Code of Conduct

01Purpose and scope

This Code of Conduct ("Code") defines minimum standards of integrity, legality, human dignity, security and accountability for Binnovy’s own conduct and for parties that engage with Binnovy. It applies, as relevant, to directors, officers, employees, contractors, customers, partners, suppliers, intermediaries and other persons acting for or with Binnovy.

02Compliance with law and integrity

• Act honestly, transparently and in good faith.
• Comply with applicable Qatar laws, Qatar Free Zones requirements and mandatory laws in other jurisdictions where they apply.
• Do not offer, request, authorize or accept bribery, kickbacks or other improper benefits.
• Do not facilitate money laundering, terrorism financing, sanctions evasion, fraud, trafficking, corruption or other criminal conduct.
• Maintain accurate records and do not falsify evidence, reports, audit trails, identities or compliance information.
• Disclose material conflicts of interest and manage them appropriately.

03Human rights and international humanitarian law

Binnovy respects internationally recognized human rights and the principles of international humanitarian law applicable in armed conflict. Binnovy’s approach is informed by the UN Guiding Principles on Business and Human Rights and internationally recognized definitions of genocide, crimes against humanity, war crimes and the crime of aggression. This commitment applies to Binnovy’s own operations, products, services and business relationships.

04Absolute business restriction for atrocity-linked parties

Binnovy will not knowingly enter into, maintain, renew, materially support or knowingly enable a business relationship with any person, entity or organization that Binnovy, on the basis of applicable legal designations, competent-authority findings, reliable public evidence and proportionate due diligence, reasonably concludes is directly engaged in, directing, materially supporting or materially profiting from genocide, crimes against humanity, war crimes, unlawful armed aggression, torture, enforced disappearance, slavery, forced labour, human trafficking, deliberate attacks against civilians, hostage-taking, terrorism, or other grave violations of international humanitarian law or international human-rights law.

This restriction applies regardless of nationality, political alignment, ownership model or whether the party is a state body, state-owned enterprise, armed force, security service, non-state armed group, private military/security actor, company, contractor, intermediary, investor, customer, supplier or partner.

Binnovy does not make such determinations on rumor, ethnicity, nationality or political viewpoint. Decisions are risk-based and may rely on binding sanctions or designation lists, final or authoritative findings of competent courts or international bodies, credible investigations, and documented due diligence. Where credible risk is unresolved, Binnovy may pause onboarding, refuse a transaction, restrict service or suspend the relationship while enhanced due diligence is completed.

05Conflict-affected and high-risk areas

Where a customer, partner, transaction or use case has a material connection to an armed conflict, occupation, mass-atrocity risk or other high-risk environment, Binnovy applies enhanced due diligence proportionate to the risk. This may include identifying beneficial ownership and end users, reviewing sanctions and designation lists, assessing the intended use of Binnovy technology, evaluating links to military or security operations, requiring contractual assurances, restricting functionality, and escalating the decision to senior governance or legal review.

06Prohibited contribution to harm

Binnovy services, AI capabilities, data, infrastructure or expertise must not be used to materially facilitate:

• Targeting civilians or civilian objects in violation of international humanitarian law.
• Indiscriminate or unlawful attacks, persecution, collective punishment, unlawful forced displacement or hostage-taking.
• Torture, cruel or degrading treatment, human trafficking, slavery, forced labour or exploitation.
• Unlawful surveillance, profiling or identification intended to persecute protected populations or enable grave rights abuses.
• Autonomous or automated selection or engagement of human targets where prohibited by law or Binnovy policy.
• Concealment, falsification or destruction of evidence relating to serious human-rights abuses or international crimes.

07Sanctions, terrorism and financial crime

Binnovy complies with applicable targeted financial sanctions, anti-money-laundering and counter-terrorism requirements, including, where applicable to Binnovy or the transaction, Law No. 20 of 2019 on Combating Money Laundering and Terrorism Financing and Law No. 27 of 2019 on Counter-Terrorism, together with implementing measures and competent-authority designations. Screening and due diligence may take account of designations maintained by competent Qatar authorities, the United Nations Security Council and other sanctions regimes that legally apply to Binnovy or a transaction. No party may use Binnovy to evade sanctions, disguise beneficial ownership, move criminal proceeds or finance terrorism.

08People, dignity and fair treatment

Binnovy expects respectful, professional and lawful conduct. Harassment, violence, threats, exploitation, unlawful discrimination, retaliation and forced labour are prohibited. Suppliers and partners are expected to respect applicable labour rights, health and safety requirements and human dignity throughout their operations and supply chains.

09Privacy, security and confidentiality

Personal data, confidential information, credentials and customer systems must be handled only for authorized purposes and protected with measures appropriate to their sensitivity. Attempted unauthorized access, concealment of a security incident, misuse of privileged access, or intentional weakening of governance or audit controls is a serious breach of this Code.

10Responsible AI and evidence integrity

Binnovy expects AI and automated systems to be used within defined legal, safety, accountability and human-oversight boundaries. Parties must not misrepresent an AI output as verified evidence, fabricate assurance records, manipulate audit logs, or intentionally bypass required governance gates, human approvals or risk controls.

11Reporting concerns and non-retaliation

Suspected violations may be reported through /contact and should be marked "Code of Conduct / Compliance". Binnovy will assess credible reports with appropriate confidentiality. Retaliation against a person who raises a concern in good faith is prohibited.

12Enforcement

A substantiated breach may result in remediation requirements, refusal of onboarding, suspension or termination of access or a commercial relationship, preservation of relevant evidence, contractual remedies, or referral to competent authorities where required by law. Decisions will be documented and proportionate to the severity, credibility and immediacy of the risk.