CORPORATE GOVERANCE – HEADING
ORDIENT is deeply committed to maintaining high standards of ethical conduct, transparency, and forward-thinking practices within our organization. We believe in creating an inclusive workplace where every individual feels valued and empowered.
In practice, this commitment is reflected through our rigorous implementation of comprehensive policies. These policies are designed to guide employees in their daily responsibilities, ensuring that they understand and adhere to ethical guidelines and operational standards. Through regular training sessions, we equip our team members with the knowledge and skills necessary to uphold these principles effectively.
Our goal is to maintain consistency across all facets of our global operations. By adhering to these policies, we not only foster a culture of integrity and accountability but also mitigate risks associated with potential deviations from established best practices in different regions. This approach underscores our dedication to conducting business in a sustainable, responsible, and transparent manner, aligned with our organizational values and mission.
DATA ETHICS POLICY – HEADING
The purpose of this Policy is to formally articulate Ordient’s data ethics principles and outline our approach to data processing. It aims to provide clarity to our customers, employees, and stakeholders, reaffirming our commitment to safeguarding their data with the utmost ethical and security standards. This policy ensures transparency in how we handle and protect data, fostering trust and accountability across all our operations.
At Ordient, we firmly uphold data protection and ethical data processing as fundamental rights. Our commitment to these principles is encapsulated in Ordient’s Data Ethics Policy, which outlines our approach to data handling in a transparent and responsible manner.
Our Data Ethics Policy formally establishes Ordient’s data ethics principles and provides comprehensive guidelines on how we process data. This policy serves to assure our customers, employees, and stakeholders that we prioritize the protection and ethical processing of their data to the highest standards.
At Ordient, we are dedicated to acting responsibly towards our customers, employees, business partners, and the broader community. Central to our commitment is the ethical handling of data, guided by principles of transparency and forward-thinking best practices. We prioritize integrity in all our interactions and operations, ensuring trust and accountability across every aspect of our business.
Principles, Products and Processes
At Ordient, our guiding principles emphasize Believing and Behaving with Decency. We expect all employees to uphold respect, fairness, and integrity in their interactions with clients, suppliers, and colleagues. These principles guide every aspect of how Ordient operates, both within our core business as an advertising technology platform and in our relationships with employees, job applicants, and vendors.
As a company that processes significant volumes of data for our customers and within our own operations, data protection and information security are fundamental to Ordient’s business practices. We prioritize creating a safe environment where our customers and employees can trust us with their data without hesitation.
Our approach to data handling encompasses our products, our workforce, and our commitment to security and compliance with emerging legislation, including Artificial Intelligence (AI) regulations.
Our Products :
As a provider of an advertising technology platform, Ordient enables advertisers and agency clients to optimize their advertising budgets for enhancing sales efforts and brand awareness. Additionally, Ordient supports publisher clients in monetizing their digital properties such as websites, mobile apps, and other digital platforms. In this process, our customers utilize either their own 1st party cookies or Ordient’s 3rd party cookies (or a combination thereof) to deliver targeted messages to their audience at the right time.
It’s important to note that Ordient does not knowingly collect personal data that is traditionally considered directly identifiable, such as names, email addresses, addresses, phone numbers, social security numbers, credit card numbers, health data, sexual orientation, or religious beliefs. Furthermore, we contractually prohibit our customers from transferring such directly identifiable personal data onto our advertising technology platform.
However, Ordient does collect and store certain data, including truncated IP addresses, truncated geo-location data, unique identifiers placed electronically on a person’s device, and integrated first-party data (such as shopping history, geography, and device information) within our Data Management Platform (DMP).
The data we collect originates from all European countries and globally, depending on end-user permissions facilitated through cookies, software development kits, and similar technologies. With respect to end-users, Ordient may act as a processor for our customers, a joint controller, or a controller, depending on the services enabled by our customers within Ordient’s advertising platform and how personal data is processed as a result. Ordient treats all cookie data and data related to other identifiers as personal data, ensuring compliance with applicable data protection regulations.
Processes :
Ordient is committed to processing all data with the highest level of respect, taking into account the sensitivity of the information and prioritizing compliance with all relevant privacy rights. This approach is crucial in building and maintaining trust among our diverse stakeholders, including customers, employees, shareholders, vendors, and others.
