clarifAI, qualifAI, dignifAI and medifAI

Establishing standards for ethical collaboration in medical communications

Table of Contents

Foundation

• Our Commitment to Partnership Excellence

• Application and Scope

• Core Values and Expectations

Workforce Standards

• Building Inclusive Teams

• Safeguarding Health and Wellbeing

Environmental Responsibility

• Sustainable Operations

• Climate Consciousness

Social Accountability

• Protecting Human Dignity

• Employment Standards and Fair Treatment

Professional Conduct

• Ethical Business Operations

• Managing Hospitality and Benefits

• Competitive Practice and Market Conduct

• Excellence in Delivery and Data Handling

• Information Protection and Privacy

• Information Security Protocols

• Ethical Technology Deployment

• Subcontractor and Third-Party Management

• External Communications Standards

• Managing Potential Conflicts

• Scientific Integrity and Safety Reporting

• Open Communication and Incident Disclosure

Our Commitment to Partnership Excellence

Who We Are

clarifAI operates at the forefront of medical communications, committed to scientific excellence, ethical conduct, and meaningful impact. Our work demands precision, integrity, and a relentless focus on clarity that serves healthcare professionals, patients, and the broader medical community.

We recognise that our success depends fundamentally on the calibre and conduct of our partners. This Code establishes the standards we expect from all organisations and individuals who collaborate with us across clarifAI, qualifAI, dignifAI, and medifAI.

Our Partnership Philosophy

We seek partners who share our commitment to:

• Scientific Rigour: Upholding the highest standards of accuracy and evidence-based practice

• Ethical Leadership: Operating with integrity in every interaction and decision

• Patient-Centricity: Placing patient welfare at the heart of all activities

• Professional Excellence: Delivering work that meets and exceeds industry standards

• Regulatory Compliance: Adhering to all applicable laws, regulations, and professional codes

• Continuous Improvement: Embracing learning and advancing best practice

Foundational Framework

Our approach is structured around four interconnected pillars that reflect our values and the UN Sustainable Development Goals relevant to our sector:

Workforce Standards: Creating environments where people thrive with dignity, health, equity, and opportunity for professional growth.

Environmental Responsibility: Operating sustainably with consciousness of our environmental footprint and commitment to protecting our planet.

Social Accountability: Respecting human rights, supporting fair labour practices, and contributing positively to communities.

Professional Conduct: Maintaining impeccable business ethics, data stewardship, quality standards, and transparent operations.

Application and Scope

Who Must Comply

This Code applies comprehensively to:

• Specialist medical writers and scientific consultants

• Technology providers and platform developers

• Creative agencies and design partners

• Research organisations and data analytics firms

• Training providers and educational collaborators

• Event management and logistics partners

• All contractors, freelancers, and temporary personnel

• Subcontractors engaged by primary partners

Geographical Application

These standards apply globally to all partners regardless of location, though we recognise that local laws and regulations may impose additional requirements. Where local standards exceed these requirements, the higher standard prevails.

Partner Classification and Expectations

We operate a tiered partnership framework:

Strategic Partners: Long-term collaborators working across multiple projects who demonstrate exemplary adherence to these standards and contribute to our continuous improvement.

Preferred Partners: Regular collaborators with proven track records of compliance and quality delivery.

Approved Partners: Partners who have successfully completed our assessment process and maintain good standing.

Provisional Partners: New partners undergoing initial assessment period.

Expectations increase proportionally with partnership tier, with Strategic Partners expected to demonstrate leadership in responsible business practices.

Core Values and Expectations

Fundamental Requirements

Partners engaging with clarifAI must demonstrate:

Regulatory Alignment: Full compliance with pharmaceutical industry codes, medical communications standards, data protection legislation, and all relevant regulatory frameworks applicable to their services.

Quality Embedded: Robust quality management systems appropriate to the scale and nature of services provided, with documented procedures and regular audits.

Professional Development: Investment in training and competency development for all personnel working on clarifAI projects, ensuring currency of knowledge and skills.

Ethical Operations: Documented policies addressing business ethics, anti-corruption, conflicts of interest, and professional conduct with evidence of implementation.

