# Code of Conduct

Last updated: October 22, 2026

Everyone at Summerbase ApS acts with integrity, treats people with respect, and protects the data customers trust us with.

## Scope

All employees, contractors and board members.

## Standards

1. **Integrity.** Be honest with customers, colleagues and auditors. Do not misrepresent the product, its security or its compliance status.
2. **Respect.** The company does not tolerate harassment or discrimination, consistent with the Danish Equal Treatment Act (forskelsbehandlingsloven) and related law.
3. **Confidentiality.** Protect confidential company and customer information during and after employment, as set out in employment and contractor agreements.
4. **Data protection.** Handle personal data only as needed for the job and in line with GDPR and the Data Management Policy.
5. **Conflicts of interest.** Disclose any interest that could influence decisions, such as ownership in a vendor or competitor, to the CEO.
6. **Anti-bribery.** Do not offer or accept bribes, kickbacks or gifts beyond modest hospitality.
7. **Compliance with law.** Follow applicable laws, including export controls and sanctions where they apply to customers.
8. **Company assets.** Use company property and accounts as set out in the Acceptable Use Policy.

## Raising concerns

Report concerns to the CEO. Retaliation against anyone who raises a concern in good faith is prohibited.

## Acknowledgment

All personnel acknowledge this Code at hire and yearly.