Code of CONDUCT
This Code of Conduct applies to all employees of Cuseum. In this sense, “employees” includes all employees, members of management, temporary workers and freelancers. The Cuseum AcquiCo Inc (also “Cuseum”, “company” and “we”) means Cuseum and all subsidiaries in which those companies hold the majority of shares.
I. Our Corporate Responsibilities
At Cuseum, we not only abide by the law, we also practice a culture of integrity. We follow the principles that are essential for society as a whole.
1. Quality
We work to the highest principles of quality, adhere to all applicable legal requirements, technical rules and regulations, and comply with all applicable approval processes.
2. Human Rights
We are committed to respecting and promoting the human rights of our employees and persons with whom we have business relationships. We acknowledge the Universal Declaration of Human Rights and the core labour standards of the International Labour Organization (ILO), which include the elimination of forced or compulsory labour, the effective abolition of child labour, the elimination of discrimination in respect of employment and occupation, and the freedom of association and the right to collective bargaining.
3. Equal Opportunities and Respect
We believe that we work better because of our differences, not despite them. We therefore have respect and appreciation for each other. We show openness to people from different countries and cultures. Discrimination on the grounds of nationality, citizenship, pregnancy or parenthood, marital status, sexual orientation, skin colour, gender, disability, veteran status, religion or belief, age, race, social/ethnic origin, political opinions, or any other legally protected reasons is not accepted.
4. Health and Safety at Work
We promote and maintain a safe, healthy and secure work environment. We comply with the applicable regulations and take all necessary measures to prevent workplace accidents, occupational diseases and work-related health risks.
5. Environmental and Social Aspects
We are aware of our responsibility to the environment and society. We seek to conduct our operations safely, continuously reduce the environmental impact of our business activities and make an active contribution to environmental and climate protection and the conservation of natural resources.
We are committed to responsible sourcing practices and expect our suppliers to uphold similar standards regarding human rights, environmental protection and labour conditions.
We integrate environmental, social and governance factors into our decision-making process. We believe that sustainable and responsible business practices create long-term value and minimize risk for all stakeholders.
6. Data Protection and IT Security
We respect the privacy of our employees, customers, suppliers and business partners and their right to have their personal data protected. As a company involved in providing software services for cultural institutions, we have a great responsibility regarding the handling of data entrusted to us.
We protect all personal data by complying with the applicable provisions and requirements under data protection law. In particular, we are committed to the basic principles of data protection, including lawfulness, fairness and transparency, purpose limitation, data minimization, accuracy, storage limitations, integrity and confidentiality, and the accountability of the person processing the data.
We also ensure data security by taking all appropriate measures in relation to the confidentiality, integrity and availability of information stored. In particular, Cuseum has implemented appropriate technical and organizational measures to prevent the data from unauthorized access, misappropriation or loss. This also includes the data of our customers, business partners and employees.
As a digital business, we face evolving cybersecurity threats, including phishing, ransomware, social engineering and zero-day exploits. All employees must remain vigilant and we encourage employees to report suspicious activity to the supervisor.
7. Responsible Use of Technology
As a technology-driven organization, we are committed to ensuring that our products and platforms are developed securely and responsibly.
We apply secure development practices and regularly review our systems for vulnerabilities. Our use of artificial intelligence and data-driven systems is guided by ethical principles, including fairness, accountability, transparency, and non-discrimination.
8. Protecting Property and Confidential Information
Our property – both tangible and intellectual – serves a specific company purpose. Unless private use is explicitly permitted, company property must only be used for business purposes. It must be treated properly and protected from loss or damage.
In the course of work, we will have access to and deal with confidential information. This may include technical and financial data, business strategies and other information which can also relate to customers, suppliers and business partners. Unless you know that specific information has been released for publication, please always assume it is confidential. Confidential information may not be disclosed, and necessary steps have to be taken to prevent disclosure.
II. Our Commitment to Fair Competition
Our customers, business partners and the entire market must have confidence that we do business in a responsible way. Natural market mechanisms help create the best products and services for customers; We therefore do our part to maintain fair and balanced competition.