Sustainability Commitment: Demonstrable efforts towards environmental sustainability, social responsibility, and ethical business practices commensurate with organisation size and capability.

Supply Chain Responsibility: Application of equivalent standards throughout their own supply chains, ensuring that subcontractors and suppliers meet these requirements.

Transparent Communication: Open, honest, and timely communication regarding capabilities, limitations, challenges, and risks.

Continuous Improvement: Active engagement in feedback processes, lessons-learned exercises, and quality improvement initiatives.

Assessment and Due Diligence

Partners undergo risk-based assessment aligned with:

• Scope and sensitivity of work undertaken

• Access to confidential or personal data

• Interaction with patients or healthcare professionals

• Regulatory implications of services provided

• Partnership tier and strategic importance

We reserve the right to conduct periodic reassessments and request evidence of continued compliance.

Workforce Standards

Building Inclusive Teams

Equality and Non-Discrimination

Partners must create workplaces characterised by fairness and respect:

Non-Discrimination: Employment decisions—recruitment, compensation, promotion, training, discipline, and termination—must be made on merit, free from discrimination based on race, colour, nationality, ethnic origin, religion, belief, age, disability, sex, sexual orientation, gender identity, marital status, pregnancy, or any other protected characteristic.

Equal Opportunities: Proactive measures to ensure equal access to opportunities, including:

• Diverse candidate pools for recruitment

• Fair and transparent promotion criteria

• Equitable access to training and development

• Regular pay equity reviews and remediation

Inclusive Culture: Policies and practices that foster inclusion:

• Zero tolerance for harassment, bullying, or intimidation

• Accessible workplace adjustments for people with disabilities

• Support for diverse working arrangements

• Employee resource groups or similar support structures (for larger organisations)

Pay Equity: Documented processes to identify and address gender pay gaps and other remuneration inequities, with regular monitoring and corrective action.

Voice and Representation: Channels for employees to raise concerns regarding discrimination or unfair treatment without fear of retaliation, with prompt and fair investigation of complaints.

Professional Conduct Standards

All personnel working on clarifAI projects must:

• Maintain professional demeanour and respectful communication

• Uphold confidentiality and discretion

• Declare and manage conflicts of interest

• Complete mandatory training on applicable standards and regulations

• Operate within the scope of their competence and qualifications

Safeguarding Health and Wellbeing

Physical Safety

Partners must maintain safe working environments through:

Risk Assessment: Regular evaluation of workplace hazards—whether physical offices, remote working arrangements, or fieldwork—with documented control measures.

Safety Management: Systematic approach to health and safety including:

• Clear responsibilities and accountabilities

• Incident reporting and investigation procedures

• Emergency preparedness and response plans

• Regular safety inspections and audits

Hazard Control: Where relevant to service provision:

• Safe handling, storage, and disposal of any hazardous materials

• Proper management of equipment and machinery

• Appropriate personal protective equipment

• Control of environmental emissions and waste

Training and Competence: Personnel receive adequate health and safety training relevant to their roles, with refresher training at appropriate intervals.

Mental Health and Wellbeing

Recognising that mental health is fundamental to overall wellbeing:

Supportive Environment: Policies and practices that promote positive mental health:

• Reasonable workload management

• Support for work-life balance

• Access to mental health resources

• Destigmatisation of mental health discussions

Stress Management: Proactive identification and mitigation of workplace stressors, particularly during high-pressure periods.

Support Services: Access to appropriate mental health support, whether through employee assistance programmes, occupational health services, or other mechanisms suitable to organisation size.

Awareness and Training: Education for managers and employees on recognising and responding to mental health concerns.

Environmental Responsibility

Sustainable Operations

Resource Stewardship

Partners should operate with environmental consciousness:

Resource Efficiency: Measures to reduce consumption of:

• Energy (with consideration of renewable sources where feasible)

• Water and other natural resources

• Raw materials and consumables

Circular Economy Principles: Where applicable:

• Preference for reusable, recyclable, or sustainably sourced materials

• Extension of product lifecycles through maintenance and refurbishment

• Responsible end-of-life management of equipment and materials

Waste Minimisation: Systematic approach to waste reduction:

• Segregation for recycling and recovery

• Composting of organic waste where practical

• Responsible disposal of hazardous waste

• Minimisation of single-use items

Sustainable Sourcing: Verification that materials derived from forests or plants are legally and ethically produced, with preference for certified sustainable sources.

