Terms & Privacy
  1. Terms of use


    Acceptance of Terms:


    Description and use of this Website:

    Ciklum requires that all visitors to this World Wide Website owned, operated, licensed, and controlled by Ciklum (the “Website”) adhere to the following Terms And Conditions of Use. Ciklum may change, suspend or discontinue any aspect of the Website at any time, including the availability of any feature, database or content. Ciklum may also impose limits on certain features and services and/or restrict your access to parts or all of the Website without notice or liability of any kind. To the extent that you and Ciklum have entered into a client’s service/license agreement (“Client Agreement”) for any portion of the Website, the terms and conditions of the Client Agreement will control in the event that of any provisions that may conflict with these Terms and Conditions of Use.

    This Website provides authorized users with access to a collection of resources, including access to certain service deliverables, articles, and insights for general informational purposes. The Content (as such term is defined below) is to be used solely as a research tool and not as specific guides for action. YOU UNDERSTAND AND AGREE THAT THIS WEBSITE AND THE CONTENT IS PROVIDED “AS-IS” AND YOU ASSUME FULL RISK FOR ANY AND ALL USE OF THIS WEBSITE AND FOR ANALYSIS OF THE CONTENT. You may not use this Website or the Content for any illegal purpose or in any manner inconsistent with these Terms and Conditions of Use. We make every effort to ensure that the Content on this Website is accurate and up to date, however accuracy cannot be guaranteed.

    You are responsible for obtaining access to the Service and that access may involve third party fees (such as Internet service provider or airtime charges). In addition, you must provide and are responsible for all equipment necessary to access the Website. No installation, implementation, customization, consultation, support or similar services are included within the scope of these Terms and Conditions of Use.


    To the extent that your use of this Website is in connection with services received through a Client Agreement, we will request that you select a Password and Screen Name in connection with the operation of this Website. You alone are responsible for maintaining the confidentiality of your Password and Screen Name. You are responsible for all uses of our services with your Password and Screen Name, with or without your consent, by yourself and others.


    You may access certain “forums” or “blogs” through the Website. You may not post on any forum/blog any material that is libelous, defamatory, obscene, abusive, invades a person’s privacy, violates any intellectual property rights, or that would otherwise violate any law. You acknowledge that you are responsible for whatever material you submit, and you, not Ciklum, have full responsibility for the message, including its legality, reliability, appropriateness, originality, and copyright. You may not post material that solicits funds, or that advertises or solicits goods or services. You may not post material known to be false. You may not post or transmit any information, software or other material that contains a virus or other harmful component. We also reserve the right to remove any such violative material. All remarks, suggestions, ideas, graphics or other information communicated through the Website will become, once posted, the property of Ciklum (“Posting”). Ciklum will not be required to treat any Posting as confidential. Ciklum will be entitled to use the Postings for any commercial or other purpose whatsoever, without compensation to you or any other person. You agree to indemnify, defend and hold Ciklum harmless from any liability arising due to the use or distribution of your Postings. You further grant Ciklum the right to use your name in connection with the reproduction or distribution of your Postings.

    Modifications to Website:

    We reserve the right at any time to modify or discontinue, temporarily or permanently, this Website (or any part thereof) with or without notice. You agree that we shall not be liable to you or to any third party for any modification, suspension or discontinuance of this Website.

    Copyright/Restrictions on use of Content:

    The content, including but not limited to the written materials, images, audio, video and all other materials and information on this Website (“Content”) is the intellectual property of Ciklum or republished by Ciklum under limited exceptions to the copyright laws. All rights of Ciklum or other copyright holders are reserved. Content from this Website may only be used, copied, and/or reproduced for internal business informational purposes. In no event may it be used for the commercialization of any product, service or entity, or released to the general public. You agree that if you download any Content that you will assure that the Content is used only as permitted by these Terms and Conditions of Use. You also agree that you will not change any Content or create your own derivative work from any Content. Any other use of or link to the Content on this Website, including reproduction for purposes other than those noted above, without the prior written permission of Ciklum is strictly prohibited. You may seek our permission by writing to Ciklum, Attention: Data Controller, Østerbrogade 125, 3rd floor
    DK 2100 Copenhagen Ø Cvr: 26768624 If permission is granted by us (or by other entities with an interest in the relevant intellectual property), you may not change or delete any author attribution, trademark, legend or copyright notice. In the event that you are given authority to use any Content, your use of any Content should be attributed to Ciklum or the author if specified.

    Where copyright for any Content is not owned by Ciklum, the source of this Content is provided (“Third Party Content”). Any copying, republication or redistribution of Third Party Content whatsoever is expressly prohibited. Thus, should you wish to use any Third Party Content you are responsible for seeking appropriate approvals from the copyright owner.

    If you use Content from this Website in violation of these Terms and Conditions of Use you may be in violation of your Client Agreement and may be subject to termination of your Client Agreement and damages for the copyright violation under federal statutes.


    This Website contains many valuable trademarks, names, titles, logos and other proprietary materials owned and registered by Ciklum and its affiliates (“Trademarks”). Nothing contained on this Website should be construed as granting any license or right to use any Trademark displayed on this Website. All other trademarks appearing on the Website are trademarks of their respective owners and nothing contained on this Website should be construed as granting any license to use the trademark owned by any other third party. Our reference to any third party trademarks does not imply or indicate any approval or endorsement by their owners, or Ciklum’s approval or endorsement of the owners or their products or services.

    Linked Sites:

    This Website may include links to other sites which are not maintained by Ciklum. Ciklum is not responsible for the content of those sites and makes no representations whatsoever concerning the content or accuracy of, opinions expressed in or other links provided by, such other sites. The inclusion of any link to such sites does not imply endorsement by Ciklum of the sites or any products or services referred to therein. Ciklum may terminate a link at any time. The terms of use and privacy policies applicable to such sites may be different from those applicable to the Website. If you decide to access any third party site linked to the Website, you do so entirely at your own risk and Ciklum shall have no liability for any loss or damage arising from your use of any such site. Any owner of a site which may be referred to or to which a link is provided in this Website, may request that the link be removed, by promptly notifying us in writing by fax or regular mail (not by email) at the following address: Data Controller, Østerbrogade 125, 3rd floor DK 2100 Copenhagen Ø Cvr: 26768624. Please include the following information in your Notice: (i) your full name, address, telephone number and email address; (ii) full details of the location on this Website of the material or information in question (including the URL of the link shown on the Website where such material or information may be found); and (iii) full details of why you want the link removed.

    Notification of Alleged Infringement of Copyright or Other Intellectual Property Rights:

    In order to promptly address claims of alleged infringement of intellectual property rights, we have established the following procedures. If you are the owner of copyright or other Intellectual Property Rights, or have been authorized to act on behalf of the owner of such rights, and you believe your rights have been or are being infringed, please notify us immediately. Notice should be in writing and should be sent by fax or regular mail (not by email) to the following address: Data Controller, Østerbrogade 125, 3rd floor DK 2100 Copenhagen Ø Cvr: 26768624 Notices should include the information set forth below. Please note that you will be liable for damages (including costs and attorneys’ fees) if you materially misrepresent that an activity is infringing your copyrights or other Intellectual Property Rights. Accordingly, if you are not sure whether certain material of yours is protected by copyright laws, we suggest that you first contact an attorney. To expedite our ability to process your request, please use the following format (including section numbers): (i) Identify in sufficient detail the copyrighted work that you believe has been infringed. For example, “The copyrighted work at issue is the text that appears on http://www.legal.com/legal_page.html”; (ii) Identify the material that you claim is infringing the copyrighted work listed in item #1 above. Identify each page that allegedly contains infringing material by providing its URL; (iii) Provide information reasonably sufficient to permit us to contact you (email address is preferred); (iv) Include the following statement: “I have a good faith belief that use of the copyrighted materials as described above is not authorized by the copyright owner, its agent, or the law.”; (v) Include the following statement: “I swear, under penalty of perjury, that the information in the notification is accurate and that I am the copyright owner or am authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.” ; (vi) Sign the paper; and (vii) Send the written communication to our designated contact, Data Controller. Failure to include all of the above information may result in a delay of the processing the notification.

