Code of Conduct


From humble beginnings in a kitchen, Kpler has evolved into a global powerhouse with
over 500 talented individuals spanning 12 offices worldwide. Our journey thrives on our
unique approach, relentless pursuit of excellence, and agility in meeting industry and
customer demands.

Kpler's environment is characterised by the fact that we are approachable and move
fast. Spread across diverse cultures, backgrounds and legal landscapes, we hold
ourselves to the highest standards of scalable business practices. At our core, we value
relationships with colleagues, customers, partners, and the communities we touch.
Our success is about more than just hitting financial goals. It is about making a real,
positive impact on the world.

In this context, we need to acknowledge that achieving success requires directness,
adaptability, transparency, honesty, and most of all a diverse group of highly committed
individuals who put this into motion.

Think of our Code of Conduct as our compass, helping us navigate the challenges we
face every day and keeping us grounded in the core values that define Kpler. As Kpler's
ambassadors, we uphold these values, cultivating a positive atmosphere of innovation
and mutual respect.

This Code is our playbook; we embrace it in everything we do related to Kpler. By
adhering, we cement our leadership, fostering a culture that empowers each one of us
to thrive.

Together, we shape a future where data sparks change and drives impact.

François Cazor,
CEO Kpler


This Code has been written to serve as a clear guidance for all individuals associated
with our organisation, including employees, customers, partners, and third parties. It
sets forth the principles, expectations, and standards of behaviour that we uphold to
ensure ethical conduct, legal compliance, and responsible business practices. It reflects
our commitment to integrity, transparency, and accountability in all our interactions and
it is intended to:

  • Inform: It provides a clear understanding of our values, expectations, and ethical
    standards, enabling individuals to align their actions with our organisational
  • Guide: It offers guidance on navigating complex ethical dilemmas, encouraging
    individuals to make informed decisions that prioritise integrity and ethical
  • Raise awareness: It fosters awareness of potential ethical issues and promotes a
    culture of vigilance, encouraging individuals to report concerns and seek
    guidance when faced with ethical dilemmas.
  • Foster accountability: It establishes a framework for accountability, enabling
    individuals to take responsibility for their actions and understand the
    consequences of non-compliance.


Our Vision: One World, One Platform for Global Trade Intelligence

At Kpler, we aspire to break down barriers and bring global trade intelligence to all
corners of the world through our unified platform. Our vision drives us to create
seamless connections and build a community of collaboration, empowering businesses
and decision-makers to thrive in a rapidly evolving marketplace.

Our Mission: Explore, Build, and Grow

We are united in our mission to explore, build, and grow together as a team.

Explore: We boldly venture into uncharted territories, seeking new data sets, advanced
technologies, and the seamless synergy between artificial intelligence and human
intelligence. Our thirst for knowledge and innovation propels us forward, continuously
expanding our capabilities to provide unparalleled insights to our customers.

Build: Our commitment to building strong foundations, simple yet effective tools, and
enduring relationships defines our success. As we map global trade with precision, we
lay the groundwork for long-lasting and fruitful collaborations with our valued partners.

Grow: We embrace change and adapt our strategies around the evolving needs of our
customers. By staying agile and responsive, we position ourselves at the forefront of the
industry, ready to tackle new challenges and opportunities that arise.

Core Values:

Our core values are the pillars that uphold our code of conduct and define the Kpler way
of doing business.

We make things happen: We are relentless in our pursuit of excellence, taking
ownership of our responsibilities and driving positive outcomes. Our actions speak
louder than words, and we rise to the occasion, delivering results that exceed

We create together: Collaboration is the heart of Kpler's success. By harnessing the
power of diverse perspectives and talents, we foster a creative and inclusive
environment that nurtures innovation and collective growth.

Hey, how can I help you today? We pride ourselves on being accessible and supportive
to our customers and colleagues alike. Our commitment to exceptional service and
teamwork reinforces the strong bonds that unite us as the Kpler community.


