Code of Conduct

MESSAGE FROM THE CEO

Since its inception in 2014, Kpler has grown into a global leader with over 650 talented individuals spanning 12 offices worldwide. This journey has been fueled by our unique approach, an unwavering commitment to excellence, and our ability to swiftly adapt to industry and customer needs.

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Kpler's culture is defined by the fact that we are approachable, agile and move fast. Across diverse cultures, backgrounds, and legal landscapes, we hold ourselves to the highest standards, ensuring our business practices are scalable and responsible. At our core, we value relationships we build with colleagues, customers, partners, and the communities we touch. Our success goes beyond numbers. It is about making a real, positive impact in the world.

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To achieve this, we recognise the importance of being direct, adaptable, transparent, honest, with a team of highly committed individuals who put this into motion.

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This Code of Conduct serves as our compass, helping us navigate the challenges we face every day and keeping us grounded in the core values that define Kpler. As Kpler's ambassadors, we uphold these values, creating a positive environment of innovation and mutual respect.

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By embracing this Code in everything we do related to Kpler, we strengthen our leadership, and help foster a culture that empowers each one of us to thrive. Together, let’s continue to shape a workplace we’re proud of and a company that inspires trust and meaningful impact globally.

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Mark Cunningham

CEO, Kpler

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ABOUT THIS CODE

This Code has been written to serve as a clear guidance for all individuals associated with our organisation, including employees, customers, partners, and third parties. It sets forth the principles, expectations, and standards of behaviour that we uphold to ensure ethical conduct, legal compliance, and responsible business practices. It reflects our commitment to integrity, transparency, and accountability in all our interactions and it is intended to:

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● Inform: It provides a clear understanding of our values, expectations, and ethical standards, enabling individuals to align their actions with our organisational principles.

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● Guide: It offers guidance on navigating complex ethical dilemmas, encouraging

individuals to make informed decisions that prioritise integrity and ethical considerations.

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● Raise awareness: It fosters awareness of potential ethical issues and promotes a culture of vigilance, encouraging individuals to report concerns and seek guidance when faced with ethical dilemmas.

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● Foster accountability: It establishes a framework for accountability, enabling individuals to take responsibility for their actions and understand the consequences of non-compliance.

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VISION, MISSION AND CORE VALUES

Our Vision: One World, One Platform for Global Trade Intelligence

At Kpler, we aspire to break down barriers and bring global trade intelligence to all corners of the world through our unified platform. Our vision drives us to create seamless connections and build a community of collaboration, empowering businesses and decision-makers to thrive in a rapidly evolving marketplace.

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Our Mission: Explore, Build, and Grow

We are united in our mission to explore, build, and grow together as a team.

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Explore: We boldly venture into uncharted territories, seeking new data sets, advanced technologies, and the seamless synergy between artificial intelligence and human intelligence. Our thirst for knowledge and innovation propels us forward, continuously expanding our capabilities to provide unparalleled insights to our customers.

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Build: Our commitment to building strong foundations, simple yet effective tools, and enduring relationships defines our success. As we map global trade with precision, we lay the groundwork for long-lasting and fruitful collaborations with our valued partners.

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Grow: We embrace change and adapt our strategies around the evolving needs of our customers. By staying agile and responsive, we position ourselves at the forefront of the industry, ready to tackle new challenges and opportunities that arise.

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Core Values‍

Our core values are the pillars that uphold our code of conduct and define the Kpler way of doing business.

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We make things happen: We are relentless in our pursuit of excellence, taking ownership of our responsibilities and driving positive outcomes. Our actions speak louder than words, and we rise to the occasion, delivering results that exceed expectations.

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We create together: Collaboration is the heart of Kpler's success. By harnessing the power of diverse perspectives and talents, we foster a creative and inclusive environment that nurtures innovation and collective growth.

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Hey, how can I help you today? We pride ourselves on being accessible and supportive to our customers and colleagues alike. Our commitment to exceptional service and teamwork reinforces the strong bonds that unite us as the Kpler community.

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WE FOLLOW THE LAW AND ACT WITH INTEGRITY

At Kpler, we move fast while upholding the law. Our values emphasise approachability and transparent ethics. We act with integrity and responsibility, always inviting open dialogue.

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Anti-Bribery and Corruption

Kpler is committed to maintaining the highest standards of integrity and transparency. We strictly prohibit any form of bribery, corruption, or unethical practices in all aspects of our business operations. Employees and representatives are expected to comply with all applicable anti-bribery and anti-corruption laws and regulations. Gifts, entertainment, or other favours must not be used to influence business decisions, and relationships with government officials and business partners must be conducted with utmost honesty and fairness.

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Anti-Fraud and Money Laundering

As part of our commitment to combating money laundering and terrorist financing, we have implemented robust AML policies and procedures. All employees must be vigilant in identifying and reporting suspicious activities, adhering to Know Your Customer (KYC) requirements, and cooperating with authorities when necessary. We conduct regular training to ensure that everyone is aware of their responsibilities in preventing money laundering and other financial crimes.

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Conflicts of Interest

We avoid conflicts of interest that could compromise our objectivity in decision-making. Employees must promptly disclose any potential conflicts to their supervisors or to the Legal, Risk and Compliance Team. This includes financial interests, family relationships, or any other affiliations that could influence their decision-making.