To ensure rigorous compliance and transparency for our end-users, Ordient has established a dedicated privacy department within its legal organization. This department plays a critical role in overseeing the review process for all newly developed platform features, ensuring they adhere to stringent compliance standards. Additionally, the privacy department continuously updates and maintains Ordient’s “Privacy Center” on www.Ordient.com, ensuring it remains current and comprehensive in addressing privacy concerns and regulatory requirements.
Moreover, the privacy department takes proactive measures to uphold Ordient’s commitment to data privacy in relation to our employees. They ensure that internal processes and policies regarding employee data are not only compliant with regulations but also effectively communicated to current and prospective employees.
At Ordient, we place significant emphasis on education and training in GDPR and Privacy practices. We have implemented a robust training program that is mandatory for all employees. This training is accessible through Ordient’s internal training system, ensuring ease of participation and scalability across the organization. New employees undergo orientation that includes familiarization with our data protection policies, and they are required to complete the comprehensive training program within their first three months of employment. This structured approach ensures that all employees are well-equipped to uphold Ordient’s high standards of data protection and privacy from the onset of their tenure with us.
Information Security
Security forms a cornerstone of Ordient’s commitment to ethical and compliant data processing. Our daily operations are underpinned by a robust security policy and well-defined organizational procedures that ensure ongoing compliance and effectiveness.
In addition to these foundational measures, Ordient employs advanced techniques to bolster data protection. Our network architecture includes segmentation and firewalls, fortified with intrusion detection systems (IDS) and deep packet inspection (DPI), providing robust defenses against unauthorized access and threats. These firewalls serve as vigilant gatekeepers, meticulously controlling and monitoring data flow to safeguard the integrity of our information.
Simultaneously, our endpoint protection tools play a crucial role in our security framework. Integrated with firewall monitoring, these tools enable proactive incident investigation, ensuring swift response and effective mitigation of threats.
Furthermore, Ordient prioritizes data availability and resilience by securely housing it in our owned data servers. This strategic decision ensures high availability standards, maintaining operational continuity even in the face of unforeseen technical challenges.
By adhering to these comprehensive security measures, Ordient not only meets regulatory requirements but also upholds our commitment to safeguarding data with utmost integrity and reliability.
Artificial intelligence, Governance and Controls:
Ordient integrates artificial intelligence (AI) and machine learning into our advertising technology platform. Machine learning, a subset of AI, involves algorithms analyzing aggregated personal or non-personal data to identify patterns or predict behaviors, enhancing specific functions or outcomes. In Ordient’s approach, machine learning operates primarily under supervised learning, where we control and restrict the datasets accessed by algorithms to predict behaviors accurately.
We do not employ unsupervised learning methods where algorithms autonomously generate entirely new outcomes from unrestricted datasets. This ensures that Ordient maintains oversight and ensures predictability in the outcomes derived from machine learning processes.
Recognizing the growing significance of AI-driven tools across various departments, Ordient has implemented a dedicated AI Policy. This policy establishes guidelines, regulations, and prohibitions governing the use of AI tools under specific circumstances and requirements.
The AI Policy is rooted in overarching principles of data ethics, fairness, data protection, privacy, security, and confidentiality. By adhering to these principles, Ordient ensures responsible and ethical deployment of AI technologies throughout our operations, fostering trust and accountability in our use of advanced technologies.
GENDER DIVERSITY POLICY – HEADNG
The purpose of this policy at Ordient is to achieve and maintain a diverse and balanced workforce across all levels of the organization. Specifically, the policy aims for women in leadership positions to mirror the overall gender ratio of the workforce within the Group. This commitment underscores Ordient’s dedication to fostering gender diversity and equality throughout the organization’s leadership hierarchy.
At Ordient, we prioritize individual qualifications and performance in every stage of the hiring, promotion, and talent attraction processes. We firmly believe that a diverse workplace not only enhances our success but also fulfills a moral responsibility.
Our commitment to gender diversity is encapsulated in Ordient’s Gender Diversity Policy. This policy sets ambitious goals for achieving gender parity in leadership positions that mirror the overall gender ratio within our organization.
