1 Introduction
1.1 Purpose
At Beyond Now, we are committed to conducting business with integrity, fairness, and respect for all individuals. This Code of Conduct sets out the principles and expectations that guide our behavior and decision-making across all levels of the organization. It reflects our dedication to ethical conduct in our interactions with colleagues, clients, partners, and the wider community.
This Code forms an integrated part of the employment contract or supplier contract (as applicable). We expect every individual at Beyond Now to uphold these standards consistently and responsibly.
1.2 Scope and Applicability
This Code applies to all employees of the following entities:
- BEYOND NOW SPV IE Ltd. (Ireland)
- Beyond Now GmbH (Austria)
- Beyond Now DAC (Ireland)
- Beyond Now Technology Ltd. (United Kingdom)
- Beyond Now LLC (United States)
Collectively referred to as “Beyond Now,” this Code is binding for all individuals at every level of the organization, including board members, directors, and appointed company officers. It also extends to all third parties, subcontractors, and suppliers acting on behalf of, in partnership with, or providing services to Beyond Now.
We engage only with third parties who share our core values and ethical standards. These expectations are embedded in our contractual relationships with vendors, suppliers, and other business partners to ensure alignment with our principles.
2 Diversity, Discrimination & Harassment
Our people are the foundation of our success. We embrace diversity and value the unique contributions of individuals from different backgrounds, experiences, and working styles. This diversity enables us to engage effectively with global stakeholders and foster innovation.
We do not tolerate discrimination based on race, colour, gender identity, age, family or marital status, religion, disability, national origin, sexual orientation, trade union affiliation, or any other legally protected characteristic.
Our policies promote equality of opportunity and ensure that no employee, job applicant, client, or business partner is treated less favourably. We are committed to maintaining a respectful, inclusive, and harassment-free work environment across all physical offices and digital/remote working environments (including messaging apps, video calls, and virtual workspaces).
Threatening language, harassment, or acts of violence are strictly prohibited. We are dedicated to providing a safe, healthy, and rewarding workplace for all.
3 Conflicts of Interest
Everyone covered by this Code must act in the best interests of the company. Personal interests must never interfere with professional responsibilities.
A conflict of interest arises when personal, financial, or other interests could compromise, or appear to compromise, our ability to act objectively and in Beyond Now’s best interest. Examples include:
- Holding a financial interest in a competitor, supplier, or customer
- Engaging in outside employment that conflicts with Beyond Now duties
- Using company resources for personal gain
All actual, potential, or perceived conflicts must be disclosed to the Legal or Compliance team. Transparency is essential to maintaining trust and integrity.
4 Anti-Bribery and Corruption
Beyond Now has zero tolerance for bribery or corruption in any form. We comply strictly with all applicable anti-bribery and anti-corruption laws globally, including the US Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and local European regulations.
No individual or entity bound by this Code may offer, give, solicit, or accept bribes, kickbacks, or inappropriate incentives, whether directly or indirectly, to gain an unfair advantage.
Gifts and hospitality must be:
- Reasonable, transparent, and proportionate
- Not intended to influence business decisions or create a sense of obligation
- Approved in strict accordance with internal limits and policies
Any suspicion of bribery, extortion, or corrupt conduct must be reported immediately.
5 Confidentiality and Data Protection
We are entrusted with sensitive information – about our business, our clients, and our people. We must protect this information and use it only for legitimate business purposes.
As a global SaaS provider, we process data in compliance with strict international regulations, including the EU/UK GDPR and applicable US State Privacy Laws (such as the CCPA/CPRA).
Everyone at Beyond Now must:
- Safeguard proprietary business information and protect corporate trade secrets
- Treat customer data with the highest degree of security, restricting access to authorized personnel only
- Comply with data protection laws and internal information security policies
- Immediately report any suspected data breaches, cybersecurity incidents, or unauthorized disclosures
This obligation to maintain confidentiality continues indefinitely, even after leaving Beyond Now.
6 Protection of Company Property and Intellectual Property
All individuals covered by this Code share a responsibility to safeguard Beyond Now’s assets, both physical and intellectual, from loss, damage, misuse, or theft. This includes practicing strong security posture against cyber threats and ensuring that any assets entrusted to us by clients are used solely for their intended purpose.
Information obtained and work developed by employees or contractors in the course of their duties is considered the property of Beyond Now or, where applicable, the client. Such materials must be handled with care and protected in accordance with relevant confidentiality and data protection standards.
