Code of Business Ethics

1Why this code matters

Clients trust Arcsen with their most important systems and data. That trust depends on how each of us behaves. This code sets the standards of conduct for everyone who works for Arcsen, including employees, contractors and directors, in every Arcsen entity. We expect partners, suppliers and anyone acting on our behalf to meet the same standards.

No code can cover every situation. When in doubt, ask yourself whether an action is legal, honest, and something you would be comfortable explaining to a client, to a colleague or in public. If the answer is no, do not do it, and ask for advice.

2Honesty in what we say and sell

• We describe our services, capabilities and experience accurately.
• We only claim the certifications, partner status, awards, references and results that we can support with evidence, and we use client names only where we are allowed to.
• Our proposals, estimates, timesheets, expenses and reports are complete and accurate.
• We keep accurate books and records, and never hide or misdescribe a transaction.

3Anti-bribery and corruption

We have zero tolerance for bribery and corruption. We do not offer, promise, give, request or accept anything of value to influence a decision improperly, whether the other party is a public official or works for a private company. Anything of value includes cash, gifts, entertainment, travel, jobs and internships, donations and sponsorships.

Facilitation payments, meaning small payments to speed up routine government actions, are not allowed.

Before we appoint agents, resellers, consultants or subcontractors who could act for us, we carry out appropriate checks, and we expect them to follow this code.

We comply with the anti-bribery laws of every country where we operate, and with any other anti-bribery laws that apply to our work.

4Gifts and hospitality

Modest gifts and hospitality can support good business relationships. They must be:

• reasonable in value and frequency, and appropriate to the occasion;
• given or received openly, and never in cash or cash equivalents such as vouchers;
• never offered or accepted while a tender, contract award or renewal involving the other party is being decided;
• allowed under the rules of the recipient’s organization, which for public officials are often very strict.

Declare to our compliance team any gift or hospitality that goes beyond the modest and occasional, and ask before you offer anything to a public official.

5Working with the public sector

We work with government entities and on national programmes. When we work with the public sector, we:

• follow procurement rules, and communicate with evaluators only through the channels that the tender allows;
• never seek or use confidential procurement information that we are not entitled to;
• check for conflicts of interest before we hire or engage current or former public officials;
• respect the confidentiality and security requirements of public sector clients.

6Conflicts of interest

A conflict of interest arises when your personal interests could influence your judgement at work, or appear to. Examples include a financial interest in a client, supplier or competitor, a close family member who works for a client or supplier you deal with, and outside work that competes with Arcsen or uses its time or information.

Declare any actual or potential conflict in writing to your manager and to our compliance team, so that it can be managed. Failing to declare a conflict is a breach of this code.

7Fair competition

We compete on the quality and value of our work. We do not agree with competitors on prices, bids, clients, territories or terms, and we do not share competitively sensitive information with them. When we team with other firms on a bid, we agree the scope of our cooperation in writing and share only what the bid needs. We gather market information only from legitimate sources.

8Technology partners and certifications

Our partnerships with Salesforce, Sitecore and other technology vendors depend on our integrity. We:

• follow the rules of each partner programme, including its rules on opportunity registration, licences, demo environments and partner benefits;
• earn certifications honestly, and never share exam content or sit an exam for someone else;
• recommend the products and licences that fit each client’s needs, whatever incentive applies.

9Sanctions and export controls

We comply with the trade sanctions and export control laws that apply to our business. We do not deal with sanctioned individuals or organizations, or in sanctioned territories, in breach of those laws, and we check new clients, suppliers and partners where the risk requires it.

10Confidentiality and personal data

We protect the confidential information of our clients, our partners and Arcsen, and use it only for the purpose for which it was shared. This duty continues after an engagement or employment ends. We handle personal data in line with our Data Privacy Policy, and protect systems and information in line with our Information Security Policy and Code of IT Security.

11Responsible use of AI

We use AI to improve our work and our clients’ work, with people accountable for the outcome. We:

• use only approved AI tools, and use AI on client data only within platforms and settings the client has approved, such as Agentforce in the client’s Salesforce org;
• keep people in control of decisions that affect individuals;
• check AI output for accuracy, bias and security before we rely on it;
• are open with clients about where and how AI is used in the work we deliver.

12Respect at work

We treat everyone with dignity and respect. We do not tolerate harassment, bullying, discrimination or abuse of any kind. We hire, develop and promote people on merit, and we provide a safe and healthy workplace. We respect human rights, and we expect our suppliers to treat their workers fairly and lawfully.

13Communications and social media

Only authorized people speak to the media or publish statements on behalf of Arcsen. Do not share client names, client work or confidential information on social media or elsewhere unless it has been approved for publication. When you post about your work, make it clear that the views are your own.

14Community and environment

We support the communities where we work, and we aim to reduce the environmental impact of our operations, for example through sensible travel and the efficient use of resources.

15Speaking up

If you see or suspect a breach of this code, the law or our policies, speak up. You can raise a concern with your manager, with a member of the leadership team or with our compliance team at compliance@arcsen.com. People outside Arcsen can use the same address. We treat every concern seriously, keep it as confidential as the investigation and the law allow, and look into it fairly.

We do not tolerate retaliation against anyone who raises a concern in good faith or helps with an investigation. Retaliation is itself a serious breach of this code.

16Breaches of this code

Breaking this code may lead to disciplinary action, up to and including termination of employment or contract. Some breaches are also crimes, and we may report them to the authorities.

17Questions and review

Send any questions about this code to compliance@arcsen.com. We review this code at least once a year.