Smartly.io Corporate Social Responsibility

 

Smartly.io Customer and Vendor Code of Conduct

This Customer and Vendor Code of Conduct and our company values represent the standards by which we require our Customers and Vendors to operate.

Compliance with the law.  At a bare minimum, we require and expect that all of our Customer and Vendor business, labor and financial practices comply with all applicable laws. This includes all applicable international, national, and local laws, rules, and regulations. 

Human Rights, Fairness, and Equal Opportunity. We believe in inclusion and diversity.  We engage only with Customers and Vendors who demonstrate this same commitment. We do business only with Customers and Vendors that adequately uphold and protect human rights.  Customers and Vendors are required to provide fair working conditions, prohibit the use of human trafficking in their operations and prohibit the use of any other type of forced, compulsory, or child labor, and ensure that their own suppliers and vendors do the same.  Vendors and Customers must provide a work environment free from any form of discrimination, harassment, and intimidation and equal opportunity in all aspects of hiring and employment. Our Customers and Vendors will not tolerate discrimination, harassment, violence, or threatening behavior of any kind, and will be committed to treating their workforce and others with respect and dignity.

Honesty and Integrity. We seek to work with Customers and Vendors who are open, transparent, and honest. It is expected that all Customers and Vendors honor their commitments and communicate with us, our employees, their own employees and suppliers in an honest and unambiguous way, and to avoid making any misstatements of fact, making misleading or exaggerated communications, or creating false impressions. 

Ethical Behavior. All Customers and Vendors must comply with all applicable anti-corruption, anti-bribery and anti-money laundering laws, rules and regulations.  No Customer or Vendor shall make or accept bribes to advance our business or their own. A bribe is something of value that is offered or given to improperly influence a decision. Bribes often consist of money, but they could also be disguised as gifts, trips, entertainment, charitable donations, favors, or jobs. Customers and Vendors shall not offer or give anything of value for an improper or corrupt purpose, whether in dealings with a government official or the private sector, and regardless of the norms of local custom. 

Whistleblowing.  Our Customers and Vendors shall provide a reporting mechanism for their employees and partners to raise workplace or ethical concerns without fear of retaliation. Customers and Vendors shall not retaliate against whistleblowers.

Privacy and Data Protection.  We expect our Customers and Vendors to fully and adequately protect personal data and confidential information. All Customers and Vendors must adopt and maintain processes to provide reasonable protections for personal, proprietary and confidential information that are in full compliance with all applicable laws, rules and regulations.

Environmental Sustainability.  We are committed to doing our part to protect the environment.  We seek to work with Customers and Vendors who share this commitment.  Customers and Vendors must comply with all applicable environmental laws and shall obtain and maintain any and all required environmental permits, approvals and registrations.  Customers and Vendors shall  comply with any applicable environmental operational and/or reporting requirements. We strive to work with Customers and Vendors who make efficient and thoughtful use of natural resources. 

Corporate Social Responsibility. We believe in giving back.  We strive to do business with Customers and Vendors that actively maintain corporate social responsibility programs that give back to their communities, promote social justice, as well as protect and preserve the environment. 

Smartly.io Code of Conduct

Code of Conduct. This Code of Conduct and our company values represent the standards by which we all must operate. All employees of Smartly.io Solutions Oy (“Smartly.io) or any subsidiary of Smartly.io (collectively, “Smartly.io”), as well as Smartly.io’s officers and Board members, must abide by this Code of Conduct. Smartly.io’s contractors, consultants, suppliers, and agents must abide by our Code of Conduct in connection with their work for Smartly.io.

We operate with honesty and integrity. We are open, transparent, and honest. We keep our commitments to each other, to our customers, and to our partners. We endeavor to communicate with our customers, partners, fellow employees, and suppliers in an honest and unambiguous way, and to avoid making any misstatements of fact, making misleading or exaggerated communications, or creating false impressions. We may make mistakes, but we quickly admit and correct them.