    Notification of Alleged Unlawful Activities:

    If you believe in good faith that any unlawful activity is taking place on or through this Website or that any unlawful information has been submitted or uploaded on or to this Website, please promptly report the same to us by sending written notice by fax or regular mail (not by email) to the following address: Data Controller, Østerbrogade 125, 3rd floor DK 2100 Copenhagen Ø Cvr: 26768624 Please include the following information in your Notice of Unlawful Activity: (i) your full name, address, telephone number and email address; (ii) full details of the location on this Website of the material or information in question (including the URL of the link shown on the Website where such material or information may be found); and (iii) full details of the unlawful nature of the activity or material or information in question.

    What we will do when we receive a Notice of Infringement or Notice of Unlawful Activity:

    If we receive full and proper notification of an alleged infringement of Intellectual Property Rights or of any unlawful activity occurring on or through this Website or of any unlawful information being submitted or uploaded on or to this Website, we will take such action which we believe to be appropriate in the circumstances. Without limiting the foregoing, we will make an attempt to secure the voluntary take down of the Content which is the subject of any Notice of Infringement or Notice of Unlawful Activity. In any event, we reserve the right, in our sole discretion and without notice to any User, to: (i) delete, move, edit and/or disable access to any Content which is the subject of any Notice of Infringement or Notice of Unlawful Activity; or (ii) terminate access of any User whose Content is the subject of any Notice of Infringement or Notice of Unlawful Activity.


    Use of portions of this Website may be subject to the terms of a Client Agreement. Subject to the terms of the Client Agreement, we grant to you a limited, nonexclusive, nontransferable, nonsublicensable license to use this Website, solely for your internal business purposes. The Client Agreement may limit the number of users who are allowed access to this Website. You are required to take reasonable measures to protect access information and to assure that you do not permit unauthorized use of or access to this Website. We may audit your use of this Website to assure compliance with access restrictions and will pursue all available remedies for a breach of these access rules. You may not sell, rent, lease, lend, or transfer any services provided on this Website and you may not assign or sublicense your license to this Website. To the extent that you are not subject to a Client Agreement, we grant to you a limited, nonexclusive, nontransferable, nonsublicensable license to use those non-password protected portions of this Website, solely for your personal or business use. The licenses set forth herein may be terminated in the event you breach the terms of these Terms and Conditions of Use. RIGHTS NOT EXPRESSLY GRANTED HEREIN ARE RESERVED BY CIKLUM.


    You understand that we may in our sole discretion terminate your ability to use this Website if you violate these Terms and Conditions of Use. You may terminate these Terms and Conditions of Use by destroying all materials obtained from this Website and all related documentation and all copies and installations. Ciklum may terminate these Terms and Conditions of Use immediately without notice if, in its sole judgment, you breach any of these Terms and Conditions of Use. Upon termination, you must destroy all materials obtained from this site and all related documentation and all copies and installations. You may not access this site after termination of these Terms and Conditions of Use without the written approval of Ciklum, provided, however, that Ciklum shall retain all rights, including all copyright rights and the right to use Postings as provided herein, and the limitations on use and treatment of the Contents shall remain in full force.









    Limitation of Liability:



    Our failure to exercise or enforce any right or provision of hereunder shall not constitute a waiver of such right or provision. If any provision hereunder is found by a court of competent jurisdiction to be invalid, the parties nevertheless agree that the court should attempt to give effect to the parties’ intentions as reflected in the provision, and the other provisions hereof shall remain in full force and effect. You agree that regardless of any statute or law to the contrary, any claim or cause of action arising out of or related to use of the Website or these Terms and Conditions of Use must be filed within one (1) year after such claim or cause of action arose or be forever barred.


    You agree to indemnify, and hold Ciklum and its affiliates and each of their directors, officer, employees and agents (“Ciklum Indemnities”) harmless from and against any and all claims, actions or demands brought against Ciklum Indemnities arising out of or relating to your use of the Website or your breach of these Terms and Conditions of Use. The indemnification set forth in this Paragraph shall include all expenses and costs (including reasonable attorney fees) resulting from or arising out of the above claims.


    By using the Website, you are deemed to agree to these Terms and Conditions of Use.

  2. Privacy Policy

    1. Introduction

    The privacy and confidentiality of your information is a top priority for Ciklum. The Privacy Policy (Policy)will advise you about how we protect your information. Please read this policy carefully. This Policyapplies to your use of Ciklum website at https://www.ciklum.com/ and all other web resources,developed by Ciklum and published on the Internet (Website). This Policy does not apply to any other websites, used by Ciklum, but not controlled by Ciklum. By using our Website and reading this Policy, you confirm your acceptance for our using of your personal data, and you are deemed notified of such processing. If you do not agree to the processing of your data, please do not use the Website. We may need to change this Policy from time to time, so you should refer back to this Policy regularly. Your use of the Website after changes have been made shall be deemed to be your acceptance of any changes.

    2. Information we may collect and how we may use it

    We only collect information about you that is necessary for us to allow you to use the Website, and only to the extent specifically provided in this Policy. By using the Website, you consent to the collection, use, disclosure and other forms of processing of your information in the manner, provided in this Policy.

    2.1. Information we obtain from you

    Examples of personal data that we may collect from you are the following: full name, record of communication, language skills, e-mail, phone number, and location.

    When you contact us via the request form, we keep a record of your communication to help us solve issues you might be facing. We may use your e-mail address to inform you about our services, such as letting you know about upcoming changes or improvements.

    2.2. Information we may obtain from your use of our Website

    We may collect the following information about you:

    • information about your device(s), in particular, hardware model, version of the operating system, mobile network information;
    • login information, such as details regarding how you use our Website, frequency and duration of your visits, search information, internet protocol address, cookies. The “cookies” may be used by us to help us manage the Website and provide functionality and customized messages to you, but we do not provide this information to third parties, except as required by law. Ciklum also uses session cookies. These are not permanent cookies, and are removed when your browser closes or your computer is powered off. For more information on the cookies being used on the Website and how you can opt out, please visit the Cookies Info page.

    2.3. Processing personal data of children

    This site is not meant for children under 16 and does not knowingly collect any personal data from children under 16.

    3. Purposes of processing

    We use all your personal data only for the following purposes:

    • operate, provide, improve, and maintain our Website and services;
    • prevent abusive and fraudulent use of our Website and services;
    • respond to your inquiries and for other customer service purposes;
    • monitor aggregate Website usage metrics such as total number of visitors and pages viewed;
    • remember your information so that you will not have to re-enter it the next time you visit the Website;
    • for other administrative and internal business purposes.

    In case the purpose of processing will be changed to a contradictory purpose, we will obtain additional consent from you for the processing.

    4. Security of your personal data

    Ciklum uses a variety of security measures to keep your personal data protected from unauthorised access and disclosure. For more details, please contact Ciklum Privacy Team via data.privacy@ciklum.com.

    5. Principles of processing your personal data

    We process your personal data based on the following principles of fairness and lawfulness:

    5.1. Fairness and lawfulness

    We process your personal data only after obtaining your consent for the processing, and for a determined specific purpose, unless otherwise expressly specified by law. Ciklum has developed clear procedures regarding the processing of personal data based on lawfulness.

