1. Preamble
Frontify's corporate social responsibility framework, as outlined in our Frontify for Good policy, demonstrates our commitment to universally recognized ethical principles and responsible practices. Frontify requires all internal and external stakeholders, including all its subcontractors and affiliates, to abide by ethical principles that are at least equivalent to those in our Frontify for Good and any other additional policy composing the framework of our corporate social responsibility commitment.
"We Embrace Ethics and Integrity," the second of our five pillars, demonstrates our commitment to conducting business with honesty and integrity throughout our operations and supply chain. Frontify maintains a zero-tolerance stance against all forms of corruption, promotes an ethical company culture, and ensures respectful engagement with all stakeholders — including customers and subcontractors.
2. The aim of this policy
This policy affirms Frontify’s commitment to embedding ethical principles into our daily operations and ensuring full compliance with all applicable laws.
It defines our anti-bribery and anti-corruption standards and requires all stakeholders to act with integrity and uphold these principles across their business activities and supply chains when working with or on behalf of Frontify.
As a recipient of this policy, you are deemed a stakeholder and are responsible for ensuring compliance with its provisions across your organization and any affiliated third parties. Any breach of these principles will be treated as a material violation of our corporate values and may result in the immediate termination of any contractual relationship with Frontify without liability.
We deeply value our relationships with partners and customers and welcome appropriate expressions of appreciation — such as cards, modest giMs, flowers, or business meals — as long as they comply with the standards set out in this policy.
3. Anti-corruption policy
3.1 What is corruption?
Corruption, as defined by Transparency International, is "the abuse of entrusted power for private gain." It occurs when individuals misuse their position of power or authority to unlawfully benefit themselves or their associates. Examples of corruption include offering bribes or kickbacks to potential customers to secure business deals. Corruption can occur in any context and involve any individual, regardless of their position. It may manifest in various forms and can be concealed within routine business activities. Frontify maintains a zero-tolerance policy toward corrupt practices. This prohibition extends to all forms of improper payments — including kickbacks and facilitation payments — whether made through charitable or political donations, sponsorships, travel, or promotional expenses. Such practices are forbidden regardless of local customs or where our operations take place, as they create unfair advantages or conflicts of interest.
3.2 Primary forms of corruption
In the SaaS industry, corruption commonly manifests in four primary forms: bribery, facilitation payments, kickback payments, and coercion.
3.2.1 Bribery
Transparency International defines bribery as "the offering, promising, giving, accepting or soliciting of an advantage to induce an action which is illegal, unethical or a breach of trust."
For example, offering or promising money to procurement staff to sway their decision during an RFP in your favor is bribery.
3.2.2 Facilitation payment
A facilitation payment, also known as a "speed payment" or "grease payment," is a form of bribe made to expedite or secure the performance of a routine action to which the payer is legally entitled.
For example, offering money to a key stakeholder to close a deal faster than the norm is a facilitation payment.
3.2.3 Kickback payment
A kickback payment is a form of corruption where a portion of the payment is returned to an individual as a reward for directing business to a specific vendor or service provider.
For example, receiving a percentage of the fees paid to a vendor in exchange for ensuring that vendor's selection during a procurement process.
3.2.4 Coercion
Coercion is a form of corruption where threats or intimidation are used to influence decisions or obtain compliance from others.
For example, threatening to expose a person's personal confidential information if they don't sway their decision in your favor is coercion.
3.3 The anti-corruption guidelines
All stakeholders must implement and follow these anti-corruption rules throughout their supply chain to ensure compliance with applicable laws and maintain the highest standards of honesty and integrity:
- Do not offer, give, or receive any benefit that could improperly influence or appear to influence a business decision.
- Never offer or accept facilitation payments or kickbacks of any kind.
- Ensure all transactions made on behalf of Frontify are properly documented and registered through approved internal channels.
- Report any concerns or suspected violations of this policy using the designated confidential reporting channels.
- Do not offer gifts, services, or hospitality intended as personal rewards.
- Do not offer gifts, services, or hospitality that could be intended to influence or reward improper behavior by the recipient.
- Do not request or accept gifts, services, or hospitality that could influence your judgment or create a sense of obligation.
- Never offer cash, gift cards, or any other form of cash equivalent
4. Gift and hospitality policy
4.1 What is a gift?
A gift is any item, cash, goods, or service of commercial value given to an individual for personal use or benefit without expectation of payment or reciprocal benefit.
4.2 What is hospitality?
Hospitality refers to the provision of meals, beverages, travel, accommodation, and entertainment to business contacts. This may include business meals, client trips, site tours, and cultural or sporting events.
