Truecaller

Code of
Conduct
 1

Index.

Letter from the CEO

3

1 Introduction
4

1.1 Application 5

1.2 Compliance with laws and regulations 5

1.3 Monitoring 5

2 Human rights 6

3 Elimination of discrimination 7

3.1 Respect and dignity 7

3.2 Freedom of association 7

3.3 Prohibition of forced labour 7

3.4 Prohibition of child labour 8

3.5 Fair employment conditions 8

3.6 Fair, safe and healthy working conditions 8

3.7 Responsible sourcing of raw materials 9

4 Anti-corruption and business integrity 1 0

5 Environment 1 1

6 Business principles 1 2

6.1 Conflicts of interest and competition 12

6.2 Communication and financial information 12

6.3 Protection and proper use of company assets 13

6.3.1 Intellectual property 13

6.3.2 Information technology resources 13

6.4 Protecting information 14

v
6.5 Pre enting insider trading 14

6.6 Personal data and pri acyv 15

6. 7 Use of information technology 15

7 Anti-money laundering 1 6

8 Reporting compliance concerns 1 7

9 Consequences in case of violations 1 8

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Approved by the Board of Directors on May 10, 2023.

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Letter from the CEO
We know that winning is not just about results,
but how you get those results. Ethics and
compliance is a fundamental part of a
performance culture in a successful company.
Ethical leadership is about each individual’s
decisions and actions with others. Just as we
have a responsibility to our customers, we
have a responsibility to ourselves to uphold
the value of uncompromising integrity.

The Code of Conduct is our foundation of

ethical leadership and encompasses the
basic principles that govern our ethical and
legal obligations to Truecaller. These
standards provide clarity and guidance on
how Truecaller expects all employees to
operate on a daily basis, both internally and
externally. Adhering to these standards
strengthens our reputation with our customers
and shareholders for honesty and fair dealing
and protects our bottom line.

Each of us has a personal responsibility to

understand these policies and practice them
in our daily business lives. Unethical or illegal
business conduct on the part of Truecaller is
simply unacceptable and will not be tolerated.

I appreciate the commitment and continued

efforts of the Truecaller community to
strengthen and protect both our company
and our reputation.

Alan Mamedi

Chief Executive Officer

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 1. Introduction
This Code of Conduct has the purpose of ensuring the promotion of fair employment
conditions, safe working conditions, responsible management of environmental issues,
protection of human rights and high ethical standards.

This Code of Conduct sets out the We shall avoid causing, contributing to
fundamental principles of law and ethics and being linked to adverse human rights
governing the way that Truecaller does impacts, and adequately address such
business. These standards are not the impacts when they occur. We shall, in all
exclusive source of guidance and contexts, seek ways to honour the
information on Truecaller’s expectations, principles of internationally recognized
but they serve as the basis for other human rights.

Truecaller policies, instructions and

guidelines. Every member of Truecaller Breaching this Code of Conduct could
community – directors, executives, have serious implications for Truecaller
managers, employees and business and for individuals involved. Where illegal
partners has a duty to comply with conduct is found, the consequences
applicable laws and adhere to the could include significant fines for
highest standards of business ethics.

Truecaller, imprisonment for individuals

and significant damage to our brand
In order to ensure high standards, True name and therefore financial damage.

Software Scandinavia AB, Truecaller

International LLP and every other As a company that deals with significant
company in the group of companies amounts of information and with over
(hereinafter jointly referred to as 350 million monthly active users
“Truecaller”, “we”, “our”) shall respect all worldwide, respecting the privacy of
internationally recognized human rights individuals is essential to how Truecaller
demanded by national laws and operates its business. Truecaller sets out
regulation, including in relation to to work together with its Business Partners 2
freedom of association and collective to ensure that their activities are aligned
bargaining, forced labour, child labour, with our Code of Conduct.

and non-discrimination.

2 References in this Code of Conduct to ”Business Partners” include: 1) consultants, 2) agents, 3) distributors, 4) suppliers, and 5)
other business partners..

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 1.1 Application 1.2 Compliance with

laws and regulations

This Code of Conduct shall be applied All Truecaller units, companies,

throughout our operations globally, executives, board members, Employees
including in the management, and Business Partners shall comply with
development, supply, sales and support relevant laws and regulations in the
of our solutions and services.

countries where we operate.