    5.2. Transparency

    We process your personal data in a fair and transparent manner, and only with your knowledge and in respect of your given rights.

    5.3. Purpose limitation

    We ensure that your personal data is only processed within the purposes as outlined in the consent form and only by those Ciklumers needed to be involved in the processing operations to fulfil these purposes. Subsequent changes to the purpose are only possible to a limited extent, and require substantiation and your additional consent.

    We will ask for your consent before using information for a purpose other than is set out in this Policy.

    5.4. Data minimization

    We collect and process only your personal data if actually needed in order to achieve its processing purposes. Ciklum also does not retain your personal data longer then is required to achieve the relevant purposes.

    5.5. Accuracy

    Personal data must be accurate and, where necessary, kept up-to-date. We take every reasonable step to ensure that your data, when inaccurate or incomplete, is either erased or corrected. We ensure that inaccurate or misleading data will be corrected as soon as possible.

    5.6. Storage limitation

    Ciklum is limiting the storage scope and time to a level appropriate and necessary to fulfill the purposes of the processing of your data in line with your consent. Therefore, we have specified limited periods for personal data storage.

    5.7. Integrity and confidentiality

    We acknowledge personal data to be subject to data secrecy. Our priority is to secure the confidentiality and integrity of your processed personal data. Ciklum secures your personal data with suitable organisational and technical measures to prevent unauthorised access, illegal processing or distribution, as well as accidental loss, modification or destruction.

    5.8. Accountability

    We will be responsible for and be able to demonstrate compliance with the aforesaid six data protection principles.

    6. How we process your personal data

    We may process your data by way of collecting, recording, organising, storing, using, structuring, adapting or altering, retrieving, consulting, disclosing by transmission, disseminating or otherwise making available, aligning or combining, restricting, and erasing or destructing. We may transfer your personal data to our subsidiaries, in which case they are obliged to provide you with an adequate level of personal data protection. We will not transfer personal data of the European Economic Area residents out of the European Economic Area without reasonably ensuring that your rights and freedoms as a data subject are protected and that you are informed of such transfer. We do not sell or pass your personal data to a third party for the purposes of direct marketing.

    7. Where we store your personal data

    All your personal data, collected by us, is stored within the information technology systems, owned and operated by Ciklum, and in the cloud systems. Once we receive your information, we will use all reasonable procedures and security measures to avoid unauthorised access, loss, disclosure or amendment of the received data.

    8. Disclosure of your information

    We are using our best efforts not to intentionally disclose any information about you to any third party without having received your written consent. However, we will have to release specific information about you, if necessary, in relation to the services, provided to you, or to comply with any valid legal process such as a search warrant, subpoena, statute or court order. We will also have to release specific information in special cases, such as if there is an attempted breach of the security of the Website, or to report to the legal enforcement officials any activities that we reasonably believe to be unlawful. While Ciklum maintains the secure Website, you should know that computer use may be monitored by third parties, such as network administrators, employers, internet providers, operation system and Internet browser vendors, and thus we cannot guarantee the security of information you post online. You disclose all information online at your own risk. Please remember that the Website may be hosted outside your home country, and your email communications to us may be directed to a server outside your home country. Communications over the Internet may not be secure.

    9. Third-party content/links

    Users will find content and products of other companies or organisations on our Website and/or links to the websites and services of our suppliers, licensors or other third parties. While we make reasonable efforts to monitor the websites or services, we do not control them. Each such third party is solely responsible for complying with the laws, rules and regulations applicable to its business and operation of its website. We are not responsible for the privacy practices, the content, or the legal and regulatory compliance of such websites or their owners and operators. These websites and services may have their own privacy policies and customer service policies, or no policies at all. We encourage you to review the privacy policies of any third party websites before providing your information to them.

    10. Your privacy rights

    We provide you with data protection rights, prescribed by the European Union laws, in particular the General Data Protection Regulation, and the relevant national laws. You have, for example, the following rights.

    • the right to obtain any information about the processed personal data within one month;
    • the right to access your personal data;
    • the right to correct or erase your personal data;
    • the right to be aware of any correction or erasure of your personal data, restriction of processing, and recipients of personal data;
    • the right to object to the processing of your personal data;
    • the right of data portability;
    • the right not to be subject to a decision, based solely on the automated processing; and
    • the right to lodge a complaint with a data protection authority.

    You may exercise these rights by sending a request to data.privacy@ciklum.com.

  3. Cookie Policy

    1. Introduction

    This Policy applies to any websites, branded pages on third-party platforms (such as Facebook or YouTube), and applications accessed or used through such websites or third-party platforms (hereinafter, “Sites” or “Ciklum Sites”) which are operated by or on behalf of Ciklum.

    By using Ciklum Sites, you consent to our use of cookies in accordance with this Policy. If you do not agree to our use of cookies this way, you should set your browser settings accordingly or not use Ciklum Sites. If you disable cookies that we use, this may impact your user experience while on Ciklum Sites.

    2. What are cookies

    Cookies are files or pieces of information that may be stored on your computer (or other devices, such as smartphone or tablet) when you visit Ciklum Sites. This allows Ciklum Sites to distinguish your device from those of other users of the Sites. A cookie will usually contain the name of the website the cookie has come from, the "lifetime" of the cookie (i.e. how long it will stay on your device), and the value, which is usually a randomly generated unique number.

    3. How do Ciklum Sites use cookies

    Ciklum Sites use cookies to identify your device and your interests, to remember your preferences, and to track how you use our Sites. We also use cookies and other tracking technologies to control access to certain content on our Sites, protect the Sites, and to process any requests you make to us. To administer our Sites and for the research purposes, Ciklum Sites also incorporate a few third-party
    services to track and analyse statistical usage and volume of information from users of the Sites. These third-party services use persistent cookies to help us improve user experience, manage the content of
    the Sites, as well as analyse how users navigate and use the Sites.
    Our cookies are used for the following purposes:


    • These cookies are necessary to allow us to operate our Sites so you may access them as requested. For example, they let us recognise that you have created an account and have logged in this account to access the Site content.
    • These also include cookies, which allow us to remember your previous actions within the same browsing session, and to secure the Sites.


    These cookies are used by Ciklum or a third-party service provider to analyse how the Sites are used and their performance. For example, they track the most visited pages, and where the visitors come from. They include, for example, Google Analytics cookies.


    These cookies let us operate the Sites in respect to the choices you make and actions you take. They allow us to "remember" your device in-between the visits. For example, our systems can recognise your user name and remember how you customised the Sites and services (changed the text size, fonts, languages and other configurable elements), and provide you the same customisations during the future visits.

    Third-party Advertising

    These cookies collect information about your activities on the Sites to provide
    you the targeted advertising. We may also allow our third-party service
    providers to use cookies on the Sites for this purpose, or to collect information
    about your online activities over time and across different websites. The third-
    party service providers, which generate these cookies, such as Google, LinkedIn,
    and Facebook, have their own privacy policies, and may use their cookies to
    target advertising to you on other websites, based on your visits to Ciklum Sites.

    4. First-party and third-party cookies

    “First-party cookies” are cookies, which belong to Ciklum Sites, and located on your device. “Third-party cookies” are cookies, which another party places on your device through our Sites. Ciklum may contract with third-party service providers to send emails to users, who have shared their contact information with us. To help measure and improve the effectiveness of our email communications, and/or to determine if users have opened the messages and have clicked the links, the third-party service providers may place cookies on the devices of these users. For more information on how third parties collect and use information on our behalf, please refer to their privacy policies.

    Ciklum Sites use the following types of cookies:

    • Persistent cookies. We use persistent cookies to improve your experience of using the Sites.
    • Session cookies. Session cookies are temporary and removed at once from your device after your web browser closes. We use session cookies to help us track the internet usage as described above.

