Code of conduct

Our way of doing things in a competitive and fast-moving environment will make us stand out. The basis of our culture has always been our actionable principles and behaviors that unite and guide us in how we do business.

Our culture focuses on a positive growth mindset – enabling and empowering people to innovate, collaborate, and learn where
we can do better. It comes in part from the founding team’s background in engineering, which involves a mindset of not settling with the status quo, constantly innovating, and learning by doing – a big part of it is that we create it all together through the decisions we make, the actions we take and behaviors we show.

Infobip aspires to be a company in which every one of us behaves and operates respectfully, fairly, and ethically. It has always been why we follow the highest possible standards of ethical business conduct.

As we operate in many countries, it may sometimes be confusing how to adhere to the applicable rules, laws, and standards and do the right thing in the right way. This code outlines

our business principles to help you understand your important role in our company and in building our culture. It affirms what we stand for.

Please read the code carefully and apply it to your daily work.

We expect everyone, no matter what country or position in the company, to comply with the principles of the code. We do
not allow disrespect or tolerate breaches of law or our internal policies.  If you have any questions, our compliance team is here to advise and guide you.

Best,

Silvio Kutić, CEO

We communicate openly, honestly, and fairly while being mutually respectful – with colleagues, customers, suppliers, or any stakeholder we are in contact with. We respect personal dignity, human rights, and privacy. We empower people.

We come from many backgrounds and nationalities, and our differences strengthen us. As a multinational company, we create an inclusive environment and encourage diversity by supporting different cultures, backgrounds, perspectives, and ideas. We believe this is equally important for people’s engagement and driving innovation to unreachable heights.

We are committed to fair and equal treatment, allowing each Bipper to reach their potential. We are a diverse workforce and do not tolerate discrimination, harassment, or bullying. We know that your skin color, gender, nationality or religion, age or medical condition, who you love, or how you self-identify does not affect your ability to do your job.

We want you to feel safe at work without worrying that you are going to injure yourself.

In the interest of our and other people’s safety, we follow safe work practices and actively report any possibly unsafe conditions. We invest in a safe and healthy environment to ensure you can do your job to the best of your abilities.

Substance abuse limits human abilities, so we are all committed to ensuring that our work is not jeopardized or impaired by the consumption of any substance. We are therefore committed to a working environment free of drugs and alcohol, imposing a strict zero-tolerance policy towards alcohol and drug consumption.

Our assets and resources include everything Infobip owns, manages, or uses to conduct business with our partners and provide customer services. Each Bipper, partner, and customer is entrusted with the care of these resources and is required to protect them!

As a Bipper, you use company assets in everyday work to perform and do your job well. Company assets, like computers, chairs, printers, hardware, software, etc., are not to be sold, borrowed, given away, or removed from the company, used for personal gain or that of another person or organization.

Within reason and under applicable regulations, Bippers may use company assets for personal use under the following conditions:

All company assets should be used in accordance with our internal policies and protected from use by unauthorized individuals.

We expect you to treat company assets with care and respect, using your common sense. By protecting company assets, we protect our business and future.

In our daily work we innovate with passion
and come up with creative ideas, processes, or designs that make us proud and contribute to our success.

That is why we are committed to preserving the Company’s intellectual property, including copyrights, patents and trade secrets or, other intangible assets created on company time and expense and by using company resources.

Likewise, we respect the intellectual property rights of others, so we never knowingly infringe on others’ copyrights, trademarks, patents, or misappropriate trade secrets. We only use the intellectual property rights of others if we have the permission and/or the license to do so.

// NOTE

Before publishing any technical documentation on Infobip’s website, please ensure it does not contain any product/solution specifics and always consult the IP_Squad ([email protected]) first.

As a Bipper you may have access to information related to different business areas that might be worth a great deal.

Such information is considered the company’s confidential information and needs to be protected. The company protects your personal data and keeps it confidential. The same applies to the company’s confidential information.

Our company might be hurt if information about our clients, suppliers, partners, sales figures, or future plans ends up in the wrong hands!

Therefore, please keep our business information, and information received from our suppliers, partners, and customers, confidential at all times and keep it to yourself.

Confidential information should be used only internally for company/business purposes. It should not be disclosed to anyone outside of Infobip unless permitted to do so or required by the law. Even inside the Company, only those Bippers who truly need to know the information to perform their tasks should have access to confidential information.

We should be careful not to discuss Infobip’s confidential information with non-employees (including family members and friends) and at places where it might be overheard by those who do not need to know it (e.g. the Company’s restaurant and restrooms, public places, airports etc.). Be aware of your surroundings when handling confidential information and do your best to avoid shoulder surfing attacks.