Beyond Now’s intellectual property includes proprietary software code, know-how, tools, methodologies, patents, trademarks, copyrights, and trade secrets. These assets are critical to our competitive advantage and must be protected diligently. Any work product that may be subject to intellectual property rights, such as inventions, designs, or software, must be promptly disclosed to Beyond Now’s Legal or Executive Management for appropriate protection or recordation.
Use of third-party products, including open-source software, is governed by Beyond Now’s policy on third-party usage. Everyone must ensure compliance with licensing terms and avoid introducing legal or security risks to our products or systems.
Downloading, distributing, publicly displaying, performing, or modifying copyrighted content, such as documents, graphics, or third-party software, without proper authorization is strictly prohibited when using Beyond Now time, property, or resources. All content used or shared must align with our core values and standards of business conduct.
7 Responsible Use of Technology and AI
As Beyond Now embraces digital innovation, we are committed to the ethical and responsible use of emerging technologies, including artificial intelligence (AI).
Everyone at Beyond Now must:
- Use technology in ways that are transparent, fair, and respectful of data privacy
- Avoid bias, discrimination, or automated harm in the development, deployment, or internal application of AI tools
- Comply with global legal frameworks (such as the EU AI Act) and internal policies governing data usage, automation, and digital ethics
- Prevent Shadow IT: Never input proprietary source code, trade secrets, intellectual property, or customer personal data into public, unapproved third-party IT tools
We encourage thoughtful, secure innovation that aligns with our corporate values and enhances trust with our clients, partners, and communities.
8 Fair Competition and Antitrust
Beyond Now supports open and fair competition. We comply with all applicable antitrust and competition laws globally.
To maintain market fairness, we do not engage in:
- Price fixing, bid rigging, or capacity restrictions
- Market, territory, or customer allocation
- Exchanging commercially sensitive, non-public information with competitors
All interactions with competitors must be lawful, transparent, and bound by appropriate parameters. If in doubt, seek guidance from the Legal team before engaging.
9 Use of Company Resources
Company resources, including time, equipment, systems, and information, must be used responsibly and for legitimate business purposes. Misuse of resources, including for unauthorized commercial activities or personal gain, is prohibited.
Everyone at Beyond Now is expected to:
- Protect company assets from loss, theft, damage, or unauthorized access
- Use IT systems in accordance with security, access control, and usage policies
- Practice good cybersecurity hygiene, including securing authentication credentials and remaining vigilant against phishing or social engineering attacks
- Avoid excessive or disruptive personal use of company resources
10 Speaking Up and Reporting Concerns
We encourage a culture of openness, accountability, and psychological safety. If you witness, suspect, or become aware of unethical behaviour, you have the responsibility to speak up.
Concerns can be reported to:
- Your direct line manager or department manager
- The Legal or Compliance function
- The confidential, secure, and independent anonymous whistleblowing channel
Beyond Now does not tolerate retaliation, harassment, or adverse employment action against anyone who raises a concern or reports a suspected breach in good faith. All reports will be handled with strict confidentiality, treated seriously, and investigated thoroughly and fairly.
11 Compliance with Laws and Regulations
This Code provides guiding principles but is not exhaustive. Everyone at Beyond Now must comply with the local, national, and international laws and regulations of the jurisdictions in which we operate or serve customers, including:
- International trade compliance, economic sanctions, and export controls (e.g., US OFAC, EU, and UK sanctions lists), ensuring our software and services are not accessed from or deployed to restricted territories or embargoed entities
- Anti-money laundering (AML) and counter-terrorist financing rules
- Applicable labour, employment, and tax regulations
We must also maintain accurate, timely, and complete business records, including time and expense reporting, and retain them in accordance with legal and tax requirements.
Any legal notices, demands, or communications from regulatory authorities must be reported to the Legal department immediately upon receipt.
12 Environmental Stewardship and Corporate Social Responsibility
At Beyond Now, we recognize that our responsibilities extend beyond business performance. We are committed to operating in a way that respects the environment, supports our communities, and contributes to a sustainable future.
12.1 Environmental Stewardship
As a digital-first SaaS provider, we strive to minimize our environmental footprint by:
- Partnering preferentially with cloud infrastructure and data center providers that are committed to renewable energy, energy efficiency, and carbon neutrality
- Promoting sustainable resource consumption, reducing physical waste, and practicing responsible electronic waste (e-waste) recycling across our corporate offices
- Prioritizing digital-first workflow options to limit unnecessary corporate travel and eliminate paper consumption.