    You may refuse to accept cookies by changing the corresponding settings in your web browser. However, if you choose to do so, you might be unable to access certain content of the Sites. Unless you change your web browser settings regarding cookies, our systems will place cookies on your device when you visit Ciklum Sites.

    The data collected by the Sites and/or through cookies, which may be placed on your device, will be stored only as long as is needed to fulfil the purposes mentioned above.

  4. Code of Conduct

    1. Introduction

    1.1. Message from Torben Majgaard, Founder

    Integrity and transparency are the core principles under which Ciklum operates on a daily basis, principles which have been core in supporting our growth and success to date. As Ciklum increases its international footprint, scale and complexity, the imperative to demonstrate and evidence our ethical behaviours becomes ever more important.

    To that extent, we have created this Code of Conduct, to support the Ciklum family in their understanding of the business conduct and ethical stance that we are all expected to follow, regardless of seniority. We can’t hope to define all scenarios which may require consideration, but we can give practical guidance which will help support every day decision making, and information on where to seek or report concerns.

    It is each person’s responsibility to read and understand our Code of Conduct and to demonstrate personal commitment to our shared principles through their daily actions and interactions in accordance with it. I am personally committed to supporting you all in achieving this goal.

    1.2. Purpose of this Code

    As a multi-national group of companies with an identifiable brand the actions of one Ciklumer1
    has the potential to impact upon the entire group. Furthermore, with the diverse range of jurisdictions in which Ciklum operates there is a wide range of laws, rules, regulations, customs and approaches to conducting business. The continued success of Ciklum depends on the actions of every Ciklumer being transparent, lawful and ethical. As such, the primary function of this Code is to provide a unified set of principles and behaviours which are designed to act as a guide to help you make the right decisions for yourself and for Ciklum.

    At the same time, the Code of Conduct cannot describe every law, policy or process that may apply to us or every
    situation that we may face within our everyday role. As a general rule, we are responsible for understanding and
    complying with the laws, regulations and policies that relate to our business activities.
    Detailed guidance on how to deal with important ethical and compliance issues will be described in Ciklum’s corporate
    policies and other relevant documents. These will be available on the MyCiklum portal. However, being aware,
    understanding and following the principles described in this Code will help to protect the reputation of Ciklum and

    1.3. Scope

    This Code applies to and is mandatory to be followed by all Ciklumers. Each of us, wherever we work, must behave in
    accordance with these standards when dealing with fellow Ciklumers, clients, suppliers, stakeholders, governmental
    authorities and competitors. We also should require our suppliers or vendors to adhere to this Code or adopt similar
    ethical standards.

    1.4. Responsibilities

    The primary responsibility for maintaining an environment of ethical behaviour rests with Ciklumers through a
    demonstrated commitment to compliance with the Code of Conduct and with legal and regulatory requirements relevant
    to Ciklum’s business. To carry out this responsibility, Ciklumers will:

    • Read, understand, and abide by the Code of Conduct.
    • Exercise appropriate behaviour and maintain the highest standards of ethical conduct when representing
      Ciklum. This includes when travelling on the company business and attending functions hosted by Ciklum or third parties (e.g., conferences, trade shows, events). Seek advice from a supervisor2 if uncertain about the meaning or application of the Code of Conduct or when in doubt about the best course of action in a particular situation.
    • Learn and contribute to a workplace environment that is conducive to and encourages compliance with the
      Code of Conduct and with laws and regulations.
    • Maintain sensitivity to alleged, actual, or suspected illegal, unethical, or improper conduct by a supplier, client, consultant, or other person or organization with whom Ciklum has a relationship, and to report such conduct to the Compliance Director.

    1 Please refer to Definitions section (in the end of this document)
    2 Supervisor is a Ciklumer you report to

    Leadership Team
    In addition to their professional responsibilities in Ciklum, Senior Management (Leadership team & Invited Members3) must maintain a workplace environment that stresses commitment to compliance with the Code of Conduct and with laws and regulations. Ciklum’s Leadership Team will:

    • Exhibit the highest standards of ethical conduct at all times and avoid the perception of unethical behaviour.
    • Ensure that Ciklumers understand their duty to report actual or suspected Code of Conduct violations and that there are procedures and mechanisms available to facilitate reporting.
    • Ensure that Ciklumers receive appropriate training in the meaning and application of Ciklum’s compliance
    • Ensure that all policies and references are in place and in the laws and regulations related to Ciklum.
    • Maintain a workplace environment that prevents reprisals against a Ciklumers who in good faith reports actual or suspected Code of Conduct violations.

    Board of Directors
    The Board of Directors4 is accountable for ensuring overall compliance with the Code of Conduct and the legal and
    regulatory requirements relevant to the Ciklum’s business. The Board has the overall responsibility and authority to:

    • Approve and/or make modifications to the Code of Conduct as needed.
    • Review current and proposed corporate policies, processes, and procedures for consistency with the Code of
    • Establish and maintain the means, methods, and procedures for investigating violations of the Code of Conduct.
    • Monitor disciplinary measures taken for violations of the Code of Conduct.
    • Provide training and educational programs to enhance Ciklumers awareness of and compliance with the Code of Conduct.

    1.5. How to raise an issue or concern?

    The Code cannot cover every situation that we may face. We may find ourselves faced with a dilemma that we are not
    sure how to resolve. If in doubt, ask yourself these questions:

    • Does it comply with the Ciklum’s Code of Conduct?
    • Does it comply with policy, regulation and law?
    • Would I be setting a good example?
    • Would I be comfortable explaining what I did to my colleagues, family and friends without shame or
    • Would I or Ciklum be comfortable if the action was written about in a newspaper?
    • Have I consulted others who have knowledge of the topic and sought advice to help me make an informed

    If the answer is ‘No’ to any of these questions, or if you are not sure, stop and seek further advice.
    If you become aware or suspect a violation of this Code, we expect you to report promptly to your Line Manager /
    Project Manager, HR Business Partner / People Partner or Compliance Department. If you are uncomfortable making
    such a notification, you may do so anonymously using Ciklum SpeakUp mailbox: SpeakUp@ciklum.com

    3 Leadership Team and Invited Members is the group of Ciklum top managers that contains from C-level officers (CEO, Global CFO, COO, CTO, CDO, CHRO, CRO and VP C&C) and directors – Legal D., Compliance D., Finance D., Delivery D. and Commercial D.
    4 Board of Directors of the Ciklum Group Holdings Limited Holding Company, BVI

    There are a number of ways that you can seek advice and support, including through any of the following:

    1. Discussing with your Project Manager, People Partner or anyone in management;
    2. Discussing with the Compliance Department; and
    3. Writing a mail to Ciklum SpeakUp: SpeakUp@ciklum.com

    Never hesitate to ask questions, raise concerns, or seek the guidance you need. Ciklum will not tolerate any
    discrimination against anyone who has reported a concern in good faith.

    1.6. Breach of this Code

    Ciklum will investigate any report of a violation with the principles of the Code of Conduct. You must cooperate fully with any investigation, but should not investigate independently as alleged violations may involve complex legal issues, and you may risk compromising the integrity of a formal investigation.
    Conduct that violates the law and/or company policies is ground for disciplinary or remedial action. In addition, failure to report a known violation of law or company policy by someone else may result in disciplinary action for Ciklumers and/or termination of employment/your relationship with Ciklum. The disciplinary action taken will be decided on a case by case basis. The action will be conducted in accordance with Ciklum’s HR procedures and corresponding legal requirements.
    Where laws have been violated, we will cooperate fully with the appropriate authorities.

