Code of Conduct

3.1 Anti-corruption and bribery

We have zero tolerance for bribery, kickbacks, facilitation payments, extortion, or any other form of corruption.

• Do not offer, promise, authorize, request, or accept anything of value intended to improperly influence a business decision.
• Keep transactions and approvals transparent and properly recorded.

3.2 Antitrust and fair competition

We compete fairly and comply with antitrust and competition laws.

• Do not engage in price-fixing, bid rigging, market allocation, or improper information sharing with competitors.
• Avoid discussing sensitive competitive information (pricing, sales strategy, customer lists) with competitors unless clearly lawful and approved.

3.3 Trade compliance and sanctions

Where relevant, we comply with applicable export controls, sanctions, and trade regulations.

• Do not provide restricted technology or services to prohibited parties or destinations.
• Escalate trade compliance questions promptly.

3.4 Accessibility

We strive to make our products and experiences accessible to people of all abilities, and we support accessibility best practices in product design and communications.

3.5 Intellectual property

We respect the intellectual property rights of others.

• Use third-party software and content only as allowed by license and applicable terms.
• Do not use or distribute unlicensed materials, pirated software, or misappropriated content.

4.1 Honest, transparent communication

We communicate in a way that is accurate, clear, and not misleading—internally and externally. This includes communications with customers, partners, auditors, regulators, and the public.

4.2 Conflicts of interest

We avoid situations where personal interests conflict—or appear to conflict—with Harmonity’s interests. Examples include:

• Outside employment that interferes with your obligations to Harmonity
• Personal investments or relationships that influence vendor selection or customer dealings
• Accepting improper benefits from vendors or customers

Potential conflicts must be disclosed promptly through appropriate internal channels.

4.3 Gifts, meals, and entertainment

We do not offer or accept gifts or entertainment that could improperly influence business decisions or create the appearance of undue influence.

• Nominal, reasonable hospitality may be acceptable if lawful and transparent.
• Anything extravagant, frequent, or tied to a decision must be avoided and escalated.

4.4 Respectful conduct in our environments

We do not tolerate harassment, threats, or abusive behavior in Harmonity-run environments (support channels, events, community spaces, or other platforms we control). We may restrict access to our Services or spaces for violations.

5.1 Accurate record-keeping

All financial transactions and business activities must be recorded:

• Accurately, completely, and in a timely manner
• With appropriate supporting documentation
• In accordance with applicable accounting standards and legal requirements

5.2 Internal controls and approvals

We maintain controls designed to protect company assets and support accurate reporting.

• Follow approval processes and delegated authority rules.
• Do not bypass controls or create side agreements.

5.3 Preventing fraud and misuse of assets

We have zero tolerance for fraud, theft, embezzlement, or misuse of company assets (including funds, systems, devices, and intellectual property).

• Report suspicious activity promptly.
• Cooperate with audits, reviews, and investigations.

5.4 Documentation and retention

Business and financial records must be retained and disposed of in accordance with legal requirements and company retention schedules. Do not alter or destroy records in anticipation of litigation, audit, or investigation.

5.5 Working with auditors and regulators

We cooperate with lawful audits and regulatory requests and expect truthful, accurate responses. Any contact from a regulator should be escalated through appropriate internal channels.

7.1 Reasonable and appropriate spending

• Choose cost-effective options consistent with business needs.
• Avoid luxury purchases, excessive meals, and entertainment not tied to legitimate business activities.

7.2 Documentation requirements

• Submit accurate expense reports with itemized receipts when required.
• Clearly describe the business purpose and attendees (as relevant).
• Do not misclassify expenses or submit personal expenses for reimbursement.

7.3 No improper reimbursements

Expense fraud is a serious violation and may result in disciplinary action, termination, or legal action.

8.1 No forced labor or human trafficking

We do not engage in or tolerate forced labor, bonded labor, or human trafficking.

8.2 No unlawful child labor

We do not employ or tolerate unlawful child labor and expect our suppliers and partners to uphold similar standards.

8.3 Safe and respectful workplace

We seek to provide a workplace free from harassment and unsafe conditions and expect those who work with us to respect these principles.

11.1 Privacy and data protection

We process personal data in accordance with applicable privacy laws and our published policies. For more information about security and privacy practices, subprocessors, and related controls, please visit our Trust Center.

11.2 Confidential information

Confidential information includes non-public business, technical, or customer information.

• Do not disclose confidential information without authorization.
• Use confidentiality safeguards in communication and storage.

11.3 Secure practices

We expect secure behavior, including:

• Strong authentication practices
• Least-privilege access
• Prompt reporting of suspected security incidents
• Avoiding unauthorized tools, integrations, or data transfers

13.1 Speak up

We encourage anyone covered by this Code to raise concerns about suspected misconduct, unethical behavior, fraud, security issues, or legal violations.

13.2 How to report

Email: support@harmonity.ai (subject line: “Code of Conduct Concern”). To help us investigate efficiently, include (if possible):

• What happened (clear description)
• When and where it happened
• Who was involved or witnessed it
• Any relevant documents or evidence

13.3 Confidentiality and no retaliation

We handle reports with appropriate confidentiality. We do not tolerate retaliation against anyone who raises concerns in good faith.

13.4 Investigations and outcomes

We review reports promptly and take appropriate action, which may include remediation, policy changes, disciplinary action, contract termination, or referral to authorities where required.