At Kpler, we move fast while upholding the law. Our values emphasise approachability
and transparent ethics. We act with integrity and responsibility, always inviting open

Anti-Bribery and Corruption
Kpler is committed to maintaining the highest standards of integrity and transparency.
We strictly prohibit any form of bribery, corruption, or unethical practices in all aspects
of our business operations. Employees and representatives are expected to comply with
all applicable anti-bribery and anti-corruption laws and regulations. Gifts, entertainment,
or other favours must not be used to influence business decisions, and relationships
with government officials and business partners must be conducted with utmost
honesty and fairness.

Anti-Fraud and Money Laundering
As part of our commitment to combating money laundering and terrorist financing, we
have implemented robust AML policies and procedures. All employees must be vigilant
in identifying and reporting suspicious activities, adhering to Know Your Customer (KYC)
requirements, and cooperating with authorities when necessary. We conduct regular
training to ensure that everyone is aware of their responsibilities in preventing money
laundering and other financial crimes.

Conflicts of Interest
We avoid conflicts of interest that could compromise our objectivity in decision-making.
Employees must promptly disclose any potential conflicts to their supervisors or to the
Legal, Risk and Compliance Team. This includes financial interests, family relationships,
or any other affiliations that could influence their decision-making.

Data Protection and Privacy
Respecting individuals' privacy and safeguarding their personal information is of
paramount importance to us. We strictly adhere to data protection laws and regulations,
ensuring the proper collection, processing, and storage of personal data. Employees are
trained to handle data securely, only accessing information relevant to their roles. We
maintain data confidentiality and have mechanisms in place to address any data

breaches promptly and responsibly. Further information can be found on:

Environmental Responsibility
We are committed to minimising our environmental impact and promoting sustainability
in all aspects of our operations. Kpler strives to reduce waste, conserve resources, and
adopt eco-friendly technologies wherever feasible. We work closely with suppliers and
partners who share our commitment to environmental sustainability.

Fair Competition and Antitrust
We compete fairly and ethically, adhering to antitrust and competition laws. We do not
engage in anti-competitive practices, price-fixing, or bid-rigging.

Health and Safety
We prioritise the health and safety of our employees, clients, and partners. Compliance
with health and safety regulations is non-negotiable. We comply with all relevant health
and safety laws, regulations, and industry standards.

Non-Discrimination, Fair and Equal Treatment, and Anti-Harassment
We foster an inclusive environment where everyone is treated with respect, dignity, and
equality. Any type of discrimination, including cumulative and intersectional
discrimination, and harassment are strictly prohibited. We respect and uphold human
rights, ensuring fair treatment and opportunities for all individuals associated with our

Respect, Dignity, and Inclusion
We promote a culture of inclusion, embracing diversity and fostering a sense of
belonging for all. We encourage open communication and mutual respect, valuing
diverse perspectives. Kpler promotes equal opportunities and actively works to remove
barriers to participation and advancement.

Sanctions and Export Controls
We prioritise adherence to sanctions and export control laws to prevent any
engagement in prohibited activities. Our commitment to responsible global trade
intelligence ensures that our data and services remain compliant, protecting our
integrity and reputation. Kpler establishes internal controls and procedures to ensure
compliance with export control and sanctions requirements, integrating them into
day-to-day business operations.

Working Environment
We strive to create a positive and safe working environment that nurtures growth,
creativity, and collaboration among our employees. In order to maintain and achieve a
healthy working environment, Kpler will regularly review and update the code of conduct

and working environment policies to ensure they remain relevant, effective, and aligned
with the organisation's values.


