Ethics & Compliances

Codeguardian.ai Code of Business Conduct and Ethics

Introduction

At Codeguardian.ai, we are dedicated to redefining the landscape of cybersecurity through innovation, integrity, and excellence. This Code of Business Conduct and Ethics underpins our commitment to uphold the highest standards of ethical conduct across all operations and relationships. Herein, we outline the principles and policies that guide our actions, ensuring we navigate the complexities of our industry with unwavering ethical clarity.

Our Ethical Framework

1. Integrity and Honesty: We expect every member of our team—from the boardroom to our global offices—to embody integrity and honesty, ensuring that our actions align with our words and our corporate values.
2. Compliance and Governance: Adherence to laws, rules, and regulations is foundational to our operations. We navigate the global regulatory environment with precision and proactive compliance, understanding that our credibility depends on our legal and ethical rectitude.
3. Conflict of Interest Avoidance: We diligently avoid conflicts of interest. Each team member is expected to act in the best interests of Codeguardian.ai, ensuring that no personal or external interests compromise our corporate decisions or actions.
4. Protection of Company Assets: The resources entrusted to us by stakeholders are safeguarded with rigor and thoughtfulness. We utilize these assets solely for legitimate business purposes, ensuring their optimal use for the benefit of our mission.
5. Confidentiality and Data Integrity: We hold the sanctity of confidential and personal data in the highest regard. Every piece of information is managed with strict protocols and respect for privacy, reflecting our role as custodians of sensitive digital assets.
6. Responsible Communication: Clear, accurate, and responsible communication is critical in maintaining our reputation and operational effectiveness. We ensure all public disclosures and internal communications meet our standards of clarity and integrity.
7. Respectful Workplace: We foster a workplace where diversity is valued, and inclusivity is practiced. Discrimination, harassment, or any form of disrespectful behavior is unequivocally prohibited. Each member contributes to a culture of respect and dignity.
8. Global Citizenship: As a corporate citizen, we commit to ethical interactions within the markets we serve, respecting cultural, legal, and ethical norms worldwide. Our global operations adhere to international standards of business conduct, reflecting our role as a leader in the cybersecurity industry.

Ethics and Compliance Resources

Codeguardian.ai provides numerous resources to assist team members in understanding and fulfilling these ethical commitments. Our compliance department offers guidance and support, ensuring that ethical dilemmas and compliance questions are addressed promptly and effectively.

Reporting and Accountability

We maintain multiple channels for reporting ethical concerns or potential violations of this code, assuring confidentiality and protection from retaliation. We value the courage it takes to speak up, and we commit to thorough investigations and appropriate responses.

Amendment and Enforcement

This code is dynamic, evolving with our industry and company. Amendments will be made transparently and with thoughtful consideration, ensuring they align with our mission and values. Adherence to this code is paramount, and violations will meet with appropriate corrective actions, reinforcing our commitment to ethical conduct at every level of our organization.

Conclusion

At Codeguardian.ai, we engineer more than cybersecurity solutions—we engineer trust, integrity, and ethical excellence into every aspect of our operations. This code is a declaration of our commitment to lead responsibly, fostering a legacy of ethical innovation and security assurance for all our stakeholders.

Codeguardian.ai Conflict Minerals Policy

Introduction

At Codeguardian.ai, our commitment extends beyond the realm of cybersecurity to uphold and advocate for human rights globally, particularly within our supply chain. We are resolute in our dedication to integrity and ethical practices, ensuring that our suppliers and partners align with our standards and contribute positively to human rights across all operational territories.

Background

In alignment with the 2012 Securities and Exchange Commission (SEC) mandates under the Dodd-Frank Wall Street Reform and Consumer Protection Act, specifically the Conflict Minerals Rules, Codeguardian.ai is steadfast in our responsibility to disclose the origins of conflict minerals in our products. These minerals, namely columbite-tantalite (coltan), cassiterite, wolframite (including derivatives like tantalum, tin, and tungsten), and gold, are sourced from designated "Covered Countries" which include regions afflicted by armed conflict and human rights abuses, notably in the Democratic Republic of the Congo (DRC) and neighboring nations.

Our Policy

Codeguardian.ai supports the Dodd-Frank Act's objective to prevent the exploitation of conflict minerals that financially benefit armed groups in the Covered Countries. Our policy is to engage suppliers who are committed to ethical practices and who support our vision of a responsible and transparent supply chain.

