CodeTwo
Business Ethics

Code of Business Ethics

Published: October 29, 2025

Since day one, CodeTwo sp. z o. o. sp. k. ("CodeTwo" or simply "we") adheres to a simple yet fundamental principle: we strive to do things in the best possible way – both professionally and ethically. We believe that the success of our company is not defined solely by financial results, but above all by how we achieved those results: through honest, responsible, and transparent actions that reflect our core values.

We are committed to equality, respect, and responsibility. We do not tolerate discrimination, mobbing, corruption, or any form of abuse. CodeTwo is also socially engaged and encourages others to get involved as well. We want to be a company that each of us, every CodeTwo Employee, can be proud of – not only because of what we create as a software company, but also because of the values we embody.

This Code of Business Ethics ("Code") should not serve as a strict rulebook, but as guidebook that helps us make the right decisions – whether it’s about teamwork, interactions with Customers, relationships with Business Partners, or our impact on the environment. It’s a collection of the values and Principles that have been the foundation of our organizational culture for years, and which we aim to uphold as we continue to grow.

The Code does not replace the specific procedures and policies within our organization, which apply to all Employees. CodeTwo has a number of internal regulations in place that clearly define rules of conduct on anti-corruption, personal data protection, information security, and many other areas. The Code serves as a common framework that brings these regulations together and is accessible to everyone.

This document is addressed primarily to the entire CodeTwo team. However, we also encourage our Customers, Contractors, Business Partners – as well as anyone interested in our organizational culture and the way we work – to become familiar with the Code. We believe that transparency and shared values are the foundation of lasting business relationships. The Code sets out what can be expected from us and what we expect from one another.

Our Principles

The shared Principles adopted at CodeTwo are the foundation of our organizational culture. They shape the way we work, make decisions, and build relationships – both between our Employees and with our Customers and Business Partners. CodeTwo is not a company focused on obtaining maximum profit at any cost. We aim to achieve financial success while remaining true to the following Principles:

Respect and honesty

We treat others the same way we expect to be treated – with respect, openness, and honesty. We build trust through transparency and accountability.

Top quality and professionalism

We deliver IT solutions we are proud of. We pay attention to every detail and always strive to ensure our work meets the highest professional standards.

Accuracy and attention to details

We believe that quality lies in the details. We see diligence and precision not only as technical requirements, but also a sign of respect for our Customers and end users.

Continuous development

We are constantly learning through one another, from end users of our software, and from the environment in which we operate. Personal and professional growth is an integral part of our daily work.

100% commitment

We work with full commitment, regardless of the task. We believe that we can achieve exceptional results only by putting our hearts into what we do.

Ambition

We set ambitious goals and are not afraid of challenges. We strive to become better as a team, a company, and as people.

Effective communication

We communicate clearly, concisely, and respectfully. Good communication is the foundation of effective collaboration and a healthy workplace atmosphere.

Teamwork and common goal

We’re all on the same team. We support one another and believe that the best results are achieved together, as a team, not individually.

Creativity, innovation, and every opinion matters

We value fresh ideas and outside-the-box thinking. Every Employee’s voice counts, no matter their role or experience.

Procedures and their automation

We value well-designed processes and strive to automate them wherever possible. This allows us to focus on what truly matters and helps our Employees grow.

Getting things done

What matters to us is the effective execution of assigned tasks and projects. We act efficiently, responsibly, and with determination, so that we can see real results.

Rules of workplace ethics

We foster a work environment built on mutual respect, safety, and personal growth. We believe that we can achieve the best results, both individually and as a team, only in an atmosphere of trust and openness. The following ethical rules and procedures help us build such a culture:

Prevention of mobbing and discrimination

Mobbing (workplace bullying) refers to persistent and long-term harassment or intimidation that may lead to reduced self-esteem, social isolation, or deterioration of the targeted person’s health.

By discrimination we mean, in particular, unequal treatment of individuals based on gender, age, origin, sexual orientation, disability, beliefs, or any other characteristic unrelated to job performance.

At CodeTwo, we treat everyone equally and with respect. We do not tolerate any form of mobbing or discrimination. Our goal is to ensure a safe, supportive, and fair working environment.