All Truecaller units, companies,

executives, board members, and
Employees3shall comply with this Code of
1.3 Monitoring
Conduct. Truecaller also requires that all
its Business Partners comply with Compliance with this Code of Conduct is
equivalent standards as set out in this essential to Truecaller. The Board of
Code of Conduct and that they have Directors is responsible for ensuring this
appropriate systems in place to ensure Code of Conduct and the standards
continuous compliance and to therein are applied throughout
demonstrate such compliance. Any Truecaller’s operations.

breach of this Code of Conduct will allow

Truecaller to terminate its relationship
with the Business Partners with Assurance of compliance within
immediate effect.

Truecaller is monitored by senior

management on an annual basis. Senior
management shall see to, and
This Code of Conduct cannot provide a Employees must ensure, that all
solution for every situation, particularly as Employees know and understand the
laws differ between countries. If specific requirements of this Code of Conduct.

eventualities are not expressly covered,

the spirit of this Code of Conduct, and
other group policies, must be upheld by Any breaches of the Code of Conduct
exercising common sense and good must be reported. The Board of True
judgement, always in compliance with Software Scandinavia AB and Truecaller
applicable laws. International LLP will not criticise senior
management for any loss of business
that is a result from observance of this
3 References in this Code of Conduct to ”Employees” include:
Code of Conduct, and other group
1) employees, whether full-time, part-time, fixed-term, policies.

permanent or trainees, 2) contractors, temporary staff,

secondees, work-experience placements, 3) persons with
statutory director roles or equivalent responsibilities, 4)
employees of joint-ventures and approved third-party
labour providers where Truecaller has direct management
control, and 5) employees of new acquisitions, wherever
located.

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2. Human rights

Truecaller and its Business Partners shall

respect all internationally recognized

human rights, including the International

Bill of Human Rights.

We shall avoid causing, contributing to

and being linked to adverse human rights

impacts, and adequately address such

impacts when they occur.

We recognize that businesses such as

ours have the responsibility to respect

human rights, as well as the ability to

contribute to positive human rights

impacts.

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 3. Elimination of
discrimination
3.1 Respect and Dignity 3.2 Freedom of
association

All Employees shall be treated with All Employees shall be free to form and to
respect and dignity, and all forms of join, or not to join, trade unions or similar
discrimination are prohibited. This external representative organizations and
includes, but is not limited to, to bargain collectively. Information and
discrimination based on race, colour, consultation with Employees can be done
gender, sexual orientation, gender through formal arrangements or, if such
identity, marital status, pregnancy, do not exist, other mechanisms may be
parental status, religion, political opinion, used.
nationality, ethnic background, social
origin, social status, indigenous status,
disability, age, union membership or
Employee representation and any other 3.3 Prohibition of forced
characteristic protected by local law, as labour
applicable.

Truecaller respects all internationally Modern day slavery, including forced,

recognized human rights, including the bonded or compulsory labour and
principles concerning fundamental rights human trafficking are strictly prohibited.
set out in the International Labour Employees shall be free to leave their
Organization´s (ILO) Declaration on employment after reasonable notice as
Fundamental Principles and Rights at required by applicable law or contract.
Work, and the eight ILO core conventions. 4 Employees shall not be required to lodge
deposits of money or identity papers with
their employer.

4 The eight core conventions are: Freedom of Association and Protection of the Right to Organise Convention, 1948 (No. 87), Right
to Organise and Collective Bargaining Convention, 1949 (No. 98), Forced Labour Convention, 1930 (No. 29), Abolition of Forced
Labour Convention, 1957 (No. 105), Minimum Age Convention, 1973 (No. 138), Worst Forms of Child Labour Convention, 1999 (No.
182), Equal Remuneration Convention, 1951 (No. 100), and Discrimination (Employment and Occupation) Convention, 1958 (No. 111)

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3.4 Prohibition of child 3.6 Fair, safe and healthy

labour working conditions

No person shall be employed who is Truecaller complies with all applicable

below the minimum legal age for legislation and regulation concerning fair,

employment. Minimum age is the age of safe and healthy working conditions, and

completion of compulsory schooling, or aims to continuously improve health and

not less than 18 years. A child means a safety performance.

person below the age of 18 years.

Personal development includes a child’s

The health and safety of our Employees
health or physical, mental, spiritual, moral,
shall be prioritised. A healthy and safe
or social development.
working environment, including

psychosocial considerations, shall be

provided for Employees, in accordance

with international standards and national

3.5 Fair employment
laws. The health and safety of workers
conditions
shall never be compromised because of

cost efficiency or expediency concerns.

Employees shall understand their

Detected unsafe or unhealthy practices

employment conditions. All Employees

shall be reported to the immediate

will be provided with a written document

manager so that they can be adequately

that outlines the basic terms and

addressed.

conditions of employment in a language

understandable to them.

