Code of Ethics
1. Our mission and values
1. This Code of Ethics defines the standards by which we conduct business at Clouds onMars. We require compliance not only from ourselves, but also from our suppliers and business partners.
2. Our core values are:
a. Respect
b. Integrity
c. Responsibility
3. Our practices reflect our desire to have a positive impact on our environment. We maintain high standards to build and protect the trust of our Clients, partners and associates-because we believe it is the right and ethical thing to do.
2. Purpose and scope of the Code
1. This Code forms the foundation of our organizational culture, is based on our values, and serves as a guide for our daily activities.
2. All Clouds on Mars associates, regardless of their position, must comply with this Code. The Code applies to all entities directly or indirectly associated with Clouds on Mars.
3. We also expect third parties, such as suppliers, subcontractors, partners, and consultants, to adhere to the values contained in our Code.
3. Our core values
1. Trust, integrity, and responsibility are the core values that enable us to achieve our mission. We build them by ensuring that our actions are consistent with our values, i.e.:
a. Trust – we build it through honest, transparent, and responsible actions in our relationships with associates , colleagues, partners, third parties, Clients, and government institutions and agencies.
b. We act in an honest and ethical manner. We keep our word, fulfill our commitments, and act in accordance with ethical principles – even when we are under pressure or other actions would be more financially profitable.
c. We take full responsibility for our decisions, the effects of our actions, and the results we achieve.
d. We present our goals and intentions in a clear and transparent manner and encourage others to share their opinions – we are also open to constructive criticism and dialogue.
4. Human rights
1. We promote, respect and fully comply with all applicable human rights laws. We take their protection seriously, which is why we reject all forms of slavery, forced labor, human trafficking, child labor, discrimination and unequal treatment in our own operations and in our supply chain.
2. We ensure fair remuneration and expect the same from our business partners and suppliers. We comply with working time regulations, ensuring that associates have the right to rest. We also ensure safe and hygienic working environment, minimizing the risk of accidents and occupational diseases. In the context of our office and remote work, we also care about the mental well-being of our associates.
3. We strongly reject child labor and exploitation—we do not employ anyone under the age permitted by generally applicable laws, and we require the same from all our suppliers and business partners.
4. We respect the dignity and equality of all people; we believe that every person has the right to be treated with dignity and respect. We do not tolerate any form of discrimination, harassment, intimidation, or humiliation. We create a workplace free from bias based on race, color, gender, age, disability, sexual orientation, gender identity, religion, political views, or origin. We value people solely based on their competence and work attitude. We regard sexual harassment and all forms of gender-based violence as serious violations of human rights and the principles of this Code.
5. Wherever appropriate, we carry out due diligence to identify whether our company may have an impact on human rights – we report any suspicions of forced labor, child labor, or other forms of human rights violations.
5. Our workplace
1. We believe that people are our company’s greatest value. We create a work environment based on respect, trust, safety, and dignity. We respect associates rights. All associates should be fairly paid for their services and treated fairly.
2. Every associate has the right to:
· equal treatment and fair, decent compensation for services provided,
· a safe work environment free from violence and pressure,
· reporting violations without fear of retaliatory action
3. We support international labor standards and require compliance with them from ourselves and everyone working in our supply chain
4. We strive to create a work environment where everyone can do their job to the best of their ability. We create an organizational culture free from discrimination. We respect diversity in views, background, gender, and religion. We do not tolerate bullying or any form of harassment or discrimination. We believe that diverse backgrounds, experiences, and views improve our workplace, enrich our teams, and provide better solutions for our clients.
5. We help our associates develop professionally to increase their commitment, supporting our values and attractiveness as a company. We operate transparently. Every associate has the right to know the criteria for the evaluation of their work and the opportunities for career development within the company. Promotions are based on competence, commitment, and performance.
6. We care about the mental health of our associates —we never come to work under the influence of drugs or alcohol, nor do we start work when our health or medication may pose a safety risk to ourselves or others.
6. Communication rules
1. We are aware that communication is a key element of our business, and the way we communicate impacts our company and our reputation among Partners, Clients and other stakeholders.
2. In our company, it is strictly forbidden to use language that could be considered discriminatory, intimidating, sexually harassing, offensive, bullying, abusive, or otherwise inappropriate. These rules apply to all forms of communication: in person, via email, through messaging apps, during meetings, business visits and company events.
3. When communicating, we treat others with respect, honesty, and dignity. We respond in a professional and calm manner. We provide accurate, clear, and reliable information.
4. We speak to the media on behalf of the company only when we are authorized to do so.
7. Compliance with generally applicable laws
1. We are active in various locations around the world and with entities from different parts of the world.
2. We are committed to complying with generally applicable laws wherever we do business.
3. We maintain honesty, transparency, and openness in our communications with client representatives, authorities, and government officials.
8. Intellectual property protection and software licensing
1. All software that we use in our work is legally obtained. Our company uses only legal software with valid licenses and in accordance with those licenses. We prohibit the installation and use of illegal software on company equipment.