We have adopted the Anti-Mobbing and Anti-Discrimination Policy, which sets out in detail the rules for preventing and responding to such undesirable behaviors. As part of our preventive measures, we conduct training sessions and awareness campaigns. We also monitor the work environment by nurturing healthy relationships between managers or team leaders and their teams, conducting regular Employee evaluations, and providing constructive feedback. By staying in close contact with Employees, we can identify potential issues and undesirable behaviors.

Any instances of mobbing or discrimination may be reported in accordance with the procedure set out in the Anti-mobbing and Anti-Discrimination Policy. Reports may be submitted by either the person directly affected or by a witness. The person making the report is assured confidentiality and protection against any retaliation.

Any investigation arising from a report is carried out by a committee which, depending on the nature of the case, may also include external experts (e.g., a psychologist). If misconduct is confirmed, we will take remedial action and hold the perpetrator accountable in accordance with applicable law.

Safety and well-being

We strive to make CodeTwo a friendly workplace, supporting both mental and physical well-being. We comply with occupational health and safety regulations, provide ergonomic workspace, and support wellness initiatives. CodeTwo Employees have access to private healthcare and membership cards for sports facilities.

We understand that well-being at work means more than just the absence of hazards. It’s also about comfort and a sense of purpose in what we do. That is why we promote a culture of mutual support, openness, and empathy.

Diversity

At CodeTwo, we believe that diverse workplace creates opportunities. We support a work environment where everyone, regardless of gender, religion, sexual orientation, or any other personal characteristic, feels respected, safe, and valued.

The entire CodeTwo team operates in Poland, a country that is relatively homogeneous in terms of ethnicity and culture. For this reason, we do not actively collect statistics on the participation of minorities in our workforce.

Nevertheless, we make every effort to ensure that each person, regardless of their background or identity, feels at home with us.

We apply the same principles of equal treatment and respect externally, especially in our interactions with Business Partners, our relationships with Customers, and throughout our recruitment processes. Regardless of who we are speaking to or working with, we are guided by the same values and expect the same from others.

Rules of business conduct

We build our business relationships on trust, transparency, and responsibility. Our goal is not only to deliver top-quality solutions but also to act with integrity, whether we are working with Customers, Business Partners, Contractors, or public institutions.

Fair competition

We believe that fair competition is the foundation of a well-functioning market. That is why we operate in a transparent and reliable manner, both in our communication with Customers and in our interactions with competitors.

The offers we present to Customers are clear and reflect the actual features of our products. We do not make promises we cannot keep. We make sure that our Customers’ decisions to trust us are based on complete and accurate information.

Anti-corruption

We define corruption primarily as the promise, offer, giving, solicitation, or acceptance of any undue financial or personal benefit in exchange for obtaining, directly or indirectly, any advantage for oneself or another person.

At CodeTwo, we firmly oppose and strive to eliminate the risk of corruption in our relations with both the public and private sectors. By applying an equal opportunity policy, we also strictly prohibit any form of so-called internal corruption (that is, using one’s employment or position for undue personal gain or for the benefit of others). To counter all forms of corruption, we have implemented the Anti-corruption Code that applies to every Employee, from interns to senior management. Additionally, to prevent situations that may pose a risk of corrupt behavior or create any ambiguity about our conduct, we have also introduced the following detailed procedures:

• CSR Budget Support Guidelines – which define the rules and acceptable purposes for donations made from CodeTwo’s CSR budget;
• Transaction Procedure; and
• Policy on Marketing Activities – which regulates, among other things, the rules for giving gifts to Business Partners and carrying out sponsorship activities.

Every new CodeTwo Employee undergoes mandatory anti-corruption training, which must then be periodically renewed.

Preventing conflicts of interest

A conflict of interest can take many forms. It may arise, in particular, when the personal interest of a CodeTwo Employee or a person related to them conflicts with the interests of our company. A conflict of interest also includes situations where a person holds multiple roles (within or outside CodeTwo) that create a conflict of duties, or makes decisions in matters where they or their close relatives stand to benefit.

CodeTwo has adopted the Conflict of Interest Prevention Policy, which describes in detail potential conflict-of-interest situations, ways to avoid them, and the procedures for handling such cases.

Any Employee who suspects that they are, or may be, in a conflict-of-interest situation must immediately inform the designated persons at CodeTwo and refrain from taking any further action until the situation is resolved.

Respect for intellectual property

As software developers, we fully understand the value of intellectual property and the effort involved in creating it. We ensure that all software and other intellectual assets we use are utilized solely under valid licenses and within their permitted scope. We expect the same from all Employees in the performance of their duties.

