Code of Corporate Ethics and Compliance —
Our Shared Commitment

We believe that compliance and ethical behavior are everyone’s responsibility. This means we must hold ourselves —and one another—accountable to our values and to creating an open and inclusive workplace. Seaberry Technologies’s leadership encourages employees to proactively seek out issues, speak up.
The Compliance department drives compliant company performance, encourages integrity and transparency, and demonstrates our commitment to compliant and ethical business practices. Seaberry Technologies’s Chief Compliance Officer works closely with the Board of Directors, senior company leaders, our employees, and external stakeholders to advance Seaberry Technologies’s compliance and ethics culture throughout the company.
Every employee takes part in company-wide compliance training that provides real-world examples of compliance issues and consequences and emphasizes that living our values and conducting business with integrity are critical to the company's success.

Code of Corporate Ethics and Compliance — Our Shared Commitment

We believe that compliance and ethical behavior are everyone’s responsibility. This means we must hold ourselves—and one another—accountable to our values and to creating an open and inclusive workplace. Seaberry Technologies’s leadership encourages employees to proactively seek out issues, speak up.

The Compliance department drives compliant company performance, encourages integrity and transparency, and demonstrates our commitment to compliant and ethical business practices. Seaberry Technologies’s Chief Compliance Officer works closely with the Board of Directors, senior company leaders, our employees, and external stakeholders to advance Seaberry Technologies’s compliance and ethics culture throughout the company.

Every employee takes part in company-wide compliance training that provides real-world examples of compliance issues and consequences and emphasizes that living our values and conducting business with integrity are critical to the company's success.

Contacting the Ethics and Compliance Service

Seaberry Technologies encourages employees to promptly raise concerns about safety, quality, potential violations of the law, or Seaberry Technologies policy. Seaberry Technologies also works to foster an environment in which employees feel safe seeking guidance, raising concerns, and identifying areas for improvement. Seaberry Technologies understands that speaking up is not always easy, and the company offers several options for confidentially reporting concerns, including bypassing management or anonymously, using the feedback form  or email: complianсe@seаberrytech.com. Any retaliation against employees who raise a concern is not tolerated.

The Seaberry Technologies Compliance Hotline operates during business hours in Serbia and is available to Seaberry Technologies employees and contractors or other persons.

Anti-Corruption Policy

Our employees design, develop, and support software that touches and impacts the lives of people around the world. That's why we're committed to doing business and operating with integrity at all times. At Seaberry Technologies, we don't tolerate corruption or bribery, and we strive to create a culture that promotes openness, trust, and accountability.

Seaberry Technologies strictly prohibits bribery and corruption of any kind. It is imperative that we compete only on our merits. Integrity is a core value of the company, and in support of this, Seaberry Technologies publishes an internal policy that includes anti-bribery and corruption requirements and expectations applicable to employees and other stakeholders. Seaberry Technologies also provides employees and other stakeholders with detailed procedures to ensure compliance with anti-corruption requirements. Seaberry Technologies requires employees to undergo annual training related to ethics and compliance.

Compliance

Seaberry Technologies is committed to ensuring compliance with applicable global laws and regulations, as well as our own internal policies and procedures. To maintain effective compliance risk management strategies and controls consistent with our deep compliance culture, Seaberry Technologies builds compliance accountability, oversight, and risk management into all levels of the business.

Seaberry Technologies regularly assesses the effectiveness of internal compliance controls, including policies and procedures, training, data analytics and control validation. Managers and executives are accountable for compliance within the business or functional areas they oversee and, along with all employees, receive annual training on compliance risk areas specific to their work responsibilities. This includes training on a range of compliance topics (e.g. proper handling of confidential or trade secret information, data privacy and cyber security, combating corruption and commercial bribery, procurement and competitive procedures rules and organization). Compliance training is regularly reviewed and updated to ensure it remains relevant, up-to-date and effective.

Under Seaberry Technologies’s Compliance Risk Management program, senior leaders are accountable for identifying, assessing, and managing effective compliance programs. The Chief Compliance Officer is responsible for creating a proactive compliance culture, integrating compliance risk management across the enterprise, and implementing effective and efficient compliance controls to achieve business objectives. Chief Compliance Officer reports at least annually to the Board of Directors on Compliance Risk Management and provides regular reporting on the company's ethics and compliance program.
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