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Code of Conduct

Effective Date: September 17, 2026

1. Introduction

This Code of Conduct (this "Code") sets out the ethical standards and business practices expected of everyone who works for or represents Omorodion Holdings Limited ("Omorodion", "we", "us", or "our"), a business-to-business (B2B) website and mobile application development and support company that also builds and operates its own websites. The Code is our ethical compass: it does not attempt to list every situation you may face, but it establishes the principles and boundaries that should guide your judgment when it does not.

Omorodion operates in a position of trust. Our clients give us access to their brands, source code, systems, customer data, credentials, and confidential business plans. Everything in this Code exists to protect that trust and to ensure we compete, advise, and deliver services with integrity.

This Code supplements, and does not replace, applicable law, your employment agreement, and any client-specific confidentiality, data protection, or security requirements set out in a Service Agreement.

2. Who This Code Applies To

This Code applies to all Omorodion employees, officers, and directors, regardless of role, seniority, or location, as well as to contractors, freelancers, and agency partners engaged to perform work on Omorodion's behalf. There are no exceptions.

Every person covered by this Code is expected to act as a role model. How you treat colleagues, clients, vendors, and the technology platforms we work with reflects directly on Omorodion's reputation and on the clients whose products we build.

3. What Is Expected of You

We expect everyone covered by this Code to:

  • conduct business honestly, professionally, and ethically at all times, including in client-facing communications, project reporting, and technical work;

  • become familiar with this Code and with the policies relevant to your role, including any client-specific data handling or system-access requirements;

  • ask for guidance from your manager, Legal, or Compliance whenever you are uncertain how to apply this Code to a real situation;

  • speak up if you notice a policy, client instruction, or business practice that appears to conflict with this Code or with the law;

  • report suspected misconduct promptly, using the channels described in Section 5.

4. How We Conduct Our Business

4.1 Anti-Bribery and Anti-Corruption

We do not offer, promise, give, or accept bribes or other improper payments or advantages, directly or indirectly, to obtain or retain business or any improper advantage. This applies to dealings with clients, prospective clients, vendors, technology and hosting platforms, government officials, and any other third party.

Improper advantages are not limited to cash. They include gifts, meals, entertainment, travel, charitable donations made on someone's behalf, political contributions, and job or internship offers extended to influence a business decision. If you are ever uncertain whether something crosses this line, consult Compliance before proceeding.

4.2 Gifts and Entertainment

Modest gifts and entertainment can be a normal part of building client and vendor relationships, but they must never be offered or accepted in a way that could influence, or appear to influence, a business decision - including which vendor, hosting provider, or subcontractor is selected, or which company wins or retains a project.

Gifts or entertainment are inappropriate if they are intended to influence a decision, consist of cash or cash equivalents, are illegal, would violate the recipient's own employer's policies, or could embarrass Omorodion or the client if made public. Extra caution and pre-approval are required for any gift or entertainment offered to a government official, or exchanged during an active pitch, procurement process, or contract negotiation.

4.3 Charitable Donations and Political Contributions

Any donation made in Omorodion's name, or using client project budget, requires prior approval from Compliance and appropriate due diligence on the recipient. Personal charitable giving is welcome but must be made independently and never presented as a contribution from Omorodion or a client.

Company funds, time, or resources must not be used to support a political party, candidate, or cause. Personal political activity is your own choice, but it must not be conducted in a way that suggests Omorodion's endorsement, including on social media accounts associated with your role at the company.

4.4 International Trade Compliance

Where we work with clients, vendors, or technology platforms based in other countries, we comply with applicable export controls, trade sanctions, and anti-boycott laws. This includes screening new clients and vendors where required, and not knowingly developing software for, transferring funds to, or providing services that would violate applicable sanctions or restricted-party lists.

4.5 Conflicts of Interest

You must act in Omorodion's and our clients' best interests, not your own. Disclose any situation where your personal interests could conflict, or appear to conflict, with those interests - actual, potential, or perceived conflicts are all covered by this policy.