2. We respect the intellectual property rights of all third parties—we only use legal methods to collect information and content. We respect the copyrights of creators, artists, and programmers. We do not copy, distribute, or use other people’s works and creations without the appropriate licenses or permissions.
3. We also care about protecting the intellectual property of our company and our clients. We treat source codes, know-how, innovations, confidential information, and personal data as key resources that are subject to strict protection.
9. Preventing technological fraud
1. We are aware that technology is often used as a tool for fraud. We do not engage in false or misrepresentative business practices, including activities that may mislead clients or consumers, including the Elderly, children, or other individuals with special needs.
2. As a company, we are also committed to actively defending against attempts at fraud, scams and manipulation. We are aware of social engineering attacks and apply the principle of limited trust, approaching with caution any unexpected message (email, SMS, messenger) that calls for urgent action, clicking on a link, or downloading an attachment. We always carefully verify the email addresses of senders. We are aware that cybercriminals may impersonate our superiors, members of the Management Board, business partners, and clients.
3. We also exercise particular care when receiving information about a change in a counterparty’s bank account number or a request to make an “urgent, non-standard transfer.”
4. We never share our passwords, MFA codes, or access tokens with other people—not even associates, colleagues, or supervisors.
5. Everyone in our company is required to work exclusively on their own personal account. Account sharing is strictly prohibited.
6. It is also strictly forbidden to falsify, delete, or modify system logs, operation histories, or database records to conceal errors or unauthorized activities. We treat any attempts to circumvent security systems, software licenses, or control mechanisms as a serious violation.
7. In the event of a suspected incident, all our collaborators are required to report it immediately in accordance with the applicable Procedure.
10. Protection of information, personal data, and privacy
1. We are aware that disclosure of confidential information obtained from our Clients and partners would result in a breach of trust. Protecting information, both our own and that of our Clients and partners, is of utmost importance to us. In practice, this means that we keep all non-public information confidential, regardless of whether it belongs to our company or to our client or partner and supplier. We take all reasonable measures to protect information from unauthorized disclosure, inappropriate use, loss, or theft.
2. We respect the right to personal data protection and the right to privacy and take all appropriate measures to protect personal data, including data entrusted to us. We respect the privacy of our associates , clients, partners, and suppliers. We protect personal data and confidential information with the highest care, using appropriate technical and organizational safeguards.
3. We process personal data in a fair and responsible manner and in accordance with generally applicable data protection laws. We make sure that people who share their personal data with us understand why we use it and what we plan to do with it – to this end, we transparently inform data subjects about the rules and purposes of data processing and their rights.
4. We do not store personal data longer than is necessary to achieve the specific purpose for which it was collected, and we treat it with confidentiality and security.
5. We also support the development of awareness of threats and protection against them, as well as a culture of cybersecurity.
11. Development and implementation of AI-based tools
1. We recognize the enormous potential of Artificial Intelligence in improving work. At the same time, we are aware of the risks associated with this technology. We are committed to using AI in an ethical, safe, and lawful manner, in accordance with values such as integrity, reliability, privacy, security, inclusion, transparency, accountability, and human control.
2. We never enter confidential data, personal data, passwords, API keys, or proprietary source code into public, open AI tools. We are aware that information entered public models may be used to train them and become available to third parties, which would constitute a breach of confidentiality, trade secrets, and GDPR regulations.
3. We only use company-approved AI tools that guarantee the protection of information, including personal data, and do not use it to train public models.
4. We apply the principle that we treat artificial intelligence as a support tool, not a decision-making or executive tool. All people at our Company are fully responsible for the results of work generated with the use of AI. Every code, text, report, image, and analysis generated by AI must be verified by a human being for correctness, logical errors, bias, and security. We do not blindly trust the results generated by algorithms.
5. We operate transparently. If we use AI to a significant extent to create content for our clients, we disclose this when required by contract or good practice.
6. We do not generate content that infringes on the copyrights of third parties. We are aware that the legal status of AI-generated works may vary depending on the jurisdiction, the materials used, and our own work.
7. In our company, it is strictly prohibited to use AI tools to create malicious software (e.g., malware), generate discriminatory content, hatred speech, misinformation, or materials that violate the dignity of others.
12. Our Clients and Partners
1. We build relationships with our clients and partners on the foundations of trust, integrity and professionalism. We are committed to conducting our business in a responsible and ethical manner. We maintain constructive and long-term relationships with partners whose values align with ours.
2. We treat every client and partner with the utmost respect, listening to their needs and providing the highest quality solutions. The success of our clients and partners is our success.
3. We believe that the way we compete is as important as the result. We respect the principles of fair competition – we win with the quality of our services, not with unfair practices or by discrediting our competitors.
4. We believe that antitrust laws protect the market by promoting free and fair competition. We support fair competition and do not engage in anti-competitive behavior—in particular, we avoid any formal or informal agreements with competitors that restrict competition.
5. We also comply with all bidding procedures, without falsifying or determining the results of the proceedings or supporting others in such activities.
13. Appropriate selection of suppliers
1. To achieve our mission, we need suppliers who, like us, perform their work reliably, comply with the law, and are committed to building trust.