Appropriate health and safety

information and training shall be

Pay and terms shall be fair and

provided to Employees, including, but not

reasonable and comply at a minimum

limited to, risks they are exposed to and

with applicable laws or industry

arrangements for safe evacuations of

standards, whichever is higher.

buildings.

Working hours shall comply with

All Employees shall be provided with

applicable laws. Deduction from wages

necessary and relevant personal

as a disciplinary measure shall not be

protective equipment, when applicable.

permitted. Corporal punishment, physical

Truecaller shall also provide support to

or verbal abuse, bullying or other unlawful

Employees to maintain a balance

harassment and any threats or other

between work and personal life.

forms of intimidation shall be prohibited.

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3.7 Responsible sourcing
of raw materials

Due diligence shall be exercised with

respect to the sourcing and extraction of
raw materials in hardware purchased by
Truecaller.

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4. Anti-corruption and
business integrity

Truecaller upholds the highest standards

of integrity in business interactions and
has a zero-tolerance policy towards any
form of corruption and financial
irregularity.

For example bribery, kickbacks, facilitation

payments, fraud, embezzlement, and
money laundering to ensure that no
Employee acts in any way that is
inconsistent with Truecaller’s objectives or
with the integrity of the business.

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 5. Environment
We shall develop, produce, and offer services that contribute to the sustainable
development of society and continuously improve, with a life cycle perspective, the
environmental performance of our business activities.

We shall work to continuously reduce the We shall endeavour to avoid or reduce

negative impact of our own operations any waste or emissions that are caused
and take a precautionary approach to as a result of our business activities. We
environmental challenges.

will use efficient technologies which aim

to reduce the environmental impact as
We are committed to making continuous much as possible. Truecaller adopts a
improvements in the management of our precautionary approach and will -where
environmental impact and to the longer- applicable- respect the polluter pays
term goal of developing a sustainable principles.

business. In this respect, we shall use

appropriate methodologies to determine
significant issues and aspects, for setting
and reviewing objectives and targets
securing that statements and
communication regarding the
sustainability performance of our
operations and services are fact based.

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 6. Business principles
6.1 Conflicts of interest 6.2 Communication and
and competition financial information

All Employees, Business Partners and Truecaller shall ensure that its Employees
others working for Truecaller are have a good understanding of their units’
expected to always act in the best operational and financial performance to
interest of Truecaller, and to avoid increase involvement in improving
personal activities and financial interests operations. Comments about financial
which could conflict with their performance and prospects to external
responsibilities to Truecaller. Employees parties shall however only be made by
must not seek gain for themselves or official company spokespersons.
others through the misuse of their Employees shall -in other cases- not
positions.

make any comments on behalf of

Truecaller, unless expressly authorised by
Truecaller and its Business Partners shall the senior management.

respect and comply with all applicable

competition laws and regulations and Everyone involved in financial reporting
not enter into discussions or agreements shall always provide full, fair, accurate,
with competitors concerning pricing, timely, and understandable disclosures in
market sharing or other anti-competitive reports and documents that Truecaller
arrangements. files with or submits to government
agencies or authorities or makes in other
public communications.

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6.3 Protection and proper 6.3.2 Information technology
resources
use of company assets

Truecaller has a wide variety of assets, Truecaller’s information technology (IT)

including physical assets, proprietary resources, including communication
information and intellectual property. systems and connections to the Internet,
Employees are responsible for protecting shall be used for conducting Truecaller
Truecaller property that has been business or for other incidental purposes,
entrusted to them, and for helping to authorised by management or
protect our assets in general.

applicable steering documents.

All Employees must be aware of and Unacceptable use of Truecaller’s IT

understand Truecaller’s information resources includes: processing, sending,
security policies and report any loss, or retrieving, accessing, displaying, storing,
risk of loss, of Truecaller property to the printing or otherwise disseminating
immediate manager, or other material and information that is
responsible manager, as soon as it fraudulent, harassing, threatening, illegal,
comes to their attention. racially or sexually oriented, obscene,
intimidating, defamatory or otherwise
inconsistent with a professional
6.3.1 Intellectual property environment.

Intellectual property includes a variety of

properties, such as computer programs,
technical documentation and inventions.
Intellectual property is an asset of utmost
value to Truecaller and must be treated
with appropriate care. Employees must
follow and, in case of doubt, seek
instructions on how Employees shall act
to protect this valuable asset.