    2. Compliance with laws and regulations

    Ciklum is a global group of companies, and our business is subject to the laws of many different countries. Each day we interact with a variety of individuals and groups including our clients, competitors, co-workers, suppliers, and sometimes government officials. We are committed to interacting with all in a respectful, ethical manner and in compliance with legal requirements. We would rather miss out on a business opportunity than compromise our integrity.

    2.1. Anti-Bribery & Corruption

    Bribery is the offering, giving, receiving or soliciting of any item of value in order to wrongfully influence someone’s actions, or to secure an improper advantage5.


    Ciklum has a zero-tolerance policy toward bribery and corrupt conduct in any form. Improper inducements involving
    government officials, clients, suppliers, business partners, and all other counterparties are strictly prohibited. We must all act with the utmost honesty, integrity and transparency in all dealings with clients, suppliers, business partners and government officials. Ciklum does not allow Ciklumers or others to make facilitation payments on its behalf.
    We are committed to complying with all anti-corruption/anti-bribery laws, everywhere in the world such as the US
    Foreign Corrupt Practices Act, the UK Bribery Act and EU Directives. Bribery can have very serious consequences, for the individuals involved and for Ciklum. Any third-party, agent or intermediary acting on Ciklum’s behalf is also prohibited from offering, giving or accepting bribes and improper inducements, including acts of favouritism to influence a business decision.

    5 For more information, please refer to Definitions section (in the end of this document)

    2.2. Gifts and Hospitality

    Ciklum policy and practice requires moderation and the use of good judgement when giving or accepting gifts or
    entertainment in the course of business. Extending or receiving common courtesies such as business meals in connection
    with legitimate business activities generally is acceptable. However, in any such dealings, Ciklumers should not request, accept, offer to give or give anything of value that would give the appearance of impropriety or suggest that the gift or entertainment was intended in any way to influence a business decision or to obtain an improper advantage.
    A gift can be an item, but it also can include event tickets or the provision of services when the gift provider is not otherwise involved in the event or service (e.g. the giver provided the tickets but does not accompany the recipient to the event). Entertainment is distinguished from a gift as it typically involves meals, events or other forms of entertainment (e.g. sporting events, concerts, shows) where the provider participates in the meal, event or other form of entertainment.

    Permissible gifts and entertainment include those that:

    • Are given openly and directly;
    • Come with no strings attached;
    • Are NOT solicited;
    • Are NOT in the form of cash or a cash equivalent, such as a cash or gift card;
    • Are NOT significant in value;
    • Are NOT accepted as part of or during a business negotiation;
    • Comply with all applicable laws and with all policies of both the giver and recipient; and
    • Would NOT reflect poorly on Ciklum.

    Gift limits and Prohibitions

    Permissible gifts, entertainment and hospitality

    • It is acceptable to extend or receive occasional gifts having a maximum retail value of USD 200 in total over the course of any one calendar year to or from the same person as a gesture of goodwill.
    • Extending or receiving certain business entertainment (e.g. attending a local cultural or sporting event or a celebratory meal with a business partner) can be appropriate. Provided that the entertainment is reasonable
      and customary and in the furtherance of a business relationship; the cost of the entertainment is not excessive;
      and it won’t inappropriately bias future decision-making about working or create an appearance of impropriety.
    • Gifts in the form of tickets to sporting events and other forms of entertainment that exceed a USD 200 value may be acceptable under certain circumstances but require the pre-approval of your manager with the
      notification of Compliance Department.


    • Gifts in the form of cash payments are not allowed. It is prohibited to provide or receive cash as well as any cash
      equivalents (e.g. gift cards or loans) in any circumstances, regardless of amount.
    • You should not actively solicit gifts or entertainment from a current or potential client or business partner to
      gain an unfair advantage.
    • It is prohibited to offer or give anything of value to a government official in order to get or keep business or gain
      an improper advantage.

    For details, please refer to the corporate Gifts, Entertainment and Hospitality policy that will be available on the
    MyCiklum portal.

    2.3. Money Laundering and Sanctions

    Money Laundering
    People who are involved in criminal activity such as bribery, fraud or trafficking narcotics may attempt to launder money through apparently legitimate businesses in order to use the funds from their criminal activity and reduce suspicion6.

    Ciklum will not accept or process money gained through criminal activity; we will only deal with reputable clients who
    are involved in legitimate business activities and whose funds are derived from legitimate sources. If you become
    suspicious, you should raise your concern immediately to the Compliance Department and document all steps that are
    taken in relation to the transaction.

    Sanctions are a foreign policy tool used by Governments to restrict the ability of designated countries, individuals or entities access to particular products, services and markets7.

    Ciklum has a zero tolerance approach to engaging with entities or individuals that are subject to sanctions restrictions implemented by the UN, EU, USA or other Governments as well as to those implemented by any local government at any of Ciklum’s locations. If you have any doubts about dealing with an entity which may be subject to sanctions, you should raise the question with the Compliance Department.

    2.4. Fair Competition and Anti-trust

    Generally, antitrust and competition laws prohibit any activity that may improperly reduce or inhibit competition8. Most countries where Ciklum does business also have laws restricting attempts to monopolise markets or otherwise restrict or control competition.
    It is CIklum’s obligation to comply with these laws where they are applicable. Because of the complexity of antitrust and competition laws, it is imperative that Ciklumers seek advice from the Compliance Department on any question
    regarding these issues. The penalties for violating antitrust laws and trade regulations can be extremely severe for both Ciklum and the individuals involved.

    2.5. Personal Information

    Ciklum takes its obligations under applicable data protection and privacy laws very seriously in all countries where Ciklum does business9. We all have a responsibility to safeguard the privacy, confidentiality and security of personally identifiable information and other private information of Ciklumers, clients, partners and other third parties in Ciklum’s possession. We have in place effective systems to only allow access to our personal information to those who have a valid business reason for accessing it, reducing the risk of our personal data being compromised. While creating documents in cloud environment we need to provide access only to those people, who are authorised to see it.
    You should never provide the information without the individual’s permission. If in doubt you should refer your enquiry to Compliance Department.

    6 For more information, please refer to Definitions section (in the end of this document)
    7 For more information, please refer to Definitions section (in the end of this document)
    8 For more information, please refer to Definitions section (in the end of this document)
    9 For more information, please refer to Definitions section (in the end of this document)

    2.6. Business Records

    We must help to ensure that Ciklum’s books and records, which include virtually all forms of business documentation,
    electronic or otherwise, accurately and fairly reflect, in reasonable detail, all transactions and dispositions of assets. It is of critical importance that Ciklum’s financial reporting, including its reports to investors and lenders, be accurate and timely. Depending on type of services they provide, Ciklumers may be called upon to give information necessary to assure that Ciklum’s financial reports are complete, fair and understandable.

    3. Managing and Protecting Ciklum’s Assets and Reputation

    3.1. Confidential and Proprietary Information

    Confidential information includes all non-public information that might be useful to competitors or that could be harmful to Ciklum if disclosed10.
    Ciklum has a duty to its clients, suppliers and personnel to respect all information it holds about them and to protect and handle such information responsibility.
    Ciklum’s legal obligations and its competitive position require that confidential information remain confidential and that we are diligent in our efforts to protect our intellectual assets. Information that is proprietary to our clients, suppliers and others should be treated as confidential and used for the purpose for which it was obtained and disclosed only as permitted between Ciklum and the other party. Confidential information should be properly and securely stored, transmitted and disposed of, and Ciklumers must be mindful of the risk of discussing confidential information in public places. This means that Ciklumers should not disclose or share information regarding internal Ciklum matters with anyone outside Ciklum, except as required in the performance of their employment duties.
    It is never acceptable to discuss confidential information in a public place even if there are no classified documents in use. The security and confidentiality of the information could be compromised if someone overhears the conversation.

