Code of Ethics

1. Introduction

• Mission
• Vision
• Why is the code of ethics so important?
• Message from the CEO

2. Values: Guiding principles

• Act courageously
• Be curious
• Feed your passions
• Promote diversity and inclusion
• Choose and Communicate
• Innovate

3. Actions

• Taking care of the team
• Taking care of our community
• Taking care of partners and investors
• Taking care of the world

4. Violation of the code – disciplinary measures

• How to raise a concern

1. Introduction

• Mission

Contents.com’s mission is to transform the content creation market by harnessing the power of the most advanced artificial intelligence technologies combined with human creative power.

The human-in-the-loop concept is our leit-motiv: we put people’s knowledge and experience at the center of machine learning processes to communicate better, globally, and enable businesses to achieve more.

• Vision

We want an inclusive world where there are no communication barriers.

Contents.com aims to become the benchmark for all those companies that want to learn how to express themselves better, communicate more powerfully and be heard more effectively.

• Why is the code of ethics important?

In order to realize this mission the code of ethics has always been our foundation.

What is it

The code of ethics is the fundamental charter of moral rights and duties that defines the ethical and social responsibility of each member of the Contents organization.

It constitutes an effective means of preventing irresponsible or possibly unlawful conduct by those who operate in the name of the company because it introduces a clear and explicit definition of the responsibilities of each company operator.

Its addressees are required to strictly and fully comply with the values and principles contained therein and are required to protect and preserve, through their own conduct, the respectability and image of Contents, as well as the integrity of its economic, social and human assets.

Through the code of ethics, Contents plans to:

• define and explain the values and general ethical principles that inform its business activities and the relationships with customers, suppliers, partners, employees, collaborators, administrators, public institutions and any other subject involved in the company’s activity;
• formalize the commitment to behave on the basis of the ethical principles of moral legitimacy, fairness and equality, protection of the individual, diligence, transparency, honesty confidentiality and impartiality;
• indicate to its employees, collaborators and directors the principles of behavior, values and responsibilities which it requires them to comply with in the performance of their duties.

What is it made for

The code of ethics is our foundation. It helps to empower everyone who works at Contents to understand the responsibilities we have. It explains some of the rules we must abide by. While it does not cover every situation you may face in your daily work, the code of ethics should be your first stop when you face an unclear or difficult decision.

All the recipients of this code of ethics are required to observe its contents and inspiring principles within the scope of their specific functions, attributions and activities.

Each recipient of this code is expressly required to be familiar with its contents, to actively contribute to its implementation and to report any shortcomings or violations.

Contents commits to:

• ensure the diffusion of the Code of Ethics among employees and external collaborators;
• provide any possible clarification regarding the interpretation and implementation of the rules of the Code of Ethics
• verify all reports of violations of the rules of the Code of Ethics and, in case of violation, to adopt the appropriate sanctioning measures;
• adopt all the security measures required by technological developments and to ensure that the physical integrity and moral personality of employees are

Contents also guarantees protection and safety in the workplace for its own personnel and for third parties, committing itself to the respect of the legislation on safety at work and to promote the safety of all the places that constitute the working environment.

• Letter/ Message from our CEO

Integrity is important. It matters to our customers, partners, colleagues and communities. And it matters to me.

We are a company of passionate and curious people. It is one of the reasons we have thrived in an industry characterized by change.

In order to build a successful company, we must all aim to maintain a correct, cooperative and respectful behaviour in relation with others. This is a commitment that must guide our behaviour more than just complying with laws and regulations, inspiring us to make the right choice when faced with any situation.

The Code cannot provide definitive answers to all questions, so we expect that everyone uses reasonable judgment to determine if an action course is consistent or not with our ethical standards, and to ask for advice in case of doubt.

This Code of Ethics contains the principles that guide us. Each of us must know them, understand them and apply them in our daily work, regardless of function or company level.

Each of us must bring the Contents.com Code of Ethics to life. Integrity is not an optional extra; it defines who we are.

Massimiliano

2. Values: Guiding principles

Our values are the guiding principles of Contents: embodying who we are and what we want to achieve.
Our principles are foundational:
The code of ethics is built on these foundational pillars, which are beliefs that we hold deeply and represent what we stand for.
Here, the drivers of our daily actions..

