Flowable’s Supplier Code of Conduct

The Flowable companies (Flowable) are bound by the principles of ethical behaviour, integrity and compliance. These principles of conduct are mandatory for all employees of Flowable. Also, Flowable expects integrity and ethical, law-abiding behaviour in line with the minimum standards set out below (Code of Conduct) from our subcontractors and suppliers (Subcontractors and Suppliers).

This Code of Conduct outlines our expectations of Flowable’s Subcontractors and Suppliers for transparency, accountability, and responsible business practices.

Flowable expects our Subcontractors and Suppliers to adhere to this Code of Conduct to help us meet our commitment to ethical and responsible business practices. We believe that working together in a spirit of transparency, accountability, and shared values will create a sustainable and mutually beneficial partnership.

• Anti-Corruption / Anti-Bribery

Subcontractors and Suppliers shall not, directly or indirectly, engage in any act of corruption, extortion or embezzlement, nor in any form of bribery. This includes but is not limited to the promising, offering, giving or accepting of any improper monetary or other incentive such as bribes, unreasonable business entertaining and gifts as well as kickbacks.

• Counteracting Corruption

Subcontractors and Suppliers shall actively and systematically prevent any form of criminal, corrupt, or otherwise unethical conduct that could influence decisions by Flowable or any external organization. They are required to maintain, document, and enforce adequate internal controls and compliance measures to prevent corruptibility within their own operations and supply chains.

• Bid Rigging

Subcontractors and Suppliers do not participate in anti-competitive bid rigging and take action against illegal cartels.

• Counteracting Illegal Employment

Subcontractors and Suppliers comply with the applicable legal requirements and effectively eliminate illegal employment.

• Confidentiality, Intellectual Property and Privacy

Subcontractors and Suppliers shall not disclose the confidential information of Flowable or Flowable’s clients without prior written consent from Flowable. Confidential information includes any information about Flowable, about Flowable’s business or about Flowable’s clients which is not generally available to the public.

Subcontractors and Suppliers shall protect the intellectual property and personal data provided to them as a result of working with Flowable. Subcontractors and Suppliers shall comply with applicable privacy laws and regulatory requirements when dealing with personal data.

• Cybersecurity

Subcontractors and Suppliers shall implement, maintain and regularly review and improve appropriate measures to protect data against unauthorised access and cyber security risks and have to strategies to safeguard data against emerging and evolving cyber security risks, in line with Flowable’s information security management system.

Subcontractors and Suppliers must notify Flowable immediately of any incident involving unauthorised access to Flowable’s or Flowable’s clients data.

• Artificial Intelligence

Subcontractors and Suppliers who, develop, deploy, operate or use artificial intelligence (AI), generative AI (GenAI) or AI agents that interact with, process, or produce outputs relating to Flowable's data, personnel, or customers shall remain fully responsible and accountable for any output, communication, work product, or decision in which AI has played a role.

AI-generated content must always be reviewed, verified, and approved by Subcontractors and Suppliers before delivery. Subcontractors and Suppliers shall be transparent about the use of AI where required by Flowable, client agreements, or applicable regulation. Subcontractors and Suppliers shall not use AI to generate misleading, deceptive, or fraudulent content. Subcontractors and Suppliers shall be aware that AI-generated outputs may incorporate third-party copyrighted material, or may themselves not be eligible for copyright protection. Before using AI-generated content in products, publications, or client deliverables, Subcontractors and Suppliers shall seek clearance from the Flowable where intellectual property rights could be affected. Subcontractors and Suppliers shall apply the same security standards to AI tools as to all other Flowable systems: use only AI tools that have been reviewed and approved by Flowable, not share credentials, and report any suspected data exposure or security incident related to AI use promptly.

• Respect for the Fundamental Rights of Employees

Subcontractors and Suppliers respect the health, safety and personal rights of their employees and adhere to the principles of respect, fairness and non-discrimination. They employ and remunerate their employees on the basis of fair and compliant contracts. They maintain international minimum labour standards and shall prevent modern slavery and not engage in any form of forced or child labour.  

• Respect for the Environment

Subcontractors and Suppliers shall observe all relevant legal environmental standards and commit to minimising their negative environmental impact by reducing waste, conserving resources, and promoting sustainable practices.

• Governance

Subcontractors and Suppliers forbid gifts to private or public officials that aim to influence business decisions or otherwise encourage them to act contrary to their obligations. Subcontractors and Suppliers respect the privacy and confidential information of all their employees and business partners as well as protect data and intellectual property from. Subcontractors and Suppliers implement an appropriate Compliance Management System, which facilitates compliance with applicable laws, regulations, and standards.

a. Flowable requests from our Subcontractors and Suppliers that they require their own subcontractors and suppliers also to comply with the principles of this Code of Conduct.

b. Subcontractors and Suppliers are required to report their own violations of this Code of Conduct, insofar as these affect their business relations with Flowable. They are also asked to report any knowledge of misconduct on the part of Flowable; reports may be made to the designated Flowable contact, or the Legal & Compliance Department. For serious matters, the Whistleblower Platform may be used, including on an anonymous or confidential basis where appropriate.

c. Subcontractors and Suppliers are required to actively resolve any suspicious cases and to cooperate unconditionally with Flowable in this regard. If there are reasonable grounds to believe that a Subcontractor or Supplier has violated this Code of Conduct or if a Subcontractor or Supplier, when a suspicious case arises, fails to sufficiently meet his obligations to resolve the case and to cooperate, Flowable, on the basis of existing contractual or legal rights, can end all business relations with the Subcontractor or Supplier with immediate effect. In the event of a violation of this Code of Conduct, Flowable retains the right to initiate further legal measures, particularly damage claims.

d. Flowable, from time to time, can appropriately update this Code of Conduct for Subcontractors and Suppliers and expects that our subcontractors and suppliers accept any such changes.

• Scope

The Code of Conduct applies to the Suppliers and Subcontractors of all Flowable legal entities, notably:

Switzerland and EU countries

Flowable AG

Flowable Deutschland GmbH

Flowable Licences AG

Flowable Polska s.p. z. o.o.

Flowable Labs Spain s.l.u.

Non-EU countries

Flowable AG UK Branch

Flowable Canada IT Services Inc.

Flowable USA Inc.