    3.2. Conflict of Interest

    ‘Conflict of interest’ arises where a person’s position or responsibilities within their business unit presents an opportunity for personal gain above the normal rewards of cooperation11. In other words, a conflict of interest exists when your personal interests interfere with the best interests of Ciklum. Ciklumers should attempt to avoid actual or apparent conflicts of interest.

    10 For more information, please refer to Definitions section (in the end of this document)
    11 For more information, please refer to Definitions section (in the end of this document)

    Any personal interests (or the interests of a member of immediate family) in relation to Ciklum’s business must be
    disclosed to your manager and the Compliance Department immediately. Disclosure is mandatory, failing to disclose a
    conflict or a perceived conflict is a violation of the Code.
    In situation that appears to present a conflict of interest we expect you to “refrain and report”. If it is not possible to avoid participating in the event or activity creating the conflict, promptly disclose the potential conflict to your supervisor and the Compliance Department, and avoid participating in decisions that might raise the appearance of a conflict until you receive appropriate guidance.

    3.3. Use and Protection of Ciklum’s Resources

    We are each responsible for protecting any equipment and property to which we have access to or have been entrusted
    to safeguard, whether that equipment belongs to Ciklum company, our clients or other third parties. We need to make
    sure that these assets are not compromised, lost, damaged, misused or wasted. We use these assets exclusively for
    Ciklum’s business purposes.

    3.4. Social media

    Ciklum recognises the role that social media plays in communications and society today. However, sometimes it gets
    difficult to make clear division between one’s private voice on social media and the role as a Ciklumer. We all need to be responsible in our engagement on social media and exercise judgement when communicating in public forums. While
    engaging on social media, you should:

    • Be transparent and make it clear that you are speaking for yourself in your private capacity;
    • Recognise that anything you say can be viewed as Ciklum’s own statement;
    • Protect confidential information;
    • Be honest, accurate and ethical at all times;
    • Not announce things which you are not authorised to announce; and
    • Understand the potential consequences of your actions.

    4. Providing a Dynamic & Diverse Work Environment

    4.1. Open, Honest & Respectful

    In our relationships with each other, we strive to be open, honest, and respectful in sharing our ideas and thoughts, and in receiving input. We value the free flow of thoughts, ideas, questions and concerns. We encourage CIklumers to raise work related issues or concerns through our established processes as soon as issues or concerns arise.

    4.2. Equal Opportunity and Anti-Discrimination

    Ciklum promotes a cooperative and productive work environment by supporting the cultural and ethnic diversity of its
    workforce. Our collective challenge is to enhance the company’s performance through valuing and understanding
    differences. Ciklum is committed to a policy of providing equal employment opportunity to all qualified individuals and applicants. This commitment is reflected in all aspects of our daily operations.

    We do not discriminate on the basis of race, color, descent, sex, sexual orientation, gender reassignment, political views, confession or religious beliefs, nationality, ethnicity, marital or civil partnership status, family / career responsibilities, pregnancy and maternity / paternity status, age, disability or impairment, profession or occupation, veteran status, physical peculiarity or genetic information in any personnel practice, including recruitment, hiring, employment, compensation and benefits / remuneration, facilities and services, promotion, training and professional development, termination and references, discipline and grievance.

    4.3. Health & Safety

    At Ciklum, we are committed to creating a safe and healthy work environment by integrating sound safety and health
    practices within our operations. We comply with applicable workplace safety and health regulations.

    5. Working Responsibly and Serving Communities

    5.1. Political Activities and Contributions

    Ciklum strives to comply with all national, federal, state, and local laws and regulations. Respecting the responsibilities of government agencies and cooperating with them in good faith as they execute established guidelines and policies is essential.

    Ciklumers shall not provide anything of value to any local, state, or national or federal elected or appointed official or government employee unless the Ciklumer’s supervisor has confirmed that the item of value complies with all laws or regulations that limit or prohibit such gifts or require the gifts to be reported.
    Ciklumers are encouraged to participate in the electoral process through voting, contributing time or other appropriate means. You may not contribute funds, assets or services for, or on behalf of, Ciklum to any political candidates, political party, charity or similar organisations unless such contribution is expressly permitted by law and authorised by Ciklum.

    5.2. Community Investment

    We will make a positive social and economic contribution through our activities to the communities in which we work,
    and we will support, sponsor and contribute to the activities of other organisations, where they are aligned with our own business objectives, our values and will enhance the reputation of Ciklum.
    We contribute to charities and good causes through sponsorship and donations and by providing materials. We
    encourage our employees to give their time as volunteers to these causes. When making sponsorship commitments,
    charitable donations or promises of ‘in-kind’ support such as company materials or resources, prior approval is required and the activity must be recorded. All requests for sponsorship and charitable donations received must be approved by Compliance Director to ensure that they meet our sponsorship and charitable giving criteria.

    6. Definitions

    Who are Ciklumers?
    Ciklumers is used in this Code as the collective reference for employees (permanent or temporary, full or part time) of any Ciklum legal entity, or any of its affiliates or subsidiaries, as well as for others performing work for, or on behalf of, Ciklum.

    What is bribery?
    Broadly, bribery is defined as giving or receiving a financial or other advantage in connection with the “improper
    performance” of a position of trust, or a function that is expected to be performed impartially or in good faith.
    Bribery does not have to involve cash or an actual payment exchanging hands and can take many forms such as a gift,
    lavish treatment during a business trip or tickets to an event. The types of bribery that take place in the commercial
    sector are numerous. Some simple examples are:

    • bribery in order to secure or keep a contract;
    • bribery to secure an order;
    • bribery to gain any advantage over a competitor;
    • bribery of a local, national or foreign official to secure a contract;
    • bribery to turn a blind eye to a health safety issue or poor performance or substitution of materials or false labour charges; and
    • bribery to falsify an inspection report or obtain a certificate.

    Ciklum’s definition of bribery also includes making “facilitation payments”. A “facilitation payment” is a payment or gift given (usually to a government official) to speed up a procedure or to encourage one to be performed. It does not
    include fees required to be made by law such as the payment of a filing fee for a legal document. The acceptance of a
    facilitation payment by a government official is an example of corrupt activity.
    Ciklum defines “corrupt conduct” or “corruption” as the abuse of entrusted power for private gain.

    What is money laundering and sanctions?
    Money laundering
    ‘Money laundering’ is the process of hiding illegal sources of money. For example, under the UK Proceeds of Crime Act
    2002 (POCA) money laundering offences are committed when a person:

    • conceals criminal property
    • enters into an arrangement regarding criminal property
    • acquires, uses or possesses criminal property.

    This process is of critical importance, as it enables the criminal to enjoy these profits without jeopardising their source. Illegal arms sales, smuggling, and the activities of organised crime can generate huge amounts of proceeds.
    Embezzlement, insider trading, bribery and computer fraud schemes can also produce large profits and create the
    incentive to “legitimise” the ill-gotten gains through money laundering. When a criminal activity generates substantial profits, the individual or group involved must find a way to control the funds without attracting attention to the underlying activity or the persons involved. Criminals do this by disguising the sources, changing the form, or moving the funds to a place where they are less likely to attract attention.

    Sanctions are a foreign policy tool used by Governments to restrict the ability of designated countries, individuals or entities access to particular products, services and markets. The jurisdictions, individuals and entities who are the target of sanctions are those who particular governments view as engaging activity which is either considered abhorrent (e.g. suppression of civil rights) or would threaten international peace and security (e.g. development of a nuclear weapon).
    These restrictive measures are most commonly enforced by the UN, EU and USA.