If you are not at your desk, lock your laptop screen and ensure you transport and store company-provided equipment safely and securely.

Use extra caution when accessing external information – don’t open suspicious emails (and don’t click on the attached links/ documents!), especially when received from people you don’t know, as well as when you plan to connect external peripheral devices to workstations (such as unverified USB devices or external HDs), otherwise, you might jeopardize all information you have access to.

If you are in doubt about your rights and obligations regarding handling confidential information, please contact the Legal Department.

We value the privacy of our Bippers and other persons who work for Infobip that share personal data with us.

The same goes for our clients and their end users, suppliers, business contacts, job applicants, and any other person with whom Infobip interacts.

We protect the data entrusted to us, and we handle it properly, using it only for the intended and by law authorized purposes. By doing so, we respect and consider the pertaining rights of the data owner at all times.

Every Bipper who collects, uses, or processes personal data
is responsible for handling the data within the scope of their work activities and must observe the required data protection and data security measures.

More information on your rights and obligations and on how we handle personal data can be found on our SharePoint.

For all questions on personal data protection, you can contact us via [email protected]

// But first things first!

We are all proud Bippers, and we are encouraged to share the company’s events, news, and happy moments.

We appreciate our Bippers being actively involved in diverse activities professionally and privately. However, please always ensure you behave responsibly and use good judgment, no matter the context. Your words and behaviors may be associated with the company.

Whether online or offline, please refrain from speaking on behalf of the company unless specifically authorized to do so. The messages that the company conveys are carefully constructed. Please leave it to our dedicated teams to handle inquiries or comments and represent our standpoints and principles.

It is equally important not to share confidential information using social media or any other media. The sending of information of a professional nature outside the company via messaging services or other external media unrelated  

to the professional environment is prohibited in principle. Please refrain from sharing, posting, or commenting, or in any other way disclosing information that has not been shared publicly through the company’s official channels and/or PR team.

Please make sure to clearly distinguish that opinions expressed on social media or otherwise are solely your own and do not express the views or opinions of the Company. While expressing your opinion, refrain from using any type of slurs, insults, or biased language. Remember, you are part of a community that promotes diversity and inclusion – we respect other people’s opinions and tackle challenges using arguments, not offensive language. The same principles apply to all internal communication channels: we respect all our colleagues and diversity.

Lastly, when in doubt about whether certain behavior is in accordance with our Social Media Policy, please consult and contact our Social Media and PR teams at [email protected], who will gladly point you in the right direction.

We take care of the only planet we have – the Earth and the communities which we operate in.

As a Bipper, each of us has a role to play in protecting our environment and is part of the solution to environmental challenges that our planet faces. We also play an active role in our immediate communities.

We conduct our business in an environmentally and socially responsible manner by ensuring our success and development do not exploit our own employees, the employees of our suppliers, communities, and natural resources.

We are committed to minimizing our environmental footprint by making changes in our everyday business and pursuing sustainable initiatives such as reducing waste, switching to renewable energy sources, conserving energy, and water, promoting recycling and many more.

It’s all about acting locally. Even our small acts can make a positive change in the communities where we work and contribute to upgrading the quality of life.

#WeAreJustStarting on our way to a more sustainable future

Our network is ever-expanding, and as we reach more diverse locations from Vodnjan, Croatia, to rural and urban landscapes across six continents, we consider the local realities and strive to improve conditions for our employees, partners, and neighbors. We are also part of the UN Global Compact voluntary initiative, in which more than 16,000 businesses worldwide have promised to adopt sustainable and socially responsible practices in areas where they operate and report on their implementation.

Each place where we do business holds a special meaning. We further our connections through partnerships, strategic alliances, and building strong networks within interdependent ecosystems. In this sense, as a company, we are careful corporate citizens, and we expect all our stakeholders to hold their own individual social responsibility and contributions to their local communities in high regard. For specific steps we take to ensure our work is done in an environmentally and socially responsible manner, you can connect with the ESG team on [email protected] to learn more.

We are committed to respecting and promoting human rights around the world, ensuring that technology and our business operations impact people’s lives for the better.

We are guided by the principles established under the UN Universal Declaration of Human Rights and International Labour Organisation Declaration on Fundamental Principles and Rights

at Work as well as its corresponding core conventions, and we do not knowingly engage in activities that are contrary to the guiding principles.

You, as a Bipper, are encouraged to be a human rights advocate and promote the fundamental values and principles of our society in your everyday business relationships with clients, suppliers, and partners.