The Global Code of Conduct at Kpler serves as a valuable guide to navigating ethical
dilemmas and making sound decisions aligned with our values. Here are some
recommendations on how to use this Code to ensure you make the right choices:

  • Familiarise Yourself: Take the time to read and understand the Code thoroughly.
    Familiarise yourself with our mission, purpose, core values, and the various risk
    topics covered in the Code.
  • Integrity as a Compass: Let integrity be your compass. When faced with
    decisions, ask yourself if your actions align with our commitment to
    transparency, honesty, and accountability.
  • Apply the Values: Our Core Values are the foundation of the Code. Apply them to
    your daily work, and overall interactions including with colleagues, customers,
    and partners.
  • Seek Guidance: If you encounter a situation that requires guidance, don't hesitate
    to seek advice from your supervisor, the Legal, Risk and Compliance Team, or any
    appropriate channel mentioned in the Code.
  • Report Concerns: If you witness or suspect any violations of the Code, promptly
    report your concerns through the available reporting channels. Confidentiality
    and non-retaliation are guaranteed.
  • Think Long-Term Impact: Consider the broader implications of your decisions on
    stakeholders, the environment, and our reputation. Strive for decisions that
    create lasting positive impact.
  • Consult Legal and Compliance: In complex situations involving legal or
    compliance matters, consult our legal and compliance experts for guidance.
  • Continuous Learning: Keep abreast of updates to the Code and participate in
    relevant training and educational resources to reinforce your understanding.
  • Lead by Example: As a member of the Kpler family, you play a crucial role in
    upholding our ethical standards. Lead by example and inspire others to do the

Remember, our Code is more than just words on paper; it represents our shared
commitment to building a responsible future. By applying these guidelines, we ensure
that each decision reflects our dedication to "One World, One Platform for Global Trade
Intelligence" and the values we hold dear.


At Kpler, we value open communication and encourage employees to speak up without
fear or hesitation. We provide accessible reporting channels to confidentially raise
concerns, ensuring a safe space for employees to share any potential violations of our
Code of Conduct. Together, we uphold a culture where voicing concerns leads to
positive change and reinforces our commitment to integrity and accountability.

Along these lines it is important to remember that:

  • Everyone has a voice
  • You can report concerns through the existing channels. You may use our
    confidential reporting line or choose online reporting to specific stakeholders
    (direct manager, People Team, Legal, Risk and Compliance Team)
  • Potential investigations will be conducted impartially and with due process,
    ensuring fairness to all parties involved.
  • Appropriate actions will be taken to address substantiated violations, which may
    include disciplinary measures and remedial actions.


We are committed to non-retaliation and guarantee that all concerns will be impartially
addressed through prompt investigations. We prioritise safety and trust. Employees can
report concerns or Code of Conduct violations without fear, using our provided
channels. We ensure a firm stance against any retaliation. Every reported concern is
addressed swiftly and impartially. We champion open dialogue, knowing it fortifies our
mission to create a secure and ethical workplace for all at Kpler.


1. For Employees
We encourage you to utilise the contact details below whenever anyone feels the need
to raise an idea, a question or concern. Your cooperation and active participation in
upholding our Code of Conduct are vital to maintaining our commitment to ethics and
compliance at Kpler.

Legal Risk and Compliance
For legal, risk and compliance-related inquiries, guidance, or reporting concerns,
employees can contact the Legal, Risk and Compliance Department. The department is
responsible for overseeing legal and compliance matters, conducting investigations,
providing legal advice and guidance on ethical conduct. You can contact this
department via

Direct Manager
Your direct Line Manager is also a great point of contact for many concerns or queries.
They're here to support you in your role and can assist or direct you to the appropriate
channel for resolution.

2. For Third Parties - General Contact
If you're external to Kpler and wish to get in touch for matters concerning our Code of
Conduct or related issues, you can reach out to the LRC team via email:

Your active participation ensures the spirit of the Code of Conduct is alive and helps us
create a workplace we're all proud to be a part of.


Version: v.01
Approval Date: September 2023

Date for Next Review: September 2024
Risk Category: High
Accountable Policy Owner: Legal, Risk and Compliance Team