We treat others fairly and respectfully. We foster a respectful work environment free from any form of discrimination, harassment, and intimidation. We provide equal opportunity in all aspects of employment. We do not tolerate discrimination, harassment, violence, or threatening behavior of any kind. We treat everyone—fellow employees, customers, partners, and other stakeholders—with dignity and respect.

We uphold human rights. We respect human rights, provide fair working conditions, and prohibit the use of any forced, compulsory, or child labor by or for Smartly.io.

We are responsible and law abiding. We follow the law. This includes all applicable international, national, and local laws, rules, and regulations. We report wrongdoing, including fraud or illegal acts, if we encounter it.

We prohibit bribery. Smartly.io’s policy against bribery is clear—we never make or accept bribes to advance our business. A bribe is something of value that is offered or given to improperly influence a decision. Bribes often consist of money, but they could also be disguised as gifts, trips, entertainment, charitable donations, favors, or jobs. We do not offer or give anything of value for an improper or corrupt purpose, whether in dealings with a government official or the private sector, and regardless of the norms of local custom. For more information, please consult Smartly.io’s Anti-Bribery Policy, which we are all required to review and follow.

We avoid conflicts of interest. We have a responsibility to make sound business decisions strictly on the basis of Smartly.io’s best interests without regard to our personal interests. A conflict of interest can occur when our personal activities, investments, or associations compromise our judgment or ability to act in the best interest of Smartly.io. We avoid conflicts of interest, or even the appearance of a conflict of interest. We always disclose any relationships, associations, or activities that may create actual, potential, or perceived conflicts of interest to Smartly.io’s General Counsel as soon as we become aware of any potential for such conflict.

We respect corporate opportunities. We may not take for ourselves opportunities that are discovered through the use of Smartly.io property, information, or position, and we will not use Smartly.io property, information, or position for personal gain, or compete with Smartly.io in any manner. We owe Smartly.io a duty to advance its legitimate business interests when business opportunities arise.

We prohibit insider trading. Legislations prohibit both trading on the basis of material nonpublic information and “tipping” others by providing material non-public information to them. Material non-public information is information that has not been released to the public and which a reasonable investor would find useful in determining whether to buy or sell stock, e.g., financial results, sales results, acquisitions, customer wins or losses, or changes in senior management. We do not buy or sell stocks on the basis of material non-public information, or pass such information to any others, including friends or family.

We protect confidential information and employee privacy. We are committed to protecting the confidential, proprietary, and private information of our employees, customers, partners, and others with whom we do business. We respect and protect the private information and intellectual property entrusted to us by our fellow employees, customers, and third parties, using it only for legitimate business purposes and in accordance with all applicable laws and governing contracts. We are all also responsible for protecting Smartly.io’s and our customers’ confidential information. The loss of confidential information can be extremely damaging to Smartly.io. We do not disclose any confidential Smartly.io or customer information without a valid business purpose and proper authorization by our Legal Team. Our obligations in this respect continue even if our employment or other relationship with Smartly.io ends.

We are committed to a safe and healthy workplace. We are committed to providing a clean, safe, healthy, secure, and drug-free workplace. Our employees have responsibility for maintaining a safe and healthy workplace by following safety and health rules and practices and by reporting accidents, injuries and unsafe conditions, procedures, or behaviors. We do not tolerate violence and threatening behavior. We prohibit the use, possession, sale, or being under the influence of any illegal substance at Smartly.io or when representing Smartly.io in any capacity or conducting Smartly.io business.

We maintain accurate and complete business and financial records. We create and maintain financial records in accordance with applicable legal requirements and generally accepted accounting practices. Our reports, disclosures, and other public communications must be full, fair, accurate, timely, and understandable. Although financial reporting and controls are especially applicable to members of Smartly.io’s Finance team, we are each responsible for complying with all financial controls and policies.