To gain deeper insights into our approach to Gender Diversity, we encourage you to download the full report below. This document provides comprehensive details on how we are advancing gender equality within Ordient, fostering an inclusive culture that values diversity as a strategic asset.
To maintain high levels of women in management and leadership roles, Ordient will focus on the following activities:
(i) Open and Transparent Recruitment Process: Implementing an open and transparent recruitment process for both internal promotions and external hires to ensure equal opportunities for all candidates.
(ii) Annual Diversity Monitoring: Regularly monitoring and assessing gender distribution and overall diversity within the organization to track progress and identify areas for improvement.
(iii) Inclusion of Personality Assessment: Incorporating personality assessments in recruitment and promotion processes to mitigate unconscious bias and ensure fair evaluations.
(iv) Global Respect Policy: Introducing a global respect policy that emphasizes equal opportunities and continuous training to foster a respectful workplace culture. Additionally, updating Ordient’s monthly employee engagement survey to include a question on employees’ perceptions of respect at work.
(v) Global Bias Training for Leaders: Launching comprehensive bias training programs for all leaders aimed at addressing unconscious bias in recruitment, promotion, and general workplace interactions.
(vi) Gender Pay Gap Assessment: Initiating an assessment to identify and address any gender pay gaps within the organization. This assessment will also evaluate the effectiveness of existing metrics used for promotion decisions.
These initiatives demonstrate Ordient’s commitment to fostering gender diversity, ensuring equal opportunities, and creating an inclusive workplace environment where all employees can thrive.
VENDOR CODE OF CONDUCT – HEADING
Our Commitment
At Ordient, we are committed to upholding the highest standards of business practices, not only in the quality of our products and services but also in our relationships with vendors. We hold our vendors to the same rigorous standards that we adhere to ourselves.
Our Vendor Code of Conduct serves as a guideline for educating Ordient’s suppliers on our expectations. It outlines compliance with applicable laws, human and labor rights, business ethics, confidentiality, data privacy, security management, and environmental responsibility. This code is integrated into the contracts we enter into with vendors, ensuring that these critical areas are prioritized throughout Ordient’s supply chain.
By embedding these principles into our vendor relationships, we aim to foster a supply chain that aligns with our values of integrity, responsibility, and sustainability.
Vendors must ensure that they, their affiliates, suppliers, and sub-suppliers adhere to the following standards:
- Prohibit the use of forced, compulsory, and slavery labor.
- Prohibit the use of child labor and comply with minimum legal age requirements in the countries of employment.
- Treat employees with respect and dignity, fostering a workplace free from discrimination, bullying, and harassment.
- Provide employees and contractors with adequate levels of occupational safety and health.
- Comply with legal minimum wage requirements and provide mandated benefits in the countries of employment.
- Respect employees’ rights to freedom of association and collective bargaining.
- Provide employees and stakeholders access to mechanisms for reporting any material concerns.
These standards reflect Ordient’s commitment to ethical business practices and ensuring that our vendors uphold fundamental human rights and fair labor practices throughout their operations and supply chains.
Business Ethics
Ordient takes business ethics standards and principles seriously. Therefore, we have not only established internal policies such as a code of business conduct and ethics policy and an internal anti-bribery policy, but also implemented compulsory trainings on the above-mentioned guidelines. In addition, Ordient operates an external managed protection policy, providing employees, contractors, directors and vendors with right to report any items subject to the protection policy in a safe and confidential manner.
ANTIBRIBERY POLICY AND ANTI-CORRUPTION
Refrain from engaging in corruption, bribery, inducement and/or any other similar activity with Ordient, other companies, any officials or other parties;
Comply with all relevant laws, rules and regulations in regards to anti-bribery, anti-corruption, anti-money laundering, sanctions, counterterrorism and alike.
Ordient’s Antibribery Policy is a comprehensive framework designed to ensure compliance with all applicable laws and regulations. It provides detailed guidance to employees and consultants on prohibited actions related to bribery, including facilitation payments and the provision of hospitality and entertainment to current or prospective clients and business partners.
The policy sets clear boundaries regarding expenses and establishes strict limits on the acceptance of gifts to uphold ethical standards in all business interactions. It emphasizes the importance of transparency, integrity, and accountability across Ordient’s operations.
