This Code of Business Conduct and Ethics (the “Code”) applies to all directors, officers, and employees of Fewmoretaps OÜ d/b/a Trustname.com (“Trustname” or the “Company”), and—unless otherwise specified—also applies to contractors, consultants, agents, and other representatives who provide services to Trustname (collectively, “Personnel”).
We created this Code to protect Trustname’s long-term interests and to promote ethical, lawful, and responsible business conduct. Noncompliance may result in disciplinary action, up to and including termination of employment or contract, and may also expose individuals and Trustname to legal and reputational risk.
A. Purpose
This Code is intended to ensure and promote:
- Fair and accurate books and records, including financial reporting;
- Ethical conduct and compliance with applicable laws, rules, and regulations;
- Prompt internal reporting of violations of this Code;
- Honest and ethical conduct, including proper handling of actual or apparent conflicts of interest;
- A culture of honesty, integrity, and accountability; and
- The deterrence of wrongdoing.
This Code serves as a set of guiding principles. It cannot cover every situation. If you are unsure how to proceed, seek guidance from your manager or the Trustname Legal/Compliance function. You may also apply the “headline test”: if your decision appeared as a headline in a major publication, would it reflect well on you and Trustname? If the answer is no—or unclear—pause and seek guidance.
You are expected to read, understand, and comply with this Code. Trustname’s Legal/Compliance function is responsible for applying these policies to specific situations and has the authority to interpret this Code.
This Code should be read together with any additional Trustname policies applicable to you (including security, privacy, acceptable use, and employment/contractor policies). Any determination regarding the application of this Code to directors or senior executives may be made only by Trustname’s management and/or supervisory body as applicable under Estonian law and Trustname’s governing documents.
B. Financial Reports and Other Records – Disclosure
Personnel are responsible for accurate and complete reporting of financial and operational information within their areas of responsibility, and for timely escalation of information that may be material to Trustname.
Trustname expects all Personnel to take this responsibility seriously to ensure full, fair, accurate, timely, and understandable disclosure in reports and documents the Company provides to regulators, counterparties, auditors, banks, or the public (as applicable).
Trustname’s books, records, accounts, and financial statements must be maintained in reasonable detail and must accurately, fairly, and completely reflect the matters to which they relate. They must conform to applicable legal requirements and the Company’s internal controls. All Company assets must be carefully and properly accounted for.
- No undisclosed or unrecorded account or fund may be established for any purpose.
- No false or misleading entries may be made in Company books or records for any reason.
- No disbursement of Company funds or property may be made without proper authorization and adequate supporting documentation.
- Misclassification of transactions as to accounts, business units, or accounting periods is prohibited.
Every person has a responsibility to avoid participating in any false or misleading accounting or reporting. Failure to follow proper approval and documentation processes may result in disciplinary action and may create legal and operational consequences for the Company.
C. Conflicts of Interest
A conflict of interest is any activity, interest, relationship, or situation that interferes—or appears to interfere—with your ability to act in Trustname’s best interests. Your actions and decisions must be based on Trustname’s interests, not personal relationships or benefits. You must never use your position with Trustname to obtain improper personal benefits.
Any actual or potential conflict of interest must be disclosed to Trustname and avoided unless approved in writing by the Company.
Examples of conflicts of interest include:
- Family Members. You may not conduct business on behalf of Trustname with family members or an organization with which a family member is associated (including vendors), unless disclosed and approved in writing in an arms-length transaction. “Family members” include spouse/partner, parents, children, siblings, and in-laws.
- Interests in Other Businesses. You may not accept compensation for Trustname work from any source other than Trustname. You should not have an undisclosed material financial interest in a competitor, supplier, customer, or business partner.
- Improper Conduct and Activities. You may not engage in conduct inconsistent with Trustname’s best interests or that materially disrupts or impairs Trustname’s business relationships.
- Gifts and Hospitality. Modest and appropriate hospitality may be acceptable. However, gifts or hospitality must never influence—or appear to influence—business decisions, and must comply with Trustname’s anti-bribery and corruption rules. Extra care is required with government or public officials (including public international organizations). When in doubt, consult Legal/Compliance before offering or accepting anything of value.
- Personal Use of Company Assets. You may not use Company assets, labor, or information for personal use beyond incidental use, unless approved by Trustname.
If you are aware of an actual or potential conflict of interest, discuss it with your manager and obtain approval from Trustname’s Legal/Compliance function before proceeding.
D. Corporate Opportunities
Personnel owe a duty to advance Trustname’s legitimate business interests. You may not take for yourself—or direct to a third party—any business opportunity discovered through your role at Trustname or through the use of Company property or information, unless Trustname has been offered the opportunity and declined it.
You are prohibited from using your position or Company property or information for personal gain and from competing with Trustname, directly or indirectly.
E. Protection of Assets and Confidentiality
You must protect Trustname’s assets and ensure they are used efficiently and only for legitimate business purposes. Suspected fraud, theft, or misuse must be reported promptly.