Examples specific to development and support work include:

  • accepting freelance work, equity, or a board or advisory role with a current or prospective client, competitor, or vendor without disclosure and approval;

  • being staffed on, or having influence over, two directly competing client projects without appropriate conflict screening and information barriers;

  • steering project budget, subcontractor work, or vendor selection (including hosting or cloud providers) toward a company in which you or a close family member has a financial interest;

  • having a close personal relationship with someone you supervise, or with a client decision-maker whose project you manage, without disclosing it;

  • using knowledge gained through your role at Omorodion to personally trade in a client's securities, to copy a client's proprietary code or business idea for yourself, or to pursue a business opportunity that belongs to Omorodion or a client.

If you identify a potential conflict, disclose it to your manager or to Legal/Compliance before proceeding, so it can be assessed and, if needed, managed.

4.6 Confidentiality and Client Data Protection

In the course of our work we routinely handle non-public information belonging to Omorodion and our clients, including source code, system architecture, credentials and access keys, project budgets, product roadmaps, unreleased designs, customer and prospect data, and personal data processed on a client's behalf. This information must be protected at all times.

Share confidential information only with colleagues or approved subcontractors who have a legitimate business need to know it, and only for the purpose for which it was shared. Do not discuss client projects, systems, or technical strategy in public places, on personal social media, or with anyone outside Omorodion without authorization. Treat client data with the same care as our own, and follow all client-specific data protection requirements, applicable data protection law (including the GDPR), and Omorodion's Privacy Policy when handling personal data on a client's behalf.

Confidentiality obligations continue after your engagement with Omorodion ends.

4.7 Company and Client Assets, Intellectual Property

Use Omorodion's and our clients' equipment, source code repositories, hosting and cloud accounts, software licenses, and systems only for legitimate business purposes; incidental personal use of company equipment should be limited and never interfere with your work or violate policy.

Respect intellectual property rights. Do not use client brand assets, source code, or project data outside the scope agreed with the client, and do not reuse one client's source code, architecture, or proprietary data for the benefit of another client without the first client's consent. Do not access systems, accounts, or data you are not authorized to access, and never use company or client systems to harass, defraud, infringe, or otherwise break the law. Report any suspected misuse of company, client, or third-party intellectual property immediately.

4.8 Side Deals and Unauthorized Commitments

All commitments to clients and vendors - scope, pricing, commissions, rebates, discounts, or service levels - must be documented in an executed Service Agreement, statement of work, purchase order, or other document approved through Omorodion's standard contracting process. No one may make verbal or informal side commitments that create, modify, or waive an agreement without authorization from Legal.

4.9 Vendor Selection Transparency and Rebates

Where we recommend or manage hosting providers, cloud infrastructure, software licenses, or other vendors on a client's behalf, we act with full transparency about costs, fees, and any value we receive from those vendors. Any rebate, referral fee, credit, or other value received from a vendor in connection with client spend must be disclosed to the client in accordance with the Service Agreement and applicable industry standards, and must never be concealed or allowed to influence vendor recommendations to Omorodion's benefit over the client's interest.

Do not accept undisclosed commissions, kickbacks, or personal benefits from a vendor, hosting provider, or platform in exchange for directing client budget their way.

4.10 Truthful Reporting and Code Quality Integrity

Clients rely on us to report project status, testing results, and technical performance accurately. Do not manipulate, inflate, or misrepresent metrics such as test coverage, bug counts, uptime, load times, or completion status, and do not misrepresent that code has been reviewed, tested, or security-checked when it has not. If you become aware of suspected misrepresentation, undisclosed security vulnerabilities, or reporting irregularities on any project, report it immediately to your manager or Compliance so it can be corrected and, where appropriate, disclosed to the client.

4.11 Platform and App Store Compliance

Projects must comply with the developer policies and technical requirements of the platforms we build for or deploy to (such as the Apple App Store, Google Play Store, and cloud hosting providers), as well as applicable data protection, accessibility, and consumer protection law. Do not knowingly submit misleading claims, prohibited content, or code that violates platform policy or security best practices, and escalate any client request that would require us to do so.