Our Commitment

Codeguardian.ai is proactive in ensuring compliance with the Dodd-Frank Act through the following measures:

• Establishing a robust governance framework to enforce our conflict minerals policy.
• Actively communicating our policy to our suppliers and third-party manufacturers.
• Conducting comprehensive supplier training and verification to ensure the responsible sourcing of conflict minerals.
• Implementing due diligence processes aligned with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
• Collaborating with industry leaders and initiatives, such as the Conflict-Free Sourcing Initiative, to enhance transparency and accountability in mineral sourcing.

Expectations for Suppliers

Codeguardian.ai recognizes the complexity of our supply chain and the challenges in tracing the origins of conflict minerals. We expect our suppliers to:

• Engage cooperatively in our efforts to trace and audit the sources of conflict minerals.
• Establish their own policies and management systems that adhere to OECD guidelines and ensure that materials sourced are verifiably DRC Conflict Free.
• Conduct due diligence to certify that the minerals sourced are from compliant smelters, as recognized by the Conflict-Free Smelter Program.
• Support industry-wide efforts to improve traceability and responsible sourcing practices.

Ongoing Evaluation and Enforcement

We continuously assess our suppliers' compliance with our Conflict Minerals Policy. Codeguardian.ai reserves the right to discontinue relationships with suppliers who fail to meet our standards. This policy does not confer any additional rights to our suppliers but is a testament to our ethical commitments.

Policy Modifications

Codeguardian.ai may revise this policy at our discretion to reflect changes in our operational practices or in response to evolving regulatory and industry standards.

Contact Information

For inquiries related to this policy, please contact us at: compliance@codeguardian.ai.

Codeguardian.ai 2022 Conflict Minerals Report

Introduction

This Conflict Minerals Report for Codeguardian.ai for the calendar year 2022 is crafted in accordance with Rule 13p-1 under the Securities Exchange Act of 1934, aiming to uphold our commitment to ethical sourcing and the support of human rights globally. This report outlines our efforts to ensure that the minerals used in our products do not finance or benefit armed conflicts in the Covered Countries.

Regulatory Background

Rule 13p-1 requires SEC registrants to disclose their use of certain minerals—known as Conflict Minerals—that originate from the Democratic Republic of the Congo (DRC) or adjoining countries. These minerals include columbite-tantalite (coltan), cassiterite, wolframite, and gold, along with their derivatives such as tantalum, tin, and tungsten.

Due Diligence Process

In 2022, Codeguardian.ai undertook comprehensive due diligence to ascertain the sources of Conflict Minerals in our products. Our approach is designed to align with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Our process includes:

• Supply Chain Surveys: Conducting detailed surveys with our suppliers using the RBA Conflict Minerals Reporting Template to identify the smelters and refiners in our supply chain.
• Smelter Verification: Comparing identified smelters against globally recognized lists of facilities that are verified as conflict-free.
• Supplier Engagement: Continual engagement with our suppliers to enhance the transparency and responsibility of our mineral sourcing.

Findings and Actions

Our due diligence has shown that while some minerals may originate from the Covered Countries, efforts are in place to ensure they are sourced responsibly:

• Smelter Compliance: A significant percentage of our known smelters or refiners are compliant with or actively participating in the Responsible Minerals Assurance Process (RMAP).
• Continuous Improvement: We are committed to refining our processes, increasing supplier engagement, and using tools that help track the origins of minerals used in our products.

Commitment to Ethical Practices

Codeguardian.ai is dedicated to improving our practices continuously:

• Internal Training: Educating our team on the requirements of Rule 13p-1 and ethical sourcing standards.
• Industry Collaboration: Participating in forums and conferences to stay at the forefront of responsible mineral sourcing practices.
• Supplier Accountability: Regular assessments and follow-ups with suppliers to ensure compliance with our conflict minerals policy.

Conclusion

Codeguardian.ai strives not only to comply with legal standards but to exceed them, reinforcing our commitment to corporate responsibility and ethical business practices in every aspect of our operations.

Forward-Looking Statements

This report contains forward-looking statements based on current expectations and plans that involve risks and uncertainties. Codeguardian.ai does not undertake any obligation to update any forward-looking statements, except as required by law.

