Poppulo Ethics & Compliance

Data Privacy and Protection

We and our subsidiaries take our responsibilities under applicable data protection laws, including the EU General Data Protection Regulation 2016/679, the California Consumer Privacy Act, and all similar applicable consumer privacy laws and regulations in other regions, very seriously.

We have established our Privacy Policy to explain and describe the personal information Poppulo collects, how we use that information, and your options regarding the personal information collected about you.

For frequently asked questions, please see our Data Privacy FAQs.

Security Standards & Certificates

Poppulo is driven by providing industry leading data security standards. Security is managed at the highest levels of the company and is paramount to the services we provide.

Our security framework is based on the ISO 27001 Information Security Management System and the SOC 2 Type 2 Trust Service Principles.

For further details and resources, please see our Security page.

Ethical AI

Our approach to Artificial Intelligence (AI) is guided by strong ethical principles and underpinned by an industry leading compliance framework. Poppulo is the first in our industry to achieve the ISO 42001 certification, the first internationally recognized standard for Artificial Intelligence Management (AIMS).

For further details please see our Ethical AI page.

Code of Ethics and Conduct

Poppulo maintains a strict Code of Ethics and Conduct that outlines our commitment to integrity, professionalism, compliance and responsible business practices across all our areas of operations. This policy is reviewed regularly and is available for review upon request through our Trust Portal.

Whistleblower Policy

Poppulo recognizes the importance of providing a safe and confidential channel for employees and stakeholders to report concerns about unethical behavior, misconduct, or violations of company policies or legal requirements. We ensure that personnel can raise concerns without fear of retaliation and that the reported issues are promptly investigated and appropriately addressed.

Poppulo maintains strict confidentiality regarding the identity of whistleblowers, to the extent permitted by law. Once reported, Poppulo prohibits retaliation against individuals who make good faith reports of misconduct or unethical behavior. All reports of whistleblowing are taken seriously and investigated swiftly and impartially.

Investigations are conducted by trained professionals and spearheaded by the People Operations team, to ensure fairness, thoroughness and appropriate documentation. Poppulo recognizes that compliance with applicable laws and regulations regarding whistleblowing activities is of the utmost importance and implements processes to ensure these obligations are met.

Poppulo encourages all employees and stakeholders to speak up where needed, knowing that their voices will be heard and concerns addressed in a fair and confidential manner.

Anti-Corruption

Poppulo is committed to conducting business free from extortion, bribery and all unlawful, unethical and fraudulent activity. Poppulo partners must not offer, give, promise or authorize any bribe, gift, loan, fee, reward or other advantage to any government official or employee, any customer, any Poppulo employee or any other person to obtain any business advantage or improperly influence any action or decision.

Poppulo business partners, suppliers and vendors must comply with all applicable international anti-corruption laws and regulations, including but not limited to the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act, the Ireland Criminal Justice (Corruption Offences) Act 2018, and the Indian Prevention of Corruption Act 1988.

Anti-Facilitation of Tax Evasion

Poppulo commits that we will carry out business fairly, honestly and openly. We will not provide services or sell to parties where we know or suspect that the services or the items sold will be misused or abused by a customer for the purposes of fraudulent tax evasion.

We will not buy services or goods from any supplier where we know or suspect them not to be properly declaring their income and any relevant tax and duties in connection with those activities. Any colleague found to be in breach of these principles will face disciplinary action. No colleague shall suffer retaliation for refusing to engage in the sale or purchase of services and goods where they reasonably suspect or know tax evasion to be taking place.

Modern Slavery

Poppulo is committed to upholding human rights and preventing modern slavery and human trafficking across our business and supply chain in accordance with the UK Modern Slavery Act 2015 and reflects our commitment to operating responsibly and ethically worldwide.

As a provider of cloud-based employee communications and workplace solutions, our operations are primarily software-driven, and we assess the risk of modern slavery in our direct business and supply chain as low. However, we recognize that risks can exist in any supply chain and we remain vigilant in identifying and addressing them.

Our approach is guided by the following principles:

• Zero tolerance:We have a zero-tolerance policy towards modern slavery and human trafficking, and this commitment extends to our supply chain and business operations.
• Supplier expectations:We expect our suppliers and partners to meet ethical standards that prohibit modern slavery and demonstrate their compliance with applicable laws when required.
• Accountability:We hold ourselves accountable for continuously improving our practices.
• Whistleblower protections:We provide confidential channels for employees and stakeholders to report concerns related to modern slavery and human trafficking without fear of retaliation.

Supplier Standards

Poppulo’s supply chain has a strong technology focus. We abide by labor and employment laws in the jurisdictions where we employ people and operate a robust recruitment program including conducting eligibility to work checks for all employees.

Poppulo endeavors to continue to monitor potential risk areas within our supply chains and address any issues if they arise.

Energy Efficiency

Poppulo relies heavily on the use of data centers to provide our services to customers.

While backend infrastructure energy usage requirements for our offerings are not insignificant, we have partnered with a data center operator that is working towards making a positive environmental impact: Amazon Web Services (AWS). AWS is an active participant in the Climate Neutral Data Centre Pact (the “Pact”). The Pact is an industry leading commitment to proactively lead the transition to a climate neutral economy. The signatories of the Pact have committed to make data centers climate neutral by 2050.

Resource Conservation

We prioritize the efficient use of natural resources within our facilities. We encourage digital communications and minimize paper resources through electronic documentation and processes.

Carbon Offsetting

We support initiatives to offset our carbon emissions through our partnerships with reputable organizations. This includes investing in renewable energy projects and participating in carbon offset programs to mitigate our environmental impact.

Diversity, Equity, Inclusion and Belonging

Poppulo is committed to fostering a workplace that embraces diversity and inclusion as fundamental to our success and growth. We believe that diversity encompasses all the characteristics that make each of us unique, including but not limited to race, ethnicity, gender, sexual orientation, age, religion, disability, nationality, and socio-economic background.

Our focus is on building a culture where people feel respected, valued, included, and where people are given equal opportunities to succeed.

Our commitment to diversity is reflected in the following principles:

• Inclusive culture:We cultivate an inclusive culture where every individual feels valued, respected, and empowered to contribute their best. We celebrate the diverse perspectives and experiences that enrich our organization and drive innovation.
• Equal opportunities:We provide equal opportunities for career development, advancement, and leadership to all employees, regardless of their background or identity. Our recruitment and promotion processes are merit-based and free from bias.
• Education and awareness:We promote awareness and understanding of diversity issues through training, workshops, and ongoing dialogue. We encourage employees to expand their cultural competence and embrace diversity in all aspects of our business.
• Supplier diversity:We support supplier diversity and believe in promoting economic opportunities and equity within our supply chain where we can.
• Community engagement:We engage within the communities where we operate, supporting initiatives that promote social justice, equality, and inclusion. We strive to make a positive impact beyond our organization through philanthropy and volunteerism.
• Continuous improvement:We continuously evaluate and evolve our diversity strategies and practices to adapt to changing demographics and societal expectations. We are committed to creating a workplace that reflects the diversity of the global community we serve.

Through these commitments, Poppulo aims to not only attract and retain top talent but also to create a culture where diversity is not just celebrated but integral to our collective success and ability to innovate in a global marketplace.

Community Impact

Our commitment to corporate responsibility extends beyond our business. Through charitable partnerships, employee volunteerism, fundraising efforts, and community engagement, we work alongside organizations dedicated to supporting people, strengthening communities, and creating positive social impact. By contributing our time, skills, and resources, we strive to help drive meaningful change and build a better future together.