EmpoorioChain: Code of Conduct

Introduction: Our Commitment to Ethical Excellence

EmpoorioChain, as a leader in blockchain innovation, recognizes the profound responsibility we hold in shaping a decentralized future that prioritizes integrity, transparency, and accountability. This Code of Conduct serves as the cornerstone of our operations, reflecting our core values and commitment to ethical business practices across all facets of our ecosystem. It is designed to guide every member of the EmpoorioChain community—employees, executives, board members, contractors, partners, and suppliers—in upholding the highest standards of behavior, ensuring that our actions align with our mission to drive global positive impact through technology.

Our Code of Conduct is not merely a set of rules but a living framework that embodies our culture of innovation, trust, and respect. It applies universally, without exception, to all individuals representing EmpoorioChain, regardless of role or location, and extends to our interactions with external stakeholders. We strive to go beyond legal compliance, embracing the spirit of integrity and fostering a workplace where ethical decision-making is the norm, not the exception. This document is approved by the EmpoorioChain Board of Directors and is complemented by detailed policies on anti-corruption, data privacy, and environmental responsibility, ensuring alignment with global standards such as the United Nations Universal Declaration of Human Rights, the UN Global Compact, and the International Labour Organization (ILO) conventions.

The word cloud below visually represents the core values that underpin our Code of Conduct, emphasizing the principles that guide our daily operations and long-term vision.

Word cloud representing EmpoorioChain’s core values underpinning the Code of Conduct.

Purpose and Scope

The purpose of this Code of Conduct is to establish a framework for ethical decision-making, ensuring that all actions within EmpoorioChain’s ecosystem reflect our commitment to integrity, transparency, and fairness. It provides clear guidelines for behavior, helping employees and stakeholders navigate complex ethical dilemmas and fostering a culture of accountability. This Code connects our broad mission—to drive innovation through blockchain technology—with the day-to-day behaviors expected of our community, ensuring that our operations align with legal, ethical, and social standards.

This Code applies to all individuals associated with EmpoorioChain, including but not limited to:

• Employees at all levels, including executives and board members
• Temporary and agency workers
• Contractors, consultants, and third-party partners
• Suppliers, vendors, and business partners
• Participants in EmpoorioChain events, forums, or digital platforms

We expect our partners and suppliers to adhere to similar ethical standards, as outlined in our Supplier Code of Conduct, ensuring alignment across our ecosystem. While this Code is not legally binding, it serves as a commitment to self-regulation, protecting EmpoorioChain from compliance violations that could result in legal repercussions, financial penalties, or reputational damage. It also reflects our dedication to global standards, including GDPR, anti-corruption laws, and environmental regulations, ensuring that our operations remain ethical and sustainable in every jurisdiction we operate.

Core Values and Principles

EmpoorioChain’s Code of Conduct is rooted in our core values, which shape our culture and guide our actions. These values are the foundation of our commitment to ethical excellence and are reflected in every aspect of our operations.

• Integrity: We conduct all business with honesty, fairness, and ethical rigor, ensuring that our actions align with our principles, even when faced with difficult choices.
• Transparency: We prioritize openness in our operations, providing clear and truthful information to employees, partners, and stakeholders to foster trust and accountability.
• Innovation: We drive technological advancement responsibly, ensuring that our innovations in blockchain technology contribute positively to society.
• Respect: We value diversity, equity, and inclusion, treating all individuals with dignity and fostering a workplace free from discrimination and harassment.
• Accountability: We hold ourselves accountable for our actions, ensuring compliance with legal and ethical standards and taking responsibility for our impact on stakeholders and the environment.
• Sustainability: We are committed to sustainable practices, minimizing our environmental footprint and promoting responsible business operations.

These values are not just ideals but actionable principles that guide our daily decisions and interactions. They ensure that EmpoorioChain remains a trusted partner in the blockchain ecosystem, delivering value to all stakeholders while maintaining the highest ethical standards.

Ethical Standards and Expectations

EmpoorioChain expects all members of its community to adhere to the following ethical standards, ensuring that our operations reflect our commitment to integrity and fairness.

Compliance with Laws and Regulations

All employees, partners, and stakeholders must comply with applicable local, national, and international laws, including but not limited to anti-corruption laws, data privacy regulations (e.g., GDPR), and labor laws. EmpoorioChain operates in multiple jurisdictions, and where local laws are less stringent than our standards, we will apply our higher ethical benchmarks. For example, in regions with lax anti-bribery laws, we will still enforce our zero-tolerance policy on corruption.

Anti-Corruption and Bribery

EmpoorioChain maintains a strict zero-tolerance policy on bribery, corruption, money laundering, and embezzlement. It is prohibited to offer, accept, or authorize any improper payment, gift, or benefit to gain a business advantage, whether involving government officials or private entities. This includes cash, gifts, hospitality, or anything of value that could be perceived as influencing decisions. Employees and partners must disclose any potential conflicts of interest, such as personal financial interests that could affect business decisions.

For example, if an employee is offered a lavish trip by a vendor seeking a contract, they must decline and report the incident immediately. Violations will result in disciplinary action, up to and including termination, and may lead to legal action.

Confidentiality and Data Privacy

Protecting confidential information and personal data is paramount at EmpoorioChain. Employees must safeguard sensitive information, including proprietary business data, customer information, and employee records, in compliance with GDPR and other data protection laws. Unauthorized disclosure, misuse, or mishandling of data is strictly prohibited. For instance, sharing customer wallet addresses without consent would violate this policy and result in immediate disciplinary action.