Prohibited Substances: Assurance that products and materials do not contain banned or restricted substances under relevant legislation (e.g., REACH, RoHS).

Digital Sustainability

Given our sector's digital nature:

• Optimisation of digital file sizes and storage

• Efficient use of cloud computing resources

• Consideration of data centre energy sources

• Sustainable practices in IT equipment procurement and disposal

Climate Consciousness

Understanding and Action

Partners should demonstrate climate awareness appropriate to their scale:

Risk Assessment: Understanding of climate-related risks to business continuity (e.g., extreme weather events, resource availability disruptions) with appropriate mitigation strategies.

Impact Awareness: Recognition of environmental impacts from operations, including consideration of biodiversity and ecosystem effects where relevant.

Emissions Measurement: For larger partners (as appropriate to tier):

• Measurement and reporting of carbon emissions (Scope 1, 2, and ideally Scope 3)

• Participation in recognised frameworks (e.g., CDP, Science Based Targets initiative)

Reduction Initiatives: Active steps to reduce environmental impact:

• Energy efficiency improvements

• Transition to renewable energy where feasible

• Low-carbon transportation choices

• Remote working and digital-first approaches

Transparency: Willingness to share sustainability data and collaborate on improvement initiatives, including making available any existing sustainability reports or scorecards.

Social Accountability

Protecting Human Dignity

Fundamental Rights

Partners must respect and uphold human rights throughout their operations:

International Standards: Alignment with:

• UN Universal Declaration of Human Rights

• UN Guiding Principles on Business and Human Rights

• International Labour Organisation (ILO) core conventions

Stakeholder Rights: Respect for rights and freedoms of:

• Employees and workers at all levels

• Contractors and supply chain workers

• Customers and end-users

• Community members affected by operations

Due Diligence: Processes to identify, prevent, and mitigate human rights risks in operations and supply chains, with particular attention to vulnerable groups.

Remediation: Where adverse human rights impacts occur, commitment to provide or cooperate in legitimate remediation.

Prohibition of Forced Labour and Exploitation

Absolute Prohibitions: Zero tolerance for:

• Forced, bonded, or compulsory labour

• Human trafficking and modern slavery

• Withholding of identity documents or wages

• Unreasonable restrictions on movement

• Physical, sexual, or psychological coercion

• Threats, intimidation, or punishment

Recruitment Ethics: Ethical recruitment practices ensuring:

• No recruitment fees charged to workers

• Clear terms of employment before engagement

• Freedom to terminate employment with reasonable notice

Child Labour: Absolute prohibition on child labour. Any employment of young persons must:

• Comply with ILO Conventions 138 and 182

• Meet or exceed minimum age requirements under applicable law

• Not interfere with compulsory education

• Not involve hazardous work or conditions harmful to health, safety, or development

• Comply with all applicable regulations regarding working hours, remuneration, and conditions

Employment Standards and Fair Treatment

Freedom of Association

Partners must respect workers' rights to:

• Form and join trade unions of their choosing

• Engage in collective bargaining

• Seek representation and voice concerns

• Participate in peaceful assembly

• Refrain from association if they choose

Open Dialogue: Workers can communicate with management regarding working conditions without fear of retaliation, discrimination, or harassment.

Good Faith Engagement: Where workers are represented, partners engage constructively with their representatives.

Legal Compliance: All compensation meets or exceeds:

• Applicable minimum wage legislation

• Industry standards and living wage benchmarks

• Contractual obligations

Transparent Terms: Workers understand in advance:

• Base salary or wages

• Overtime calculation and rates

• Deductions (which must be lawful)

• Payment frequency and method

• Benefits and entitlements

Working Hours: Compliance with applicable laws and standards regarding:

• Maximum working hours

• Rest periods and breaks

• Overtime (which must be voluntary except where business necessity requires otherwise, with due consideration for worker health and safety)

Written Contracts: Workers receive written employment contracts or terms clearly setting out their rights, responsibilities, and conditions of employment.

