Title: Gamium Code of Conduct
Document control number: PPL.GEN.POL.03.V2
Area: People
V1 Issue date: 13/12/2022
This version Issue date: 10/11/2023
1. Purpose
Employee Code of Conduct company policy outlines our expectations regarding employees’ behavior
towards their colleagues, supervisors, and overall organization.
We promote freedom of expression and open communication. But we expect all employees to follow
our code of conduct. They should avoid offending, participating in serious disputes and disrupting
our work connectivity. We also expect them to foster a well-organized, respectful, and collaborative
environment.
2. Scope
This policy applies to all our employees regardless of employment agreement or rank.
3. References
N/A
4. Employee Responsibilities
• Do not share or distribute this document. It belongs to Gamium.
• Read and understand carefully all the clauses written below
• Provide feedback when discrepancies or opportunities are found
5. Policy
Company employees are bound by their contract to follow our Employee Code of Conduct while
performing their duties. We outline the components of our Code of Conduct below:
5.1 Compliance with law
All employees must protect our company’s legality. They should comply with all environmental, safety
and fair dealing laws. We expect employees to be ethical and responsible when dealing with our
company’s finances, products, partnerships, information, personal data and public image.
All employees should respect their colleagues. We won’t allow any kind of discriminatory
behavior, harassment or victimization. Employees should conform with our equal opportunity
policy in all aspects of their work, professional or personal behaviors, throughout all the employee life
cycle at Gamium.
If you suffer any case of discrimination or want to declare something related to any colleague at work
and with absolute confidentiality, you can reach to our internal email of
[email protected] and we will reach out to you. Any breach of this policy or
discriminatory behavior will be addressed with extreme caution and confidentiality.
5.2 Protection of Company Property
All employees should treat our company’s property, whether material or intangible, with respect and
care.
Employees:
• Shouldn’t misuse company equipment or use it frivolously.
• Should respect all kinds of incorporeal property. This includes trademarks, copyright and
other property (information, reports etc.) Employees should use them only to complete their
job duties.
Employees should protect company work centers and other material property from damage and
vandalism, whenever possible. Any vandalism or lack of care will be investigated and can lead to any
disciplinary action as per the policy of disciplinary actions,
5.3 Cyber security and digital devices
The more we rely on technology to collect, store, and manage information, the more vulnerable we
become, more severe security breaches. Gamium is especially sensible to this threat. Human errors,
hacker attacks and system malfunctions could cause great financial damage and may jeopardize our
company’s reputation.
For this reason, we have implemented several security measures. You are expected to follow all
internal measures defined in TEC.GEN.POL.06 Duties and Acceptable Use Policy to protect Gamium
from any external attack or information security breach.
5.3.1 Company resources
Company resources should be protected from improper or fraudulent use that could damage the
security of the information, the business results or the reputation of the company.
Gamium employes shouldn’t:
• Access networks, servers, drives, folders, or files to which the employee has not been granted
access or authorization from someone with the right to make such a grant;
• Make unauthorized copies of Gamium files or other Gamium data;
• Destroy, delete, erase, or conceal Gamium files or other Gamium data, or otherwise make
such files or data unavailable or inaccessible to the Company or to other authorized users of
Gamium systems;
• Defeat or attempt to defeat security restrictions on Gamium systems and applications;
• Cause congestion, disruption, disablement, alteration, or impairment of Gamium networks or
systems;
5.3.2 Internet usage
Our corporate internet connection is primarily for business. You can occasionally use our connection
for personal purposes if they don’t interfere with your job responsibilities and is not used to access
any site that could compromise Gamium integrity, stability, and reputation.
Also, we expect you to temporarily halt personal activities that slow down the connection or
communication if you’re asked to.
Internet connection shall not be used to:
• Download or upload obscene, offensive, or illegal material.
• Send confidential information to unauthorized recipients.
• Invade another person’s privacy and gain access to sensitive information.
• Download or upload pirated movies, music, material, or software.
• Visit potentially dangerous websites that can compromise our network and computers’ safety.
• Misrepresent oneself or the Company one’s.
• Send, download, or access pornographic or other inappropriate materials.