In carrying out Trustname’s business, you may learn confidential or proprietary information of Trustname or third parties (customers, suppliers, partners). “Proprietary Information” includes any non-public information that could be useful to competitors or harmful to Trustname or its customers if disclosed, including (without limitation) trade secrets, source code, security practices, product plans, financial information, pricing, vendor and customer information, and personnel compensation information.
You must:
- Maintain confidentiality of Proprietary Information;
- Use it only for authorized business purposes and according to any restrictions imposed by the disclosing party;
- Share it only with those who have a legitimate need to know and are bound by confidentiality obligations; and
- Disclose it only when authorized or legally required.
Your confidentiality obligations continue after your relationship with Trustname ends. Questions about whether information is confidential should be directed to Legal/Compliance.
F. Communications
Clear and consistent communication is important. Public statements on behalf of Trustname must be accurate, complete, and not misleading. Only authorized spokespersons may respond to media or public inquiries about Trustname.
If you are contacted by the media or an external party for comment about Trustname, refer them to the designated communications contact or management. Remember you may be viewed as a Trustname representative at all times—follow confidentiality obligations and applicable social media and communications guidelines.
G. Fair Dealing
Trustname competes through honest business practices. We do not seek competitive advantages through illegal, unfair, or unethical means. You must deal fairly with colleagues, customers, service providers, suppliers, partners, and competitors. Never take unfair advantage through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or other unfair dealing practices.
H. Compliance with Laws, Rules, and Regulations
You must comply with all applicable laws in carrying out responsibilities on behalf of Trustname and refrain from illegal conduct. You are expected to understand the laws and regulations relevant to your role. If a law conflicts with this Code, you must follow the law and seek guidance from Legal/Compliance.
Key topics include:
- Competition / Antitrust. Competition laws prohibit agreements or practices that restrain trade or unfairly exclude competition. The rules can be complex—consult Legal/Compliance before engaging in conduct that could implicate competition laws.
- Health, Safety, and Environment. Trustname strives to operate in a manner that promotes safety and environmental responsibility. Compliance with applicable health, safety, and environmental laws is required.
- Fair Employment Practices. Trustname is committed to a respectful, professional workplace with equal opportunity. Discrimination or harassment on any protected basis is prohibited. Trustname prohibits retaliation for good faith reports or participation in investigations.
- Political Activities and Lobbying. Political contributions and lobbying may be regulated and may require pre-approval. You must not use Trustname resources to support political activities in a way that suggests Trustname endorsement without authorization. Never offer anything of value in exchange for official action.
- Anti-Bribery and Anti-Corruption. Bribery, kickbacks, and corruption are prohibited in all dealings with customers, suppliers, and officials, regardless of local practice. Do not offer, give, or authorize anything of value to improperly influence any decision or obtain an improper advantage. Consult Legal/Compliance when dealing with government or public officials.
- Insider Trading. If you possess material non-public information about a company, you must not trade in that company’s securities or tip others. (This topic may apply if Trustname has access to sensitive information relating to partners, vendors, or customers that are public companies.)
- Human Rights. Trustname respects human rights and expects partners and suppliers to adhere to strict standards related to child labor, modern slavery, and human trafficking. See Trustname’s Human Rights Policy and Modern Slavery Statement (if published).
I. Compliance and Reporting
1. Seeking Guidance
If you are uncertain about the best course of action, seek guidance from your manager or Legal/Compliance. It is always better to ask first than to risk a violation.
2. Reporting Violations
If you know of or suspect a violation of this Code or applicable law—including concerns about accounting, auditing, bribery, corruption, discrimination, harassment, or security—report it promptly to your manager or Legal/Compliance.
Reports will be handled as confidentially as possible, consistent with law and the need to conduct a fair and thorough investigation. Trustname prohibits retaliation against anyone who reports concerns in good faith.
3. International Laws and Local Requirements
Trustname operates globally and is subject to many different laws. If local laws impose stricter requirements than this Code, you must comply with the stricter standard. When local customs conflict with this Code, consult Legal/Compliance before proceeding.
4. Investigations
Trustname will investigate reported violations promptly and thoroughly. Do not conduct your own investigation. You must cooperate fully with authorized investigations and must not withhold, tamper with, or fail to communicate relevant information. Misleading investigators, auditors, counsel, or regulators may result in immediate termination and could be criminal.
5. Sanctions
Violations may result in disciplinary action, up to and including termination of employment or contract. Individuals who direct, approve, or knowingly fail to report misconduct may also be disciplined. Certain violations may result in civil or criminal liability.
6. Protected Disclosures
Nothing in this Code is intended to restrict lawful reporting of concerns to governmental, regulatory, or self-regulatory agencies, or to restrict rights under applicable whistleblower laws.
J. Waivers of this Code
Any waiver of this Code must be approved in writing by Trustname’s authorized decision-makers in accordance with Trustname’s governance and applicable law. Where required, waivers may be disclosed as appropriate.
K. Amendment
Trustname may amend this Code at any time to reflect legal requirements, operational changes, and evolving best practices.
Compliance
Failure to follow this Code may result in disciplinary action, up to and including termination. Known or suspected violations should be reported as described above. Trustname maintains a strong non-retaliation commitment to protect those who make reports in good faith.