• Act courageously

We are not afraid of embracing challenges. To make a difference it is fundamental, to take action, risk. Failure in Contents represents new opportunities and stimuli to improve ourselves and learn.
Without pushing ourselves there would not be space for progress in the world. We are temerarious. We experiment with complex ideas and we are not afraid of the magnitude of our tasks: we believe and trust each other.

• Be curious

For us, curiosity must drive our actions. We stimulate our community to explore and think outside the box. Every day we broaden our perspective, promoting the research not only for solutions but also for new challenges and obstacles that need to be addressed. We invite you to learn from the most talented people with the most upto-date technology.

• Feed your passions

Do what you enjoy, it will be the driver and key of future innovations and successes.
Doing what we love permits our minds to push forward and to put the maximum effort into our work.

• Choose and Communicate

We encourage people to make their voice heard, but not only. We strongly believe in the power of communication. The latter one must be perceived as a strong dichotomy made by two different points of view. Indeed, it is fundamental not only to express yourself but also to listen to others and make them speak. Having different perspectives and consulting each other is what has enabled our team to achieve every result.

• Promote diversity and inclusion

We work better together because of our differences, not despite them.
Contents strives to build an inclusive workplace where all Contents Personnel feel a sense of belonging and value for who they are and the differences they bring.
Diversity, Equity and Inclusion are fundamental to our business ethics. We prioritize diversity and inclusion in our recruiting efforts!
We must eliminate all differences to increase our collective intelligence. We need everyone’s voice to be heard and valued if we are to make the best decisions together.

We believe that we best serve everyone and enrich our own culture through the diverse skills, experiences, and backgrounds that each of us brings to the company.

Contents prohibits discrimination based on:

• Race, color, ethnic or national origin
• Age
• Religion or religious creed (or belief)
• Sex, including pregnancy, childbirth, breastfeeding, reproductive health decisions or related medical conditions
• Sexual orientation
• Gender, gender identity, gender expression, transgender status or sexual stereotypes
• Nationality, immigration status, citizenship or ancestry
• Marital status
• Protected military or veteran status
• Physical or mental disability, medical condition, genetic information or characteristics (or those of a family member)
• Political views or activity
• Status as a victim of domestic violence, sexual assault or stalking
• Any other basis prohibited under applicable law

We examine our unconscious biases and take steps to create an inclusive culture that makes every employee feel welcome.

• Innovate

Drivers of our success are the constant experimentation that characterized our daily work life. The energy of recent progress inspires the team to look for modern solutions that provide operational efficiency. New ideas are our driving force and our strength to achieve continuous exponential growth.

3. Actions

The entire Contents team does their best to create a supportive work environment, where everyone has the opportunity to reach their full potential, and is free from harassment, intimidation, prejudice and unlawful discrimination.

• Taking care of the team

Our community is our most valuable asset. We believe that with each other we can keep building better and innovative solutions.

– Integrity, empathy, diversity, respect, fairness, inclusion, safety, well being, equal opportunity employment, no bullying or discrimination, no conflicts of interest, personal relationship

1) Create a Safe and Healthy Workplace
2) Foster an Inclusive Culture & Embrace diversity and inclusion

1) Create a Safe and Healthy Workplace

We are committed to creating a safe, healthy and violence-free work environment.
Behaviors that put safety, health or security at risk are prohibited.
We strive to create a workplace where we all feel emotionally, physically and mentally safe and healthy. When we have a safe and healthy workplace, we are more likely to be empathetic and caring toward others. Taking care of us helps to take care of you.

We maintain a work environment that empowers everyone to do their best work. A safe workplace inspires trust and allows us all to contribute and succeed.

– We comply with workplace health and safety laws.
– Violent acts or threats of violence, verbal or emotional abuse are not permitted.
– We have zero tolerance for discrimination, harassment or retaliation.
– We condemn the use of drugs or alcohol.
– We follow company security guidelines.
– We protect the personal and confidential information of team members.
– We are empathetic: We think about how our words reach the customer and listen deeply and without judgment.