Codeguardian.ai Global Supplier Code of Business Conduct and Ethics

Introduction

At Codeguardian.ai, we are dedicated to redefining the future of cybersecurity with a commitment to ethical excellence and integrity. Our Global Supplier Code of Business Conduct and Ethics sets forth the principles we uphold and expect from our partners and suppliers. This document guides our global network of suppliers in maintaining high standards of workplace ethics, safety, respect, and environmental responsibility.

Code Compliance

Codeguardian.ai is committed to lawful and ethical behavior in all our activities, and we require the same from our suppliers. We expect compliance with all applicable laws and regulations of the countries and regions in which we and our suppliers operate. Should local regulations be less stringent than our Code, we expect adherence to our stricter standards.

Ethical Conduct Guidelines

1. Compliance with Laws: All suppliers must fully understand and comply with all applicable laws and regulations.
2. Reporting and Transparency: We encourage open communication. Any concerns or violations of our Code should be promptly reported through designated channels such as our compliance email or through anonymous reporting systems.
3. Anti-Bribery and Corruption: Absolute adherence to anti-bribery laws is mandatory. All forms of bribery and corruption are prohibited, irrespective of local practices or norms.
4. Fair Competition: We advocate for fairness in all business dealings. Suppliers must avoid conflicts of interest and ensure transparency and honesty in their operations.
5. Confidentiality and Data Protection: Protecting the confidentiality and integrity of information is paramount. Suppliers must safeguard sensitive data and intellectual property with the highest security measures.

Human Rights and Labor Practices

Codeguardian.ai supports and respects the protection of internationally proclaimed human rights. Our suppliers must ensure:

• No forced labor or human trafficking.
• No child labor; adherence to minimum age laws.
• Fair working hours and compensation.
• Humane treatment of all employees without risk of harassment or abuse.
• Non-discrimination and a commitment to diversity and inclusion.
• Respect for workers’ right to freely associate and collective bargaining.

Health, Safety, and Environmental Responsibility

Our suppliers are expected to operate in a manner that actively manages risk and minimizes adverse effects on the environment and public health:

• Compliance with safety laws and regulations.
• Emergency preparedness and response planning.
• Proper management of waste and emissions.
• Reduction of resources use and promotion of recycling efforts.

Management and Accountability

Suppliers must maintain effective management systems to ensure adherence to this Code, including routine audits and worker training programs. Transparency and ongoing assessment are required to continually improve ethical compliance.

Consequences of Non-Compliance

Failure to adhere to this Code can result in corrective action, including potential termination of contracts. This Code is intended to supplement, not replace, contractual obligations between Codeguardian.ai and our suppliers.

Continuous Improvement

We are committed to continuous improvement in our operations and expect the same from our suppliers. This includes staying abreast of technological, legal, and regulatory developments that impact ethical standards in our industry.

Contact Information

Suppliers with questions or needing to report concerns should contact: [compliance@codeguardian.ai].

Final Remarks

Codeguardian.ai values integrity and sustainability, not only in cybersecurity solutions but also in our business practices and partnerships. Together with our suppliers, we strive to uphold these principles, fostering a secure, ethical, and responsible supply chain.

Codeguardian.ai Human Rights Policy

Effective Date: August 17, 2023

Introduction

At Codeguardian.ai, we are committed to advancing cybersecurity while upholding the highest standards of human rights. Our Human Rights Policy embodies our dedication to the fundamental rights and freedoms to which all individuals are entitled. This policy is aligned with international human rights standards, including the United Nations Global Compact, the United Nations Guiding Principles on Business and Human Rights, and applicable local laws.

Scope

This policy applies globally to all operations of Codeguardian.ai, including our subsidiaries, affiliates, and business entities. It covers all our employees, contingent workers, suppliers, and partners. This policy complements our Global Code of Business Conduct and Ethics and other related corporate policies.

Human Rights Practices

• Respect for Human Rights: Codeguardian.ai acknowledges and respects the inherent dignity and equal rights of all individuals. We are proactive in identifying, preventing, and mitigating any adverse human rights impacts related to our business activities.
• Diversity and Inclusion: We foster a workplace environment that embraces diversity and provides equal opportunities without discrimination. Harassment in any form is strictly prohibited.
• Freedom of Association: Consistent with legal provisions, we support the right of our employees to form or join trade unions and engage in collective bargaining.
• Safe and Secure Workplaces: We commit to ensuring a safe and healthy work environment that is free from violence, harassment, or intimidation.
• Prohibition of Forced and Child Labor: Codeguardian.ai opposes all forms of forced labor and human trafficking. We strictly prohibit child labor in our operations and require our suppliers to adhere to these principles.
• Working Conditions and Fair Compensation: We strive to uphold fair labor practices, including reasonable working hours, fair wages, and benefits that comply with local laws.