• Perform unauthorized or illegal actions, like hacking, fraud or buying/selling illegal goods.
• Engage in private or personal business activities, including excessive use of instant messaging
and chat rooms.
• Engaging in unlawful or malicious activities.
• Deliberately propagating any malware designed to disrupt, disable, impair, or otherwise harm
either the Gamium's networks or systems or those of any other individual or entity
Internet connection from your mobile has the same threats, if not more, than any other connection.
If you are carrying Gamium confidential information in your phone you should exercise extra care and
caution to protect Gamium.
In case of any breach of the security of any of your devices, please communicate immediately with the
Employee Relations area to stop any access that could impact in Gamium’s activities and business.
5.3.3 Corporate email
Email is essential to our work. You should use Gamium’s mail exclusively for work related situations.
You can use your corporate email for work-related purposes without limitations. For example, you can
sign up for newsletters and online services that will help you in your job or professional growth.
The email account of Gamium may not be used without authorization to communicate with third
parties on behalf of Gamium for reasons unrelated to the professional tasks entrusted.
Always keep it safe and avoid spamming and disclosing confidential information.
No matter how you use your corporate email, we expect you to avoid:
• Signing up for illegal, unreliable, disreputable, or suspect websites and services.
• Sending unauthorized marketing content or emails.
• Registering for a competitor’s services, unless authorized.
• Sending insulting or discriminatory messages and content.
• Spamming other people’s emails, including your coworkers.
• Sending chain letters or participating in any way in the creation or transmission of unsolicited
"spam" that is unrelated to legitimate Company purposes.
• Using abusive, profane, threatening, racist, sexist, or otherwise objectionable language in
either public or private messages.
In general, use strong passwords and be vigilant in catching emails that carry malware or phishing
attempts. If you are not sure that an email you received is safe, do not forward, delete it.
5.3.4 Social media
We address two types of social media uses: 1) using personal social media at work and 2) representing
our company through social media.
1. Using personal social media at work
You are permitted to access your personal accounts at work. But we expect you to act responsibly,
according to our policies and ensure that you stay productive. Specifically, we ask you to:
• Discipline yourself. Avoid getting sidetracked by your social platforms.
• Ensure others know that your personal account or statements don’t represent our
company. For example, use a disclaimer such as “opinions are my own.”
• Avoid sharing intellectual property (e.g trademarks) or confidential information. Ask your
manager or PR first before you share company news that’s not officially announced.
• Avoid any defamatory, offensive, or derogatory content. You may violate our company’s anti-
harassment policy if you direct such content towards colleagues, clients, or partners.
• Do not use your personal account to represent or post anything related to Gamium. All social
media activity representing or providing Gamium information should be coordinated with the
Marketing Department.
2. Representing our company through social media
Only those accounts approved can publish information on behalf of Gamium or disclose any internal
information.
If you handle Gamium social media accounts or speak on our company’s behalf, we expect you to
protect our company’s image and reputation. Specifically, you should:
• Be respectful, polite, and patient.
• Avoid speaking on matters outside your field of expertise.
• Follow our confidentiality and data protection policies and observe laws governing copyrights,
trademarks, plagiarism, and fair use.
• Coordinate with our Communications and Marketing department when you’re about to share
any major-impact content.
• Avoid deleting or ignoring comments for no reason.
• Correct or remove any misleading or false content as quickly as possible.
• Not use abusive, profane, threatening, racist, sexist, or otherwise objectionable language
5.4 Dress code
All employees must show integrity and professionalism in the workplace. Casual for working in co-
working centers or home and business casual for Representing Gamium in different forums (adjusted
to match as minimum the dress code of the interlocutor). All employees must be clean and well-
groomed. Grooming styles dictated by religion and ethnicity aren’t restricted.
Employees must avoid clothes with stamps that are offensive or inappropriate.
5.5 Corruption and bribery
We discourage employees from accepting gifts from clients or partners. We prohibit briberies for the
benefit of any external or internal party. More details regarding this topic can be found in
FIN.L&C.POL.01 and FIN.L&C.POL.02 related to Anti bribery, and Gifts and Hospitality.
