Code of Conduct

Introduction. Our Code of Conduct reflects our values and establishes the ethical standards that all our employees, partners, and suppliers are expected to uphold. The Code of Conduct guides our actions, decisions, and interactions ensuring that we build trust and operate with integrity and accountability at every level.

Human rights. We uphold and respect all internationally recognised human rights of every individual and prohibit the use of any forced, compulsory, or child labour by or for UpCloud.

Equal opportunity. We are committed to maintaining a workplace free from discrimination. We value diversity and we treat each other equally and with respect, regardless of gender, ethnicity, nationality, sexual orientation, family relationships, religion, political or trade union activity, age, disability, or any other personal characteristics.

Employee wellbeing. We believe that employee wellbeing is the foundation of a thriving company. We are committed to offering resources for maintaining a work environment that supports both physical and mental health. We do not tolerate sexual, physical or psychological harassment or any form of abuse or workplace bullying.

Environmental commitment. Together with our customers and suppliers we seek to minimise our ecological footprint and emissions, and we encourage sustainable behaviour in our partnerships. UpCloud’s commitments on environmental and sustainability matters are set out in our Environmental Policy.

Safeguarding privacy. We take the protection of personal data and privacy seriously. We respect the privacy of our employees, customers, and partners, and are committed to processing all personal data in compliance with the applicable data protection laws.

Conflicts of interest. We value our employees’ private lives and do not seek to interfere with personal relationships. At the same time we need to ensure that personal interests, associations or relationships, which may conflict with our organisational goals, do not affect our decision-making or activities. To meet this requirement, we communicate openly about all actual, potential, or perceived conflicts of interest and expect everyone to disclose them promptly. Conflicts are addressed with relevant parties and must be notified through the UpCloud whistleblowing channel to find a solution together.

Anti-bribery and corruption. We strictly prohibit any form of bribery or corruption, whether offering, giving, receiving, or soliciting anything of value intended to improperly influence business decisions. Our commitment extends to all interactions, whether with public officials, customers, suppliers, or third parties.

Respecting IP rights. We value innovation and respect and protect intellectual property rights, both our own and those of others.

Compliance and fair business practices. We adhere to the applicable laws and regulations and commit to dealing fairly with our suppliers, competitors, and employees. We do not engage in actions that could unfairly restrict competition, such as price-fixing, market allocation, or bid- rigging. Our employees, suppliers and partners are expected to safeguard confidential information and refrain from sharing it to any unauthorised parties in any media.

Violation of this Code of Conduct or law. Violating this Code of Conduct or any applicable law may lead to disciplinary or legal actions, including potential termination of employment or business relationship. We encourage reporting any suspected violations through our whistleblowing channel.