Privacy and Freedom of Expression

As a leader in cybersecurity, protecting individual privacy and data security is integral to our operations. We are committed to protecting and enhancing people's rights to privacy and freedom of expression, ensuring that our technologies and practices reflect these principles.

Supplier and Partner Expectations

Our suppliers and business partners are expected to adhere to this Human Rights Policy and our Global Supplier Code of Business Conduct and Ethics. We engage with our supply chain to ensure compliance with these standards, particularly concerning the sourcing of conflict minerals.

Reporting and Compliance

Codeguardian.ai encourages transparency and open communication. Concerns about potential human rights violations can be reported through:

We ensure confidentiality and protect all individuals who report concerns in good faith from retaliation.

Policy Governance

This policy is overseen by the Codeguardian.ai Corporate Responsibility Committee, which is responsible for its annual review and updates. The policy reflects our ongoing commitment to human rights and serves as a framework for action and accountability across our global operations.

Conclusion

Codeguardian.ai's commitment to human rights is a cornerstone of our ethical practices. By respecting, protecting, and remedying human rights within our sphere of influence, we reinforce our commitment to ethical business conduct and enhance our corporate accountability.

Codeguardian.ai Modern Slavery and Human Trafficking Statement

Introduction

At Codeguardian.ai, we are dedicated to safeguarding not just our digital environment but also the integrity and dignity of every individual affected by our operations. As part of our commitment to ethical business practices, we ensure that our supply chains and business activities are free from modern slavery and human trafficking. This statement reflects our ongoing efforts to address these issues, in compliance with the UK Modern Slavery Act 2015 and the Australia Modern Slavery Act 2018.

Company Structure and Operations

Codeguardian.ai, incorporated and headquartered in the United States, is a global leader in cybersecurity solutions. With about 12,500 employees spread across over 30 countries, we specialize in delivering advanced cybersecurity software and services designed to secure critical data and infrastructure. Our operations encompass design, development, marketing, sales, and customer support, with a focus on providing cutting-edge security solutions that respect ethical standards and human rights.

Supply Chain Dynamics

Our supply chain is extensive, involving multiple international partners responsible for manufacturing and assembling our products based on our stringent specifications and forecasts. We engage with over 300 suppliers across various continents, ensuring that our high standards for quality and ethical practices are met consistently.

Risk Assessment and Mitigation

We proactively assess and mitigate risks of modern slavery and human trafficking in our supply chain through several measures:

• Conflict Minerals Policy: Implementation of a comprehensive policy to track minerals from their source to ensure they are conflict-free.
• Supplier Code of Conduct: Requiring all suppliers to adhere to our Code of Conduct, which includes strict guidelines against modern slavery.
• Due Diligence: Conducting regular assessments, including surveys and audits, to ensure compliance with our ethical standards.

Training and Compliance

We require all employees, especially those involved in supply chain management, to undergo training related to our Code of Business Conduct and Ethics. This training emphasizes the importance of human rights and the prohibition of modern slavery. Additionally, we keep our team updated on best practices and regulatory requirements through various educational platforms.

Reporting and Remediation

We maintain open channels for reporting concerns related to modern slavery, ensuring that any issues raised are investigated thoroughly and addressed promptly. Our approach is designed to support continuous improvement and compliance across all aspects of our operations.

Effectiveness and Continuous Improvement

Our effectiveness in combating modern slavery is assessed through feedback from our supply chain partners, compliance audits, and ongoing risk assessments. We are committed to refining our strategies and actions based on these insights to better combat modern slavery and human trafficking.

Governance

This statement has been approved by our leadership and reflects our commitment to upholding the principles of the United Nations Global Compact concerning human rights and labor standards. It forms a part of our broader human rights policy and aligns with our core mission to ensure a secure and ethical operational environment.

Conclusion

Codeguardian.ai recognizes the importance of actively fighting against modern slavery and human trafficking. Through stringent policies, rigorous due diligence, and a commitment to transparency, we strive to maintain a supply chain that reflects our values of integrity and respect for human rights.