Professional Conduct

Ethical Business Operations

Anti-Bribery and Corruption

Zero Tolerance: Absolute prohibition on:

• Offering, promising, giving, requesting, or accepting bribes

• Facilitation payments

• Kickbacks or improper inducements

• Corruption, extortion, or embezzlement

• Any action intended to improperly influence decision-making

This applies to interactions with:

• Government officials and public servants

• Healthcare professionals and organisations

• Commercial partners and customers

• Any other party

Preventive Measures: Partners must implement:

• Written anti-bribery and corruption policies

• Risk assessments for corruption

• Training for all personnel on anti-corruption requirements

• Due diligence on third parties

• Financial controls and transparent record-keeping

• Whistleblowing mechanisms

Incident Reporting: Immediate disclosure of any suspected or actual bribery or corruption incidents to clarifAI.

Financial Crime Prevention

Partners must maintain:

• Adequate systems to prevent money laundering

• Controls against fraud and financial manipulation

• Accurate financial records and reporting

• Transparent beneficial ownership (where relevant)

• Compliance with sanctions and export controls

• Tax compliance and ethical tax practices

Managing Hospitality and Benefits

Appropriate Interactions

Modest and Reasonable: Any gifts, hospitality, or entertainment involving clarifAI personnel or on behalf of clarifAI must be:

• Modest in value

• Reasonable and proportionate to the business relationship

• Transparent and properly documented

• Compliant with applicable codes (e.g., ABPI, PhRMA, EFPIA)

• Never intended to improperly influence decision-making

• Consistent with clarifAI's own policies on gifts and hospitality

Particular Restrictions: Enhanced restrictions apply to:

• Healthcare professionals and organisations

• Government officials

• Procurement decision-makers

Documentation: All material hospitality or benefits must be documented with business justification.

Prohibition: Partners must never offer anything of value that could reasonably be perceived as an inducement for business or preferential treatment.

Competitive Practice and Market Conduct

Fair Competition

Partners must:

Comply with Competition Law: Adherence to antitrust and competition legislation in all jurisdictions of operation, including prohibitions on:

• Price fixing or coordination

• Market allocation

• Bid rigging

• Abuse of dominant position

• Anticompetitive information exchange

Respect Intellectual Property: Recognition and protection of:

• clarifAI's intellectual property and proprietary information

• Client intellectual property

• Third-party intellectual property rights

• Proper licensing and authorisation for materials used

Ethical Marketing: Accurate, fair, and non-misleading promotional materials and commercial communications.

Confidentiality

Restricted Use: Confidential, proprietary, or commercially sensitive information provided by clarifAI or our clients must be:

• Used solely for the authorised purpose

• Protected with appropriate safeguards

• Not disclosed to unauthorised parties

• Returned or destroyed upon request or contract termination

Segregation: Where partners work with multiple clients in the same sector, robust information barriers to prevent inadvertent disclosure or conflicts of interest.

Excellence in Delivery and Data Handling

Quality Assurance

Partners must ensure:

Consistent Standards: Quality management appropriate to the services provided:

• Documented procedures and work instructions

• Clear roles and responsibilities

• Regular review and improvement processes

• Management of non-conformances and corrective actions

Competence and Training: Personnel possess necessary qualifications, experience, and training for their roles with:

• Initial competency assessment

• Regular performance review

• Continuing professional development

• Succession planning for key roles

Healthcare and Research Standards: Where relevant, adherence to:

• Good Clinical Practice (GCP)

• Good Pharmacovigilance Practice (GVP)

• Medical writing and publication ethics guidelines

• Research ethics principles

Data Integrity

Fundamental Principle: All data and records must be Attributable, Legible, Contemporaneous, Original, and Accurate (ALCOA principles).

