Influencer Code of Ethics

Effective date: May 11, 2023

1. Introduction

1.1. Purpose

An Influencer (a person who is able to generate interest in something, such as a consumer product, by posting about it on social media as a blogger, an ambassador, a video blogger, a podcaster, a microblogger or a general social media participant, etc.) plays an important role in public knowledge creation and discussion of products. This role carries with it a responsibility to be fair, honest, truthful, and respectful toward members of society, toward facts and toward clients.

The MacPaw Family Ltd., its affiliates, subsidiaries and parent companies (the "Company") is willing to:

  • foster its positive reputation;
  • unify and standardize messages which Company translate to the public;
  • build trust and authority of Company, its products;
  • protect Company's reputation, brand name and goodwill;
  • prevent any potential reputational risk from illegal, unethical, damaging actions or inactions of Influencers, which goes beyond Company's mission, purpose, vision, values, principles and positioning.

These guidelines establish key behavioral and ethical standards for influencers representing Company and its products to ensure ethical conduct.

By accepting this Influencer Code of Ethics you agree to abide by it and acknowledge that any conduct contradicting the provisions of this Code of Ethics will lead to immediate termination of business relations between You, as Influencer, and Company.

1.2. Scope

This Code of Ethics applies to Influencers as defined in clause 1.1. of this Section promoting Company and its product(s), being whether legal entities or individuals.

2. Guidelines

2.1. Commitment to Ethics

Each Influencer with whom Company enters into contractual relations, shall:

2.1.1. Comply with all applicable legal regulations, legal statutes, and with standards of equity and justice. Employees and contractors of the Influencer shall strive to meet and exceed the requirements of their designated position;

2.1.2. Refrain from condoning as well as participating in, or engaging in dishonesty, fraud, deceit or misrepresentation;

2.1.3. Respect differences in people, this includes (but not limited to) age, color, race, citizenship, place of origin, disability, gender, sexual orientation, family status etc.

2.1.4. Refrain from the use of profanity, verbal abuse or violence;

2.1.5. Refrain from engaging in public criticism that would jeopardize the reputation of Company and its employees or contractors;

2.1.6. Notify Company if they have a conflict of interest or potential conflict of interest;

2.1.7. Not mention Company next to the brands and companies related to shady niches, such as gambling, betting and politics, or other niches and brands with a possibly stained reputation.

2.1.8. Not use Company's name, logos, trademarks or other Company-owned symbols, logos, icons etc. in a disparaging manner;

2.1.9. Not use Company's name, logos, trademarks or other Company-owned symbols, logos, icons etc. in a way that might rise claims for unfair competition;

2.1.10. Not use Company's competitors' names, logos, trademarks or other symbols, logos, icons etc. without Company's prior approval.

2.2. Unethical Behavior

2.2.1. The intent and appearance of unethical or compromising practice in relationships, actions and communications of the Influencer are not acceptable. The Influencer, its employees, contractors, subcontractors shall not participate in:

  • any act of corruption, bribery or other illegal behavior;
  • any type of discrimination;
  • victimization;
  • victim blaming;
  • hate speeches;
  • any other actions or expressions that violate human rights.

2.3. Russian war against Ukraine response

2.3.1. Company does not tolerate and will not tolerate justification of Russia's political position towards Ukraine.

2.3.2. Company does not tolerate any expressions or acts of justification, recognizing as legitimate or denial of hostilities of the Russian army in Ukraine. As well as mistrust and contempt for the country, insults to the honor and dignity of Ukrainian armed forces and servicemen and discrediting the military policy of the state and/or military actions of the government.

2.3.3. Company also does not tolerate calls against the territorial integrity of Ukraine (such as "give them Crimea or Donbas", etc.).

2.3.4. Company will not enter into or will terminate the contractual relations with Influencers who do not share the Company's position and spread the messages contrary to the position of Company underlined in this Code, including, but not limited to justifying Russian war against Ukraine.

2.3.5. Company relies on the position of the Government of Ukraine and the Geneva Convention when discussing Ukraine's military action against Russia.