Code of Ethics and Business Conduct

Scope

Our principles

• Integrity: We act honestly, lawfully and fairly.
• Respect: We treat people with dignity and support an inclusive learning and working environment.
• Professional quality: We acceptwork we are qualified to perform and deliver it with care.
• Confidentiality: We protectpersonal data, business information and the private nature of learningconversations.
• Accountability: We take responsibility for our decisions, correct mistakes and raise concerns.

Lawful and honest business conduct

• Comply with the laws, regulations and contractual requirements that apply to your work.
• Do not engage in fraud, deception, theft, falsification of records, money laundering or other unlawful conduct.
• Describe mYngle services,qualifications, prices, capabilities and expected outcomes accurately.
• Do not make commitments, offerdiscounts, sign agreements or represent that you can bind mYngle unless youhave written authority.
• Keep learner, attendance,progress, sales, expense, invoice and other business records accurate andcomplete.
• Cooperate honestly with clientreviews, audits, investigations and lawful requests from authorities.
• Follow applicable sanctions,export-control and anti-money-laundering requirements.

Anti-bribery, gifts and conflicts of interest

• Do not offer, promise, request or accept bribes, kickbacks, facilitation payments or any improper advantage.
• Do not use another person or organisation to do something that would be prohibited if done directly.
• Gifts and hospitality must belawful, modest, infrequent and must never be intended to influence a decision.
• Cash and cash equivalents mustnot be offered or accepted.
• Disclose any actual, potentialor perceived conflict of interest promptly.
• Business decisions must bebased on legitimate factors such as quality, capability, service, need andprice.

Respect, inclusion and professional boundaries

• Treat learners, clientcontacts, colleagues, teachers, contractors and partners with dignity andrespect.
• Do not discriminate on anyground protected by applicable law.
• Harassment, bullying, sexualharassment, hate speech, threats, intimidation, exploitation and retaliationare prohibited.
• Respect differences in culture,nationality, religion, belief, opinion and communication style.
• Do not exploit a position oftrust or pursue inappropriate personal, romantic, sexual, financial orcommercial relationships with learners or client contacts.
• Do not work while impaired in away that makes safe and professional performance impossible.
• Where a learner is under 18 orotherwise vulnerable, follow all applicable safeguarding requirements and useauthorised communication channels.
• Raise concerns promptly whenconduct may place a learner or another person at risk.

Professional standards for learning services

• Accept only assignments forwhich you have the appropriate qualifications, language competence, experienceand capacity.
• Present your identity,qualifications and experience truthfully.
• Prepare appropriately, bepunctual and make reasonable efforts to deliver confirmed lessons and servicesas agreed.
• Notify the learner and mYnglepromptly when illness, emergency or technical failure prevents delivery, andsupport rescheduling or handover.
• Use professional judgementwhile respecting agreed course objectives, learner needs, quality standards andauthorised client requirements.
• Use inclusive, accurate andappropriate learning materials.
• Assess learners fairly andconsistently against communicated criteria.
• Do not manipulate results orallow personal bias to affect an assessment.
• Do not guarantee learning,assessment or business outcomes that cannot reasonably be guaranteed.
• Complete agreed feedback,progress records, course plans and achievement reports accurately and on time.
• Do not contact corporate clientrepresentatives about programme arrangements unless authorised by mYngle.
• Do not solicit learners orprovide competing services outside authorised mYngle channels in breach ofcontractual or platform rules.

Learner confidentiality and corporate reporting

• Reports to corporate clientsmust be limited to information that is agreed and relevant, such as attendance,completion, level, progress and learning outcomes.
• Do not share private statementsmade during a lesson, personal opinions, workplace information or unrelatedpersonal details.
• Information may be disclosedwhere the learner has been informed and the disclosure is authorised, wheredisclosure is legally required, or where it is necessary to address a serioussafety risk.
• When uncertain about what maybe reported, ask the appropriate mYngle contact before sharing the information.

Confidentiality, privacy and information security

• Use confidential information and personal data only for the authorised business or learning purpose.
• Access only the information needed for your role.
• Do not share accounts,passwords or access rights.
• Do not disclose, copy,download, publish, sell or use mYngle, client, learner or teacher informationfor personal purposes.
• Use approved systems, securedevices, strong passwords, multi-factor authentication and current securityupdates.
• Do not store mYngle or clientinformation in personal email, personal cloud storage, unapproved messagingservices or unapproved external tools.
• Take reasonable precautionswhen working remotely, including protecting screens and conversations andavoiding unsecured public networks.
• Report loss, theft, malware,suspicious access, accidental disclosure or a suspected personal data breachimmediately.
• Keep information only for aslong as authorised, then return or securely delete it.
• Confidentiality continues afteremployment, an assignment or a contract ends.