- Complying fully with all applicable environmental laws and regulations
We encourage everyone at Beyond Now to be environmentally conscious in their daily work and to contribute ideas that support our sustainability goals.
12.2 Corporate Social Responsibility (CSR) & Human Rights
We are dedicated to making a positive impact in the communities where we operate. Our CSR and ethical supply chain efforts focus on:
- Supporting education, inclusion, and digital empowerment initiatives
- Partnering with local organizations and charities to drive meaningful change
- Encouraging employee volunteerism and community engagement
- Preventing Modern Slavery: Upholding human rights, fair wages, and ethical labor practices throughout our operations and value chain, enforcing a zero-tolerance policy for modern slavery, forced labor, or human trafficking
We believe that ethical business conduct includes a responsibility to society and the planet. Through our actions, we aim to build trust, create long-term value, and contribute to a better world.
13 Company Representation
Only individuals who have been expressly authorized by Beyond Now’s management – either through formal appointment, corporate policy, applicable law, or a valid power of attorney – are permitted to legally bind or sign agreements on behalf of any Beyond Now entity.
To protect our reputation and mitigate commercial, legal, or contractual risk, all representations made about Beyond Now’s platform, products, features, services, and solutions must be accurate, transparent and truthful. Misleading, exaggerated, or false statements are strictly prohibited.
We recognize the value of social media and digital platforms in promoting our brand and engaging with our ecosystem. However, we expect everyone at Beyond Now to uphold professional, respectful, and responsible conduct online. Inappropriate, defamatory, or harmful behaviour in digital spaces will be treated with the same seriousness as misconduct in the physical workplace.
The disclosure of non-public financial information, security postures, or confidential information about Beyond Now or its business activities to the public or media (including via social media), is strictly prohibited unless prior approval has been granted by Executive Management.
All media enquiries or requests for official comments about the company must be referred immediately to the Executive Management.
14 Training and Awareness
Beyond Now is committed to ensuring that everyone at Beyond Now understands, internalizes, and applies the principles outlined in this Code. To support this, we provide regular training and awareness initiatives that reinforce ethical conduct, legal compliance, and security awareness.
All employees (and third parties where contractually required) must:
- Complete mandatory ethics, privacy, and compliance training during onboarding and at regular mandated intervals thereafter
- Stay informed about operational updates to this Code and its supporting corporate policies
- Participate in role-specific training where required (e.g., data protection, anti-bribery)
Leadership and people managers are responsible for actively fostering a culture of integrity, psychological safety, and compliance within their respective teams.
15 Monitoring and Enforcement
We take compliance with this Code with the utmost seriousness. Beyond Now continuously monitors adherence to these principles through internal controls, security audits, and reporting mechanisms.
Violations of this Code constitute a breach of professional obligations and may result in disciplinary action, up to and including the immediate termination of employment or contractual agreements. In cases involving clear violations of civil or criminal law, Beyond Now reserves the right to refer the matter to appropriate regulatory or law enforcement authorities.
All people working with, at, or on behalf of Beyond Now are required to cooperate fully, truthfully and transparently with any authorized internal reviews or compliance investigations.
16 Third-Party Ethics and Compliance
Because our Suppliers are a direct extension of the Beyond Now Ecosystem, they are required to adhere to the same ethical, legal, and operational principles detailed throughout this Code.
As set out in the Scope of this document, third parties must:
- Comply with all applicable international laws, economic sanctions, and local regulations
- Maintain robust cybersecurity hygiene when connecting to or interacting with Beyond Now environments
- Proactively avoid conflicts of interest and corrupt business practices
- Uphold universal human rights, safe working conditions, and fair labour standards
- Protect Beyond Now’s intellectual property, trade secrets, and customer data with the same level of care defined in this document
These expectations are embedded into our procurement process, standard vendor agreements and Master Services Agreements. We reserve the right to audit third-party compliance and to terminate commercial relationships where serious or un-remedied ethical or legal breaches occur.
17 Policy Governance and Updates
This Code of Conduct is owned and maintained by the Legal and Compliance function and is reviewed regularly as needed to reflect changes in global laws, regulation, or evolving business practices.
Any material updates will be communicated transparently through official company channels, and everyone at Beyond Now is expected to familiarize themselves with the latest version.
Suggestions for continuous improvement, clarification, or updates to this Code may be submitted directly to the Legal or Compliance team.