    What is fair competition and anti-trust?
    Generally, antitrust and competition laws prohibit any activity that may improperly reduce or inhibit competition. Most competition laws and trade regulations apply to the sale and marketing of services as well as products. It is expected that each of us compete vigorously and fairly in the conduct of business matters but always in compliance with the local and other countries’ laws.

    What is personal information?
    Personal information is any information that can be used, alone or in combination with other information, to identify a specific individual. It includes such information as a person’s name, address, email address, date of birth, driving licence number, financial account numbers, passport, Social Security/Tax ID number or other government identification number and other identifiers.

    What is confidential and proprietary information?
    Confidential information includes all non-public information that might be useful to competitors or that could be harmful to Ciklum if disclosed. Proprietary information, i.e. intellectual property, includes data such as trade secrets, patents, trademarks and copyrights, and business information, research and new product plans, objectives and strategies, records, databases, salary and benefits data, employee personal and medical information, client, employee and supplier lists and any unpublished financial or pricing information.

    What is conflict of interest?
    ‘Conflict of interest’ arises where a person’s position or responsibilities within their business unit presents an opportunity for personal gain above the normal rewards of cooperation. A conflict of interest can arise in many situations, including:

    • Family and relationships among Ciklumers or with the employees of our suppliers, partners, or clients;
    • Giving or receiving gifts, hospitality, or travel;
    • Outside work activities;
    • Dealing with family members employed by a vendor or partner;
    • Dealing with a vendor or partner who employs family members; and
    • Dealing with a vendor or partner in which you or a family member have a financial interest.
  5. Anti-Slavery and Anti-Human Trafficking Statement

    Slavary and human trafficking statement


    This slavery and human trafficking statement is made on behalf of Ciklum UK Limited (“Ciklum”) and is supported by Ciklum Group offices worldwide.

    Ciklum has a zero tolerance approach to slavery and human trafficking. We are committed to addressing the contents of the Modern Slavery Act 2015 and to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

    Organisational Structure

    Ciklum is a global software engineering and technology partner. We deliver software engineering excellence to Fortune 500 and fast-growing organisations alike around the world. Details of the Group’s office locations can be found on the company’s website.


    We are committed to acting ethically and with integrity in all our business relationships and expect the same ofour suppliers and those we work with. We are considering any further due diligence procedures or requirements which it would be appropriate to put in place to assist with and furtherthis commitment.

    Ciklum Global Code of Conduct promotes and supports our staff to act with respect towards human rights and is obligatory for acknowledgement and implementation at all times. When in doubt about any breach of human rights, our employees can speak up according to procedures set up in the Code of Conduct.

    An Anti-Slavery and Human Trafficking Policy has been put in place in advance of the publication of this statement. This policy applies to all employees, contractors and other individuals working for the company and provides further guidance on how to identify, manage and report risks related to Slavery and Human Trafficking.

    We also have a Whistleblowing Policy in place. The Whistleblowing Policy applicable to all our employees forms part ofthe Employee Handbook and is published on the company’s intranet. This policy enables genuine concerns about any wrongdoing or breaches ofthe law, including modern slavery laws, to be raised in confidence and without fear of disciplinary action.

    Ciklum also provides periodical and obligatory training to its relevant staff on related topics such as Anti-Bribery, Corruption and Dignity at Work.

    This statement will be reviewed annually and made available on our website.



    For and on behalf of

    08 September 2017

  6. Whistleblower Policy

    November 2017

    1. Terms and definitions

    Ciklum or Ciklum Group
    Ciklum or Ciklum Group is a group of companies that directly or indirectly are under common control of Ciklum Group Holdings Limited Holding Company, BVI and operating under Ciklum Trademark.


    Ciklum defines “corrupt conduct” or “corruption” as the abuse of entrusted power for private gain.


    The collective reference for employees, permanent or temporary, full or part time, of any Ciklum legal entity, or any of its affiliates or subsidiaries, as well as for other individuals (such as, but not limited to, contractors and private entrepreneurs) performing work for, or on behalf of, Ciklum.


    A whistleblower is anyone who has and reports insider knowledge of illegal activities occurring in an organization. Whistleblowers can be employees, suppliers, contractors, clients or any individual who somehow becomes aware of illegal activities taking place in a business either through witnessing the behaviour or being told about it.

    2. Purpose

    Ciklumers who are aware of possible wrongdoing within Ciklum have a responsibility to disclose that information to appropriate parties inside Ciklum. The purpose of the Ciklum Whistleblower Policy (hereinafter – “the Policy” or “the
    Whistleblower Policy”) is to set out the framework for collection and processing of the information from both internal and external whistleblowers.
    By implementing this Policy, Ciklum is asking and encouraging Ciklumers as well as representatives of third parties to inform responsible stakeholders of potential misconduct and unethical behaviour.
    Topics for whistleblower reports have to be directly related to the content of sections
    2-5 of the Ciklum Code of Conduct:

    This policy is not applicable for feedback on the quality of services provided by Ciklum, the maintenance of applications and equipment, as well as all for all other issues not mentioned in the table above (as the latter topics are in scope of Delivery Department, IT Help Desk and other services and facilities at Ciklum).
    Policy demonstrates Ciklum’s commitment to operate ethically.

    The two main aims of the Policy implementation are following:

    • to reduce Ciklumers misconduct and reduce Ciklum’s compliance risk1 by
      identifying and resolving allegations of business ethics and compliance
      violations – as quickly and as efficiently as possible.
    • to help all potential whistleblowers who may feel concerned or unnerved
      by a situation but don’t know how to act, by describing the right way how
      to report the issue or concern effectively and safely (under the veil of
      anonymity and having the non-retaliation shield and being protected by the
      non-retaliation2 approach).

    Requirements of the Policy are mandatory and to apply by all Ciklumers in every
    jurisdiction where Ciklum operates.

    3. Ownership, approval and periodic review

    This Policy, which is owned by the Compliance Director, will be reviewed at least annually, and any material changes will be approved by the Group CFO.

    4. Core provisions

    The Policy covers all three stages of whistleblowing process – collection, investigation and reporting.
    The key element of whistleblowing process in Ciklum is the Speak Up facility that is supported by an external provider. The external provider performs independent registration and storage of all Speak Up claims and requests.
    Speak Up facility provides:

    • A variety of mechanisms for Ciklumers to raise issues. These include reporting
      to a manager or higher up in Ciklum, as well as to human resources, legal, and
      compliance office via a 24/7/365 phone or web intake process, e-mail
    • Tracking and case management processes to make sure reported incidents
      are collected in a centralised location, resolved in a timely manner, and accurately reported – no matter where they originate.
    • Access to a centralised data source to identify trends and gaps in Compliance
      programme, determine where training is needed, locate “hot spots” within Ciklum, and
      update any unclear or outdated policies.

    5. Non-retaliation

    Ciklum guarantees that Ciklumers who in good faith disclose perceived wrongdoing to the designated parties inside the organization or via Speak Up facility will be protected from adverse employment consequences According to Ciklum Code of Conduct (Section 5), Ciklum will not tolerate any discrimination against anyone who has reported a concern in good faith.
    Incidents of retaliation against any Ciklumer reporting a violation or participating in the investigation of a reasonably suspected violation will result in appropriate disciplinary action against anyone responsible, including possible termination of employment. Those working for or with Ciklum who engage in retaliation against reporting Ciklumers may also be subject to civil, criminal and administrative penalties.

    6. Speak Up collection methods

    The operation of the Speak Up facility is based on four methods of information collection:

    1. Hotline (phone) Toll-free numbers for every jurisdiction

      Every Ciklumer as well as any third party representative have a 24/7 access to hotline with the purpose to report an incident anonymously3 or with providing its name.
      Ciklum’s Hotline is a toll-free number available in every country where Ciklum
      operates 24/7 with English-speaking phone operator support.

