Code of Conduct

Version: 1.3

Last Review Date: December 25, 2025

This Code of Conduct establishes the ethical principles, governance standards, and compliance framework guiding all activities of Paradigma.

It applies to:

- Board members and executives

- Employees and consultants

- Temporary staff and interns

- Suppliers, contractors, and third parties acting on behalf of Paradigma

All covered persons are expected to comply with this Code, applicable laws, contractual obligations, and professional standards.

Paradigma operates based on the following foundational principles:

- Integrity and honesty in all professional actions

- Independence and objectivity, especially in research, analysis, and advisory work

- Transparency and accountability toward stakeholders

- Respect for human rights, dignity, and diversity

- Commitment to public benefit, scientific responsibility, and societal trust

 

Paradigma complies with all applicable national and international laws, regulations, and professional frameworks in every jurisdiction where it operates.

Paradigma:

- Maintains accurate records and lawful business practices

- Cooperates transparently with competent authorities

- Ensures neutrality toward political actors and public institutions

- Avoids any unlawful, misleading, or unethical conduct

 

Paradigma applies zero tolerance toward bribery, facilitation payments, kickbacks, or any improper advantage.

Accordingly:

- No person may offer, give, request, or accept anything of value to influence a business decision.

- Gifts, hospitality, and representation must be lawful, reasonable, transparent, and documented.

- Third-party engagements are subject to risk-based due diligence and contractual compliance obligations.

- Suspected corruption must be reported immediately through designated channels.

 

All decisions must prioritize Paradigma’s legitimate interests and stakeholder trust.

Covered persons must:

- Disclose actual, potential, or perceived conflicts of interest

- Avoid personal gain from company position or confidential information

- Refrain from external roles that compromise independence or objectivity

Given Paradigma’s work in research, policy analysis, and advisory services:

- Findings, analyses, and reports must remain objective, evidence-based, and free from undue influence.

- Sponsorships, funding, or partnerships must be clearly disclosed where relevant.

- Data manipulation, selective reporting, or misleading interpretation is prohibited.

 

Paradigma protects personal data, confidential information, and intellectual assets in accordance with applicable data protection laws.

This includes:

- Lawful and purpose-limited data processing

- Secure storage and controlled access

- Confidential handling of client, partner, and employee information

- Transparent privacy notices and responsible data sharing

 

Paradigma maintains safeguards to protect digital systems, research data, and operational information.

Covered persons must:

- Use authorized systems and secure credentials

- Prevent unauthorized disclosure or cyber risk

- Report suspected data breaches or security incidents immediately

 

Paradigma respects copyright, data ownership, software licensing, and research integrity.

Accordingly:

- Third-party materials and AI-generated content must be used lawfully and transparently.

- Client deliverables and internal methodologies are protected intellectual assets.

- Unauthorized copying, distribution, or misuse is prohibited.

 

Paradigma competes lawfully, ethically, and transparently.

The company prohibits:

- Collusion, price-fixing, or market manipulation

- Misrepresentation of services or credentials

- Unfair or deceptive competitive practices

 

11.1 Clients

Deliver accurate, timely, and high-quality services

Protect confidentiality and intellectual property

Communicate honestly about scope, limits, and outcomes

 

11.2 Employees and Collaborators

Ensure fair treatment, equal opportunity, and non-discrimination

Provide a safe, respectful, harassment-free workplace

Support professional development and well-being

 

11.3 Suppliers and Third Parties

Apply fair, transparent, and risk-based selection

Require ethical and legal compliance

Protect shared confidential information

 

11.4 Society and Public Interest

Paradigma contributes to:

Ethical research and evidence-based policy

Public health, knowledge production, and social benefit

Responsible civic engagement and sustainability awareness

 

Paradigma promotes sustainable and responsible business practices, including:

- Efficient resource use

- Reduced environmental impact where feasible

- Consideration of long-term societal value in decision-making

 

All covered persons are encouraged to report concerns in good faith regarding:

- Legal violations

- Ethical misconduct

- Corruption or conflicts of interest

- Data breaches or security risks

 

Paradigma ensures:

- Confidential or anonymous reporting channels

- Fair, impartial, and timely investigation

- Strict prohibition of retaliation against reporters acting in good faith

 

- Compliance with this Code is mandatory.

- Violations may lead to disciplinary, contractual, or legal consequences.

- Management is responsible for training, oversight, and continuous improvement of the ethics and compliance framework.

This Code is reviewed periodically to reflect legal developments, international standards, and organizational learning.

This Policy establishes the principles, controls, and responsibilities designed to prevent, detect, and respond to bribery and corruption risks in all activities carried out by Paradigma.

The structure and control logic of this Policy reflect commonly recognized anti-bribery management expectations associated with ISO 37001-aligned frameworks, while legal enforceability depends on applicable jurisdiction.

This Policy applies to:

- Board members and senior management

- Employees, consultants, and interns

- Suppliers, contractors, and intermediaries

- Any third party acting for or on behalf of Paradigma

Compliance with this Policy is mandatory.

Paradigma adopts a zero-tolerance approach to bribery and corruption.

No person covered by this Policy may:

- Offer, promise, give, request, or accept a bribe or improper advantage

- Provide anything of value to influence a business, regulatory, or professional decision

- Engage in facilitation payments, kickbacks, or hidden commissions

- Circumvent controls through third parties

 

Bribery:

Offering, giving, receiving, or soliciting anything of value to improperly influence a decision or action.

Improper advantage:

Any benefit not legitimately due, including money, gifts, services, employment, sponsorship, or preferential treatment.

Public official:

Any government employee, regulator, public institution representative, or person acting in an official public capacity.

Paradigma implements proportionate controls including:

- Periodic bribery risk assessments

- Due diligence on third parties and partners

- Financial and contractual approval controls

- Accurate books, records, and documentation

- Segregation of duties where feasible

Controls are reviewed regularly.

Permitted only when all conditions are met:

- Lawful under applicable regulations

- Reasonable and proportionate in value and frequency

- Transparent and properly recorded

- Not intended to influence a decision

 

The following are prohibited:

- Cash or cash-equivalent gifts

- Gifts during tender, approval, or regulatory processes

- Hidden or undisclosed benefits

- Must serve legitimate, transparent, and documented purposes.

- Cannot be used to obtain business or regulatory advantage.

- Political donations on behalf of Paradigma are prohibited.

 

Paradigma ensures:

- Accurate, complete, and transparent accounting records

- No off-book accounts or undisclosed transactions

- Proper authorization for payments and reimbursements

- Traceable supporting documentation

Falsification of records is strictly prohibited.

All persons must promptly report:

- Suspected bribery or corruption

- Requests for improper payments

- Control failures or suspicious transactions

 

Paradigma provides:

- Confidential and, where permitted, anonymous reporting channels

- Impartial and timely investigations

-Protection from retaliation for good-faith reporting

Failure to report known misconduct may constitute a violation.

Violations of this Policy may result in:

- Disciplinary measures up to termination of employment or contract

- Reporting to competent authorities where required

- Civil or criminal liability under applicable law

 

Senior Management

Demonstrates visible commitment to anti-bribery culture

Ensures adequate resources and oversight

 

Compliance / Ethics Function

Monitors implementation

Advises on risks and controls

Maintains reporting mechanisms

 

All Personnel

Must understand and comply with this Policy

Must report concerns promptly

Paradigma periodically:

- Reviews bribery risk exposure

- Tests effectiveness of controls

- Updates this Policy in line with legal and international developments

 

This Policy enters into force upon management approval and remains effective until revised or withdrawn.