## 1. Purpose and Scope This Business Code of Conduct (“Code”) establishes the standards of conduct expected of all employees, officers, directors, contractors, consultants, suppliers, and other third parties (“Covered Parties”) acting on behalf of or in connection with Aspose Pty Ltd (“Aspose”). This Code applies globally and supplements, but does not replace, applicable laws, regulations, contractual obligations, and Aspose policies. Where conflicts arise, the more stringent requirement shall apply. ## 2. Compliance with Laws and Regulations Covered Parties must comply with all applicable laws, rules, and regulations in the jurisdictions in which they operate, including but not limited to those relating to: * Anti-corruption and anti-bribery * Trade compliance and economic sanctions * Data protection and privacy * Labor and employment * Environmental protection No business objective justifies non-compliance. ## 3. Ethics, Integrity, and Fair Dealing Covered Parties must conduct business with honesty, integrity, transparency, and in compliance with all applicable anti-corruption, anti-money laundering, sanctions, fraud prevention, and ethical conduct requirements. Covered Parties are required to comply with Aspose’s Financial Crime, Anti-Money Laundering (AML), Anti-Bribery, and Ethical Conduct Policy, as amended from time to time, which establishes additional requirements and controls relating to: * anti-bribery and anti-corruption, * gifts, hospitality, and entertainment, * sanctions compliance, * anti-money laundering, * fraud prevention, * conflicts of interest, and * ethical business conduct. In the event of any inconsistency between this Code and the Financial Crime, Anti-Money Laundering (AML), Anti-Bribery, and Ethical Conduct Policy, the stricter requirement shall apply. ## 4. Data Protection, Confidentiality, and Information Security Covered Parties must protect the confidentiality, integrity, and availability of Aspose information and any personal or third-party data. * Confidential information must not be disclosed or used except for legitimate business purposes * Personal data must be processed in compliance with applicable data protection laws * Appropriate technical and organizational safeguards must be implemented * Cross-border data transfers must comply with legal requirements Unauthorized access, disclosure, or misuse of information is strictly prohibited. ## 5. Human Rights and Labor Practices Aspose is committed to respecting internationally recognized human rights. Covered Parties must: * Prohibit forced, bonded, or involuntary labor * Prohibit child labor in violation of applicable laws * Provide fair wages and comply with working hour requirements * Respect freedom of association and collective bargaining rights * Provide a workplace free from discrimination, harassment, and retaliation All individuals must be treated with dignity and respect. ## 6. Health and Safety Covered Parties must provide and maintain a safe and healthy working environment. This includes: * Identifying and mitigating workplace hazards * Implementing appropriate safety procedures and training * Maintaining emergency preparedness and response measures Unsafe conditions must be reported and addressed promptly. ## 7. Environmental Responsibility Covered Parties must conduct operations in an environmentally responsible manner and comply with applicable environmental laws and regulations. Covered Parties are expected to support sustainable business practices, including responsible resource usage, waste reduction, and environmental risk management. Additional environmental commitments, sustainability practices, and governance standards are set forth in Aspose’s [Environmental, Social, and Governance (ESG) Policy](https://trust.aspose.com/environment-social-governance/environment-social-governance-policy/), as amended from time to time. ## 8. Diversity, Equity, and Inclusion Aspose is committed to fostering a respectful, inclusive, and equitable environment grounded in fairness, professionalism, and equal opportunity. Covered Parties must avoid discriminatory practices and support professional conduct consistent with applicable laws and Aspose values. Additional social responsibility, diversity, equity, inclusion, and employee well-being commitments are set forth in the Aspose’s [Environmental, Social, and Governance (ESG) Policy](https://trust.aspose.com/environment-social-governance/environment-social-governance-policy/), as amended from time to time. ## 9. Reporting, Speak-Up, and Non-Retaliation Covered Parties are expected to report suspected violations of applicable laws, regulations, Aspose policies, or this Code. Aspose prohibits retaliation against any individual who, in good faith, reports concerns or participates in an investigation. Additional governance, accountability, reporting, and continuous improvement practices may be set forth in Aspose’s [Environmental, Social, and Governance (ESG) Policy](https://trust.aspose.com/environment-social-governance/environment-social-governance-policy/) and related Aspose policies, as amended from time to time. ## 10. Monitoring, Audits, and Due Diligence Aspose reserves the right to assess compliance with this Code. Covered Parties must: * Cooperate with audits, reviews, and investigations * Provide accurate and complete information upon request * Implement corrective actions where deficiencies are identified Aspose may conduct ongoing due diligence, including risk assessments and compliance evaluations. ## 11. Governance, Accountability, and Internal Controls Covered Parties must maintain appropriate systems and controls to ensure compliance with this Code. This includes: * Documented policies and procedures * Training and awareness programs * Internal monitoring and reporting mechanisms Management is responsible for ensuring effective implementation and oversight. ## 12. Third-Party and Flow-Down Obligations Covered Parties engaging subcontractors or third parties in connection with Aspose business must: * Ensure such parties adhere to standards consistent with this Code * Conduct appropriate due diligence * Monitor ongoing compliance Responsibility for compliance may not be delegated. ## 13. Violations and Consequences Violations of this Code may result in disciplinary action, up to and including termination of employment or business relationships. Aspose reserves all rights available under applicable law and contract, including the right to: * Suspend or terminate engagements * Seek damages or other remedies * Report violations to regulatory authorities where appropriate ## 14. Continuous Improvement Employees and stakeholders are encouraged to provide feedback to improve compliance strategies and enforcement mechanisms. Non-compliance due to lack of awareness will be addressed through targeted training and communication initiatives. ## 15. Periodic Review and Policy Updates This Business Code of Conduct will be reviewed periodically or as required to address emerging risks, regulatory changes, or Aspose’s evolving operational needs. This ensures the policy remains aligned with current best practices and business requirements. Updates to the policy will be communicated to all employees, contractors, and relevant stakeholders. Any significant changes will be accompanied by training or guidance to ensure continued adherence to standards promoted within this policy. ## 16. Policy Management This policy is actively maintained and forms part of Aspose’s operational and governance framework. * Material updates are supported by communication, guidance, or training where appropriate. * It is reviewed at least annually, and more frequently where required to address changes in business practices, regulatory expectations, risk posture, or emerging threats. * Where applicable, it is approved through Aspose’s internal governance processes, including review by the Board of Directors or designated leadership. * Its publication confirms that it has been reviewed within the past 12 months and remains current and in effect.