We use social media wisely. We use social media appropriately and responsibly. We do not disclose confidential Smartly.io information or the confidential information of our customers, suppliers, business partners, or other employees.

We deal fairly. We endeavor to deal fairly with our customers, suppliers, competitors, and employees. We should not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation, or any other unfair-dealing. We are prohibited to collude with a competitor. When interacting with a competitor, questions about whether our actions are proper and in compliance with the law should be directed to our General Counsel.

We protect and properly use Smartly.io assets. Theft, carelessness, and waste have a direct impact on our profitability. We use Smartly.io assets for legitimate business purposes, and in particular, will use Smartly.io’s information systems assets in a responsible manner.

We respect the environment. We conduct our business in an environmentally responsible and sustainable manner, and we are committed to complying with all applicable environmental laws.

Waivers of the Code of Conduct. Waivers of our Code of Conduct must be approved in writing. Waivers for Board members and executive officers require Board approval and must be disclosed as required, while waivers involving any other employee, agent, or contractor require the approval of our General Counsel.

Violations of the Code, Smartly.io Policies, or the Law. Anyone who violates the law, our Code of Conduct, or other Smartly.io policies or procedures may be disciplined, including termination of employment and/or his or her business relationship with Smartly.io, in accordance with local legal requirements. Certain violations of this Code of Conduct may be violations of the law, which may result in civil or criminal penalties, and Smartly.io will cooperate fully with the appropriate authorities in these situations.

We use common sense and ask questions if necessary. We use common sense in our business dealings and in upholding this Code of Conduct. If we have any questions regarding the matters discussed in this Code of Conduct, we promptly contact our manager or our General Counsel for answers.

Reporting Suspected Non-Compliance. If we witness, or even suspect, a violation of this policy or the law, we promptly report it.

No Retaliation. Smartly.io takes its non-retaliatory culture very seriously and will not allow anyone to take adverse action, threaten, intimidate, or retaliate if one of us reports a violation or suspected violation in good faith, or cooperates in an investigation. Smartly.io considers Smartly.io Solutions Oy Code of Conduct 4 1.4.2019 retaliation itself a violation of this Code of Conduct and will respond accordingly.

How to Report Suspected Non-Compliance

Smartly.io has established a Compliance Committee comprised of the General Counsel, the Head of People & Learning and the Chief Financial Officer. All violations or suspected violations of this policy should be promptly reported to the Compliance Committee.

If you are not comfortable reporting it to any of those people, then you should make your report directly to the Legal Department or the Smartly.io Ethics & Compliance Hotline either online at www.smartly.ethicspoint.com or at the numbers on the website for your location.

Reports made on the Ethics Hotline or on the portal may be made on a confidential and anonymous basis. If you make an anonymous report, please provide as much detail as possible, including copies of documents you believe relevant to the matter.

Hotline numbers are also listed below for ease of reference. If you do not see your location listed below, please go directly to the website above to locate the reporting hotline number.

United States: 1-844-476-9146

Argentina:
Argentina (Telecom) 0 800 555 4288
Argentina(Telefonica) 0-800-222-1288
Then at the English prompt dial 844-476-9146

Australia
Australia (Optus) 1-800-551-155
Australia (Telesta) 1-800-881-011
Then at the English prompt dial 844-476-9146

Brazil
Brazil (cellular) 0-800-888-8288
Brazil 0-800-890-0288
Then at the English prompt dial 844-476-9146

Finland
0-800-11-0015
Then at the English prompt dial 844-476-9146

France
France (France Telecom) 0-800-99-0011
France (Paris only) 0-800-99-0111
France 0-800-99-1111 or 0-800-99-1211 France (Telecom Development) 0805-701-288
Then at the English prompt dial 844-476-9146

Germany
0-800-225-5288
Then at the English prompt dial 844-476-9146

Ireland
Ireland (UIFN) 00-800-222-55288
Ireland 1-800-550-000
Then at the English prompt dial 844-476-9146

Japan
Japan (NTT) 0034-811-001
Japan (KDDI) 00-539-111
Japan (Softbank Telecom) 00-663-5111
Then at the English prompt dial 844-476-9146.

