Code of Corporate Ethics

Alfateam

1. Introduction

This Code of Corporate Ethics of Alfateam reflects our core values: integrity, innovation, transparency and teamwork. It establishes the fundamental principles and standards of conduct that guide employees in their daily activities and in decision-making. The purpose of the Code is to ensure uniform high standards of business ethics, to strengthen trust both within the team and beyond it, and to contribute to the long-term success of the company.

The Code is addressed to all parties associated with Alfateam: employees, clients and partners. For employees, it serves as a guide to responsible and ethical conduct at work. To clients and partners, the Code demonstrates our company’s commitment to conducting business openly and in good faith. Operating predominantly in the CIS market, we take local business specifics into account, but invariably adhere to the universal principles of integrity, transparency and respectful cooperation. Everyone who interacts with Alfateam can rely on our commitment to these values.

2. Values and Principles

We build our corporate culture on four fundamental values. These principles define Alfateam’s approach to work and to interaction with others:

Integrity: We conduct business decently and truthfully. Every employee keeps the promises made, communicates honestly with colleagues and clients, and does not allow deception or the provision of false information. Any form of fraud, corruption or dishonest conduct is unacceptable – Alfateam’s reputation is founded on trust.

Innovation: We value innovation and strive for continuous development. Alfateam encourages a creative approach, the search for fresh ideas and the adoption of modern technologies to create high-quality digital products. Openness to new solutions and improvements allows us to remain competitive and to offer clients optimal solutions to their tasks. Every employee contributes to an atmosphere of innovation by sharing ideas and experience.

Transparency: We adhere to a policy of openness in our work. Transparency means that information is accessible and clear to colleagues, clients and partners. We make decisions and act in such a way that all participants in the process understand the goals and reasons for these actions. Within the team, we openly discuss emerging issues and problems, and in external relations we provide complete and clear information about our services, the terms of cooperation and the progress of projects. This approach strengthens mutual trust and accountability.

Teamwork: Alfateam’s success is achieved through the well-coordinated work of the team. We value the spirit of cooperation, mutual assistance and respect in relations between employees. Each team member contributes to the overall result, shares knowledge and supports colleagues. We encourage constructive communication, joint problem-solving and the exchange of experience. Teamwork also extends to interaction with clients and partners – we regard them as part of a single project team acting to achieve the best results.

3. Employee Conduct

Alfateam employees are expected to conduct themselves professionally, in accordance with the company’s values and high standards of business ethics. Through their attitude and actions, every employee affects the company’s reputation; it is therefore important to adhere to the following principles:

Compliance with the law and internal rules: Employees comply with the requirements of applicable legislation and adhere to the company’s internal policies and procedures. Strict adherence to the rule of law and to the provisions of this Code is mandatory regardless of position held or length of service. We reject any illegal or unethical business practices.

Integrity and accountability at work: Every employee must act in good faith, openly and reliably. We encourage taking responsibility for one’s decisions and commitments. Deliberate misrepresentation of facts, the submission of false reports or the concealment of errors is unacceptable. If a problem arises or a mistake is made, the employee informs management in a timely manner so that a solution can be found together – this open approach is consistent with the spirit of transparency and allows us to remedy situations without undermining trust.

Professionalism and respect: In relations with colleagues, management and subordinates, employees show courtesy, tact and respect. We value the diversity of skills and opinions within the team and build the working atmosphere on mutual respect. Constructive criticism and discussion are welcome, whereas abusive behavior, rudeness or bias are unacceptable. Everyone should contribute to creating a favorable, friendly climate in the team, where everyone’s contribution is valued and success is achieved together.

Initiative and development: Alfateam encourages employees to show initiative, be proactive and continuously learn new things. The pursuit of professional development, advanced training and the improvement of work processes is regarded as an important part of the corporate culture. Employees openly propose ideas that can benefit projects and the company and share knowledge with colleagues. Such an active stance, based on an innovative approach, helps the company grow and create better digital products.

Protection of the company’s interests: Every employee treats the company’s resources – material, financial and informational – with care. Working time, equipment and company funds must be used rationally, avoiding abuse. Conflicts of interest are unacceptable: personal benefits or connections must not influence work decisions to the detriment of Alfateam or its clients. Employees are obliged to inform management of any situation in which their personal interest may impede the objective performance of their job duties. We also require compliance with confidentiality (see Section 5): internal information and client data must not be disclosed or used for personal purposes.

Quality and diligence of work: We expect employees to strive to perform their tasks with quality and on time, honoring the commitments they have undertaken. Attention to detail, responsibility for the result and a focus on meeting the client’s needs are important in our work. If an employee encounters difficulties, they seek assistance or advice in order to ensure the proper performance of the work. The diligent approach and accountability of every employee directly affect the success of projects and clients’ trust in the company.

By adhering to these principles of conduct, Alfateam employees create a trusting, effective and ethical working environment in which the company’s values are manifested in practice.

4. Working with Clients and Partners

For Alfateam, clients and business partners are an integral part of our common team and success. We build cooperation with them on the basis of trust, mutual respect and transparency. Our principles for working with clients and partners are as follows:

Honesty and openness in interaction: We always inform clients and partners honestly and directly about all material aspects of cooperation. Contract terms, prices for services, development timelines and other obligations are communicated transparently and in full. If changes, difficulties or delays arise in the course of a project, we notify the client immediately and propose possible solutions. This approach helps avoid misunderstandings and strengthens long-term cooperation. Client trust is our top priority; therefore, we never make promises that we cannot keep and do not exaggerate our capabilities.

