Anti-corruption and gift policy

1. Frontify’s anti-corruption and gift policy

Frontify’s corporate social responsibility framework is embedded in our policy called Frontify for Good and results from a holistic approach that combines our culture and respect for universally recognized ethical principles. Frontify requires all internal and external stakeholders, including all its subcontractors, to abide by ethical principles that are at least equivalent to our Frontify for Good and any other additional policy composing the framework of our corporate social responsibility commitment. “We Embrace Ethics and Integrity” is the second of our five pillars representing our commitment to operate with honesty and integrity throughout our entire business chain. Frontify promotes a bribery and corruption-free company culture while ensuring that our stakeholders, including customers and subcontractors, are always appreciated while taking a firm and principled stand against all forms of corruption.

1.1. The aim of this policy

This policy provides an overview of Frontify’s initiatives to ensure the integration of certain fundamental ethical principles into our daily operations and compliance with applicable law.

This policy aims to communicate our commitment to the fight against corruption and bribery and ensures our stakeholders respect and implement, internally and throughout their entire supply chain, these principles of ethics and integrity while doing business with and for Frontify. We want to operate with honesty and integrity in all jurisdictions where we do business, and to do so, we cannot simply integrate these principles into our processes, but we need the same commitment from all our stakeholders.

If this document is shared with you, you are one of our stakeholders, and we expect you and your entire supply chain to abide by this framework. Any action or conduct in contradiction is contrary to our corporate culture, and Frontify has the right to immediately terminate any contractual relationship we have established without any liability.

We also want to ensure that our great partners and customers are treated with the special care they deserve. So, while we are encouraged to show them their importance in the form of a card, a present, flowers, or having a meal together, we should always make sure to do so within the scope of this policy.

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2. Anti-corruption policy

2.1. What is corruption?

Transparency International defines corruption as “the abuse of entrusted power for private gain.” Corruption involves behavior in which people seek to improperly and unlawfully enrich themselves or those close to them by leveraging a position of power or accountability.

For example, offering money to a potential customer to close a deal is a form of corruption.

Corruption can happen anywhere and can involve anyone. Even if you think that corruption might not apply to your position, bear in mind that corruption can take different forms and be disguised in daily actions. At Frontify, we don’t want anyone to engage in and tolerate any corrupt practices. This includes kickbacks, facilitation payments through charitable and political donations, for example sponsorship, travel, and promotional expenses to gain an unfair advantage or to create a conflict of interest, regardless of where our operations take place and of any local established practices.

2.2. Different forms of corruption

Corruption can be disguised in different ways, but in the SaaS industry, the three most common three forms of corruption are bribery, facilitation payments, and coercion.

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.

Facilitation payment

A facilitation payment is a very subtle form of bribe, which might also be called “facilitating speed” or “grease payment.” Usually, it’s provided to expedite the performance of a routine or necessary action to which the payer is already entitled. For example, offering money to a key stakeholder to close a deal faster than the norm is a facilitation payment.

Coercion

Coercion is a form of corruption that uses threats or intimidation to obtain compliance for oneself or third parties. For example, threatening to expose a person’s personal confidential information if they don’t sway their decision in your favor is coercion.

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3. Ethics and integrity: The anti-corruption policy

To ensure that all stakeholders and their entire supply chain operate with honesty and integrity, comply with applicable laws, and avoid bribery and corruption, they should implement and follow these rules throughout your supply chain:

1. Do not be involved in the offering, giving, or receiving of benefits if they could improperly influence or be seen as seeking to influence the outcome of a business decision.
2. Do not be involved in the offering or making of facilitation payments.
3. Register every transaction performed on behalf of the company via the appropriate internally approved channels.
4. Raise concerns and report violations of this policy using the appropriate confidential channels.
5. Do not offer any gifts, services, or hospitality that may be a personal reward for the recipient.
6. Do not offer any gifts, services, or hospitality that might be intended or reasonably be perceived to influence the recipient to act improperly or to reward improper behavior on the part of the recipient.
7. Do not request, agree to receive, or accept any gifts, services, or hospitality that you believe are intended to influence improper behavior or decisions or which would impose an obligation on you to treat another third party unfavorably.
8. Do not offer cash, gift cards, or cash in any other form.

