Introduction 

Netcraft is committed to acting ethically in all business dealings. This Netcraft Code of Conduct articulates Netcraft’s commitment to ethical working conditions and business operations.  This Netcraft Code of Conduct is not intended to reduce, replace, or limit any of Netcraft’s legal or contractual obligations, and is not intended to serve as a replacement or substitute for any applicable laws, rules, standards, codes or regulations (“Laws”).   Netcraft conducts business in accordance with the Laws of the countries in which it operates at all times, as well as following this Netcraft Code of Conduct. If local Laws are less restrictive than this Netcraft Code of Conduct, Netcraft, at a minimum, complies with the Netcraft Code of Code. If local Laws are more restrictive than this Netcraft Code of Conduct, Netcraft, at a minimum, complies with local Laws.  Netcraft will establish policies and procedures to ensure and manage compliance with this Internal Code of Conduct and all Laws.  Netcraft’s Code of Conduct applies to all Netcraft employees, directors and officers in every country.   

Labour and Human Rights 

Netcraft conducts business in accordance with all local Laws concerning working hours and conditions for all Workers, including but not limited to minimum wage Laws. Netcraft also respects its Workers’ human rights. “Worker(s)” means contractors, direct employees, student interns or any other type of worker of Netcraft. Netcraft complies with human rights Laws. Working weeks do not exceed the maximum set by local Laws, unless opt outs are agreed in accordance with local Laws.   Netcraft: (a) respects its Workers’ rights to freely associate and bargain collectively in accordance with all Laws; (b) complies with all wage Laws when compensating its Workers; and (c) has a zero-tolerance policy for inhumane or cruel treatment. Netcraft respects its Workers’ rights to join or not join labour unions, seek representation or join workers’ councils in accordance with local Laws.   Netcraft does not allow, permit or otherwise tolerate harsh or inhumane treatment, including without limitation any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, verbal abuse or threat of any such treatment with regard to its Workers. 

Netcraft does not engage in unlawful layoffs of its Workers, including temporary layoffs to promote or increase company revenue or turnover. Further, wage deductions as a disciplinary measure or to keep Workers tied to Netcraft as their employer or to their current roles, are prohibited.  

Modern Slavery and Child Labour 

Netcraft does not use Child labour. “Child” means any person who is either: (a) under the age of fifteen (15); (b) under the minimum age for employment; or (c) under the local legal age for completing compulsory education. Netcraft has procedures in place to verify and maintain documentation that none of its Workers are younger than the local legal age for completing compulsory education. Netcraft may run voluntary and legitimate apprenticeship programs (e.g. student internships) in accordance with all Laws. Netcraft’s Workers under the age of eighteen (18) do not perform hazardous work.  All work is voluntary, with Workers free to leave at their own free will upon giving notice per their employment contract. Netcraft does not use any kind of modern slavery, including but not limited to forced labour, debt bondage, indentured servitude, involuntary prison labour, trafficking or slavery when conducting business. Netcraft, at a minimum, follows all Laws in respect of human rights violations such as human trafficking, Child labour and forced labour.  

Non-discrimination 

Netcraft is committed to creating and maintaining a workplace where workers feel safe, supported and valued. Netcraft believes that everyone has the right to work in a safe environment and Netcraft takes a zero-tolerance approach to all types of harassment and discrimination, including sexual harassment, both in the workplace and from third parties with whom Netcraft engages. As such, any third party engaging in work or business with Netcraft is expected to also adhere to with applicable law, ensuring a safe and respectful environment for all.  Netcraft does not discriminate on the basis of race, colour, sex (including pregnancy, childbirth, breastfeeding or related medical conditions), ancestry, physical or mental disability, legally protected medical condition, family care status, gender, gender identity or expression, sexual orientation, age, religion, disability, marital status, caste, political affiliation, veteran status, national origin, citizenship, cultural, religious, personal beliefs, or any other relevant characteristics in hiring and employment practices such as, without limitation, promotions, rewards and access to training ("Characteristics”).  Netcraft also takes a zero-tolerance approach against unlawful discrimination or harassment on the basis of a perception that someone has any of these Characteristics or is associated with a person who has or is perceived as having any of these Characteristics. Netcraft’s Workers and potential Workers are not subjected to medical tests that could be used in a discriminatory way.  All Netcraft Workers, irrespective of the Characteristics above, are treated fairly and equally.   

Whistleblower Policy 

Netcraft has communicated a process for its Workers to raise grievances without concerns of harassment, intimidation or reprisal. Netcraft also protects Whistleblower confidentiality, including without limitation establishing and maintaining procedures that ensure Whistleblowers’ confidentiality and protection. “Whistleblower” means any person who makes a disclosure about illicit conduct by: (a) a Netcraft employee, officer, or Worker; (b) a public official; or (c) an official body.  