If it is life-threatening or an emergency, call your local police, fire, or other emergency responders first, and then report it to Contents.com

2) Foster an Inclusive Culture & Embrace diversity and inclusion

Contents strives to build an inclusive workplace where all Contents Personnel feel a sense of belonging and value for who they are and the differences they bring.
Diversity, Equity and Inclusion are fundamental to our business ethics. We prioritize diversity and inclusion in our recruiting efforts!
We must eliminate all differences to increase our collective intelligence. We need everyone’s voice to be heard and valued if we are to make the best decisions together.

When we hire and promote based on merit, we not only honor our core values but we also help ensure that our Company and our customers get the very best. We avoid discrimination of any kind. This improves our chances of finding the right person for every position while elevating our standing as a premier place to work and grow.

Contents prohibits discrimination based on:

• Race, color, ethnic or national origin
• Age
• Religion or religious creed (or belief)
• Sex, including pregnancy, childbirth, breastfeeding, reproductive health decisions or related medical conditions
• Sexual orientation
• Gender, gender identity, gender expression, transgender status or sexual stereotypes
• Nationality, immigration status, citizenship or ancestry
• Marital status
• Protected military or veteran status
• Physical or mental disability, medical condition, genetic information or characteristics (or those of a family member)
• Political views or activity
• Status as a victim of domestic violence, sexual assault or stalking
• Any other basis prohibited under applicable law

• Taking care of our community

1) How we build trust
2) Protect Our Community’s Privacy
3) Confidential Information

1) Taking Care of our community. How we build trust

• We provide clear and accurate privacy notices when collecting or processing personal data.
• We honor privacy choices by using customer data to provide the services customers have agreed to.
• We protect our customers’ data by building secure products and services.

We are transparent about how we handle customer data. We’re successful when our customers trust us to protect their privacy.

2) Taking Care of our community. Protect Our Community’s Privacy

We do not improperly use or disclose confidential business information.
Disclosing confidential information outside of Contents or to those who do not need it for legitimate business purposes can have dire consequences on Contents business.
Leaks could result in lawsuits or undermine the work, or even safety, of our colleagues.

Privacy is important to us. Respecting it allows us to trust each other and our users, and enables us to comply with our legal obligations.

Take careful and vigorous measures to prevent any unauthorized use of sensitive information.
We recognize that our information assets are vital and distinguish us from competitors. We are committed to protecting all company information but especially our confidential and restricted information, as well as any sensitive business partner information entrusted to us. Information security is everyone’s responsibility, even if you discontinue your employment.

„Confidential or restricted information“ might include:

– Nonpublic financial information or projections
– Marketing plans
– Proprietary processes, formulas, products or services
– Intellectual property, patents and trade secrets
– Information about investments or proposed transactions
– Pricing strategies
– Company-developed software and related documents
– Business partner information
– Certain operating procedure
– Personal information of any individual (employee, agent, consumer or customer)

We are meticulous in handling user data while doing our jobs. We access user data only if we have been explicitly granted access rights as part of our job and only if we need to do so to perform our job function, and we always respect those users‘ privacy and product settings. Violations of this rule will be taken extremely seriously and will carry consequences up to and including termination.

3) Taking Care of our community. Confidential Information

The Contents’ activities may require data, documents and information regarding business negotiations, procedures, transactions and contracts to which the company is party to be obtained, retained, processed, disclosed and circulated.

Each Employee is thus required to safeguard the private and confidential nature of the information acquired as part of his/her work duties, and – more specifically – to comply with the confidentiality clauses requested by Clients and other counterparties.

All information, knowledge and data acquired or processed by Employees by way of their duties belong to Contents and may not be utilized, disclosed or divulged without prior and specific authorization being granted by a superior.

Each Employee shall:

– obtain and process only the data that is necessary and directly related to his/her duties
– retain said data in such a way that outside third parties are prevented from becoming aware of it
– disclose and divulge data as part of procedures that are pre-established by Contents or with prior approval of the competent person

Protecting Contents confidential information means:

– We are diligent in dealing with users‘ data while doing our job. We only access user data if we have been explicitly granted access rights.
– We do not disclose confidential, proprietary, competitive or other sensitive information to a third party unless there is an appropriate agreement
– We follow privacy and data laws. We pay careful attention to the company’s required privacy training.
– We do not share confidential information internally beyond those who need it for work
– We do not bring or share any confidential proprietary information belonging to a former employer or entity to Contents
– We understand our obligations under our employment agreement

• Taking care of partners and investors

We act on the values of trust, loyalty, transparency, privacy, data protection, human rights. We do not disclose confidential info.