Workplace Behavior and Inclusion

EmpoorioChain is committed to fostering a workplace free from discrimination, harassment, and retaliation. We value diversity, equity, and inclusion, ensuring that all individuals are treated with respect regardless of race, gender, age, religion, sexual orientation, or any other characteristic. Any behavior that restricts or inhibits the enjoyment of our workplace or digital platforms, such as harassment or bullying, is unacceptable and will result in disciplinary action.

For example, if an employee engages in discriminatory behavior during a team meeting, they will face immediate investigation and potential termination, ensuring a safe and inclusive environment for all.

Environmental Responsibility

As a blockchain company, EmpoorioChain is committed to sustainable practices, minimizing our environmental impact through energy-efficient operations and responsible sourcing. We align with global standards like the Paris Agreement, striving to reduce our carbon footprint and support circular supply chains. Employees and partners are expected to prioritize sustainability in all business activities, such as opting for eco-friendly vendors and reducing waste in operations.

Conflicts of Interest

Employees must avoid situations where personal interests conflict with EmpoorioChain’s interests. This includes financial interests, outside employment, or relationships that could influence business decisions. For example, an employee must disclose if a family member works for a competing blockchain company, ensuring transparency and impartiality in decision-making.

Fair Competition

EmpoorioChain competes fairly and ethically, adhering to anti-trust and competition laws. We prohibit practices such as price-fixing, market manipulation, or unfair competitive tactics. Employees and partners must engage in business practices that promote fair competition, ensuring that our success is driven by innovation and integrity.

Responsibilities and Compliance Training

Upholding this Code of Conduct begins with each individual at EmpoorioChain. We adopt a “It Begins with Me” philosophy, emphasizing that ethical behavior is a shared responsibility across all levels of the organization. Leadership sets the tone by exemplifying these standards, ensuring that ethical conduct is embedded in our culture.

To ensure compliance, EmpoorioChain provides regular training programs for all employees, covering topics such as anti-corruption, data privacy, workplace behavior, and sustainability. New employees receive mandatory onboarding training, and annual refreshers are required for all staff. For example, in 2024, 98% of employees completed anti-corruption training, ensuring widespread awareness of our ethical standards, per internal analytics.

Employees are encouraged to seek guidance from supervisors, the Legal and Compliance team, or HR when in doubt about ethical decisions. EmpoorioChain maintains an open-door policy, fostering an environment where questions and concerns can be raised without fear of retaliation.

Enforcement and Reporting

EmpoorioChain enforces this Code of Conduct diligently, ensuring that violations are addressed promptly and fairly. The flowchart below illustrates the process for reporting violations and the enforcement steps, providing clarity on how we handle misconduct.

Flowchart illustrating the process for reporting violations and enforcement steps at EmpoorioChain.

Violations of this Code, including unethical behavior, harassment, or non-compliance with laws, will result in disciplinary action, up to and including termination of employment or partnership agreements. For example, an employee found engaging in bribery will face immediate termination and potential legal action, ensuring accountability at all levels.

EmpoorioChain provides multiple channels for reporting concerns, including a secure, anonymous whistleblowing hotline accessible via the EmpoorioChain Ethics Open Line. Employees, partners, and stakeholders are encouraged to report any behavior that violates this Code, such as fraud, harassment, or data breaches, without fear of retaliation. Retaliation against whistleblowers is strictly prohibited and will result in severe disciplinary action.

Reports are reviewed by our Legal and Compliance team, followed by a thorough investigation. Enforcement actions are applied proportionately based on the nature, frequency, and severity of the violation. For instance, a minor breach, such as failing to disclose a minor conflict of interest, may result in a warning and additional training, while a severe violation, such as data theft, will lead to termination and legal proceedings.

Supplier and Partner Expectations

EmpoorioChain expects its suppliers, vendors, and business partners to uphold the same ethical standards outlined in this Code of Conduct, as detailed in our Supplier Code of Conduct. This includes compliance with anti-corruption laws, respect for human rights, and adherence to environmental sustainability standards. Suppliers must disclose the origins of materials to enable traceability, ensuring alignment with regulations such as the EU’s anti-deforestation laws and conflict minerals directives.

For example, a supplier providing hardware for EmpoorioChain’s blockchain infrastructure must certify that their materials are conflict-free, in line with Section 1502 of the Dodd-Frank Act. Failure to comply may result in termination of the partnership, ensuring that our supply chain reflects our ethical commitments.

Stakeholder Engagement and Community Impact

EmpoorioChain is committed to building strong relationships with stakeholders, including employees, customers, partners, investors, and the communities in which we operate. We engage transparently, responding to concerns and communicating our ethical practices to foster trust and collaboration. For instance, we regularly publish Reports on Payments to Governments for Extractive Activities, ensuring transparency in jurisdictions where we operate.

We also strive to make a positive impact on communities through charitable initiatives, employee volunteer programs, and sustainable practices. In 2024, EmpoorioChain donated $1 million to blockchain education programs in underserved regions, empowering the next generation of innovators, per internal analytics. Our commitment to diversity ensures that our workforce and partnerships reflect the communities we serve, promoting inclusivity at every level.

Updates and Accessibility

This Code of Conduct is a living document, regularly updated to reflect changes in laws, regulations, and industry standards. Employees and stakeholders are notified of updates via the EmpoorioChain intranet and email communications, ensuring awareness and compliance. The Code is accessible to all employees, partners, and stakeholders through our website, intranet, and employee handbook, available in multiple languages to accommodate our global workforce.

For questions or to report concerns, contact our Legal and Compliance team at compliance@empoorio.com or through the EmpoorioChain Ethics Open Line at +1-800-ETHICS-LINE. We are committed to maintaining an ethical culture that supports our mission and values, ensuring that EmpoorioChain remains a trusted leader in the blockchain industry.