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Pipedrive’s Statement on Modern Slavery and Human Trafficking

Partner Code of Conduct

Pipedrive is committed to the highest level of integrity and ethical business conduct. We believe in developing and maintaining strong relationships with vendors, suppliers, contractors, resellers, agents and partners (“Partners”). Critical to fostering and maintaining this relationship is a shared commitment to high ethical standards.

All Partners agree to comply with this Code and are responsible for ensuring their suppliers, representatives, agents, contractors and subcontractors (“Third Parties”) also comply to the same or higher standards. If any of the requirements in this Code conflicts with applicable law, the law takes precedence. Partners must promptly inform Pipedrive of any known or suspected area of non-compliance.

Workplace Standards and Practices

Pipedrive is committed to ensuring that working conditions in our supply chain are safe, employees are treated with dignity and respect and that business operations are environmentally responsible.

Non-Discrimination

Partners will value diversity, equity, and inclusion in the workplace. Partners will not discriminate against their employees or candidates for employment on the basis of any protected class including race, color, religion, national origin, gender, age, disability, pregnancy, political affiliation, union membership, veteran status, marital status, citizenship status, creed, sexual orientation or as otherwise provided by applicable laws.

Respectful Work Environment

Partners must be committed to a harassment-free workplace. Partners may not threaten or subject employees to harsh or inhumane treatment, including sexual harassment, sexual abuse, corporal punishment, mental coercion, or verbal abuse.

Forced Labor

Partners will not use forced or involuntary labor whether in the form of prison labor, slavery, bonded labor or any other form of human trafficking. Partners shall not require any worker to surrender control over original identity documents or work permits. Employees should be allowed to freely terminate employment and enjoy freedom of movement. Partners will ensure it has adequate controls to ensure compliance with this requirement by it and its Third Parties. Partners may be audited for compliance with this provision.

Child Labor

Partners must comply with all applicable minimum age laws and requirements and will not employ any person under the age of 15, under the age for mandatory education, or under the minimum age for employment in the country - whichever age is highest.

Conflict Minerals

Partners will not source from companies manufacturing products containing tantalum, tin, tungsten or gold derived from the Democratic Republic of the Congo and/or surrounding countries due to the human rights abuses involved in mining in these regions.

Working Hours

Partners’ employee working hours will conform to local labor laws and will not be excessive. Partners’ employees should be granted a minimum of at least one day off every seven-day period.

Wages and Benefits

Partners will fairly and competitively compensate their employees in compliance with applicable local and national wage and hours laws. Partners will not make deductions or withhold compensation from employee wages that are not agreed to in a signed contract and allowed under governing law.

Freedom of Association

Partners will not interfere with the legal rights of employees to associate with groups of their choice, including the right to form or join trade unions and to engage in collective bargaining.

Health and Safety Practices

Health and safety are fundamental to all businesses. Partners must provide employees with a safe work environment consistent with all applicable laws and regulations including, but not limited to, implementing procedures and safeguards to prevent, manage, and track workplace hazards, work-related accidents and injuries.

Environmental Practices

Partners should be committed to sustainable development and minimizing the negative impact of their operations on the environment including complying with all local environmental laws and regulations.

Business Integrity

Pipedrive expects its Partners to conduct business ethically, transparently and in compliance with all applicable laws and regulations.

Bribery and Corruption

Partners must not offer, promise, give or receive bribes or any other form of inducement, regardless of the value, with the intention or appearance of influencing a business decision or securing an improper business advantage, whether directly or through a third party.

Partners shall implement adequate controls to prevent, detect, oversee and audit employees or its suppliers and affiliates from committing offenses of bribery or corruption. The effectiveness of such controls should be reviewed and updated regularly to ensure that they are effective.

Gifts and Hospitality

The exchange of gifts and hospitality is often used to build normal business relationships. However, it can create an actual or perceived conflict of interest or an improper or unfair business advantage.

Partners must ensure that any offering or receipt of any gift or business hospitality does not violate any law and is consistent with reasonable market customs and practices. Extravagant or lavish gifts, meals, entertainment or travel expenses, must not be given or accepted particularly where they are disproportionate, frequent or provided in the context of ongoing business negotiations.

Conflict of Interest

Partners must ensure that they supply or provide goods and/or services to Pipedrive in an open and transparent manner. Any actual or potential conflicts of interest must be disclosed immediately.