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4. Gift policy

4.1. What is a gift?

A gift is an item of cash or goods or any service of commercial value that’s given to an individual for personal use/benefit without getting or expecting a return of payment of any kind.

4.2. Key principle

When you are thinking about giving or receiving gifts of any kind and value, you must always ensure that there is no sign of corrupt practice. Once you have ensured that, the next step should be to give or receive gifts only of modest value but never in cash.

4.3. Frontify’s approach to gifts

While giving and receiving gifts and hospitality is commonly a part of or courtesy of business relationship building, this shall be done by always taking into account respect and adherence to the rules of ethics and integrity. We expect all our stakeholders to have internal business practices that ensure the highest standards of transparency including within their supply chain — so that incidents of non-compliance are easy to identify, avoid, and correct. Frontify does not tolerate any gifting practice that could resemble or be perceived as a corrupt practice.

4.4. Three key criteria for gifts

1. Proportionality

Firstly, the value of gifts received or given by all our stakeholders in their business operation should always be beneath or equal to CHF/EUR/GBP/USD 100, and in no case must a gift look disproportionate in connection to the person to whom they are directed. To ensure a gift is proportionate, we expect our stakeholders and their entire supply chain to always abide by the following rules:

• Ensure to accept or offer gifts of a modest value only (up to CHF/EUR/GBP/USD 100 max).
• Take into consideration the organization or the recipient of the gift, as some recipients are more regulated than others (e.g., public offices and officials). Always contact the legal team for clarity.
• As a preferred option, it’s better to offer gifts in the form of charitable donations, but when this is not feasible, any other form of a gift must be provided in accordance with the applicable laws and customary practices, including the internal policies of the recipient.
• If you invite a third party for lunch or dinner, keep meal expenses at a “usual meal costs” level. A good guide would be more or less around CHF/EUR/GBP/USD 100 max per person.
• Contact your legal and finance team if you plan to spend more than CHF 100 to make sure your gift follows the relevant guidelines:
  • Compliance with bribery laws in a specific country.
  • There is no client gift policy binding upon you, which might prevent you from offering/receiving gifts regardless of their value.

2. Transparency

We also expect the offering or accepting of gifts to always be done with the highest attainable level of transparency, making sure that all gifts are duly planned, recorded, and approved internally. To ensure transparency, we expect our stakeholders and their entire supply chain to always abide by the following rules.

• Ensure that the receipt and giving of gifts and hospitality are duly planned and authorized internally by the appropriate teams.
• Ensure that the receipt or giving of gifts and hospitality is recorded and verifiable.
• Ensure that gifts are planned and purchased (or if this is not needed, they are at least approved) by the appropriate team.
• Ensure that gifts are legal, appropriate, and proportional, taking into consideration the context and person receiving the gift.
• Register every financial transaction performed for or on behalf of your business.

3. No conflict of interest

While giving or offering gifts, conflict of interest is an aspect nobody should forget. A conflict between personal and business interests can often arise. Thus, we expect all stakeholders to always follow procedures to handle situations where conflict of interest might arise.

• Disclose the situation to your direct manager and ask for advice.
• Refer to the legal team for counseling since not all circumstances where private interests are involved in a business situation qualify as a conflict of interest.
• Document the personal interests and show clearly why there is no conflict to enable the quick resolution of these cases.

4.5. Awareness

We expect all our stakeholders to be aware of, abide by, and ensure compliance with these fundamental ethical principles. All stakeholders should have laid down internal procedures and promote employee awareness of this policy by providing detailed/clear guidelines and training.

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5. Contact the Frontify Legal Team

The practice and rules of giving and accepting gifts and hospitality can be complex and differ among countries, cultures, and customary rules. In some industries, providing and receiving any gift 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 are unsure whether a gift or hospitality that they are offered is permitted by this policy or by any applicable local law.

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6. Conclusion

We have zero tolerance for corruption within our and our stakeholders’ supply chains. Business decisions and relationships throughout our supply chain and that of our stakeholders should never be based on gifts or hospitality received or provided through business relationships. We avoid and expect our stakeholders to avoid even the appearance of improper behavior or business decisions based on gifts and hospitality.