4.12 Sustainability and Environmental Responsibility

We aim to minimize our environmental footprint, including through efficient use of energy, equipment, and business travel, and by favoring digital, low-waste ways of working where practical. Comply with applicable environmental laws and any Omorodion sustainability commitments, and raise concerns about practices that seem inconsistent with them.

4.13 Responsible Use of Generative AI

Generative AI tools can support research, copywriting, code generation, design concepting, and technical analysis, but their use must be transparent, disclosed where required by a client or by law, and consistent with this Code and applicable Omorodion technology policies.

Before using AI-generated output (including code) in client Deliverables, review it carefully for factual accuracy, security vulnerabilities, license compliance, bias, and unintended similarity to third-party copyrighted or trademarked material, and confirm the tool's licensing terms permit commercial use of its output. Do not input client confidential information, source code, or personal data into a generative AI tool unless it is an approved, contractually covered tool. When in doubt about a specific use case, contact Legal or Compliance before proceeding.

4.14 Fair Dealing

Win and keep business on the strength of our work, not through unethical or unlawful practices. Do not acquire a competitor's or another company's confidential pitch materials, pricing, source code, or trade secrets through improper means, and do not pressure a new hire, freelancer, or partner to disclose a former employer's or client's confidential information. If you come into possession of a third party's trade secrets through no fault of your own, do not use them - contact Legal for guidance.

4.15 Antitrust and Fair Competition

We compete on the merits of our services. Do not discuss or agree with competing companies, freelancers, or vendors on pricing, fee structures, bids, or which clients or markets each will pursue. Prohibited conduct includes price fixing, market or client allocation, and agreements that limit competition, reduce service quality, or restrict compensation or hiring practices (such as "no-poach" agreements). Violations of competition law can carry serious personal and corporate penalties - consult Legal before engaging in any joint activity with a competitor, including through industry associations.

4.16 Human Rights

We support the principles reflected in the UN Universal Declaration of Human Rights and core International Labour Organization conventions. We have zero tolerance for forced labor, child labor, human trafficking, and unlawful discrimination in our own operations and expect the same from vendors and partners we engage. Report any suspected violation to Compliance.

4.17 Diversity and Inclusion

We are committed to a workplace that reflects and welcomes diverse backgrounds, perspectives, and experiences. Discrimination or exclusion based on a protected characteristic has no place at Omorodion. We expect everyone to support equitable hiring, development, and decision-making, and to raise concerns openly, without fear of retaliation.

4.18 Harassment-Free Workplace

Omorodion has zero tolerance for harassment of any kind - verbal, physical, visual, or online - including unwelcome comments, offensive jokes, bullying, threats, or unwanted contact that creates an intimidating, hostile, or offensive environment. This policy protects and applies to employees, clients, vendors, and anyone else we interact with in a business context. Report concerns promptly; reports are investigated and retaliation against anyone raising a good-faith concern is prohibited.

4.19 Health and Safety

Follow applicable health and safety laws and Omorodion policies, whether working from an office, a client site, or remotely. Report unsafe conditions, incidents, or injuries promptly so they can be addressed.

4.20 Substances in the Workplace

Being impaired by alcohol or illegal or controlled substances while performing work for Omorodion is prohibited, as is possessing, using, distributing, or manufacturing illegal drugs in the workplace or while representing Omorodion.

5. Addressing Concerns and Reporting Violations

If you become aware of conduct that may violate this Code, applicable law, or a client agreement, raise it promptly. In most cases, the fastest path is to speak with your manager, their manager, or an HR business partner. If you are not comfortable raising a concern through those channels, or the concern involves them, you may instead contact Compliance directly at:

Email: info@omorodion.org

Concerns raised in good faith will be reviewed and, where appropriate, investigated confidentially. Omorodion does not tolerate retaliation against anyone who reports a concern in good faith or participates in an investigation, even if the concern is ultimately not substantiated. Knowingly making a false or malicious report, however, may result in disciplinary action.

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