4.3 Key guiding principles
All gifts and hospitality, regardless of value, must be free from any appearance of corrupt practice. Only modest-value gifts and hospitality may be given or received, and cash gifts are strictly prohibited. All such exchanges must comply with the guidelines set forth in this policy.
While gifts and hospitality are common courtesies in business relationships, they must always align with ethical standards and this policy's guidelines. We require all stakeholders to maintain transparent business practices throughout their operations — including their supply chain — to prevent, identify, and address any compliance issues.
Frontify maintains zero tolerance for any gifting or hospitality practices that could be perceived as corrupt. Frontify is committed to ensuring that all gifts and hospitality are handled with integrity and transparency and in line with anti-bribery and corruption laws. Gifts and hospitality must never be used to improperly influence a business decision or secure an unfair advantage. The following principles apply to all stakeholders and throughout the supply chain:
- Proportionality and appropriateness
Gifts and hospitality must be modest, appropriate, and aligned with legitimate business purposes, such as relationship-building or the celebration of business milestones. Hospitality must be proportionate to the local market context and reflect customary and lawful business practices. To ensure proportionality:- Gifts or hospitality must not exceed CHF/EUR/GBP/USD 100 per person unless a documented exception is approved in advance by senior management;
- For hospitality events, a company host must be present; otherwise, the expenditure will be classified as a gift;
- Consider local economic conditions and cultural norms when determining what is appropriate;
- Prefer charitable donations in lieu of personal gifts, provided they are lawful and compliant with all internal and recipient-specific policies;
- Meals and hospitality should remain within reasonable limits, typically CHF/EUR/GBP/USD 100 per person as a benchmark;
- Consider the recipient and their organization, as stricter rules may apply (e.g., for public officials or government entities). If unsure, the Legal Team should be consulted.
- If you plan to exceed CHF 100 for a gift or hospitality, consult the Legal and Finance Teams to confirm compliance with relevant guidelines.
We do not offer or accept gifts or hospitality that fall outside the scope of reasonable business entertainment or are prohibited under applicable law. Gifts or hospitality must never be offered in return for a business advantage.
- Transparency and documentation
All gifts must be offered or accepted with complete transparency, including proper planning, recording, and internal approval.
To ensure transparency:- Make sure all gifts and hospitality — whether given or received — are properly planned, authorized, and approved by the appropriate internal team.
- Accurate, verifiable records must be maintained, including the purpose, cost, attendees, and business justification of the event or exchange.
- All financial transactions related to gifts or hospitality must be documented in line with internal finance policies.
- Hospitality must be traceable to legitimate business objectives — never for personal benefit or private gain.
- Avoiding conflicts of interest
Stakeholders must actively avoid situations where personal interests could conflict with business interests, particularly in relation to gifts and hospitality. To manage potential conflicts:- Disclose any situation involving personal interests to your direct manager and seek guidance.
- Consult the Legal Team for advice, as not all situations involving private interests necessarily constitute a conflict of interest.
- Clearly document any personal interests and explain why no conflict exists to support prompt and transparent resolution.
5. Corporate contributions
At Frontify, we monitor all corporate contributions, including charitable donations and sponsorships, which are made with strict oversight by the Legal Team — which oversees the company’s CSR/ESG strategy — and by the Social Engagement Committee, which evaluates all philanthropic initiatives. Whether financial or in-kind, these contributions must go through a thorough review and approval process to ensure compliance with applicable laws and regulations in all jurisdictions where we operate. All Frontify stakeholders must be careful and ensure that charitable contributions are not used to facilitate and conceal acts of bribery.
5.1 Charitable donations and sponsorships
Frontify is committed to supporting communities where we operate through strategic charitable giving and sponsorships. All contributions are subject to robust oversight and transparency standards. Our Social Engagement program promotes employee involvement in community investment and volunteering efforts across all countries where we operate. As part of this initiative, the company allocates an annual corporate fund — which is currently CHF 150,000 — to support charitable initiatives. The objective of this program is to back initiatives that are aligned with the company's values and serve a charitable purpose, whether through financial donations, in-kind contributions, or other forms of support. We aim to create a positive impact by addressing specific social, environmental, or economic challenges affecting our communities.
5.2 Key guiding principles:
- Align all donations and sponsorships with our corporate values and sustainability goals;
- Ensure recipients are legally recognized and duly registered charitable organizations.
- Conduct a thorough due diligence on all potential recipients, including:
- Verify all recipient organizations' legal status and reputation
- Confirm the charitable purpose and use of funds
- Assess all potential conflicts of interest
- Ensure compliance with anti-money laundering and anti-corruption laws - Ensure all contributions are approved and properly documented by the Social Engagement Committee.