While performing our daily jobs, we don’t let our personal interests affect the business decisions we make on behalf of Infobip.

If you use your position at Infobip for personal gain or if your personal activity could compromise your ability to make sound business decisions for Infobip, that situation is known as a conflict of interest (CoI).

To avoid conflict of interest, we must first know how to recognize it. Here are the most common examples of Col:

…or you can ask yourself: will my private interests affect my decisions while performing any of my duties in Infobip? If the answer is yes, this is a potential conflict of interest.

We are committed to conducting business with reputable clients and partners whose funds come from legitimate sources.

As a diligent Bipper, always check the (potential) client and partner to identify any potential signs of their involvement in money laundering or terrorist financing.

Money laundering is a process of integrating money generated from criminal activity into legitimate financial systems; criminals convert money and other assets into clean money or assets that have no obvious link to their criminal origins.

Infobip competes fairly and with integrity and makes its own business strategy free from arrangements with competitors and suppliers that restrict competition!

Competition rules (or “antitrust rules”) apply in all countries where Infobip does business. The objective of these rules is to ensure equal conditions for all competitors on the market by setting limits on the freedom of how to compete and prohibiting certain market behavior.

Most common example of prohibited behavior: Company X and Company Y are telecom service providers. They agree not

to lower their current prices and not to reach out to each other’s clients.

In order to respect competition rules, keep in mind to avoid any formal or informal, written or oral, explicit or tacit, or any other kind of discussion/agreement with competitors on:

// Please remember:

Violating competition laws is a serious matter that may result in substantial fines and penalties for Infobip, in some jurisdictions even with imprisonment of individuals. If you are not sure whether certain behavior/agreement is contrary to the competition rules, you can always contact the Regulator/Antitrust Team ([email protected])

Offering, promising, giving or, accepting money or anything of value to or from others in order to acquire any kind of business advantage is strictly forbidden.

Most countries where Infobip does business consider such behavior a crime. Even a relatively small gift or donation to a third party could, in some situations, be construed as a bribe and result in severe penalties for you and the company.

Therefore, employees of Infobip are advised to:

Bippers, the rule to remember here is quite simple: Don’t bribe anybody, anytime, for any reason.

Business entertainment and gifts may be offered or accepted:

// Please remember:

The exchange of entertainment and gifts is strictly prohibited during tender or competitive bidding processes, as the entertainment or gifts in such cases may be seen as influencing business transactions.

We expect our suppliers and clients to comply with all applicable laws and international human rights, as a minimum.

Here’s a short description of the business partners we value and want to work with:

…and they share the vision of behavior as set in this Code.

// Please remember:

Infobip is committed to all applicable standards of ethical and responsible business conduct, including but not limited to all applicable customs, export control, anti-boycott laws, and regulations, as well as all relevant economic and financial sanctions and trade embargoes. Therefore, Infobip does not conduct business with third parties that are subject to any type of trade embargoes, sanctions or other regulatory restrictions.

If you have any questions concerning this, please reach out to the Compliance team.

Remember, it is vital that you speak up and address your concerns. Our company is dedicated to ensuring a safe
and pleasant workplace for all Bippers as well as compliant business conduct according to the applicable rules, regulations, and internal policies, but we need your help in detecting any irregularities. Breaches of the law or internal policies may have consequences, both legal and employment-related implications.

We are aware that such situations may be stressful and uncomfortable. However, ignoring inappropriate behavior only serves to make the problem worse as we are not doing anything to fix it. For this reason, please rest assured that we will have zero tolerance for retaliation. No Bipper will suffer any adverse

consequences for reporting a concern and/or being involved in an investigation following such a report.

To whom do I send the question about the Code or how do I report a concern?

If you have any questions regarding the code you can always send an e-mail to the Compliance team – the mailing address is Compliance_Infobip@infobip.com.

To report non-compliance with the code or any other regulation, law, or Infobip’s policy, you can use the address [email protected] or the Speak-Up Platform. In the process of resolving of such reports, the Compliance team will involve the relevant stakeholders. The Ethics Committee will confirm the final assessment.

You may choose to stay anonymous and use our Speak-Up Platform, but we encourage you to provide your name and contact details because anonymous reports can be more difficult to investigate.

You will receive feedback on your report in the same way you submitted it.

We strongly encourage you to seek help and advice from our Compliance Team whenever needed. The Compliance Team will ensure that:

// Please remember:

Infobip will never tolerate retaliation against or the victimization of any Bipper who raises a concern in good faith.
Please speak up to safeguard the Bip Culture and reputation.