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Data Protection and Privacy

Respecting individuals' privacy and safeguarding their personal information is of paramount importance to us. We strictly adhere to data protection laws and regulations, ensuring the proper collection, processing, and storage of personal data. Employees are trained to handle data

securely, only accessing information relevant to their roles. We maintain data confidentiality and have mechanisms in place to address any data breaches promptly and responsibly. Further information can be found on: https://www.kpler.com/privacy.

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Environmental Responsibility

We are committed to minimising our environmental impact and promoting sustainability in all aspects of our operations. Kpler strives to reduce waste, conserve resources, and adopt eco-friendly technologies wherever feasible. We work closely with suppliers and partners who share our commitment to environmental sustainability.

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Fair Competition and Antitrust

We compete fairly and ethically, adhering to antitrust and competition laws. We do not engage in anti-competitive practices, price-fixing, or bid-rigging.

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Health and Safety

We prioritise the health and safety of our employees, clients, and partners. Compliance with health and safety regulations is non-negotiable. We comply with all relevant health and safety laws, regulations, and industry standards.

Non-Discrimination, Fair and Equal Treatment, and Anti-Harassment We foster an inclusive environment where everyone is treated with respect, dignity, and equality. Any type of discrimination, including cumulative and intersectional discrimination, and harassment are strictly prohibited. We respect and uphold human rights, ensuring fair treatment and opportunities for all individuals associated with our business.

Respect, Dignity, and Inclusion

We promote a culture of inclusion, embracing diversity and fostering a sense of belonging for all. We encourage open communication and mutual respect, valuing diverse perspectives. Kpler promotes equal opportunities and actively works to remove barriers to participation and advancement.

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Sanctions and Export Controls

We prioritise adherence to sanctions and export control laws to prevent any engagement in prohibited activities. Our commitment to responsible global trade intelligence ensures that our data and services remain compliant, protecting our integrity and reputation. Kpler establishes internal controls and procedures to ensure compliance with export control and sanctions requirements, integrating them into day-to-day business operations.

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Working Environment

We strive to create a positive and safe working environment that nurtures growth, creativity, and collaboration among our employees. In order to maintain and achieve a healthy working environment, Kpler will regularly review and update the code of conduct and working environment policies to ensure they remain relevant, effective, and aligned with the organisation's values.

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USING THE CODE TO MAKE THE RIGHT DECISION

The Global Code of Conduct at Kpler serves as a valuable guide to navigating ethical dilemmas and making sound decisions aligned with our values. Here are some recommendations on how to use this Code to ensure you make the right choices:

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● Familiarise Yourself: Take the time to read and understand the Code thoroughly. Familiarise yourself with our mission, purpose, core values, and the various risk topics covered in the Code.

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● Integrity as a Compass: Let integrity be your compass. When faced with decisions, ask yourself if your actions align with our commitment to transparency, honesty, and accountability.

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● Apply the Values: Our Core Values are the foundation of the Code. Apply them to your daily work, and overall interactions including with colleagues, customers, and partners.

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● Seek Guidance: If you encounter a situation that requires guidance, don't hesitate to seek

advice from your supervisor, the Legal, Risk and Compliance Team, or any appropriate channel mentioned in the Code.

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● Report Concerns: If you witness or suspect any violations of the Code, promptly report your concerns through the available reporting channels. Confidentiality and non-retaliation are guaranteed.

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● Think Long-Term Impact: Consider the broader implications of your decisions on stakeholders, the environment, and our reputation. Strive for decisions that create lasting positive impact.

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● Consult Legal and Compliance: In complex situations involving legal or compliance matters, consult our legal and compliance experts for guidance.

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● Continuous Learning: Keep abreast of updates to the Code and participate in relevant training and educational resources to reinforce your understanding.

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● Lead by Example: As a member of the Kpler family, you play a crucial role in upholding our ethical standards. Lead by example and inspire others to do the same.

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Remember, our Code is more than just words on paper; it represents our shared commitment to building a responsible future. By applying these guidelines, we ensure that each decision reflects our dedication to "One World, One Platform for Global Trade Intelligence" and the values we hold dear.

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SPEAK UP

At Kpler, we value open communication and encourage employees to speak up without fear or hesitation. We provide accessible reporting channels to confidentially raise concerns, ensuring a safe space for employees to share any potential violations of our Code of Conduct. Together, we uphold a culture where voicing concerns leads to positive change and reinforces our commitment to integrity and accountability.

Along these lines it is important to remember that:

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● Everyone has a voice

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● You can report concerns through the existing channels. You may use our confidential reporting line or choose online reporting to specific stakeholders (direct manager, People Team, Legal, Risk and Compliance Team)

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● Potential investigations will be conducted impartially and with due process, ensuring fairness to all parties involved.

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● Appropriate actions will be taken to address substantiated violations, which may include disciplinary measures and remedial actions.

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NO RETALIATION

We are committed to non-retaliation and guarantee that all concerns will be impartially addressed through prompt investigations. We prioritise safety and trust. Employees can report concerns or Code of Conduct violations without fear, using our provided channels. We ensure a firm stance against any retaliation. Every reported concern is addressed swiftly and impartially. We champion open dialogue, knowing it fortifies our mission to create a secure and ethical workplace for all at Kpler.

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FURTHER DOCUMENT DETAILS

Version: v.02

Approval Date: December 2024 Date for Next Review: December 2025

Risk Category: High

Accountable Policy Owner: Legal, Risk and Compliance (LRC) Team