5.6 Professionalism: Job duties and authority
All employees should fulfill their job duties with integrity and respect toward customers, stakeholders
and the community. Supervisors and managers shall not abuse their authority. We expect them to
delegate duties to their team members considering their competences and workload. Likewise, we
expect team members to follow team leaders’ instructions and complete their duties with skill and in
a timely manner.
5.7 Conflict of interest.
We expect employees to avoid any personal, financial, or other interests that might hinder their
capability or willingness to perform their job duties. When you are experiencing a conflict of interest
your personal goals are no longer aligned with your responsibilities towards us. For example, owning
stocks of one of our competitors is a conflict of interest or placing an offer to a vendor that has
personal relationship with you.
In other cases, you may be faced with an ethical issue. For example, accepting a bribe may benefit you
financially, but it is illegal and against our business code of ethics. If we become aware of such
behavior, you might lose your job and may face legal trouble.
For this reason, conflicts of interest are a serious issue for all of us. We expect you to be vigilant to
spot circumstances that create conflicts of interest, either to yourself or for your direct reports. Follow
our policies and always act in our company’s best interests. Whenever possible, do not let personal or
financial interests get in the way of your job. If you are experiencing an ethical dilemma, talk to your
manager or HR and we will try to help you resolve it.
More details regarding this topic can be found in FIN.L&C.POL.04
5.8 Employee relationships
We want to ensure that relationships between employees are appropriate and harmonious. We
outline our guidelines, and we ask you to always behave professionally.
5.8.1 Fraternization
Refers to dating or being intimate friends with your work colleagues. In this policy, “dating” equals
consensual romantic relationships and sexual relations. Non-consensual relationships constitute
sexual violence, and we prohibit them explicitly.
If you start dating a colleague, we expect you to maintain professionalism and keep personal
discussions outside of our workplace. If this relationship brings up a conflict of interest, we are
expecting you to disclose it to Employee Relations Department.
You are also obliged to respect your colleagues who date each other. We won’t tolerate sexual jokes,
malicious gossip, and improper comments. If you witness this kind of behavior, please report it to
Employee Relations.
To avoid accusations of favoritism, abuse of authority and sexual harassment, supervisors must not
date their direct reports. This restriction extends to every manager above an employee. Gamium will
be taking the necessary actions, that could even lead to termination
Also, if you act as a hiring manager, you aren’t allowed to hire your partner to your team. You can
refer them for employment to other teams or departments where you don’t have any managerial or
hiring authority.
5.8.2 Friendships at work
Employees who work together may naturally form friendships either in or outside of the workplace.
We encourage this relationship between peers, as it can help you communicate and collaborate. But
we expect you to focus on your work and keep personal disputes outside of our workplace.
Always avoid disclosing any confidential information or Gamium intellectual property to any colleague
at work. There is information classified and shall never be disclosed in a friendly manner to anyone
outside the incumbents.
5.8.3 Collaboration
Employees should be friendly and collaborative. They should try not to disrupt the workplace or
present obstacles to their colleagues’ work.
All employees must be open for communication with their colleagues, supervisors or team members.
Managers should be open so employees can approach them easily to:
• Ask for counsel or feedback.
• Ask questions about a subject.
• Express a complaint or concern.
• Raise awareness for a problem.
• Ask for resolution to an inside dispute or conflict.
• Make suggestions for change.
• Discuss other personal topics.
In general, speak up when you have an opinion about something. Also, inform us when you notice
harassment, victimization or any violation of our code of conduct. We need all of you to ensure the
workplace is safe and nice to work in for everyone.
5.9 Employment of relatives
At Gamium we have no objection of employing relatives of current employees, however the candidate
should compete in equal opportunities with other candidates for the same role, and demonstrate the
skills, experience, and abilities to perform the job.
Everyone in our company should be hired, recognized or promoted because of their skills, character
and work ethic.
If the hiring manager or the area manager has conflict of interest due to the recruitment of one relative
of a current employee, he/she should declare it and refrain for taking any decision in the case. The
Chief People Officer or the CEO will decide who will take the decision in that matter.
6 Performance Measures
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7 Process flow
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8 Appendix
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Author: Ignacio Sánchez
CPO
Signature:
Date: 22/11/2023
Signature:
Firas Safieddine