We avoid conflicts of interest to make the best choices for Contents, unaffected by personal interests or relationships.

The customer is the heart of the company’s activity: the work is carried out first of all to ensure the growth of the customer himself. A customer is anyone who uses the services and works of the company in any legal form it presents itself.

It is the duty of the Company’s employees to:

1. Comply with internal procedures for managing customer relationships;
2. Provide accurate and comprehensive information about the products and services offered so that the customer can make informed decisions;
3. Adhere to the truth in advertising and other communications:
– Don’t bribe: doing business with integrity means Contents does not tolerate bribery or corruption anywhere we operate.
– Be Responsible with Entertainment, Gifts, & Travel: giving and receiving gifts, hospitality and travel can build strong working relationships and goodwill between Contents and those we do business with
– Use Trustworthy Representatives and Use Trustworthy Suppliers
– Keep Accurate Records and Contracts
– Make Truthful and Accurate Public Statements
– Compete fairly
– Competitors/Former Employers

Taking care of our PARTNERS AND INVESTORS:

We seek to earn our customers’ partnership with smart and creative solutions and products. We put our energy and resources into improving our product and winning business fairly.

It’s a common business practice to build partner relationships through entertainment, and modest gifts. These practices are fine, as long as we engage in them responsibly and in a way that feels consistent with our values.

We want people to know that we are a brand that can be trusted.

Taking care of INVESTORS

Our commitment to honesty is reflected in how we keep business records. Those records come in all shapes and sizes, from receipts to contracts to our user metrics and published financials. Whatever the type of record, we apply the same approach: we are truthful, transparent, and accurate in our documentation. That’s the kind of company that investors and the public can trust.

Investors need to trust what we say because they make their investment decisions based on our disclosures. We take that trust seriously.

Everyone benefits when there is a competitive marketplace. We protect that interest by competing according to the rules. We get ahead by being kind, smart, and creative, not by engaging in unfair or unethical business practices.

We might lose our competitive advantage if we disclose Contents confidential information. We lose trust if we disclose confidential information we learn from the companies we do business with. Protecting information and ideas, whether our own or those of others, is crucial to our business success and builds our reputation as a trustworthy partner.

• Taking care of the world

We act following the principles of sustainability, progress, innovation, economic opportunity, respect of law, fair competition, pursuing the global goal of protecting the environment. Protecting the environment is both an imperative and a source of progress. Contents as company is committed to:

– Foster and grow a collective consciousness on the environmental matters that might be affected by our daily work
– Aim for a high level of environmental performance
– Control environmental risks
– Pursue commitments beyond the company

At Contents we are committed to and hold ourselves accountable to a high standard, ensuring we build technologies that have a positive impact, keep people safe and serve everyone.

4. VIOLATION OF THE CODE – DISCIPLINARY MEASURES

Contents has so far distinguished itself for a long tradition of compliance with the regulations for each specific sector of interest, gaining credibility and appreciation from customers.
An unethical or unlawful behavior would result in the company’s relationship of trust being damaged with serious damage to its image, reputation and credibility.
Employees and external collaborators are required to comply with this Code of Ethics in all respects.

Violation of the provisions of the Code by employees and collaborators constitutes a breach of contractual obligations and may result in the application of the sanctions and disciplinary measures provided for by the Code.
Contents will take appropriate action against those whose actions are found to be in violation of this Code of Ethics.

How to raise a Concern.

Your voice matters

At Contents, we handle reports seriously, fairly and in a timely manner, and if something needs to be fixed, we’ll take action based on what we learn.

We respond with respect and take every concern seriously, we always show that we are committed to solving any kind of problem.

Raising a concern should be as easy as possible. If you need advice on a particular topic or issue or are unsure about how to report a concern, the team is always ready to help ([email protected]).

In addition, you can always raise concerns with your manager, any Contents manager, HR, Finance, or Legal. If it is life-threatening or an emergency, call your local police, fire, or other emergency responders first, and then report it to Contents.com