      Phone numbers:
      USA Call Toll Free: 1-866-921-6714
      UKRAINE Call Toll Free: 0-800-50-35-59
      POLAND Call Toll Free: 800-112-47-17
      DENMARK Call Toll Free: 00-800-2002-0033
      SWITZERLAND Call Toll Free: 00-800-2002-0033
      SPAIN Call Toll Free: 00-800-2002-0033
      UK Call Toll Free: 00-800-2002-0033
      ISRAEL Call Toll Free: 00 or 014-800-2002-0033
      BELARUS 1-604-922-5953 (Collect Call to WhistleBlower Security)
      PAKISTAN 1-604-922-5953 (Collect Call to WhistleBlower Security)

    2. E-mail

      Reporting to ciklum@integritycounts.ca is a preferable option in case reporter does not feel comfortable speaking with a live operator or does not have a private location available to make a call. With ciklum@integritycounts.ca, reporters can type information and take time to think about and review what they have written before send an e-mail. E-mail reporting is secure, confidential, and accessible 24 hours a day.

    3. “Open door”
      “Open door” method means arranging a meeting with Ciklumer’s line manager. The result of reporting an incident via “Open door” is the completed incident form via IntegrityCounts™ by line manager as a Reporter under the link https://www.integritycounts.ca/org/ciklum.
    4. Web-based tool
      Ciklum Speak Up web-based tool is fully supported by an external provider.

    It is available under the link https://www.integritycounts.ca/org/ciklum and provides an interface that is available 24/7 for anybody who wants to raise an issue or concern. In the process of registration of the message, there is an opportunity for the reporter to exclude from the list of recipients those whose notification, in the reporter’s opinion, is undesirable.

    Information on registered claims is sent by the external provider to the Compliance Department.

    If a reporter manually excludes Compliance Department representatives from a notification list, the corresponding message will proceed directly to the CHRO (Chief HR Officer).

    7. Investigating and Reporting

    Upon receipt of the initial message, Compliance Department decide whether to investigate reported incidents, or to forward the initial message to another department corresponding to the message subject.
    Compliance Department investigates cases of corporate fraud, bribery, and other financial crime violations or matters of compliance risk as prescribed by the Code of Conduct and Ciklum Compliance Policy (refer to table at Section 2.Purpose of this document).
    A log of all reported incidents should be provided on a quarterly basis to the Board of Directors4.
    Incidents that include allegations against Leadership Team members and those that could cause serious reputational or financial losses for Ciklum are escalated to the Board of Directors. Compliance Director performs first review of the internal investigation report at the latest, within two weeks of the decision to investigate. The investigation shall be completed as soon as possible, but by 5 weeks from the date when Compliance Department received the initial information at the latest.
    Based on the results of the investigation, Compliance Department issues an Internal Investigation Report, which is presented to Compliance Director for approval. Based on the results of the investigation, the Compliance Director has to assess the reasonability and appoint if needed a meeting with relevant managers following the investigation to discuss and plan necessary corrective actions.

    8. Training and Awareness

    The Compliance Director is responsible for ensuring that all Ciklumers have sufficient awareness of this Policy and know how to report incidents using Speak Up facility as well as fully aware of non-retaliation approach. All Ciklumers will be provided with Whistleblower Policy web-based training on an annual basis, and no longer than thirteen months after the last training session took place.
    This training will be followed by a mandatory test that all Ciklumers must pass based on their understanding of the material communicated. Respective training activity must be documented and maintained as required by the Company’s record keeping Policy.

    9. Availability of the Policy

    This Whistleblower Policy is available on the Ciklum Corporate intranet site.

    1 Refer to Ciklum Compliance Policy – Chapter 1.3 Compliance Risk
    2 Refer to Section 5. Non-retaliation
    3 Be aware that Spain legislation prohibits anonymous reports.
    4 The responsibility of CHRO who has an access to the Speak Up system.

  7. Fair Processing

    Based on Ciklum Fair Processing Policy

    Contact information of Ciklum and our Data Protection Officer

    If you have any questions regarding your personal data, feel free to contact Ciklum  or its Data Protection Officer.


    Information Ciklum may collect from you or third parties

    Ciklum may collect and process information that you provide, e.g., hard copies, emails, and/or via data rooms. Ciklum may process personal data of clients and other third parties (e.g., users, consumers, vendors, suppliers), which may include, for example, contact details and full names. To develop applications or other IT products for clients, Ciklum may also process sensitive personal data from third parties (e.g., sensitive personal data of third parties, including, for example, data about sexual orientation of end users). Please visit Ciklum website for further information regarding the Privacy Policy. Ciklum will not process personal data if such is prohibited in the respective country or jurisdiction of processing.

    Purposes of processing

    All personal data received will only be used for the purpose(s) expressly specified in the consent form or consent clauses signed by you as a data subject or as instructed by the data controller, if Ciklum is acting as the Processor of Personal Data. In case the purpose of processing will be changed to a purpose contradictory to the purpose(s) for which the consent was given, and in case Ciklum is acting as the Controller, it will contact you for additional consent, if necessary.

    Processing based on the legitimate interests of the Controller or a third party

    Ciklum, if obliged, will provide you separately with information about the existing legitimate interests on which the processing is based.

    Recipients of personal data

    Ciklum, if obliged, will provide you separately with the information about the recipients of your or a third party’s personal data.

    Where Ciklum stores your personal data

    The data collected by Ciklum is stored within the information technology systems, owned and operated by Ciklum, and in the cloud systems. All information you provide to Ciklum is stored (including backups) on secure servers. Unfortunately, the transmission of information via the internet or email is not completely secure, and, although Ciklum will do its best to protect your personal data, we cannot guarantee the security of your data, transmitted over the internet to our site, or by email to our email servers; any transmission in this regard is at your own risk. Once Ciklum receives personal data from you or a third parties, it will use all reasonable procedures and security measures to avoid unauthorised access, loss, disclosure or amendment of the data.

    How Ciklum processes your personal data

    Personal data is processed by way of collecting, recording, organising, storing, using, structuring, adapting or altering, retrieving, consulting, disclosing by transmission, disseminating or otherwise making available, aligning or combining, restricting, and erasing or destructing. If legally obliged, Ciklum will also inform you about the transfer of the provided personal data to third parties in addition to the ones you were informed about before. Ciklum will not transfer the provided personal data outside EEA without reasonably ensuring that the rights and freedoms of the data subject are protected and that you are informed of such transfer, if necessary. Ciklum will not sell or pass the provided personal data to a third party for the purposes of direct marketing.

    Storage period for personal data

    Ciklum adopted storage periods for personal data. Based on this, we ensure that all provided personal data will not be processed longer than necessary.

    Your rights

    As a data subject you have the following rights:

    • right to obtain information in relation to your personal data;
    • right to access your personal data;
    • right to data portability;
    • right to withdraw the consent;
    • right to correct mistakes in your personal data;
    • right to stop the unwarranted processing;
    • right to be forgotten (erase your personal data);
    • right to be aware of the existence of the automated individual decision-making and to object in this regard;
    • right to lodge a complaint to a supervisory authority.

    For more details, please contact our Data Protection Officer on data.privacy@ciklum.com 

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As a result of submitting completed “Contact Us” form, your personal data will be processed by Ciklum Group and its subsidiary entities worldwide. Please read our Fair Processing Notice and Privacy Policy for more information. If you have any questions or would like to withdraw your consent, please send your request to data.privacy@ciklum.com

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Ciklum has updated its Privacy Policy on May 25, 2018. See the updated Privacy Policy here.
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