Netherlands
0800-022-9111
Then at the English prompt dial 844-476-9146.

Singapore
Singapore (StarHub) 800-001-0001
Singapore (SingTel) 800-011-1111
Then at the English prompt dial 844-476-9146.

Spain
900-99-0011
Then at the English prompt dial 844-476-9146.

United Arab Emirates
8000-021 United Arab Emirates(du) 8000-555-66
Then at the English prompt dial 844-476-9146.

United Kingdom
0-800-89-0011
Then at the English prompt dial 844-476-9146.

Smartly.io Group Modern Slavery Statement

This statement is a Group statement made by Smartly.io Solutions OY, as the ultimate parent company, on behalf of the companies in the Smartly.io group of companies and is made pursuant to s.54(1) of the Modern Slavery Act 2015. It sets out the steps that Smartly.io has taken and will continue to take to ensure that modern slavery or human trafficking is prevented in our business and in our supply chain on a Group basis. This Statement covers all Smartly.io companies including those operating in the United Kingdom who are required by the Modern Slavery Act 2015 to publish a statement and those operating in Australia, Smartly.io Solutions Pty Ltd, ACN: 626 909 671, whose registered office is Level 11, 1 Margaret Street, Sydney, NSW 2000, and who is covered by the Modern Slavery Act (2018) (Cth) and including, but not limited to, Smartly.io Solutions Oy.

Smartly.io is committed to understanding potential modern slavery risks related to our business and ensuring that there is no modern slavery in our own business and supply chains. We do not condone modern slavery in any form and Smartly.io and the companies in the group, fully endorse and comply with the principles set out in the Modern Slavery Act 2015 and all applicable laws in the countries in which it operates.

Our business

Smartly.io is a privately held company  headquartered at Elielinaukio 2 G, FI-0100 Helsinki, Finland. It has offices in Argentina, Australia, Brazil, France, Germany, Ireland, Japan, Netherlands, Singapore, Spain, UAE and USA, and has over 400 employees.

Smartly.io offers online advertising and marketing services through its automated digital advertising platform. The platform offers marketing solutions for creative and performance marketers, across a range of social media websites including Facebook, Pinterest and Snapchat. The solutions offered include Dynamic Ads, Automated Ads and Automated Post Boosting. Smartly.io also provides tools to enable the management of online marketing campaigns and the customisable reporting of performance.

Our policies

We have a range of corporate policies such as our Anti-bribery and Corruption Compliance Policy and Culture Handbook, that guide the way our employees work. We are committed to responsible operations in our economic, social and environmental activities and our codes of conduct [https://www.smartly.io/corporate-social-responsibility] reflect our corporate responsibility by establishing a set of common standards we expect our employees, as well as our suppliers, customers and vendors, to maintain.

Our Code of Conduct, which applies to all employees as well as contractors, consultants, suppliers, and agents in connection with their work for Smartly.io, states that we respect and uphold human rights, follow all applicable laws, prohibit bribery, protect confidentiality, respect the environment, deal fairly with others and maintain a safe, healthy and discrimination-free workplace at all times.

Our Customer and Vendor Code of Conduct states that we require all of our customers and vendors to operate within the law, adhering to high standards regarding human rights, fairness and equal opportunity, to act ethically, responsibly and in accordance with environmental sustainability, and to protect whistleblowers. We will only engage customers and vendors who are able to demonstrate their shared commitment to these values.

As our employees, suppliers, customers and vendors must abide by our codes of conduct, this ensures that they act with integrity, in accordance with applicable legislation, our core values and company policies. It also provides our investors, customers and suppliers with information about these principles according to which we operate and expect our suppliers to operate. This is consistent with our Social Mission Statement, which underlines our commitment to promote trust, equality, diversity, accountability, and learning through our work and company practices.