Ethical supply chain and modern slavery

Modern slavery refers to practices such as forced labor, human trafficking, child labor, and employment under conditions that violate human dignity. This phenomenon is particularly dangerous in global supply chains, where remote suppliers may be located in regions with a heightened risk of modern slavery (such as certain countries in Africa and the Middle East).

At CodeTwo, we condemn all forms of modern slavery. We do not engage in forced labor or employ minors. We do not accept exploitative labor practices or unpaid work, including work disguised as contests or unpaid internships. Overtime work is permitted only within the limits and under the conditions provided by law. We ensure that all working relationships with CodeTwo comply with the highest ethical and legal standards, in line with both domestic and international regulations.

Moreover, due to the nature of our business (software development) and our location (all our Employees are based in Poland), CodeTwo does not import goods or services from regions particularly affected by modern slavery.

We support initiatives aimed at eliminating modern slavery from the global economy. We are always ready to cooperate with our Contractors and Business Partners to identify and eliminate risks of deriving direct or indirect benefits from forced labor.

We believe that lasting and responsible business relationships are built on shared values. Therefore, we expect our Business Partners to adhere to the same standards we require of ourselves, especially – but not limited to – those concerning employment conditions and respect for human rights. One of the conditions for entering into cooperation with CodeTwo is that our Business Partners review and accept this Code.

Legal compliance

Compliance principles are of fundamental importance to us. We strive to fully comply with Polish and international law, local regulations in all countries where we operate, and industry best practices. Below are just some of the many areas in which we fulfill our legal obligations.

Personal data protection

In our daily operations, CodeTwo processes personal data belonging to both our Employees and, in many cases, our Customers, Contractors, Business Partners and their representatives. We understand the responsibility this entails, especially at a time of increasing cybersecurity threats. That is why we regularly test our systems to ensure the effectiveness of their security safeguards.

Compliance with the requirements of the GDPR (General Data Protection Regulation) is of utmost importance to us. To achieve this, we have implemented a number of detailed procedures, including the Personal Data Security Policy, the Procedure for Handling Requests and Exercising the Rights of Data Subjects, and the Information Security Incident Management Procedure.

All Employees with access to personal data are required to familiarize themselves with and comply with the data handling procedures in force at CodeTwo. An Employee may begin working with personal data only after completing internal training, which is then repeated periodically.

We ensure that we have an appropriate legal basis for processing personal data in every case where this is required. Any third party to whom we entrust the processing of personal data may do so only after entering into an appropriate data processing agreement with us. In the case of data transfers outside the European Economic Area, we implement additional safeguards in accordance with the GDPR requirements.

The quality of our data management system is evidenced by our ISO certifications: ISO/IEC 27001 and ISO/IEC 27018. These attest to the high standards we maintain in information security and in protecting personal data stored in the cloud. We received these certifications following a thorough assessment of our procedures by authorized accreditation bodies. The certifications remain subject to annual audits.

We are also proud that our product, CodeTwo Email Signatures 365, has received the Microsoft 365 Certified designation from Microsoft for all its components – the core application, its cloud infrastructure, and the Outlook add-in. It was the first and only email signature management solution ever to receive this designation in 2022, when the certification program was launched. This certification was awarded following an in-depth security review of our cloud service by Microsoft – the world’s largest software company – which included penetration testing of the entire infrastructure. This certification is subject to annual renewal.

Whistleblowing

The Whistleblower Protection Act in Poland requires large organizations to implement procedures that enable the secure reporting of legal violations and to protect individuals who make such reports.

We meet these obligations through the implementation of the Procedure for Reporting and Investigating Legal Violations at CodeTwo. Anyone who suspects that they have encountered a legal violation within our organization may report it in a secure and confidential manner. Our procedure ensures the protection of whistleblowers’ identities, safeguards them from retaliation, and guarantees a fair and impartial investigation of every report.

Taxes and financial reporting

CodeTwo is a Polish company and fully complies with all its tax obligations to the State Treasury. We believe that accurate and transparent tax reporting is not only a legal duty but also a reflection of our social responsibility.