1. Preventing Corruption
We do not tolerate any kind of corruption or fraud. Business relations may not be exploited for personal or third-party benefit. We do not influence or distort competition through corrupt payments or other corrupt conduct.
Employees are not permitted, under any circumstances, to accept, demand, offer or grant benefits in exchange for undue influence on business decisions. Benefits, such as gifts and entertainment, may only be offered and accepted to a moderate and customary degree. We do not offer any kind of benefits to authorities or public officials. We do not offer any benefits to any public official in order to speed up the process of bureaucratic procedures.
2. Conflicts of Interest
We always act in the interests of Cuseum and avoid potential conflicts of interest. Conflicts of interest may arise when our personal relationships or financial interests overlap with our job responsibilities. This may include, for example, financial, family or close ties of friendship with competitors, customers, service providers, suppliers or other business partners. In case of a potential conflict of interest, employees must inform their superior, the Compliance Office or the Management team. We will then discuss what appropriate action Cuseum will take. Any secondary employment has to be approved by the employee’s superior.
3. Donations, Sponsorships and Charity Work
Donations may only made to selected organizations and causes in a transparent way pursuant to our internal guidelines. The same applies to sponsorships and charity work. We do not give donations or provide sponsorships that may harm Cuseum’s reputation.
4. Antitrust and Competition Laws
We are committed to fair and open competition. We expect all employees to conduct their activities on behalf of Cuseum in a manner consistent with applicable antitrust and competition laws. Agreements of any kind with competitors on prices, terms and conditions of business, market allocation and non-competition are not permitted. The principles of fair competition must also be adhered to in all dealings with business partners. This includes not only written agreements, but also informal talks, informal arrangements or the exchange of information aimed at or causing any restraints of competition.
5. Intellectual Property
We respect the intellectual property of our customers, business partners and other third parties. This includes all patents, copyrights, trademarks and know-how. Any unauthorized use must be avoided.
We value open-source innovation and ensure the responsible use of open-source software. All use must comply with applicable license terms.
6. Non-Public Information and Financial Records
We maintain the trust of our investors and the public by respecting financial laws and the confidentiality of non-public information. Non-public information is information that we become aware of in the course of our business activity which would influence investment decisions. This also includes non-public information relating to other companies of which we become aware in the course of work.
No employee may disclose any non-public information without due authorization. Employees may not use any non-public information for private purposes.
If you are unsure whether certain information qualifies as “non-public information”, please contact the Compliance Office or the Management team before taking any action.
We also recognize the importance of market transparency and acknowledge that accurate and reliable financial and business records are of critical importance for all companies.
We comply with all legal provisions on proper accounting and financial reporting.
7. Trade, Sanctions and Anti-Money-Laundering
As an international operating company, we comply with all applicable trade regulations and sanctions regimes, including those issued by the European Union and other relevant jurisdictions.
This includes financial, trade and travel sanctions, as well as embargos on specific countries, individuals, organizations and sectors. Employees must immediately report any suspicion that a transaction or partner may be subject to sanctions to the Compliance Office or the Management team. Violations of sanctions laws can lead to severe legal, financial and reputational consequences.
We may only accept money from legal sources. Any indications of money laundering, such as unusual payment methods or escrow accounts or a general lack of clarity, must be reported to the Compliance Office or the Management team.
8. Selecting Business Partners
Since dealing with our customers and business partners is also a part of our identity as a company, we build our business relationships based on the high ethical standards we set for ourselves.
We expect our business partners to follow the same high ethical principles of conduct that we follow at Cuseum and to comply with all applicable laws.
We select our business partners carefully and on the basis of objective criteria. In particular, we ensure that any remuneration is proportionate to the service provided.
III. Our Speak-Up Culture
This Code of Conduct is an important element of the Cuseum compliance system. We rely on the support of all our employees to implement the system effectively. We are committed to maintaining an environment in which everybody feels free to raise their concerns. We encourage our employees to be alert, observant and to express concerns if they suspect that the applicable law, this Code of Conduct or internal policies have been or will be violated. Such concerns can be addressed to superiors, the Compliance Office or the Management team.
IV. Publication and Accessibility
This Code of Conduct is available on our intranet and company website. New employees are required to review and acknowledge it upon onboarding. Updates are communicated company-wide.