Code of Ethics and Business Conduct

1. Introduction

At Bizzdesign, we believe that long-term success is built on a foundation of integrity, responsibility, and trust.

As a global technology company, our actions matter—not only to our employees and customers, but also to our partners, shareholders, and the broader communities in which we operate.

This Code of Conduct is one of the most important documents of our Bizzdesign group of companies, “our Group”. It defines the core values and ethical principles that guide our decisions and behaviors across all geographies and business functions. It reflects Bizzdesign’s unwavering commitment to conducting business ethically, responsibly, and in full compliance with the laws, workers council agreements and regulations applicable in every country where we do business.

This Code applies to all employees of Bizzdesign, regardless of role, seniority, or location. It also applies to our
leadership, members of the Corporate Management Team, and to third parties acting on behalf of the Group, including consultants, contractors, distributors, and suppliers. Everyone is expected to read, understand, and fully adhere to the Code—and to speak up or seek guidance whenever questions or concerns arise.

Respecting this Code is essential to preserving the trust placed in us by our stakeholders, protecting our reputation, and ensuring we remain a responsible and reliable player in the global software industry.

Violations of the Code may result in appropriate measures, in accordance with applicable laws and internal Group policies.

2. Our core values

Our core values are the foundation of our business ethics. Our values determine the way we do business. They define our company culture and set the bar for our personal and professional conduct. We aim to live our values; we act as role models and promote ethical behaviors The core values are found on the company website.

3. Our core commitments

This Code of Conduct is founded on five inseparable pillars, reflecting our commitment to balancing business
performance, social responsibility, and respect for universal principles.

Respect for Human Rights
Compliance with Sanctions and Embargo Regulations
Ethical Business Conduct
Environmental Responsibility
Product Safety and Reliability

3.1. Respect of Human Rights

3.1.1. Respect for Individuals

Every employee deserves to be treated with dignity and respect. We expect all individuals to treat one another with courtesy, fairness, and professionalism. Respecting others also means we all share responsibility for maintaining a safe and respectful work environment, free from humiliating, inappropriate, or unprofessional behavior. We strive to create a workplace culture where open communication is encouraged and diverse opinions are valued.

3.1.2. Prohibition of Child Labor

Any form of child labor is strictly prohibited across our operations and throughout our entire value chain.
This prohibition is in full alignment with international standards, including ILO Convention No. 138 on the minimum age for employment and Convention No. 182 on the worst forms of child labor. We require all business partners and suppliers to uphold these standards and implement appropriate due diligence mechanisms. Any suspected or confirmed case of child labor must be reported immediately and will be addressed rigorously by the Group.

3.1.3. Combating All Forms of Harassment

Everyone has the right to work in an environment free from all forms of harassment. We do not tolerate any conduct that constitutes harassment or that creates a hostile, offensive, intimidating, or abusive work environment—including sexual harassment or workplace violence. This standard applies equally to interactions with customers, suppliers, and business partners. If you are the victim of harassment or witness it happening to someone else, you are strongly encouraged to report it without delay.

3.1.4. Non-Discrimination

Bizzdesign is committed to a zero-tolerance approach to discrimination, whether in hiring or in day-to-day employment practices. Every employee is required to comply with all applicable anti-discrimination laws and policies. No one may be discriminated against on the basis of age, race, gender, ethnic origin, nationality, religion, health condition, disability, marital status, sexual orientation, political or philosophical beliefs, union membership, or any other protected characteristic.

3.1.5. Diversity

Cultural diversity is a vital asset to Bizzdesign. With a wide range of nationalities represented across our global offices and functions, we see diversity as a strategic element of our Human Resources policies.
We are committed to building a diverse talent pool across our ecosystem, supporting both local leadership and
international careers.

3.1.6. Disability Inclusion

No individual may be denied access to a recruitment process, internship, or corporate training program due to a disability or health condition. Likewise, no employee may be sanctioned, dismissed, or subjected to direct or indirect discrimination—whether in compensation, performance incentives, training, career development, mobility, job classification, promotion, or contract renewal—because of a disability or health status.

3.1.7. Gender Equality

Equal opportunity means giving both women and men the same chances to succeed in all aspects of professional life. We are committed to ensuring that women and men receive equal treatment, benefits, and opportunities for comparable roles and performance. Across our Group, we actively promote gender equality and take a firm stand against sexist practices or decisions that result in exclusion based on gender.

3.1.8. Personal Data Protection

At Bizzdesign, personal data protection is a core ethical commitment. Personal data is not merely technical information— it is part of an individual’s identity and dignity. We process personal data lawfully, fairly, transparently, and securely, in compliance with applicable data protection laws, including the General Data Protection Regulation (GDPR) and relevant local regulations (and workers council agreements). All employees must strictly adhere to internal policies on data privacy, whether they relate to employee, customer, user, or third-party data. Annual data protection training is mandatory for all employees. We expect the same commitment from our partners and suppliers. In case of doubt or concern, employees must promptly contact the Data Protection Officer (DPO) or their designated local compliance lead.