Business records

Partners must create and maintain accurate books and records of transactions in compliance with all applicable laws and regulatory requirements. Appropriate accounting controls must be in place and followed.

Financial crimes

Partners will have appropriate controls to prevent against and detect fraud, money laundering, terrorist financing or tax evasion in regards to its own operations or with third parties with whom it has contractual relationships.

Fair Competition and Antitrust

Partners will not propose or enter into any agreement with another company or potential supplier to fix prices, terms and conditions of sale, costs, profit margins or anything similarly prohibited by law. Partners will ensure its controls are adequate and able to detect violations.

Sanctions

Partners must comply with all applicable import and export control laws and regulations including sanctions, embargoes, and anti-boycott rules. Partners are expected to understand any sanctions, import and export control requirements relating to their work, and ensure their operations comply with these requirements.

Compliance

Partners have established systems and controls in place to demonstrate compliance with this Code. This includes demonstrating the compliance of those in their own supply chain.

Pipedrive takes ethics and compliance with laws seriously. Pipedrive reserves the right to terminate any related contracts with any Supplier who fails or refuses to comply with this Code.

Pipedrive’s Statement on Modern Slavery and Human Trafficking

Organizational Structure

Pipedrive Inc. is the parent company of Pipedrive OÜ; Pipedrive Portugal Sociedade Unipessoal LDA; Pipedrive UK LTD; Pipedrive Prague SRO; Pipedrive Ireland Limited; Pipedive Germany GmbH; and Pipedrive LatviaSIA (collectively “Pipedrive”). Pipedrive unequivocally supports the human rights of our workforce and the workforce of those with whom we do business. As protecting human rights requires initiative, action, transparency and commitment, Pipedrive has implemented controls to promote accountability and responsibility throughout the organization.

In keeping with this commitment, Pipedrive supports the United Nations Declaration of Human Rights and the International Labour Organization core standards on forced labor, child labor, freedom of association and discrimination. We also support all laws that seek to prevent and eliminate slavery and human trafficking from global supply chains by increasing transparency, including the California Transparency in Supply Chains Act of 2010 and the United Kingdom’s Modern Slavery Act 2015.

Supply Chain

Pipedrive’s modest supply chain focuses primarily on services such as security, facilities, marketing, recruitment and consulting in professional fields such as accountancy, tax, and legal advocacy.

Pipedrive holds its suppliers to the same high, ethical standards to which it holds itself by requiring that all suppliers, vendors, partners, resellers and agents comply with its Partner Code of Conduct.

Policies

Corporate Compliance Programs (CCP) are fundamental to identify, mitigate and address actual or perceived risks within an organization. The United States (US) Sentencing Guidelines for Organizations is a federal law pertaining to the assessment of damages in cases of fraud against the government combined with the European Union’s (EU) guidance for internal compliance programs to serve as a basis for establishing a proper compliance program. Pipedrive has developed a Corporate Compliance Program aligning with these frameworks.

As part of the CCP, Pipedrive maintains numerous policies, together with our Anti-Slavery and Human Trafficking statement, reinforcing our commitment to compliance with applicable laws and operations at the highest ethical standards. These policies include a Code of Conduct for employees; Partner Code of Conduct for third parties with whom we do business; Whistleblowing, Ethics Reporting Channel; Anti-Corruption Policy; Environmental, Social and Governance Policy; Economic Sanctions Policy and a Vendor Review Policy.

Due Diligence

All vendors and suppliers with whom Pipedrive contracts undergo a due diligence process by Pipedrive’s Legal, Data Privacy and Information Security teams before being formally onboarded. These parties are also vetted against applicable sanctions lists including those relating to Human Rights, Human Trafficking Cases and Anti-Corruption.

Risk Assessment

Pipedrive conducts annual enterprise risk assessments subject to an established risk framework. Potential risks are investigated and addressed through the CCP infrastructure. Matters are shared with the executives and board of directors, if necessary, based on the defined risk model.

Key Performance Indicators (KPIs)

Pipedrive is in the process of developing applicable KPIs to better demonstrate our commitment to doing the right things.

Training

While Pipedrive provides onboarding and annual training on a variety of topics relating to People and Culture, Legal, Information Security and Finance, training will be expanded to include awareness of Slavery and Human Trafficking issues.


Approved 13.06.2023