Corporate Ethics Policy

Corporate Ethics Policy

This Policy serves Natterbox (“the Company”) as our ethical commitment and as a guide to proper business conduct for all of our stakeholders. We are committed to doing business legally, ethically and in a transparent manner.

This document applies to all staff who work for the Company (including officers, directors, managers, team leaders, employees, temporary, agency, interim, sub-contractor or consultant staff).  All staff are expected to adhere to this Policy in their professional conduct, and to treat everyone with respect, honesty and fairness.

The Company is open to any questions at any time and will not allow punishment or retaliation against anyone for reporting misconduct in good faith. The company encourages candid feedback and has a whistleblowing policy.

Managers and leaders have a higher responsibility for demonstrating the importance of this Policy. Managers and leaders are responsible for promptly addressing every raised ethical question or concern. Employees must cooperate in investigations of potential or alleged misconduct.

This ethical policy is openly communicated to stakeholders and we encourage our partners and suppliers to  apply this or similar ethical codes to their own activities and those of their supply chain.

Ethical Values

Compliance with Laws and Regulations

Environmental Sustainability

Human Rights & Fair Labour Practices

Diversity and Inclusion

Anti-bribery

Anti-Fraud

Document Control

Document Approval

Ethical Values

Our core values are Passion, Agile, Customer Centric, Team & Trust.  Staff are encouraged to understand and embrace these values in all they do, and in their interactions with colleagues, prospects, customers, partners and suppliers.

Compliance with Laws and Regulations

Our commitment to integrity begins with complying with laws, rules and regulations. We understand and comply with the legal requirements and commercial practices of lawful business. We are committed to adhere to every valid and binding contractual agreement that we conclude, and we do not abuse our rights.

Environmental Sustainability

We are committed to meeting the needs of the present without compromising the ability of future generations to meet their needs. We aim to understand and reduce where possible negative impact on the environment from our operations.

Natterbox aims to do this by:

• Remote first working, reducing unnecessary travel;

• Providing a safe and healthful workplace;

• Cultivating an environmentally sustainable aware culture, where responsibility is assigned and understood;

• Being an environmentally responsible neighbour in our community;

• Conserving natural resources by reusing and recycling;

• Using, in our own operations, processes that do not adversely affect the environment;

• Ensuring the responsible use of energy throughout the organisation;

• Participating in efforts to improve environmental protection and understanding;

• Taking steps to improve environmental performance continually;

• Working with suppliers who promote sound environmental practises;

• Commitment to sustainable transport including battery electric vehicles wherever possible;

• Employees are encouraged to travel in environmentally conscious ways;

• Enhancing awareness among our employees, volunteers, and users – educating and motivating them to act in an environmentally responsible manner.

• Using AWS - their scale allows them to achieve higher resource utilisation and energy efficiency than the typical on-premises data centre.

Human Rights & Fair Labour Practices

We are committed to respect human dignity and rights of each individual and community whom we interact with during the course of work.  We shall not, in any way, cause or contribute to the violation of human rights. Our staff shall treat everybody with dignity, respect and care and uphold human rights.

As an IT software company, the Company does not have a manual worker, retail or manufacturing supply chain. However, the Company has incorporated a modern slavery question into our supplier review process to ensure to the best of our ability that slavery and trafficking is not taking place in our supply chain.

The Company has a zero-tolerance approach to slavery and trafficking. It does not have a duty to report under the Modern Slavery Act due to turnover being less than £36m.

Diversity and Inclusion

We are committed to creating an inclusive workplace for all our employees, customers and suppliers.  We believe that our workforce should reflect the vast diversity of the world we live in and that diverse voices should be elevated and intentionally integrated into our work.  We embrace difference and diversity of identity, experience and thought, and actively strive for inclusivity across our workforce.  By promoting these values, we aim to create a positive experience that encourages a sense of belonging.

Anti-bribery

The Company prohibits employees or associated persons from offering, promising, giving, soliciting or accepting any bribe. The bribe might be cash, a gift or other inducement to, or from, any person or company, whether a public or government official, official of a state-controlled industry, political party or a private person or company, regardless of whether the employee or associated person is situated in the UK or overseas. The bribe might be made to ensure that a person or company improperly performs duties or functions (for example, by not acting impartially or in good faith or in accordance with their position of trust) to gain any commercial, contractual or regulatory advantage for the Company in either obtaining or maintaining Company business, or to gain any personal advantage, financial or otherwise, for the individual or anyone connected with the individual.

This prohibition also applies to indirect contributions, payments or gifts made in any manner as an inducement or reward for improper performance, for example through consultants, contractors or subcontractors, agents or sub-agents, sponsors or sub-sponsors, joint-venture partners, advisors, customers, suppliers or other third parties.

Any breach of this policy will result in disciplinary action up to and including dismissal. Where consultants or sub-contractors are involved their contracts will be terminated with immediate effect.

Anti-Fraud

Fraud – the act or intent to cheat, steal, deceive or lie – is both unethical and, in most cases, criminal. Fraud in every form, (including e.g. submitting false expense reports; forging or altering financial documents or certifications; misappropriation of assets or misusing company property; making any untrue financial or non-financial entry on records or statements) is prohibited.

Document Control

Document Approval