Business Conduct & Ethics

Files.com's business-conduct standards govern how we make decisions, treat people, select suppliers, and respond to concerns. They apply to the company operating the service, alongside the product safeguards and information-handling practices described elsewhere in this reference.

Customers and procurement teams can use this explanation to assess Files.com's conduct as a business partner, identify the standards relevant to a supplier review, and understand how to raise a concern. Our internal policies establish employee and supplier expectations; an executed customer agreement can establish additional obligations for a particular relationship.

Business Integrity and Conflicts of Interest

Files.com's compliance program includes anti-bribery and anti-corruption, fraud prevention, anti-money-laundering, and tax-compliance policies. Employees must conduct company business lawfully and must not use their positions with Files.com or its customers for private gain, personal favors, or benefits for themselves, family members, or other parties.

A personal relationship, financial benefit, or outside interest can affect a business decision even when no improper payment occurs. Employees must promptly disclose actual or potential conflicts of interest to their manager or HR, including relationships involving customers, suppliers, coworkers, or other third parties. The appearance of a conflict also requires disclosure so that the company can assess it before it affects a decision.

Files.com prohibits tax evasion and facilitating it through activities such as false records, concealed funds, or misclassified payments. Employees, contractors, vendors, and other parties representing Files.com are subject to this standard. Employees report tax-compliance concerns to Finance or HR; Finance and Legal provide guidance when a proposed action requires review.

Fair Competition

Files.com makes its pricing, product, customer, supplier, and hiring decisions independently. Our fair-competition policy prohibits coordinating with competitors on prices, discounts, bids, allocation of customers or markets, output, compensation, or hiring restrictions.

Employees must not exchange nonpublic, competitively sensitive information with competitors. A legitimate relationship with another company, such as an integration partnership or participation in an industry event, does not remove those restrictions.

Employees end prohibited discussions, preserve an accurate record, and bring the matter to Legal. Proposed collaborations that could affect competition receive Legal review before commitments are made.

Human Rights and Labor Standards

Files.com prohibits forced labor, bonded labor, child labor, and human trafficking in our operations and supply chains. Our anti-slavery policy applies to employees and contractors, and we expect the same commitment from organizations we do business with.

We use due diligence and risk assessment to identify and reduce modern-slavery risks, and train staff to recognize and address potential issues. Employees report suspected breaches confidentially to HR for investigation.

Our workplace policies prohibit unlawful discrimination and harassment, including harassment of third parties by Files.com employees. They provide for reporting, investigation, appropriate corrective action, and protection against retaliation. Employee conduct and confidentiality obligations continue throughout employment; violations can result in disciplinary action, including termination.

Ethical Sourcing and Supplier Oversight

Suppliers must operate lawfully, respect human rights, and avoid coercion and unsafe working conditions. Files.com's ethical-sourcing standard applies to materials, software, services, and subcontracted labor. We do not rely on suppliers using illegal, harmful, or deceptive practices to produce or deliver what they provide to us.

Supplier conduct and service security are related but distinct review subjects. A supplier's security report does not establish that every aspect of its labor or business conduct meets our expectations.

Our Vendor Management Program evaluates service-provider risk, compliance information, contractual requirements, and continuing performance. A concern about ethical sourcing can trigger an additional vendor review.

Employees must raise suspected unethical or unlawful supplier practices with their manager. Customers and suppliers can use the public reporting route below.

Reporting Business-Conduct Concerns

Customers, suppliers, and other external parties can report concerns about Files.com's business conduct to legal@files.com. Legal coordinates the review and any investigation. Matters are escalated outside anyone implicated in the concern, including when that person would ordinarily participate in reviewing it.

Describe what happened, the people or organizations involved, relevant dates, and any supporting information you can appropriately provide. Do not include passwords, secret keys, or unrelated customer file contents. You do not need to establish that a violation occurred before raising a good-faith concern.

Employees also have subject-specific internal reporting routes. HR receives Code of Conduct and modern-slavery concerns; managers or HR receive conflict-of-interest concerns; Finance or HR receives tax-compliance concerns; and Legal receives discrimination, harassment, and fair-competition concerns. These routes allow the responsible team to address the subject while preserving escalation outside anyone implicated.

Review, Confidentiality, and Corrective Action

Legal coordinates review of the relevant facts and policies and the appropriate response. Reports are handled as confidentially as possible during the review and investigation. Confidential handling does not mean that a concern can be investigated without sharing relevant information with people needed to address it.

Files.com prohibits retaliation for raising a concern in good faith. Report suspected retaliation to Legal so that it can be reviewed with the underlying matter or escalated separately as appropriate.

Corrective action depends on the findings. Employee policy violations can lead to disciplinary action, including termination. Supplier concerns can lead to further due diligence and review of the relationship under the Vendor Management Program.

Service problems, suspected security incidents, and requests concerning personal information have their own response processes. Use incident reporting and Support for service and security concerns, and Privacy and Government Requests for privacy requests.

Customer Supplier Codes and Supporting Documents

Files.com reviews customer-provided supplier codes of conduct against our existing policies and practices. We generally accept a code when complying with it does not add obligations or operational burdens beyond what we already do. If your procurement process requires a signed code, provide it to your Account Executive or Account Manager for review.

Public descriptions of our practices, internal policy documents, contractual commitments, and independent assurance serve different purposes. Our SOC 2 Type II report has a defined system, criteria, and examination period; it is not a certification of every business-conduct policy.

Document Requests explains access to internal policies and supporting material, including the applicable enterprise-review and program-specific exceptions.