Partners must:

• Maintain complete, consistent, and accurate records throughout the data lifecycle

• Implement version control and audit trails

• Prevent unauthorised alteration or deletion

• Ensure data reliability and traceability

• Apply appropriate validation to systems and processes

• Conduct regular data integrity audits

Scientific Integrity: Prohibition on:

• Fabrication or falsification of data

• Plagiarism or improper attribution

• Selective reporting or cherry-picking of results

• Image manipulation beyond acceptable processing

• Any form of research or scientific misconduct

Information Protection and Privacy

Privacy by Design

Partners handling personal data on behalf of clarifAI must:

Legal Compliance: Adhere to all applicable data protection legislation including:

• UK General Data Protection Regulation (UK GDPR)

• EU GDPR (where applicable)

• Relevant territorial data protection laws

• Sector-specific requirements (e.g., health data regulations)

Data Minimisation: Collection and processing limited to what is necessary for the specified purpose.

Purpose Limitation: Personal data used only for the authorised purpose, with prohibition on secondary uses without additional authorisation.

Storage Limitation: Retention periods aligned with legal requirements and business necessity, with secure deletion thereafter.

Individual Rights: Facilitation of data subject rights including:

• Access to personal data

• Rectification of inaccuracies

• Erasure (right to be forgotten)

• Restriction of processing

• Data portability

• Objection to processing

Privacy Impact Assessments: Conducting assessments for new processing activities that present risks to individual privacy.

Processing Requirements

Lawful Basis: Clear lawful basis for all personal data processing activities.

Transparency: Provision of clear privacy information to individuals whose data is processed.

Technical and Organisational Measures: Implementation of appropriate security measures protecting personal data throughout its lifecycle.

Accountability: Documentation demonstrating compliance with data protection principles.

International Transfers: Where personal data crosses borders, appropriate transfer mechanisms compliant with applicable law.

Processor Requirements: For partners acting as data processors:

• Processing only on documented instructions from clarifAI

• Written data processing agreements in place

• Assistance with data subject rights requests

• Notification to clarifAI of any personal data breaches within 24 hours of discovery

• Support for compliance activities including audits

• Deletion or return of personal data upon contract termination

Information Security Protocols

Security Management

Partners must implement information security measures appropriate to the risks:

Access Controls: Ensuring that:

• Access is restricted to authorised personnel only

• Authentication mechanisms are robust

• Access rights are regularly reviewed and revoked when no longer required

• Privileged access is appropriately controlled

Technical Security: Implementation of:

• Encryption for data at rest and in transit

• Malware protection and prevention

• Network security controls

• Secure software development practices

• Regular security patching and updates

• Secure configuration management

Physical Security: Where relevant:

• Controlled access to facilities

• Secure storage of physical records

• Protection against environmental hazards

• Secure disposal of sensitive materials

Operational Security: Procedures addressing:

• Backup and recovery

• Business continuity and disaster recovery

• Change management

• Incident response

• Media handling and disposal

Security Awareness: Training for all personnel on information security responsibilities and good practice.

clarifAI Systems Access

Where partners access clarifAI's IT infrastructure or systems:

• Compliance with clarifAI's IT security policies and standards

• Use of approved connection methods and controls

• No introduction of unauthorised software or devices

• Prompt reporting of security incidents or vulnerabilities

• Return of credentials and access revocation upon project completion

Incident Management

Breach Notification: Immediate notification to clarifAI of any:

• Actual or suspected information security breaches

• Personal data breaches

• Loss or compromise of clarifAI or client data

• Cyberattacks or security incidents

Contact immediately: [compliance@clarifai.com]

Incident Response: Cooperation with clarifAI in:

• Investigating incidents

• Implementing containment measures

• Determining impacts and required notifications

• Conducting root cause analysis

• Implementing corrective and preventive actions

Ethical Technology Deployment

Artificial Intelligence and Emerging Technologies

Given the transformative potential of AI and our commitment to responsible innovation, partners deploying AI or machine learning technologies must:

Transparency: Clear disclosure of:

• When and how AI is being used

• Capabilities and limitations of AI systems deployed

• Potential for errors or biases

Human Oversight: AI systems must not replace human judgement on critical matters:

• Expert review of all AI-generated content before delivery

• Human accountability for outputs

• Override mechanisms for AI recommendations

Fairness and Bias: Active measures to:

• Identify and mitigate algorithmic bias

• Test for discriminatory outcomes across different populations

• Ensure representative training data

• Monitor ongoing fairness of outputs

Accuracy and Validation: Rigorous testing and validation ensuring:

• Outputs are accurate and reliable

• Quality control processes catch errors

• Continuous monitoring of performance

• Version control and audit trails

Privacy and Security: Robust controls ensuring:

• Privacy by design in AI systems

• Security of AI training data and models

• Prevention of data leakage or unauthorised learning

• Compliance with data protection regulations

Accountability Framework: Clear responsibility structures with:

• Designated oversight for AI deployment

• Documented policies and procedures

• Channels for raising concerns about AI behaviour

• Complaint and remediation mechanisms

For more detailed requirements, see clarifAI's Ethical AI Use Policy, which partners should review and align with when deploying AI technologies.

Subcontractor and Third-Party Management

Supply Chain Responsibility

Partners who engage subcontractors or third parties must:

Due Diligence: Conduct appropriate assessment of subcontractors ensuring they:

• Are suitably qualified and competent

• Can meet the standards set forth in this Code

• Have necessary authorisations and certifications

• Undergo relevant background checks

• Maintain appropriate insurance

Written Agreements: Formal contracts with subcontractors that:

• Flow down relevant requirements from this Code

• Specify service levels and quality standards

• Address confidentiality and data protection

• Include audit rights and compliance obligations

• Define responsibilities and liabilities

Prior Authorisation: clarifAI approval required before engaging subcontractors for:

• Access to confidential or personal data

• Services directly to clarifAI or our clients

• Critical or high-risk activities

Ongoing Oversight: Active management of subcontractor performance including:

• Regular performance monitoring

• Quality audits

• Compliance verification

• Incident reporting

• Continuous improvement

Supply Chain Standards: Efforts to ensure that standards cascade through multiple tiers of the supply chain.

External Communications Standards

Protecting clarifAI's Reputation

Prior Approval Required: Partners must obtain written approval from clarifAI before:

• Making any public statements about clarifAI or our relationship

• Using clarifAI's name, logo, or trademarks

• Identifying clarifAI as a client or partner in marketing materials

• Posting about clarifAI or joint work on social media

• Issuing press releases mentioning clarifAI

• Presenting about work done for clarifAI at conferences or events

Compliance with Standards: All authorised communications must:

• Align with this Code and any contractual agreements

• Comply with applicable laws and regulations

• Maintain professional tone and accuracy

• Respect confidentiality obligations

• Support clarifAI's reputation and values

Social Media Responsibility: Personnel must:

• Exercise professional judgement in online presence

• Not disclose confidential information

• Clarify when expressing personal views

• Avoid bringing clarifAI into disrepute

• Comply with professional codes of conduct

Managing Potential Conflicts

Identification and Disclosure

Prohibited Conflicts: Partners must not:

• Use clarifAI's intellectual property or confidential information for personal benefit

• Exploit business opportunities that rightfully belong to clarifAI

• Compete with clarifAI during the partnership

• Allow personal interests to compromise professional judgement

Disclosure Obligation: Immediate notification to clarifAI of:

• Any actual or potential conflicts of interest

• Financial interests in clarifAI's competitors or clients

• Personal relationships that could affect objectivity

• Outside business activities that could create conflicts

• Receipt of gifts or benefits that could influence decisions

Contact for Disclosures: [compliance@clarifai.com]

Management: Where conflicts are identified, partners must work with clarifAI to:

• Assess the significance of the conflict

• Implement appropriate mitigation measures

• Document the conflict and management approach

• Monitor ongoing effectiveness of controls

Scientific Integrity and Safety Reporting

Research Ethics

Where partners provide services connected to medical research:

Ethical Standards: Compliance with:

• World Medical Association Declaration of Helsinki

• ICH Good Clinical Practice guidelines

• Relevant national and institutional research ethics requirements

• Informed consent principles

• Research integrity frameworks

Scientific Misconduct: Absolute prohibition on and immediate reporting of:

• Data fabrication or falsification

• Plagiarism or improper attribution

• Manipulation of images beyond acceptable enhancement

• Selective reporting or suppression of data

• Deception in proposing, conducting, or reporting research

• Attempts to re-identify anonymised individuals

• Any other form of research misconduct

Suspected misconduct must be reported immediately to clarifAI for appropriate investigation and action.

