Code of Conduct

Capitalized terms used in this Code that are not otherwise defined shall have the meanings assigned to them in the Terms of Service. 

When accessing the Platform and using the Services, the User shall at all times act in good faith and in compliance with the present Code of Conduct (“Code”).

This Code forms an integral part of the Partner Terms, Terms of Service and applies to the Partner, Customer, including their Affiliates, employees, agents, and end users (“User”). By accessing or using the Services, the User agrees to comply with this Code.

1. Legal and Ethical Obligations

The User shall comply with all applicable local, national, and international laws and regulations. In particular, the User commits to comply with laws governing human rights and labor, health and safety standards, environmental protection, prevention of corruption, public procurement, fair competition, taxation, and the accurate communication of financial information.

2. Prohibition of Unlawful Payments

The User shall not engage in bribery, corruption, money laundering, or other unlawful financial practices. The User agrees to comply with applicable anti-corruption laws and frameworks.

3. Gifts and Hospitality

The User shall not offer or accept gifts or hospitality directly or indirectly to, Provider, or to any other User that might be prohibited under the applicable laws and regulations. Any form of gratuity, present, amenity, or entertainment must be of modest, symbolic value, occasional, and transparent. 

4. Conflicts of Interest

The User must avoid situations where its personal or organizational interests conflict with the fair use of the Services. The User undertakes to identify and mitigate any actual or perceived conflicts of interest when using the Provider’s platform.

5. Sanctions and Export Control Compliance

5.1. The User declares and warrants that neither the User nor any of its Affiliates, parent companies, subsidiaries, directors, officers, employees, agents, or beneficial owners ("Related Parties"):

   5.1.1. is listed on any government-issued sanctions or restricted parties list (including, but not limited to, the U.S. OFAC SDN List, EU Consolidated Sanctions List, or UN Sanctions List);

   5.1.2. is located in, incorporated in, or ordinarily resident in a country or region subject to comprehensive international sanctions or embargoes (including, without limitation, North Korea, Iran, Syria, Cuba, or the Crimea/Donetsk/Luhansk regions);

   5.1.3 is directly or indirectly affiliated with, or provides material support to, any terrorist organization, violent extremist group, criminal enterprise, or regime engaged in systematic repression or human rights abuses.

5.2. The User must comply with all applicable trade and financial sanctions imposed by Sanctions Authorities including the UN, EU, UK, U.S., or other applicable regimes. 

6. Competition and Procurement Integrity

The User shall not engage in anti-competitive conduct including, but not limited to, price fixing, market sharing, collusion, bid rigging, or the exchange of commercially sensitive information in violation of competition law. 

7. Reporting and Enforcement

The User agrees to comply with this Code. In case of breach or in the event of a change in status or sanctions designation (a “Sanctions Event”), the User shall notify Provider without undue delay. Provider reserves the right to suspend or terminate Services in connection with any Sanctions Event. User shall indemnify and hold Provider harmless from any resulting loss, including reasonable legal costs. 

8. Amendments

Provider may amend this Code from time to time to reflect legal changes or internal policy updates. The current version is always accessible via link in the Terms of Service. Continued use of the Services constitutes acceptance of the updated Code.