Gifts and Gratuities
Not provide or promise to Ordient’s employees anything of value including, but not limited to money, entertainment, gifts, discounts and/or any other monetary advantage that may be treated as a bribe and would lead the recipient to violate relevant laws and Ordient’s policies. In case Vendor would like to express gratitude with anything of value it should be approved by the concerned office at Ordient.
By implementing this policy, Ordient aims to mitigate bribery risks and maintain trust and credibility with stakeholders. Regular training and communication reinforce these principles, fostering a culture of ethical behavior and responsible business conduct throughout the organization.
Conflicts of interest
Recognize and refrain from engaging in situations where conflicts of interest can occur. In the given relationship between Vendor and Ordient, a conflict of interest implies Vendor not being impartial while working with or on behalf of Ordient. While it is not possible to describe every situation, Vendor (including its employees, directors and officers) must never use or attempt to use their position with the Company to obtain personal benefits (including benefits for its employees, directors, officers and members of their families).
Fair trade practices and sanction control
Refrain from engaging in any abusive trade practices such as price fixing, abuse of a dominant position and other prohibited anti-competitive behavior defined as such by local, EU and international authorities and organizations.
Abide by all sanctions laws or trade embargoes adopted by the United Nations, the United States, the United Kingdom and the European Union.
Confidentiality
During the course of business, Vendor may have access to Ordient’s confidential information (‘Received Information”). Vendors are required to:
- Maintain Received Information as strictly confidential;
- Not disclose confidential information to any third party unless such limited right is given by the agreement with Ordient or stipulated by applicable law;
- Share confidential information with Vendor’s employees on a need-to-know basis only;
- Implement and sustain processes to provide protection for confidential information with a degree of care no less than for Vendor’s confidential information.
For the purpose of the Code, ‘confidential information’ shall mean any internal information received from Ordient in the course of cooperation, including but not limited to non-public information regarding the Ordient’s business, financials, products, clients, prospects and agreements.
Data privacy and security management
Being a technology company, which delivers online advertising services for the world’s largest websites and advertisers, Ordient takes privacy very seriously. Therefore, we expect Vendors to:
- Respect individual privacy rights as established by applicable privacy and data protection laws and regulations;
- Collect, store, process and share all data provided by Ordient solely for the intended business need;
- Return and/or delete all data provided by Ordient upon contractual termination; and
- Report any security breaches to Ordient without undue delay.
We encourage Vendors to demonstrate a similar level of industry standards and practices in regard to security controls.
Environmental Responsibility
Ordient is dedicated to reducing the environmental footprint of its business. Due to the nature of ad tech activities Ordient’s largest impact on the environment follows from energy consumption at data centers..
Therefore, the Company expects Vendors not only to comply with minimum applicable environmental laws but also to establish additional initiatives that will create significant environmental improvements.
No employment relationship
By entering into contractual relations, both Vendor and Ordient do not intend to create an employment relationship and therefore Vendor shall not represent themselves as Ordient’s permanent or temporary employees and/or agents.,
CODE OF BUSINESS CONDUCT – HEADING
Ordient’s Code of Business Conduct establishes fundamental principles that guide our operations and interactions, emphasizing fairness, respect, and equality for all individuals. It encompasses a wide range of standards, including privacy and confidentiality, honest and equitable dealings with business partners, and commitment to health and safety.
Central to this code is our unwavering commitment to compliance with laws and regulations. We uphold diversity and non discrimination in all aspects of our business, ensuring that no individual is subject to harassment or discrimination based on gender, race, skin color, beliefs, political convictions, sexual orientation, national, social, or ethnic origins, disability, or any other characteristic.
By adhering to these principles, Ordient fosters a workplace culture built on integrity and inclusion, where every person feels valued and respected. This code serves as a foundation for ethical conduct and responsible business practices, reflecting our dedication to upholding the highest standards of corporate governance and social responsibility.
Ordient’s Privacy Center provides comprehensive information on our platform’s policies and processes, ensuring compliance with GDPR and other relevant privacy regulations. It offers detailed explanations for end users on how they can exercise their rights under these regulations, including the “right to information,” “right to be forgotten,” and “right to withdraw consent” as specified in the GDPR. Additionally, it covers guidelines related to privacy rules such as the CCPA in the United States, ensuring transparency and empowering users to manage their personal data effectively