Pharmacovigilance and Safety

Adverse Event Reporting: Partners must immediately report to clarifAI any:

• Adverse events or adverse reactions to medicinal products

• Product quality complaints

• Medication errors

• Potential safety signals

Definition: An adverse event is any untoward medical occurrence in a patient administered a medicinal product, whether or not considered related to the product.

Reporting Timeline: All safety information must be reported within 24 hours of awareness.

Contact for Safety Reports: [safety@clarifai.com]

Training: Personnel working on projects involving medicinal products must receive appropriate pharmacovigilance training.

Open Communication and Incident Disclosure

Transparency Principle

We value honest, proactive communication from our partners. Problems can be addressed when they're known; concealment serves no one's interests.

Mandatory Reporting

Partners must immediately notify clarifAI of any incident that could negatively affect:

• clarifAI's operations, reputation, or legal position

• Client relationships or project delivery

• Data security or personal privacy

• Patient safety or public health

• Regulatory compliance or legal obligations

Reportable Incidents Include:

Security and Privacy:

• Cyberattacks, ransomware, or system compromises

• Unauthorised access to systems or data

• Data breaches affecting personal or confidential information

• Loss or theft of devices containing sensitive data

• Malware infections or security vulnerabilities

Ethical and Legal:

• Bribery, corruption, or fraud (actual or suspected)

• Money laundering concerns

• Violations of competition law

• Sanctions breaches

• Significant tax irregularities

Quality and Safety:

• Major quality failures or systematic quality issues

• Adverse events or product safety concerns

• Scientific misconduct or research integrity breaches

• Regulatory inspections or enforcement actions

• Significant errors in delivered work

Social and Environmental:

• Serious health and safety incidents

• Environmental incidents or regulatory breaches

• Human rights violations

• Forced labour or modern slavery concerns

• Significant negative community impacts

Business Continuity:

• Events affecting ability to deliver services

• Key personnel departures impacting projects

• Financial distress or insolvency risks

• Business ownership or control changes

Reporting Process

Contact: [derek@trustclarifai.com]

Initial Notification: Within 24 hours of becoming aware, provide:

• Nature of the incident

• When it occurred and was discovered

• Potential impacts

• Immediate actions taken

• Contact person for further information

Follow-up: Provide updates as investigation progresses and cooperate fully with any clarifAI-led inquiry.

No Retaliation: clarifAI prohibits any retaliation against partners who raise concerns in good faith.

Compliance and Consequences

Monitoring and Assessment

clarifAI reserves the right to:

• Conduct compliance assessments and audits

• Request evidence of adherence to these standards

• Interview personnel and review documentation

• Inspect facilities (with reasonable notice)

• Verify subcontractor compliance

Partners must cooperate fully with such activities.

Non-Compliance

Failure to comply with this Code may result in:

• Corrective action requirements

• Suspension of new business

• Termination of partnership

• Exclusion from future opportunities

• Legal action where appropriate

The response will be proportionate to the nature and severity of the violation, the partner's cooperation, and efforts to remediate.

Continuous Improvement

We recognise that compliance is a journey, not a destination. We encourage:

• Open dialogue about challenges in meeting standards

• Collaborative problem-solving

• Sharing of best practices

• Requests for guidance or clarification

Partners demonstrating genuine commitment to improvement, even when facing challenges, will find clarifAI a supportive and constructive partner.

Questions and Support

Seeking Guidance

Partners uncertain about any aspect of this Code should contact derek@trustclarifai.com

Policy Updates

This Code is reviewed regularly and updated as necessary to reflect:

• Changes in legal or regulatory requirements

• Evolution of industry best practice

• Lessons learned from implementation

• Stakeholder feedback

Partners will be notified of material changes with reasonable implementation periods provided.

Date of last revision: February 2026.