3.1.9. Health, Safety, and Environmental Protection

We are committed to complying with all applicable health, safety, and environmental laws and regulations (including workers council agreements) in every country where we operate. We also commit to providing and maintaining a safe and healthy workplace and to preventing workplace accidents. Everyone must follow all applicable safety regulations, internal policies, and emergency response procedures. It is the responsibility of each person to immediately report any unsafe conditions or practices so timely action can be taken. All workplace accidents—regardless of severity—must be reported without delay to the management.

3.1.10. Drugs and Alcohol

Consumption of alcohol is not banned at our offices, but we use good judgment and never drink in a way that leads to impaired performance or inappropriate behavior, endangers the safety of others, or violates the law. Illegal or other drugs in our offices or at sponsored events are strictly prohibited.

If a manager has reasonable suspicion to believe that an employee’s use of drugs and/or alcohol may adversely affect the employee’s job performance or the safety of the employee or others in the workplace, the manager may request an alcohol and/or drug screening.

A reasonable suspicion may be based on objective symptoms such as the employee’s appearance, behavior, or speech.

This policy is subject to and will always be applied in accordance with applicable local laws and regulations. Where local requirements differ, those requirements will take precedence.

3.2. Compliance with International Sanctions and Embargo Regulations

We are firmly committed to complying with all applicable regulations on export controls, economic sanctions, and embargo measures issued by competent national, European, and international authorities.
Any commercial, financial, or technical relationship with individuals, entities, or states subject to sanctions or restrictions is strictly prohibited.

To this end, we have implemented a strict Sanctions Policy, which applies to our entire ecosystem, including subsidiaries, distributors, business partners, subcontractors, and service providers.

This policy defines two categories of countries:

Prohibited Countries, with which any activity is strictly forbidden, without exception;
Restricted Countries, with which any operation requires prior authorization from the Bizzdesign Legal Department.

No circumvention or exemption from these rules is permitted. Each employee is responsible for verifying the status of the relevant country before initiating any commercial or contractual engagement.

In case of doubt, the Bizzdesign Legal Department or the DPO must be consulted immediately.

3.3. Commercial and Financial Ethics

3.3.1. Anti-Corruption

Bizzdesign ensures that the highest standards of integrity are upheld by its employees in the course of their professional activities. Accordingly, Bizzdesign prohibits any act of corruption.

Corruption is a criminal offense involving a person soliciting or accepting any form of benefit in exchange for performing or omitting an act within the scope of their duties. Individuals found guilty of active or passive corruption face severe financial penalties or imprisonment.

Bizzdesign employees and executives are not strictly prohibited from receiving gifts or benefits, but such practices are strictly regulated:

Any gift or benefit exceeding €100 (excluding VAT) must be declared. In case of doubt, it is recommended to declare.
A gift or benefit may be accepted only if it is not intended to obtain or retain a business relationship, or to secure or reward a commercial advantage.
No contributions may be made to political activities.

The email address compliance@bizzdesign.com must be used to declare any gift or benefit, and to report any act or suspicion of corruption.

3.3.2. Anti-Money Laundering

Money laundering refers to the act of concealing the origin of funds obtained through illegal means (e.g., illegal speculation, organized crime, drug or arms trafficking, extortion, corruption, tax fraud) by reinvesting them into legal activities. Individuals found guilty of money laundering face severe financial penalties or imprisonment. Each Bizzdesign employee must exercise vigilance regarding payments to detect any irregularities, particularly with partners whose business conduct may raise concerns.

If any aspect of a transaction appears inappropriate or potentially in violation of applicable laws or regulations, it must be reported via the dedicated email address: compliance@bizzdesign.com.

3.3.3. Unfair Competition

We are particularly committed to complying with all applicable rules regarding unfair competition.

We strictly prohibit any deceptive commercial practices aimed at restricting competition, limiting market access for competitors, or exploiting a partner’s or client’s dependency. Applicable civil and criminal penalties are among the most severe under current regulations and should prompt each of us to exercise the utmost vigilance in this regard.

3.3.4. Conflict of Interest Prevention

A conflict of interest arises when an employee’s personal interests—or those of a third party—conflict with the interests of Bizzdesign. In such situations, it may become difficult for the employee to act in the best interest of Bizzdesign.

Employees must therefore avoid any conflict of interest. Each employee is bound by a duty of loyalty to the company and must refrain from engaging in any activity or making any statement that could place them in a conflict of interest. No employee may accept a mission or assignment from a supplier, client, or competitor that could impair their performance or judgment in the execution of their duties. If a conflict of interest arises, or if an employee is faced with a situation that could lead to a conflict of interest, it must be reported via email to compliance@bizzdesign.com.

3.3.5. Intellectual Property Protection

Bizzdesign and its subsidiaries hold numerous intellectual property rights (including copyrights and trademarks) as a software publisher and/or integrator. Professional secrecy and know-how are at the core of our business. These elements are among Bizzdesign’s most valuable assets and must be protected by all. Employees and executives must not represent, reproduce, market, or modify any part of Bizzdesign’s intangible assets except as strictly required for professional purposes. Any use not expressly authorized by Bizzdesign may constitute infringement, unfair competition, or parasitic behavior, subject to civil and criminal penalties.

