Code of Business Conduct

This page sets out how the Exclaimer group conducts its business. It describes the standards we apply across our operations worldwide and the commitments we make to our customers, partners and the wider community. 

Exclaimer reserves the right to update this Code at any time.  

Version: April 2026 

Anti-Bribery and Corruption 

We have a zero-tolerance approach to bribery and corruption. We comply with the UK Bribery Act 2010, the US Foreign Corrupt Practices Act and all other applicable anti-corruption legislation. This includes: 

  • Maintaining policies and procedures designed to prevent bribery by any person acting for or on behalf of us. 

  • Prohibiting facilitation payments. 

  • Prohibiting kickbacks, undisclosed rebates and any other form of improper inducement. 

  • Requiring that gifts and hospitality are modest, transparent, properly recorded and never capable of being perceived as influencing a business decision. 

  • Conducting risk-based due diligence on distributors, resellers and other intermediaries, and requiring them to meet anti-bribery standards equivalent to our own. 

Assets and Intellectual Property 

Our assets — including intellectual property, proprietary information, software and physical resources — are used solely for legitimate business purposes. Unauthorised access, copying or distribution is prohibited. Any theft, loss or unauthorised disclosure must be reported immediately. 

Background Checks 

Our staff are subject to background checks appropriate to their role and in accordance with applicable law. As a minimum and where permitted by applicable law, anyone with access to customer data, confidential information or sensitive systems is verified to a standard that meets (or is materially equivalent to) the UK Government’s Baseline Personnel Security Standard (BPSS). 

Conflicts of Interest 

Anyone acting for or on behalf of us is expected to avoid situations where personal interests could conflict, or appear to conflict, with the interests of the company. All actual, potential or perceived conflicts must be disclosed promptly. We do not permit our personnel to take, or redirect to a third party, a business opportunity discovered through the use of our property, information or position. 

Data Privacy 

We collect and process personal data in compliance with the UK GDPR, EU GDPR and all other applicable data protection legislation.  

We apply the principles of lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity and confidentiality. Access to personal and confidential data is restricted to those with a legitimate business need. 

Diversity & Equal Opportunity 

We are committed to equal opportunity in every aspect of employment and actively work to identify and remove barriers and bias. We use structured, skills-based processes in recruitment and career development to reduce the influence of unconscious bias. We make reasonable adjustments to support colleagues with disabilities or health conditions. We monitor remuneration and progression across our workforce to identify and address inconsistencies. We do not tolerate discrimination on any ground protected by applicable law. 

Fair Competition 

We compete on merit. We comply with anti-trust and competition laws where we operate. We do not enter into agreements with competitors concerning pricing, market allocation or any other competitively sensitive matter, and we do not exchange confidential commercial information with them. 

Financial Integrity 

We maintain accurate, complete and timely financial and business records. We do not permit false, misleading or fictitious entries, undisclosed accounts or the misclassification of transactions. We cooperate fully with internal and external auditors. Records subject to a legal hold are preserved in their entirety. 

Health, Safety & Physical Security 

We provide safe and secure working environments.  We implement and monitor appropriate security measures at our premises and conduct risk assessments where appropriate to identify and address potential risks to our people, data and operations.   

Human Rights & Modern Slavery 

We conduct our business with respect for human dignity. Modern slavery, forced labour, child labour and human trafficking have no place in our operations or supply chain. In accordance with the Modern Slavery Act 2015, we publish an annual statement approved by our Board. Our commitments include: 

  • Risk-based due diligence across our supply chain. 

  • Contractual prohibitions on forced and child labour in supplier agreements. 

  • Training for relevant personnel on recognising and reporting indicators of modern slavery. 

  • Reporting channels that are accessible, confidential and free from retaliation. 

We expect all parties in our supply chain to provide clear employment terms, respect freely chosen employment and freedom of association, comply with local requirements on working hours, and to eliminate all forms of discrimination. 

Information Security 

Protecting the data entrusted to us is central to our business. We maintain technical and organisational measures designed to protect data against unauthorised access, modification, loss, destruction or disclosure which are externally certified annually to ISO:27001 standards and undergo annual SOC 2: Type 2 audits.  We operate incident detection and response procedures proportionate to the nature and sensitivity of the data we handle.  Details can be found on our website and within our Trust Centre.  

Insider Dealing 

We require strict compliance with insider dealing and market abuse laws.  

Political and Charitable Activity 

We do not make contributions to political parties, candidates or campaigns.  

Charitable donations made on behalf of us require advance approval, must be directed only to bona fide charitable organisations and must not be linked to any business benefit. 

Raising Concerns 

We expect anyone who becomes aware of actual or suspected misconduct to raise it promptly. We provide multiple reporting channels — including an independently operated, anonymous whistleblowing service available 24/7 — and treat all reports as confidential to the extent reasonably possible.  

Retaliation against anyone who raises a concern in good faith is a serious disciplinary matter. 

Sanctions, Export Controls and Anti-Money Laundering 

We comply with all applicable trade sanctions, export control and anti-money laundering requirements, including those administered by UK OFSI, US OFAC, the European Union and the United Nations Security Council. 

We screen prospective customers, partners and suppliers against applicable sanctions and restricted-party lists before entering into any new relationship. We will not, directly or indirectly: 

  • Conduct business with any individual, entity, country or territory subject to applicable sanctions. 

  • Provide products, services or technical data to parties appearing on relevant sanctions, denied-persons or entity lists, or to parties that are 50% or more owned or controlled by a sanctioned party. 

  • Knowingly facilitate transactions that could involve the proceeds of crime or constitute money laundering. 

Suspected sanctions evasion or money laundering is reported immediately through our internal compliance channels.  We provide both internal and external whistleblowing reporting lines and information about territorial restrictions to customers. 

Sustainability 

We are committed to minimising our environmental impact. We measure and disclose greenhouse gas emissions annually. Where business travel is necessary, we expect sustainable transport choices to be prioritised and unavoidable emissions to be offset through reputable providers. 

Workplace Standards 

We are committed to a working environment that is safe, respectful and free from harassment, discrimination and bullying. We comply with all applicable employment laws and do not tolerate retaliation against anyone who raises a concern in good faith. These standards apply across all work settings, including offices, remote working, client sites, travel and Exclaimer-sponsored events. 

Accountability 

This Code is reviewed at least annually and updated to reflect changes in law, regulation or business circumstances. Breaches may result in disciplinary action, termination of contracts and/or referral to the relevant authorities.