Ethics Policy

Ethics Policy

Authorized By: Head of People

Purpose/Overview

The purpose of this policy is to establish a culture of openness, trust, and to emphasize the employee’s and consumer’s expectation to be treated with fair business practices. This policy serves to guide business behavior to ensure ethical conduct and prevent Insider Threats. Effective ethics is a team effort involving the participation and support of every Safire employee.

Safire, Inc. is committed to protecting employees, partners, vendors, and the company from illegal or damaging actions by individuals, either knowingly or unknowingly. When Safire addresses issues proactively and uses correct judgment, it helps set us apart from competitors.

Scope

This policy applies to company employees, contractors, consultants, temporary workers, and other workers, including all personnel affiliated with third parties.

Policy

Executive Commitment to Ethics

• Standard of Conduct: Senior leaders and executives are expected to exemplify the highest standards of ethical conduct. Integrity and transparency must serve as the foundation for all business practices.
• Open Door: Leadership must maintain a consistent open-door policy. Executives empower employees to voice concerns and share feedback without fear of retaliation.
• Disclosure: Executives must disclose any conflict of interest regarding their position within the organization.

Employee Commitment to Ethics

• Professionalism: All employees are expected to conduct themselves with fairness, mutual respect, and professionalism. Fostering a collaborative team environment and avoiding behavior that may be perceived as unethical is essential.
• Conflicts of Interest: Employees are required to proactively disclose any actual or potential conflicts of interest related to their role within Safire.
• Self-Reflection: Employees should consider the following questions when behavior is questionable:
• Is the behavior legal?
• Does the behavior comply with all appropriate Safire policies?
• Does the behavior reflect Safire values and culture?
• Could the behavior adversely affect Safire investors or other stakeholders?
• Would you feel personally concerned if the behavior appeared in a news headline?

Reporting and Whistleblower Protection

• Reporting Mechanism: Any employee who witnesses a violation of this policy, suspected fraud, or potential Insider Threat activity must report it immediately.

• Channels: Reports may be made to the Head of People, the Compliance Officer, or anonymously via a hotline/inbox.

• Non-Retaliation: Safire strictly prohibits retaliation against any employee who reports a concern in good faith.

Unethical Behavior

Safire is committed to avoiding both the intent and appearance of unethical practices. The following are strictly prohibited:

• Harassment or discrimination of any kind.
• Insider Threat Activity: Unauthorized use, exfiltration, or modification of company trade secrets, marketing data, operational data, personnel records, financial data, or source code.
• Using corporate assets or business relationships for personal use or gain.
• Any illegal activity or impropriety.

Maintaining Ethical Practices

• Tone at the Top: Safire will reinforce the importance of integrity. Every employee, manager, and director is expected to consistently uphold high ethical standards.
• Training : Employees are required to acknowledge and recertify their compliance with the Ethics Policy annually.

Compliance

Compliance Measurement

The policy owner will verify compliance through methods such as business tool reports, annual policy acknowledgement tracking, and internal audits. Oversight is provided by CISO, IT, and Compliance functions. Enforcement of this policy is coordinated through Human Resources and Executive Management. (Note: For security-related ethics violations, the CISO retains the authority to restrict system access pending investigation).

Exceptions

Any exceptions must be approved by the Policy Owner in advance.

Non-Compliance

An employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment.

Related Standards, Policies, Plans, and Procedures

• Acceptable Use Policy
• Non-Discrimination Policy

Revision History

2026-08-20 — Darren Rush

Merge pull request #2 from safire-dev/dev (16cb681)

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