact or customer information, using ZeroPact systems, or interacting with customers, suppliers, regulators, partners, or the public.

ZeroPact personnel and representatives are expected to follow these principles:

• Integrity: act honestly, transparently, and in good faith.
• Compliance: follow applicable laws, contracts, policies, and customer requirements.
• Accountability: take responsibility for decisions, records, systems, and information handled.
• Respect: maintain a professional, inclusive, and harassment-free working environment.
• Security and privacy: protect company, customer, personal, confidential, and technical information.
• Accuracy: ensure business, sustainability, environmental, and security claims are evidence-based and not misleading.

ZeroPact personnel must comply with all applicable laws and regulations relevant to their role, including data protection, anti-corruption, competition, employment, intellectual-property, financial, tax, sanctions, export-control, consumer protection, and environmental/sustainability communications requirements.

If a legal or contractual requirement appears unclear or conflicts with a request, personnel must escalate before acting.

ZeroPact prohibits bribery, corruption, facilitation payments, improper inducements, kickbacks, and any offer or acceptance of value intended to improperly influence a decision.

Personnel must follow ZeroPact’s Anti-Bribery, Ethics and Whistleblowing Policy.

Personnel must avoid conflicts of interest and promptly disclose any personal, financial, family, investment, advisory, or external business interest that could interfere, or appear to interfere, with ZeroPact’s interests, customer obligations, or independent judgement.

Personnel must protect ZeroPact and customer information from unauthorized access, disclosure, alteration, loss, or misuse.

Confidential information includes customer data, contracts, commercial discussions, credentials, source code, security information, internal documents, non-public financial information, personal data, and intellectual property.

Personnel must:

• Use company systems, accounts, credentials, and devices securely.
• Apply least privilege and only access information needed for authorized work.
• Not share passwords, tokens, API keys, private links, or secrets.
• Report suspected security incidents, phishing, lost devices, data leakage, or unauthorized access immediately.
• Not store customer data on unmanaged, insecure, or personal systems unless explicitly approved.

ZeroPact personnel must deal fairly and professionally with customers, suppliers, partners, and competitors.

Personnel must not misrepresent ZeroPact capabilities, certifications, controls, service status, pricing, sustainability claims, or customer commitments.

Supplier selection and management must consider security, privacy, confidentiality, service reliability, and ethical conduct.

Business records must be accurate, complete, and retained according to applicable retention requirements.

Personnel must not create false, misleading, backdated, incomplete, or concealed records.

External statements, public claims, customer commitments, marketing materials, and environmental or sustainability claims must be approved by authorized ZeroPact representatives and supported by reasonable evidence.

ZeroPact expects a respectful, inclusive, safe, and professional working environment.

Harassment, bullying, intimidation, discrimination, retaliation, threats, violence, or abusive conduct are not tolerated.

Personnel must communicate professionally, respect cultural and personal differences, and raise concerns in good faith.

Personnel must report suspected misconduct, policy breaches, unethical conduct, bribery, conflicts of interest, security incidents, data-protection concerns, fraud, harassment, or inaccurate customer/security representations.

Reports may be made to ZeroPact management, the CTO/CSO, or via:

• tech@zeropact.co
• dpo@zeropact.co

ZeroPact prohibits retaliation against anyone who raises a concern in good faith, assists an investigation, or refuses to participate in unlawful or unethical conduct.

Retaliation itself is a breach of this Code.

Violations of this Code may result in corrective action, removal of access, termination of contract or employment, customer notification where required, law-enforcement or regulator notification where legally required, and other remedies available to ZeroPact.

Enforcement will consider severity, intent, impact, recurrence, cooperation, and legal obligations.

ZeroPact management owns this policy.

This policy must be reviewed at least annually, and sooner if there is a material change to ZeroPact’s business, services, legal obligations, customer requirements, security posture, or operating model.

ZeroPact is committed to conducting business with integrity, accountability, respect, security, and transparency.

Everyone working for or on behalf of ZeroPact is responsible for following this Code of Conduct and for raising concerns when conduct does not meet these standards.