- Do not make any donations to organizations that discriminate or promote political or religious causes
To ensure that all initiatives are aligned with Frontify's values and serve a charitable purpose, the following non-exhaustive lists of eligible and ineligible activities must be referred to for guidance:
5.3 Eligible vs. ineligible activities
i. Corporate and charitable donations may be directed to the following types of recipients and initiatives:
- Organizations with valid charitable status, including:
- US Internal Revenue Code 501(c)(3) organizations;
- UK registered charities with Charity Commission numbers;
- Swiss-registered non-profit organizations (NPOs) recognized by cantonal authorities and
- EU-registered charitable organizations compliant with local member state requirements.
- Educational programs and initiatives
- Environmental sustainability projects
- Community development programs
- Initiatives that contribute to the United Nations Sustainable Development Goals (UN SDGs), such as reducing inequality, promoting quality education, advancing gender equality, or supporting climate action.
ii. Corporate and charitable donations may not be directed to activities, recipients, and initiatives in the following categories:
- Political parties, organizations, or campaigns
- Religious organizations, except where the donation supports a secular, inclusive, community-focused program. For clarity, donations may be made to religious organizations of any faith, but only if the funded initiative is open to all, does not promote religious beliefs, and does not require participation in religious activities. Examples of acceptable programs include a food bank operated by a church but open to all community members regardless of faith or a homeless shelter run by a religious organization that provides services without religious requirements. Examples of programs that would not qualify include youth programs that include mandatory prayer or religious instruction, missionary activities, or religious outreach programs.
- Organizations that engage in discrimination based on race, color, religion, gender, sexual orientation, national origin, age, disability, or any other legally protected status
- Personal fundraising initiatives
- Organizations that are under investigation for financial misconduct or noncompliance with charitable regulations in any jurisdiction
5.4 Donation process
- Employees interested in submitting a funding request must complete a proposal form outlining the initiative and its expected outcomes. The proposal should include:
- The purpose of the funding request
- The amount requested
- The duration of the project or activity
- Key individuals or teams involved
- The anticipated impact
- How the initiative aligns with our company values and the Frontify for Good code.
- Once submitted, depending on the amount involved, the request is reviewed either by one representative of the Social Engagement Committee or the entire Committee.
- Requests exceeding CHF 5,000 require additional layers of review and approval, including Legal and People Leads and the CEO as the final approver (only for requests exceeding CHF 15,000).
- All communication between reviewers and requestors must occur through an internal channel that allows for proper review process documentation and serves as a formal audit trail.
We're committed to complete transparency in our corporate contributions. To support this, we maintain detailed records of all charitable donations, sponsorships, and any interaction with advocacy groups. Additionally, we make reasonable efforts to publicly disclose any donation that exceeds CHF 15,000. The Legal Team and the Social Engagement Committee conduct regular audits of all corporate contributions, charitable donations, and sponsorships to ensure adherence to this policy. Any violation of this policy should be reported through our whistleblowing channel, and employees found in violation of this policy may face disciplinary action up to and including termination of employment.
6. Political contributions
Frontify maintains a stance of political neutrality. The company does not make direct contributions to political parties, candidates, or campaigns. This includes monetary contributions, in-kind support, or the use of company resources and facilities. Employees who wish to engage in political activities can do so in their personal capacity and not as representatives of the company. They are expected to avoid conflicts of interest and to disclose any personal political involvement that could affect their role. We strictly prohibit the use of company resources, including facilities, equipment, or funds, for political purposes.
7. Awareness and violation reporting
All stakeholders must comply with these fundamental ethical principles and ensure their organizations do the same. Each stakeholder organization must implement internal procedures and provide clear guidelines and training to promote employee awareness of and compliance with this policy. We strongly encourage all employees and stakeholders to report any suspected violations of this policy. Reports can be made through our whistleblowing platform at https://frontify.personiowhistleblowing.com. Frontify employees can access this platform directly through Personio, while external stakeholders can use the link "Report a Concern" on our website. All reports will be treated confidentially and investigated thoroughly.
8. Contact the Frontify Legal Team
The practice and rules of giving and accepting gifts, hospitality, and charitable donations can be complex and differ among countries, cultures, and customary rules. In some industries, providing and receiving gifts is prohibited, with some violations subject to criminal penalties. We expect all our stakeholders to seek legal guidance by contacting their legal teams or the Frontify Legal Team at legal@frontify.com if they're unsure whether a gift, hospitality, or charitable donation that they're offered is permitted by this policy or by any applicable local law.
9. Conclusion
We maintain a zero-tolerance policy for corruption throughout all supply chains, including those of our stakeholders. Business decisions and relationships must not be influenced by gifts, hospitality, or charitable donations. Both we and our stakeholders are required to avoid any appearance of improper conduct or decision-making related to such benefits.