Responsible use of technology and artificialintelligence

• Use only technology and AI tools approved for the relevant purpose.
• Do not upload confidentialinformation, learner data, client data, transcripts or mYngle materials to anunapproved AI, transcription or storage service.
• Do not secretly record ortranscribe a lesson, meeting or conversation.
• Where transcription orAI-supported pedagogical notes are used, follow the applicable Privacy Policy,contractual terms, consent or preference requirements, retention rules andclient requirements.
• Review AI-generated notes,translations, recommendations and other outputs for errors, omissions, bias andinappropriate content.
• Do not use AI output as thesole basis for a significant decision about a learner, teacher, employee orcontractor unless the use is lawful, authorised and subject to appropriatesafeguards.
• Do not use mYngle, client,learner or teacher data to train a general-purpose AI model unless specificallyauthorised and legally permitted.
• Be transparent about materialAI involvement where required by law, contract, client policy or professionalfairness.
• Report harmful, discriminatory,inaccurate or insecure AI behaviour promptly.

Intellectual property and company resources

• Respect copyright, trademarks,database rights, licences and other intellectual property rights.
• Use mYngle and client materialsonly for the authorised assignment and within the applicable licence orcontract.
• Do not reproduce, distribute,sell, publish, adapt, scrape or upload teaching materials to external toolswithout permission.
• Do not use another teacher's,supplier's or competitor's material without a valid right or licence.
• Use mYngle names, logos,systems, email addresses and other resources only for authorised purposes.
• Return or delete mYngleproperty, materials, credentials and information when requested or when therelationship ends.

Communications, marketing and sales

• Communicate accurately,respectfully and professionally.
• Identify yourself and yourrelationship with mYngle truthfully.
• Follow applicabletelemarketing, electronic marketing, consent, calling-hour,caller-identification and do-not-contact rules.
• Honour opt-outs and mYngle orclient do-not-contact instructions promptly.
• Do not send spam, create fakereviews, impersonate another person or make misleading statements aboutcompetitors.
• Do not disclose confidentialinformation or speak publicly on behalf of mYngle unless authorised.
• Use social media responsiblyand make clear when a personal opinion is your own.
• Escalate complaints, safetyconcerns, data incidents and serious service issues promptly.

Human rights, fair work and environmentalresponsibility

• Respect internationallyrecognised human rights and applicable labour standards.
• Do not use or tolerate forcedlabour, child labour, trafficking, exploitation or abusive working practices.
• Support a safe and respectfulworking and learning environment within the scope of your responsibilities.
• Respect the legal status andindependence of contractors and freelancers.
• Work with suppliers andpartners on the basis of lawful and responsible practices.
• Reduce avoidable environmentalimpact through responsible use of energy, devices, materials, travel and wastedisposal.
• Do not make unsupportedenvironmental or social-responsibility claims.

Raising concerns

• Raise the concern with yourusual mYngle contact, the Director of Operations, the CEO [email protected].
• Privacy and personal-dataconcerns may also be sent to [email protected].
• If the concern involves one ofthese people, report it to another appropriate senior person who is notinvolved.
• Provide facts, dates, documentsand names where available.
• mYngle will handle concernsdiscreetly, assess them fairly and share information only with those who needit for review or action.
• Retaliation against a personwho raises a concern or participates in a review in good faith is prohibited.
• A concern raised in good faithdoes not become a violation merely because it is unsubstantiated.
• Knowingly false or maliciousreports may result in action.
• Nothing in this Code preventslawful reporting to a regulator, law-enforcement authority or another protectedexternal channel.

Responsibilities and consequences

• Read, understand and follow the Code.
• Complete relevant training orconfirmations when requested.
• Ask for guidance before takingan action that may create legal, ethical, privacy or safety risk.
• Report suspected breaches andcooperate honestly with reviews.
• Correct mistakes promptly andhelp prevent recurrence.

• Lead by example and include ethical considerations in business decisions.
• Make it safe for people to ask questions and raise concerns.
• Respond promptly and protect people from retaliation.
• Apply standards consistently and proportionately.
• Communicate relevant client-specific requirements to the people who need them.

Administration of this Code

• The CEO and Director of Operations are responsible for maintaining this Code.
• The Code will be reviewed periodically and updated when mYngle services, technology, laws or client requirements change materially.
• Exceptions require priorwritten approval from an authorised mYngle decision-maker and cannot overrideapplicable law.
• The English version controls if a translation differs, unless applicable law requires otherwise.