Health and Safety 

Netcraft provides a safe and hygienic working environment for its Workers, including without limitation clean toilet facilities and access to potable water. Netcraft also takes all reasonable measures to avoid and/or mitigate any health and safety risks.   Netcraft complies with all applicable local health and safety Laws and takes proactive measures to prevent workplace hazards or illnesses that may be caused by conditions in the workplace. Procedures and systems are in place to manage, track and report occupational injury and illness.   Netcraft Workers are not disciplined or retaliated against in any way for raising safety concerns.   

Environment 

Netcraft follows all environmental Laws, including (but not limited to) Laws relating to air emissions controls, wastewater treatment and discharge, conflict minerals, air emissions, environmental permitting, environmental reporting and chemical and waste management, including Laws relating to recycling and waste disposal.   Netcraft will procure, maintain, keep current, and adhere to the operational and reporting standards of all required environmental approvals, registrations, and permits.   Netcraft does not engage in unlawful eviction or unlawful deprivation of land, forests and waters in the acquisition, construction or any other use of land, forests, and waterways, the use of which secures the livelihood of any person.  

Anti-Bribery and Corruption 

Netcraft has zero tolerance for all forms of bribery and corruption. Netcraft does not make, permit, offer, give, promise or authorise any bribe, loan, fee, reward or other advantage to any government official, employees of any government or public or international organisation, customer, supplier, or any other person to obtain any business or improperly influence any action or business decision that is related in any way to Netcraft. Netcraft also does not use bribes, kickbacks, any bartering arrangements, payments of money or change in terms of the contractual relationship to improperly influence business decisions.   Netcraft does not tolerate any form of corruption, bribery, extortion or embezzlement.  Netcraft complies with all international, national and local anti-corruption Laws, including the U.S. Foreign Corrupt Practices Act and the UK Bribery Act.   

Conflicts of Interest 

Netcraft avoids any actual, potential or perceived conflicts of interest in its business decisions. This includes any conduct, situation or circumstance where an actual or perceived conflict of interest may occur. Netcraft does not offer or provide excessive hospitality or entertainment or more than nominal gifts to any of its customers, customers’ Workers, or customers’ Workers’ families to obtain or retain business or to influence a decision.  

Insider Trading 

Netcraft complies with insider trading and Securities Laws. “Securities” include common stocks, bonds, options, futures, and other financial instruments. Without limiting the foregoing, Netcraft ensures that any non-public information obtained as a consequence of its business relationships is not used for the personal benefit of Netcraft Workers or any other persons.   Netcraft employees that have access to material, non-public information are not permitted to use or share that information for stock trading purposes or for any other purpose, except as required by their employment with Netcraft.  

Antitrust, Competition and Export Control 

Netcraft is committed to observing all antitrust, competition and export control Laws of all nations or organisations. Netcraft complies with economic sanctions, export controls and anti-boycott Laws, and with the trade Laws of the countries where Netcraft does business. Netcraft also complies with all competition and antitrust Laws and does not participate in activities that have the effect of reducing or destroying competition, such as price fixing, bid rigging, market allocation or otherwise unfairly excluding or foreclosing competitors from the marketplace.  Netcraft does not enter into any agreements (whether express or implied, formal, informal, reached orally or in writing) that violate economic sanctions, export controls, anti-boycott, competition, or antitrust Laws. Netcraft does not provide services from countries or regions that are subject to import and export control and sanction Laws, including without limitation the Laws of the United Kingdom, the European Union, the United States of America and the United Nations. Netcraft ensures that the provisioning of products and services to Netcraft by its suppliers is not supported by entities or individuals with whom transactions are prohibited under export control and sanctions Laws, including those listed on any applicable sanctioned party lists for the United Kingdom, the European Union, the United States of America and the United Nations.  

Personal Data and Confidential Information 

Netcraft protects all personal data received during the course of its business operations. When personal data is stored, collected, processed, transmitted, or shared, Netcraft complies with E.U. and U.K. GDPR and information security Laws.  Netcraft protects non-public or confidential information, does not disclose it to any unauthorised third party and only uses such information for the purpose for which it was made available to Netcraft. Netcraft will only allow individuals who have a need-to-know access to confidential information, and such individuals may only use it for the purpose for which it was made available to Netcraft per an applicable contractual agreement. Netcraft safeguards the confidentiality, integrity, availability, security and privacy of any materials and communications containing personal, confidential or otherwise protected data or information. Netcraft implements appropriate administrative, technical, organisational and physical safeguards for the protection of such data in accordance with applicable contractual agreements, the highest industry standards and Laws.   If Netcraft is permitted or required to use or access any personal data or confidential information, Netcraft only uses that personal data and confidential information: (i) for the purpose for which that personal data and confidential information is used or accessed under the relevant commercial relationship with Netcraft; and (ii) as permitted and consistent with any governing policies or agreements.