Our interaction with suppliers

In light of where we do business, where our suppliers are based, including but not limited to, Finland, Germany, United Kingdom and the United States, and the industry in which we operate, our assessment is that there is a low-moderate risk that modern slavery and human trafficking exists in our supply chain that would affect our business.  

We purchase professional services, IT equipment, cloud computing, technology services,  and office materials, among other things, from third party suppliers and strive to conduct business with third party suppliers who share our commitment to high ethical standards and who operate in a responsible and ethical manner towards their workers and suppliers, in line with our codes of conduct. We choose our suppliers with care and their integrity and ethical business practices form part of the selection criteria and we will monitor our suppliers to assure ourselves that they remain in line with our requirements and our ethical standards. Our suppliers are generally part of a global network and therefore, each of our local offices partners with the same global suppliers. Our arrangements with suppliers tend to be structured as longer-term relationships.

Should we become aware of any policy violations or issues related to slavery or human trafficking, we will consult with our Legal Team and/or Compliance Committee to ensure that appropriate measures are taken, which may include reporting this information to authorities and terminating our relationship with the supplier.

The approach within Smartly.io

Smartly.io is dedicated to ensuring that human rights are respected at all times. We expect our employees to maintain the highest ethical standards and comply with all applicable laws and company policies. Our Code of Conduct embodies our requirements.

Smartly.io encourages its team members to report any suspected wrongdoing or dangers in relation to any activity that falls short of our Code of Conduct.  By encouraging a culture of openness and accountability within Smartly.io, we believe that it can help prevent illegal or unethical practices from occurring. Our culture is designed to make it easy for our team members to ask questions and make disclosures without fear of retaliation.

Risk assessment

Considering our business consists of predominantly professionally qualified and highly skilled people and the lengths of our supply chains are relatively short, we assess the risk of modern slavery within our business and supply chain to be low-moderate. However, we are committed to preventing slavery in all of our corporate activities and we will work in order to ensure that our supply chains are free from slavery and forced or compulsory labour.  

Smartly.io takes the following actions to address risks of modern slavery:

  • requesting information from direct suppliers about sub-suppliers (including country of origin);
  • engaging with key suppliers to understand their business and how they address their own modern slavery risks;
  • assigning responsibility for assessing and addressing modern slavery risks to a senior manager;
  • bringing together key areas such as legal, operations, security, human resources and senior leadership to help assess and respond to risks.

Performance indicators and measuring effectiveness

We accept that effective action to prevent modern slavery and human trafficking in our business and supply chain requires constant monitoring and an effective response should issues be identified. We are evaluating measures that can provide us with meaningful information on the efficiency of our anti-slavery stance. 

Smartly.io has processes in place to assess the effectiveness of its actions including:

  • checking risk assessment processes to ensure they are up to date;
  • tracking actions taken and measuring their impact;
  • setting up processes to provide engagement and feedback between different business areas such as operations, security, human resources and legal.

Our management will continue to take a zero-tolerance approach to modern slavery and human trafficking and will react accordingly to any transgression whether by our staff or by our suppliers.

A progressive approach to modern slavery

Smartly.io recognises that the risks from modern slavery and human trafficking are constantly evolving. We also recognise that efficient methods to identify and address modern slavery and human trafficking will be developed and enhanced. Smartly.io will continue to monitor and evaluate such developments and our approach to preventing modern slavery will be reviewed annually so that we can constantly adapt and improve our approach.

Training

Smartly.io is adjusting its employee orientation and annual training to address those aspects of modern slavery and human trafficking that are relevant to them and the way they work.

Approval

This statement is made for the financial year ending December 31, 2020. The Statement has been approved by the Board of Directors of Smartly.io Solutions Oy on 21 December 2020 and was signed on its behalf by Kristo Ovaska who is the CEO of Smartly.io Solutions OY and a Director of the Board.