3.4. Environmental Responsibility

Bizzdesign acknowledges its responsibility to protect the environment and is committed to incorporating environmental considerations into all decisions, operations, and business activities. We work actively to reduce the environmental footprint of our operations, including energy consumption, waste generation, resource use, and the environmental impact of our digital solutions. We support and promote initiatives that contribute to ecological transition, climate change mitigation, and biodiversity preservation. All employees, contractors, suppliers, and business partners are expected to adopt responsible environmental practices, comply with applicable environmental regulations, and support the Group’s collective sustainability efforts.

3.5. Product and Service Security and Reliability

The security and reliability of our products and services are non-negotiable priorities. Our customers trust us with sensitive and often mission-critical data, and they rightfully expect our solutions to be secure, resilient, and fully compliant with the highest standards in cybersecurity and data protection. We design our software in accordance with security by design and privacy by design principles, proactively identifying vulnerabilities, minimizing risk exposure, and safeguarding the confidentiality, integrity, and availability of the data we process. We are committed to complying with all applicable laws and regulations, including the General Data Protection Regulation (GDPR) and relevant local data privacy frameworks, as well as recognized international standards for information security and service continuity. All employees involved in the design, development, delivery, or support of our solutions must follow internal security policies and protocols, report any incidents or anomalies without delay, and actively contribute to the protection of our digital infrastructure. We hold our partners, subcontractors, and technology providers to the same level of responsibility and security rigor.

4. Communication

We are committed to ensuring that all internal and external communications made in the course of our work are truthful, complete, accurate, timely, and easily understandable. Clear and responsible communication is essential to maintaining the trust of our stakeholders, protecting our reputation, and complying with legal and regulatory obligations. When using social media, you must comply with Bizzdesign’s Social Media Policy, which outlines, guidelines and expectations for responsible online behavior.

Use of social media may have adverse consequences for the company and may expose you to disciplinary measures where it causes an objective and demonstrable disruption to Bizzdesign’s legitimate interests.

Accordingly, we must never, under any circumstances:

Make, authorize, or allow the distribution of materially false or misleading information about Bizzdesign;
Engage in conduct that constitutes an abuse of freedom of expression (such as insults, defamation, discriminatory statements, disclosure of confidential information, etc.).

If you have any doubts, please contact Bizzdesign’s Legal Department.

5. Consequences for non-compliance

At Bizzdesign, we consider this Code of Conduct to be one of the most important governance documents of our,organization. It reflects our core values and our commitment to conducting business with integrity, transparency, and accountability.

Violations of this Code of Conduct are taken extremely seriously. Non-compliance — whether intentional or due to negligence — may expose both the individual and the company to significant consequences, including:

Civil and criminal liability, including potential fines or imprisonment,
Severe reputational harm, which can irreversibly damage customer and stakeholder trust,
And disciplinary sanctions, up to and including termination of employment or business relationships, in accordance with the group’s local regulations.

Violations may include, but are not limited to:

Engaging in or facilitating unethical or unlawful behavior,
Failing to report known misconduct or suspicions in good faith,
And, for managers, failing to ensure that employees and contractors under their supervision are informed of and trained on this Code of Conduct.

Every employee, officer, contractor, and partner is personally responsible for understanding this Code of Conduct, applying it in both spirit and letter, and fostering a culture of compliance throughout Bizzdesign’s ecosystem. If you ever have a question, face an ethical dilemma, or witness conduct that may be inconsistent with our commitments, you must speak up. Silence is not an option. Contact the Human Resources team, the DPO or the Bizzdesign Legal Department. We strongly encourage a speak-up culture and will not tolerate retaliation. In case of violation, you will always be given an opportunity to be heard. Fairness, due process, and respect for all individuals are cornerstones of how we enforce this Code of Conduct.

6. Miscellaneous

6.1. Changes

The current version of this Code of Conduct is available to all employees and contractors via the Bizzdesign intranet and website. As a result of our commitment to keep our policies and procedures current, this Code of Conduct may be modified from time to time. Any amendments or a waiver of any provision of this Code of Conduct is promptly disclosed, pursuant to applicable law and regulation.

6.2. Internal use

This Code of Conduct sets forth our fundamental principles and policies with respect to our conduct of Bizzdesign’s affairs. It is not intended to, and does not, create any rights for any associate, customer, supplier, competitor, stockholder, or any other person or entity. This Code of Conduct is intended solely for the internal use by Bizzdesign and does not in any way constitute an admission, by or on behalf of Bizzdesign, as to any fact, circumstance, or legal conclusion.

6.3. Compliance

Compliance with this Code of Conduct is monitored by Human Resources in consultation with the Bizzdesign Legal Department under the supervision of the Corporate Management Team. Compliance processes and procedures are audited by Bizzdesign Finance Department.

7. Contacts

For questions regarding this policy, please contact the Bizzdesign Legal Department at compliance@bizzdesign.com