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Code of Conduct

Last updated: 9 March 2025

Introduction and scope

Venti (“we,” “us,” or “our”) is committed to conducting business with integrity, respect, and in compliance with applicable laws. This Code of Conduct sets out the standards of behaviour we expect from our employees, contractors, partners, and anyone acting on our behalf in connection with our platform and services.

This Code applies globally. All of us are responsible for reading, understanding, and following it. Violations may result in disciplinary action, up to and including termination of employment or business relationship, and may be reported to relevant authorities where required by law.

1. Integrity and honesty

We act honestly and fairly in all business dealings. We do not engage in fraud, bribery, corruption, or misrepresentation. We maintain accurate books, records, and communications and report information in good faith to customers, partners, regulators, and other stakeholders where required.

When we provide our autonomous monitoring and automation platform, we do so in a transparent manner: we do not misrepresent the capabilities of our services, the nature of data we process, or the outcomes users can expect. Marketing and sales communications must be accurate and not misleading.

2. Respect and inclusion

We treat everyone with respect and dignity. We do not tolerate discrimination, harassment, bullying, or retaliation on the basis of race, colour, national origin, sex, gender identity, sexual orientation, religion, disability, age, or any other protected characteristic under applicable law.

We support an inclusive and safe work environment and expect the same from our partners and contractors. We comply with human rights and labour standards in the jurisdictions where we operate. We do not use forced or child labour.

3. Compliance and anti-corruption

We comply with all applicable laws and regulations in the countries where we operate, including anti-corruption and anti-bribery laws. We do not offer, give, solicit, or accept bribes or other improper advantages to or from any person—including government officials, customers, or third parties—to obtain or retain business or to secure any improper advantage.

For detailed requirements on gifts, hospitality, third parties, and record-keeping, see our Anti-Corruption Policy.

4. Conflicts of interest

We avoid situations where our personal interests could conflict with, or appear to conflict with, the interests of Venti or our customers. If a conflict of interest arises, we disclose it promptly and take steps to manage or eliminate it in accordance with our internal guidelines. We do not use our position or company resources for personal gain at the expense of Venti or our customers.

5. Confidentiality and data protection

We protect confidential information and personal data. This includes information belonging to Venti, our customers, our partners, and any third parties that we receive in the course of providing our platform and services. We use and disclose such information only for legitimate business purposes, in accordance with our Privacy Policy and applicable data protection laws (including the GDPR and similar legislation).

We do not misuse, sell, or improperly disclose confidential or personal data. We implement appropriate technical and organisational measures to safeguard data and we report breaches where required by law.

6. Fair dealing and competition

We compete fairly and comply with applicable competition and antitrust laws. We do not enter into anti-competitive agreements, abuse a dominant position, or engage in unfair or deceptive practices. We respect the intellectual property and confidential information of others.

7. Reporting and accountability

We encourage anyone who becomes aware of a potential violation of this Code to report it promptly. Reports can be made through the contact channel provided on our platform or in your account. Reports may be made anonymously where permitted by local law and our procedures.

We will investigate reported concerns in good faith and take appropriate corrective action. We do not tolerate retaliation against anyone who reports a concern in good faith or who participates in an investigation. Anyone who retaliates may be subject to disciplinary action.

If you are not comfortable reporting through our usual channel, you may contact a senior manager or use any other reporting mechanism we make available. We are committed to handling reports confidentially to the extent consistent with a thorough investigation and legal obligations.

8. Contact

For questions about this Code of Conduct or to report a concern, contact us through the contact information provided on our platform or in your account. We will respond in accordance with our internal procedures and applicable law.