We maintain accurate and legally compliant accounting and financial reporting. In accordance with applicable regulations, our financial statements for each fiscal year are published in the publicly accessible online Repository of Financial Documents, maintained by the Ministry of Justice. Additionally, due to the scale of our operations, these statements have for many years been subject to mandatory annual audits by independent auditing firms, which assess their accuracy and compliance with applicable laws.

Furthermore, under the Transaction Procedure we have implemented, we conduct due diligence on our Contractors involved in our transactions to ensure compliance with VAT and WHT requirements. As a matter of policy, we do not make purchases from so-called tax havens or sanctioned countries or territories, as regulated in CodeTwo’s MDR Procedure (concerning reportable tax arrangements). We also do not sell our products to countries or territories subject to sanctions.

Corporate Social Responsibility (CSR)

At CodeTwo, we believe that business should not only generate profit but also have a real impact on the world, by acting in a positive, responsible, and empathetic way. For us, CSR is not just a slogan but a set of tangible actions we take out of the conviction that it is worth doing more than what is merely “required” from a business perspective.

Charitable activities

We are committed to supporting children in need of costly medical treatment. We regularly make financial contributions to fundraising campaigns hosted on siepomaga.pl, one of the largest and most transparent charitable online platforms in Poland. We are fully transparent about this activity – anyone can review the history of our donations by visiting our profile on the platform: www.siepomaga.pl/codetwo.

We believe that even modest support can make a significant difference, especially when it concerns the health and lives of children. This is why we consider charitable giving an integral part of our identity.

Educational activities

Our social engagement goes beyond financial support. We also strive to share knowledge and raise public awareness in a way that is accessible, modern, and engaging.

To this end, we primarily use our channels on YouTube, Facebook, LinkedIn, and Instagram: HRejterzy, czyli CodeTwo po godzinach (HRejterzy or CodeTwo after hours), hosted by CodeTwo’s CEO, Szymon Szczęśniak. Although these channels are primarily entertainment-oriented, we also leverage their reach (over one million subscribers in total) for educational purposes.

Through the HRejterzy channels, we regularly publish content related to cybersecurity and the responsible use of technology, environmental protection, mental health, and other socially important topics. All materials are available here: hrejterzy.com (in Polish and primarily intended for a Polish-speaking audience, as these channels support our ESG initiatives focused on our immediate community).

Environmental protection and sustainable development

As a software company, we are not involved in manufacturing or transportation, so our direct impact on the environment is limited. However, that does not mean we are indifferent to environmental issues – quite the opposite.

We actively participate in educational and community initiatives focused on nature conservation, particularly in the region of Poland we originate from – Lower Silesia and the Giant Mountains (Karkonosze). We help raise awareness of illegal waste dumping, support local environmental initiatives, and strive to promote environmental awareness among our Employees.

We believe that sustainable development is a shared responsibility for all of us, regardless of industry we operate or the scale of our business.

Final provisions

We believe that ethical conduct is not a matter of declarations but, above all, of everyday decisions. Our intention is for this Code to remain a living document – current, evolving, responsive to contemporary challenges, and a true reflection of our actions. To this end, we outline below the key principles regarding its application, accessibility, and ongoing updates.

Language version

The Code is available in three language versions: Polish, English, and German. The Polish and English versions are equally authoritative. The German version is provided for convenience only.

Document availability

The Code is publicly available on the CodeTwo website and is also directly accessible to our Employees and Contractors via the appropriate internal platform.

Scope of applicability of the Code

The Code applies to all Employees and Contractors of CodeTwo, regardless of the form of employment or basis of cooperation, as well as to our Business Partners.

Each person covered by this Code is required to familiarize themselves with its contents and comply with the principles set out herein.

Updates

The Code is subject to periodic review to ensure it remains current and relevant. Amendments may be introduced, in particular, in response to legal, organizational, social, or technological developments. After any amendments are made, the updated version of the Code will be published on the CodeTwo website, communicated internally, and will require acceptance of the updated Code by all our Employees, Contractors and Business Partners.

Relationship with other policies

The Code does not replace other internal policies or regulations applicable to CodeTwo Employees.

Support and reporting violations

In case of any doubts or questions regarding the interpretation of the provisions of this Code, or upon identifying or suspecting a violation thereof, any person can contact us at the following email address:  .

Our Employees may also report violations in accordance with the principles described in the Procedure for Reporting Irregularities at CodeTwo.

Entry into force

The Code takes effect on the date of its publication.

Any future amendments will likewise take effect on the date of their publication.