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6.4 Protecting
information

Information is a valuable business asset Non-authorized access, use and

to Truecaller. As such, Employees shall disclosure may also be a violation of laws,
protect Truecaller’s confidential and including privacy regulations. Whenever
proprietary information and that of our an Employee is in doubt of his/her
users, customers, partners and suppliers. authorization, the Employee must seek
In order to protect this information instructions from an immediate
Employees are not allowed to access, manager, or other relevant function
make queries or search for data in within the company.
Truecaller’s database unless the
Employee is explicitly authorised to do so.

6.5 Preventing insider

Persons working for Truecaller have
access to information owned by
trading
Truecaller and sometimes also to
information owned by third parties. Such
information may be financial information, Employees are prohibited from using
business plans, technical information, inside information received from
information about Employees and Truecaller or from any of Truecaller’s
customers, and other types of Business Partners, for the purpose to buy
information. Non-authorized access, use or sell securities of Truecaller or of
and disclosure of such information may Truecaller’s Business Partners. Securities
damage Truecaller or the third party and, include shares, equities, warrants and
therefore, Employees are not allowed to related derivatives or spread bets.

access, use or disclose the information

unless properly authorised to do so.
Trading or encouraging others to trade
Employees are not allowed to seek,
on inside information, or giving it to
access, use or disclose confidential
unauthorised parties, is considered a
information from competitors as well.
criminal offence in most countries. A
violation of the applicable laws can lead
to fines and/or prison sentences.

Inside information is understood as

information that is not publicly available
and that a reasonable investor is likely to
consider important in deciding whether
to buy or sell a company’s shares.

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6.6 Personal data and 6.7 Use of information
privacy technology

We are subject to many different data Our Employees must ensure the
protection regulations in the countries responsible and secure use of IT, applying
where we do business and closely track the same personal and professional
the data privacy landscape in these standards as for any other business
countries to make sure that we activity when using the internet, intranet,
proactively adopt good practices and social media, messaging and email.
stand ready to comply with them. We
also allocate significant resources to take
the necessary steps to become
compliant.

Further, privacy is integral to the system

and all components of Truecaller and
Truecaller seeks to deliver the maximum
degree of privacy by ensuring that
personal data are automatically
protected in any given IT system or
business practice and that no action is
required on the part of the individual to
protect their privacy.

In this respect, our Employees access

user data only if they have been explicitly
granted access rights as part of their job
and only if it is needed to perform their
job function. This access is tightly
controlled and only allowed in a manner
that respects users' privacy. Violations of
this rule will be taken extremely seriously.
We also ensure that this is also the case
for Truecaller’s Business Partners with
whom Truecaller associates with.

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7. Anti-money laundering

Money laundering occurs when funds or

other assets originating directly or
indirectly from criminal offenses are put
into circulation in the legal economy,
making their source appear legal.

Liability for money laundering does not

require the person involved to be aware
that money is being laundered through
the legal transaction concerned or the
transfer concerned.

To protect our reputation, comply with the

laws against money laundering and thus
avoid any liability, it is essential not to
become associated – even if innocently –
with criminal activities and conduct
business solely with reputable partners
who operate in line with legal provisions
and who use resources from legitimate
sources. Truecaller’s Employees and
Truecaller itself must ensure that we do
not receive the proceeds of criminal
activities and carefully check the identity
of our Business Partners and other third
parties with whom we wish to do
business.

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 8. Reporting compliance
concerns

All Truecaller’s Employees may, and are always encouraged to, report suspected

violations of laws or this Code of Conduct to the local head of HR in India or Sweden

depending on where the violation took place, or to the Compliance function at the Legal.

Truecaller makes available appropriate Truecaller will treat all reports on potential

grievance mechanisms that are misconduct seriously. You do not need

available to Employees and other proof of your suspicions, but all reports

stakeholders, including affected must be made in good faith. Reports in

communities, to make comments, bad faith containing knowingly false and

recommendations, or complaints untrue allegations will not be handled.

concerning the workplace, the Such reports themselves constitute

environment or business practices. You potential misconduct, which can be

can file a report through emailing subject to internal investigations and

whistleblowing@truecaller.com.

potential sanctions against the person

making such reports.

This email will go to the Group Chief Legal

Officer and Chief People Officer.

Truecaller´s whistleblower system is

committed to protecting the

whistleblower and the individual affected.

We do not tolerate retaliation or pressure

on whistleblowers.

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9. Consequences in case
of violations

A fundamental principle within Truecaller

is to conduct business in a manner
compliant with this Code of Conduct.

Failures to comply with this Code of

Conduct are taken very seriously by
Truecaller and may result in disciplinary
action, including termination of
employment and legal action.

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