Fulfillment of obligations and quality of services: Alfateam undertakes realistic obligations and fulfills them strictly. We aim to provide high-quality products and services that fully comply with the agreements reached. We value every client and strive to justify the trust placed in us and, where possible, to exceed expectations. Project deadlines, agreed functional specifications and service levels are strictly observed. If problems arise, we discuss them openly and make every effort to promptly remedy the situation. Reliability and responsibility in fulfilling obligations shape our reputation as a responsible partner.

Respect and long-term cooperation: In our relations with clients and business partners, we adhere to the principles of respect, mutual benefit and a long-term approach. In communication with clients, Alfateam employees are courteous and attentive to requests and comments, and strive to understand the needs and expectations of each party. We value feedback and are open to suggestions, as we believe that dialogue with partners helps improve our products and services. Confidentiality of discussions and trust are the foundation of such relations (see Section 5 for details). We regard clients and partners as allies in a common cause and strive to build cooperation in such a way that each party is satisfied with the result.

Ethical business practices: Alfateam adheres to fair business practices in the market. We compete by lawful and ethical means, relying on quality, innovation and professionalism rather than on unfair tactics. We do not use illegal or unethical means to attract projects – for example, bribery or misleading advertising – and do not participate in schemes capable of harming the client or the market. When selecting suppliers, contractors and other partners, we give preference to companies that share our values and standards of business ethics. Our company strives to ensure that the entire chain of cooperation – from the internal team to external partners – operates transparently, responsibly and for the benefit of the end result.

By following these principles in working with clients and partners, Alfateam strengthens its position as a reliable and ethical company. We believe that honest and open cooperation creates a solid foundation for the mutual success and growth of all parties.

5. Confidentiality and Data Protection

Alfateam gives paramount attention to the protection of confidential information and data. The trust of our clients and partners largely depends on how responsibly we handle the information provided to us. The company has strict confidentiality rules in place:

All contracts, projects and client data are under the company’s control and are not transferred to third parties without authorization and necessity. We guarantee that information received from a client or partner is used solely for the purpose of fulfilling our obligations and is protected against unauthorized access. Information may be transferred to third-party organizations or individuals only with the client’s written consent or on the basis of lawful requirements (for example, at the request of state authorities in the manner established by law).

Employees are obliged to maintain the confidentiality of any official, commercial and personal information they work with. Clients’ personal data, project technical documentation, financial reports and other sensitive information must not be disclosed or discussed outside the scope of work tasks. Each employee signs the relevant non-disclosure undertakings where required and undergoes data protection training. The use of confidential information for personal purposes is strictly prohibited.

We implement the necessary measures to ensure information security: we use modern data protection tools, restrict access to information on the basis of job responsibilities, and regularly update security policies. All electronic systems, databases and documents are protected in accordance with industry standards and legal requirements. The company complies with the applicable rules on the protection of personal data and trade secrets.

When cooperating with external partners and contractors, we also ensure data protection through contractual obligations. Any third party involved in Alfateam projects is obliged to comply with the same standards of confidentiality and information security as our employees.

Our commitment to confidentiality and data protection is unwavering. Compliance with these rules is the key to maintaining clients’ trust, protecting their interests and upholding Alfateam’s impeccable business reputation.

6. Responsibility and Compliance Monitoring

Compliance with the Code. Compliance with the provisions of this Code of Corporate Ethics is the duty of every employee of Alfateam, without exception. Every employee, from senior management to interns, bears personal responsibility for observing the principles set out herein in their daily work. Heads of departments are obliged not only to personally set an example of ethical conduct, but also to ensure that their subordinates know and understand the requirements of the Code. The onboarding of new employees includes familiarization with this Code, and current employees regularly remind themselves of its provisions.

Monitoring and reporting. The company establishes procedures for monitoring compliance with the standards of the Code. Specially authorized persons (for example, the security service or compliance managers) may monitor compliance with ethical standards and review reports of possible violations. Every employee is strongly encouraged to contact management or the person responsible for ethics if they have questions about the application of the Code or if they encounter a situation of potential violation. We guarantee that such reports will be considered confidentially and without risk of adverse consequences for an employee who has reported in good faith. Open discussion of ethical dilemmas is welcome – it helps all of us better understand the principles of the Code and apply them in practice.

Liability for violations. Failure to comply with the standards and requirements of this Code may result in disciplinary measures, up to and including penalties, suspension of projects or dismissal, depending on the severity of the violation and its consequences. The company reserves the right to impose sanctions on employees who have violated ethical principles intentionally or through gross negligence, since such actions undermine the trust and well-being of the entire team. With respect to business partners, failure to comply with generally accepted ethical standards may result in the termination of cooperation. We firmly declare our commitment to a policy of zero tolerance for corruption, fraud and other illegal practices – a condition we expect both of ourselves and of everyone we work with.

Application and relevance of the Code. This Code is an official internal document of Alfateam, binding on all employees of the company. It is also open for review by our clients, partners and other stakeholders, so that everyone can see the ethical guidelines of our activities. The Code cannot anticipate absolutely every situation that the company or its employees may encounter; however, it serves as a compass in choosing the right course of conduct. In cases not directly addressed in the Code, one should be guided by its spirit – the core values of integrity, innovation, transparency and teamwork – as well as by common sense and legal requirements. The content of the Code may be periodically reviewed and supplemented to take into account changes in legislation or internal policies, of which employees will be notified.

By adhering to this Code of Corporate Ethics, Alfateam and all of its employees strengthen a culture of trust, responsibility and mutual respect. Our shared commitment to integrity, innovation, transparency and team spirit ensures the sustainable development of the business, increases the satisfaction of clients and partners, and maintains Alfateam’s impeccable reputation in the market. Each of us, through our daily work and actions, contributes to this foundation of the company’s success.