Code of Conduct and Policies

CODE OF CONDUCT

The purpose of this Code of Conduct is to communicate our common set of ethical values and business principles to our stakeholders and to give internal guidance in our daily pursuit of building the Information Society. We encourage the associates and other business partners within its sphere of influence to adopt the principles in this Code of Conduct.

Our business operations are based on high ethical standards. We promote fair competition in accordance with applicable laws. It is expected that employees compete vigorously and fairly in the conduct of business.

In every country in which we operate shall abide by the laws and regulations of that country. In situations where the law does not give guidance, we apply our own standards based on our corporate values and culture. In cases of conflict between mandatory law and the principles contained in this Code of Conduct, the law shall prevail. It is the responsibility of all employees to be aware of relevant laws or to seek legal advice to ensure compliance.

Business Practices

Safeguarding Corporate Assets

Safeguarding our assets – both tangible and intangible (such as intellectual property rights) – is vital to our business success. Employees have a duty to use our assets only for legitimate business purposes and to protect them from loss or unauthorized use. In no event may our assets be used for unlawful or improper purposes.

Conflict of Interest

In order to operate in a fair and open manner, it is important that every employee and the members of the Boards of Directors avoid any situation or interest which might interfere with their judgment regarding their responsibilities to the company, other employees, customers, suppliers and other partners. Should such a conflict of interest arise, it must be reported immediately by the person subject to the conflict to his/her immediate superior.

Gifts and Bribes

No gifts or similar benefits may be offered by an employee of our company nor accepted if it is considered as a contravention of any applicable law or code of local business practice. Gifts or similar benefits may only be offered to a third party if modest in value and if they are consistent with reasonable hospitality given in the ordinary course of business. No bribes or kickbacks may be offered to any third party.

Political Involvement

We observe neutrality with regard to political parties and candidates. Neither our name, nor any resources controlled by us, shall be used to promote the interests of political parties or candidates without a prior written consent.

Insider Trading

We expect our employees to act in the way required of insiders, even if they are not in fact registered as insiders. Employees must keep all information and secrets that relate to our present and future business operations strictly confidential. It is prohibited to misuse or disclose to any third party any information about our business operations or information about specific projects.

Accounting and Reporting

All accounting and reporting by us must be reported in accordance with generally accepted financial accounting practices and accounting records must give a true and fair view of the financial position. We shall strive to provide disclosure that is open, fair, relevant, timely and understandable.

Human Rights and Workplace Practice

Human rights

We support and respect the principles set out in the Universal Declaration of Human Rights.

Non-discrimination and Equal Opportunities

We hire and treat our employees in a manner that does not discriminate with regard to gender, nationality, religion, race, age, disability, sexual orientation, political opinion, union membership, or social or ethnic origin. We promote the idea that all employees shall be treated with equal respect and dignity. Furthermore, we promote a culture of equal opportunities and diversity where appointments to jobs, rewarding and personal success depend on individual ability and performance.

Labor

We do not accept child labor nor other forms of compulsory and forced labor. We support the freedom of association and all employees have the right to be a member of a trade union and to bargain collectively.

Work Environment

A safe and healthy working environment shall be provided for all employees.

Environmental Practice

We support a precautionary approach to environmental challenges and a responsible way of conducting our own business operations.

Responsibility of Managers and Employees

It is the responsibility of our managers to make sure that both the content and the spirit of this document are communicated, understood and acted upon within their organizations and to encourage employees to reveal behavior that may be non-compliant with this Code of Conduct. Explicit or implicit approval of questionable actions will not be tolerated. Reports of violations of this Code of Conduct may be made anonymously and in confidence to the Board of Directors. Persons reporting violations in good faith will not be subject to retaliation. Failure to act in compliance with the Code of Conduct can result in appropriate disciplinary actions.

We seek continuous improvement in the way we conduct our business and encourages all managers and employees to take part in this process. This Code of Conduct is a part of the Corporate Responsibility Framework and covers our business operations in all countries. Our Code of Conduct will be regularly reviewed.

This Code of Conduct has been adopted by the Board of Directors.

PRIVACY POLICY

PayiQ Oy, including its affiliates (“PayiQ”), is committed to respect your privacy and to comply with applicable data protection and privacy laws. This privacy policy (“Policy”) describes how we collect and use personal data where PayiQ is the data controller or where we refer to the applicability of this Policy. “Personal data” means information relating to you or another identifiable individual.

We will give you additional privacy information that is specific to a product or service in Supplements to this Policy and other notices you may see while using our products or services. If there is a difference between such notices and this Policy, the notices should be considered first.

Software on your device may access your information. Our products or services may contain links to other companies’ websites and services that have privacy policies of their own. PayiQ is not responsible for the privacy practices of others and we recommend you read their privacy notices.

If you do not agree with this Policy, do not use our products and services or provide PayiQ with your personal data.

What Information We Gather and Track

We request personal information when you place an order, register a product, request a service, answer a survey, enter a contest, correspond with us or engage in certain other activities on our services. For example:

If you submit an order on-line with us, we will ask you for information necessary to complete the transaction – such as your name, address, and credit card number. If you request technical support online, we will ask you for information necessary to complete the transaction – such as your name address and information about your computer hardware, software and the nature of the problem you are experiencing. You make the decision whether to proceed with any activity that requests personal information. If you do not wish to provide the requested information, however, you may not be able to complete the transaction.

We request your location informatation when you place an order. We use that information to secure your payments.