2. We recognize that the actions of our suppliers can affect our company’s reputation, so we use reliable, ethical suppliers who are committed to conducting business in an ethical manner.
3. When selecting suppliers to undertake a given task, we carefully analyze their achievements, reputation, and other characteristics—without favoring anyone.
14. Anti-corruption
1. We have a zero-tolerance policy towards bribery and corruption. It is prohibited to offer, promise, give, accept, or request any undue benefits (financial or personal) to influence business decisions or official actions.
2. All transactions must be accurately documented. We do not accept “hidden costs,” unclear commissions, or gifts that could be perceived as an attempt to exert pressure. We only give or accept gifts and gestures of kindness that are appropriate and proportionate within the context of legitimate business relationships. We do not give or accept anything that could lead to a conflict of interest or create the appearance of bribery.
3. We would rather lose a contract than win it unfairly through bribery or other unethical conduct.
4. We also do not make any improper payments.
5. We also maintain ethical relationships with our stakeholders, including suppliers, consultants, and government officials.
6. We hire people solely based on their competence and do not make hiring decisions to benefit a client or official.
7. When we make charitable donations, we do so to support legitimate charitable activities, not as a quid pro quo.
8. We select sponsorship activities that focus on opportunities related to our business and are consistent with our values and sustainability strategy. We approach all sponsorship arrangements in a fair and transparent manner.
15. Anti-Money Laundering and Fraud Prevention
1. We comply with all applicable laws and regulations regarding trade sanctions, embargoes, and anti-money laundering. We record and report our business information completely and accurately. We do not tolerate any form of fraud or false claims and comply with all applicable reporting requirements.
2. We maintain accurate records in accordance with applicable legal requirements, particularly those relating to trade and financial compliance, to ensure the transparency and legality of all transactions. This applies to both financial and non-financial records, such as working hours, test results, and data relating to quality, safety, or environmental impact. We record the full and accurate nature of all financial transactions in accordance with locally accepted accounting principles and do not engage in illegal tax schemes.
3. We only do business with reputable clients, business partners, and suppliers who are engaged in legitimate business activities using funds from legitimate sources. We exercise due diligence to fully identify beneficial owners and verify that transactions do not involve restricted parties, sanctioned entities, or embargoed regions. We review all contacts with state or military entities to ensure compliance with global trade regulations. We never engage in business transactions if we suspect that they are being carried out using funds derived from illegal activities or in violation of regulations.
16. Conflict of Interest Management
1. A conflict of interest occurs when there is a conflict between our personal interests and our duties to our company or our clients and partners.
2. We understand that even an apparent conflict of interest can be harmful, so we avoid situations that may cause a conflict or create the appearance of a conflict of interest. We avoid or withdraw from situations where personal relationships or involvement in another company may influence our decision-making at work. When conflicts of interest arise, we disclose them.
3. Before taking on work for another company, as associates of Clouds on Mars, we ensure that the other work will not harm the business activities of Clouds on Mars, our Partners, or our Clients, nor will it violate the terms of our agreements.
17. Corporate social responsibility and the environment
1. We are part of a wider community and feel responsible for them. We conduct our business in a responsible and balanced manner.
2. We actively participate in activities to protect our planet. We strive to minimize our carbon footprint, promote digital document exchange, energy-efficient solutions, waste sorting, and waste minimization. We support initiatives that contribute to environmental protection. Where appropriate, we conduct due diligence to identify our company’s impact on the environment, both within our own operations and within the supply chain. We ensure that we present our efforts to reduce our negative impact on the environment honestly.
3. We are involved in charitable and social activities. We promote volunteering by supporting initiatives that help those in need.
18. Ethics in Action
1. Our approach to ethics is based on clear communication, openness, prevention, detection, and response. We build a culture of awareness through regular training and clear communication of our principles and values. Any associate who observes a violation of this Code has the obligation and right to report it.
2. We guarantee the safety of those who report violations. No report made in good faith will result in any negative consequences.
19. Reporting violations and take-back actions
1. Any questions or concerns regarding the provisions of this Code should be reported immediately using the reporting platform available at: https://cloudsonmars.gowhistle.com.
2. The Company encourages all associates to submit reports and inquiries related to this Code and does not tolerate any form of retaliation or reprisal against any person who has reported a potential violation of this Code in good faith.
3. Associates who observe violations or actions that violate this Code are required to report them immediately using the reporting platform available at: https://cloudsonmars.gowhistle.com.
20. Non-compliance with the Code – consequences
1. Any violation of the rules set forth in this Code or failure to report activities that violate the provisions of this Code may be subject to criminal proceedings, may result in termination of agreement, and may lead to external investigations, civil proceedings, or the filing of a criminal complaint.
21. Code reviews and updates
1. The Code must be reviewed at least once a year by the Integrated Management System Representative to ensure that it remains up to date and relevant.
2. In the event of changes to laws, regulations, or incidents, the Code must be reviewed as soon as possible.
3. Changes to the Code must be documented.