How We Use the Information We Gather and Track

We may use personally identifiable information in the following ways:

To provide you with information about product upgrades, new products, services, newsletters, informative emails, and research on future product ideas or improvements;
To assist us in creating content that is relevant to you;
To provide you with special offers that may be of interest to you;
To assist us in creating better products and services to meet your needs;
To allow you to purchase and download products, obtain access to services or otherwise engage in activities you select;
To help you quickly find software, services or product information important to you

With Whom We May Share Your Information

From time to time, we may provide your information to selected business partners to communicate to you information about products or services that they believe are important to you or your business. If you prefer that we not provide your information to our business partners, you may let us know using one of the methods described in this policy.

In addition, we retain the services of third parties to provide services for us. They may be used to deliver additional services, provide technical support, or handle order processing. We require that these partners keep the personal information of customers secure and confidential. We also require that these partners use personal information only on behalf of us.

Please be advised that in certain instances, it may be necessary for us to disclose your personal information to government officials or otherwise as required by our legal obligations.

Security and Quality of Personal Information

We have taken security measures, consistent with international information practices, to protect your personal information. These measures include technical and procedural steps to protect your data from misuse, unauthorized access or disclosure, loss, alteration, or destruction.

We make a sincere effort to respond to your requests to update or correct your personal information. If you believe that we do not have your current personal information, you can use one of the other communication channels in this statement.

Usage of Cookies

We may use cookies from time to time. A cookie is a unique text file that a Web site can send to your browser software. Cookies enable a service to tailor information presented to you based on your browsing preferences. We may use cookies to personalize your pages at our services and support system, or to remember you when you register for products or services. If you do not want us to deploy cookies in your browser, you can set your browser to reject cookies or to notify you when a service tries to put a cookie in your browser software. Rejecting cookies may affect your ability to use of some of the products and/or services.

We may also use cookies to track your visit to our services. While our servers may automatically log your IP address, this information does not identify you and you remain anonymous.

Network Traffic

We may track domain names, IP addresses, and browser types from people who use our services. We use this information to track aggregate traffic patterns throughout our systems. Such information is not correlated with any personal information.

Linking to Business Partners

In our services, there may be a number of links to companies with whom we have a relationship. We are not responsible for the privacy practices of our business partners. We encourage you to read their privacy statements, as they may differ from ours.

Other Considerations for Privacy

Please remember that information you submit in a discussion group or forum, will be deemed public information and is not confidential. There is a risk in such communication venues that information can be collected and used by others. Please be careful and responsible when you are online.

Changes of This Policy

In the event there is a major change to our privacy practices, a prominent notice will be posted on our web site. If the change involves the use of your personally identifiable information, the notice will contain instructions on how you can opt-out of such use.

EQUALITY POLICY

PayiQ aims to provide social responsibility and accountability for the decisions that we make in respect of potential and present partners and employees. We do not discriminate people directly nor indirectly on the basis of race, color, ethnic or national origin, sex, marital status, disability, sexual orientations, age and religious belief. As discrimination in employment is inextricably linked with discrimination in the rest of society, it is totally against of our vision of freedom and globalization.

We have taken active measures to eliminate all direct and indirect discrimination in our business practices and in the provision of services. These practices are promoted as the responsibility of the management, personnel, consultants, contractors and anyone involved in our daily work.

We will seek to identify the needs of disadvantaged groups in our area of operation and ensure equality of opportunity of access to consideration for employment. When ever appropriate we will provide training for such personnel to enable them to qualify for all positions within the company. No applicant or employee of the company will be treated less or more favorably on any of the discriminatory grounds referred to above. In order to achieve this, we have an Equal Opportunities Recruitment Policy regarding employment of personnel from within these groups.

In hiring consultants, contractors and other agents, and in building partnership relations, we will be mindful of our commitment to equality of opportunity.

We aim to extend this policy further to incorporate our partners and associates whenever appropriate. The globalization of the business has awakened the consciousness of the importance of equal opportunities. A growing number of companies worldwide are transforming their practices to a more equality aware direction. It is our common belief that joint co-operation and understanding in equality issues will play a vital role not only in growing the global economy, but also in the mutual commitment and business success.

ENVIRONMENT POLICY

PayiQ is aware of the impact that the modern culture has on the exterior environment. It is our clear understanding that we need to successfully balance economy and ecology. Thinking about the environment is therefore natural for the company.

PayiQ applies the requirements of ISO 14000 standards to our processes and subscribes to the philosophy which emerged from the Rio Earth Summit as Agenda 21. We believe that “thinking globally and acting locally” can make a difference and that our actions today should not be at the expense of tomorrow’s world.

We have established technically and economically viable objectives to optimize the environmental performance of our services and daily work. Our main business revolves around the growing Information Society and the use of electronic rather than paper means of communication. We encourage our customers and partners to consider their own paper needs and not to duplicate the creation, issue and storage of paper, or data held in any form.

Equally, within our organization we have practical company policies of:

Tracking of all incoming and outgoing environmentally relevant materials, including plastic bags, plastic sheets, electricity, water and refrigerant consumption
Re-using all paper and then recycling it
Increased usage of recycled paper within our organization
Donating spent toner cartridges and purchasing refilled cartridges
Reducing or eliminating hazardous substances, such as freon
Using public transport, walking or cycling whenever possible
Sharing cars on business journeys when it is possible
Keeping office temperatures at the lowest comfortable level
Using virtualization and remote access to manage servers
Regularly servicing heating systems and other equipment
Purchasing supplies locally where possible