Plaud Code of Conduct

PLAUD BUSINESS PARTNER CODE OF CONDUCT

For all Business Partners (including suppliers, vendors, contractors, consultants, agents, distributors, resellers, clients, customers and other third parties)

Effective date: January 10, 2026
Version: 1.0

This PLAUD BUSINESS PARTNER CODE OF CONDUCT is binding upon Business Partners upon each of: (a) execution of this document by a representative of the Business Partner; (b) execution of a contract that incorporates a link or reference to this document; or (c) continued provision of goods or services to Plaud following receipt of this document (or a link thereto) via email or other written means.

Key Commitments Summary

This summary highlights core commitments. Business Partners must read and comply with the full Code of Conduct and all applicable agreements and laws.

Legal compliance

Comply with all applicable laws and regulations (including those with extraterritorial reach).
Maintain accurate books and records and cooperate with lawful audits and assessments.

Ethics and integrity

Conduct business honestly and fairly; avoid deceptive or unethical practices.
Protect Plaud’s reputation and goodwill in public communications.

Anti-bribery and corruption

Follow all anti-bribery/anti-corruption laws (e.g., USA FCPA, UK Bribery Act).
Never offer, give, request, or accept improper benefits, kickbacks, or facilitation payments.
Disclose conflicts of interest promptly.

Trade controls and sanctions

Comply with export controls and economic sanctions (UN, EU, US OFAC/BIS, UK, and others).
Do not deal with sanctioned persons or entities.
Do not divert products/technology to prohibited uses, persons, entities or destinations.
Do not provide services, products or technology to Plaud in violation of the laws.
Notify Plaud immediately of any sanctions risk or listing.

Anti-money laundering and anti-terrorism financing

Comply with AML/ATF requirements and maintain financial integrity.

Privacy, information security, and confidentiality

Protect Personal Information and confidential information; use only as authorized for Plaud-related work.
If acting as a data processor, implement required safeguards (including breach notification within 24 hours) and support Plaud’s compliance.

Human rights and labor

Respect human rights; prohibit forced labor, human trafficking, and child labor.
Provide non-discriminatory workplaces and respect freedom of association; comply with wage/hour laws.

Health, safety, and environment

Provide safe working conditions; manage hazards and emergencies.
Comply with environmental laws; reduce pollution and environmental footprint where practicable.

Supply chain responsibility

Flow down comparable requirements to subcontractors and suppliers and conduct appropriate due diligence.
Cooperate with corrective actions and remediation when issues arise.

Speak up and cooperate

Report suspected violations and cooperate with investigations and regulatory requests (as permitted by law).
Maintain non-retaliation protections for good-faith reporting.

Business Partner Code of Conduct

Applies to Plaud Inc. and all of its Affiliates (“Plaud”) and all Business Partners (as defined below).

1. Purpose

Plaud is committed to the highest standards of integrity, lawful conduct, and responsible business practices. This Code describes Plaud’s expectations for how Business Partners conduct business when working with Plaud and/or representing Plaud in any capacity.

2. Scope and applicability

2.1 Who this applies to

This Code applies to all third parties that provide products or services to Plaud or otherwise do business with Plaud, including (without limitation): suppliers, manufacturers, vendors, contractors, consultants, professional service firms, agents, advisors, distributors, resellers, sales representatives, channel partners, implementation partners, logistics providers, outsourcing providers, joint venture partners, clients, customers, and other third parties (each, a “Business Partner”).

2.2 Compliance baseline

Business Partners must (a) comply with this Code, (b) comply with all applicable laws, rules, regulations, and governmental orders in all jurisdictions where they operate, including laws with extraterritorial reach, and (c) be open and cooperative with regulators that enforce such laws.

2.3 Flow-down

Business Partners must impose substantially similar obligations on their own personnel, subcontractors, agents, and suppliers involved in work for Plaud, and remain responsible for their compliance in connection with Plaud-related work.

2.4 Contract priority

This Code complements contractual obligations. If a Plaud agreement imposes stricter requirements than this Code, the stricter requirements apply.

3. Definitions

Affiliate(s): Any entity that directly or indirectly controls, is controlled by, or is under common control with Plaud Inc.

Applicable Law: All applicable international, national, regional, and local laws, regulations, directives, rules, and binding governmental orders.

Personal Information: Any information relating to an identified or identifiable individual, including (where applicable) personal data as defined under relevant data protection laws.

Business Partner Personnel: The Business Partner’s directors, officers, employees, contractors, agents, representatives, subcontractors, and permitted suppliers engaged in Plaud-related activities.

Dangerous Content: Content relating to politics, religion, insults, rumors, intimidation, violence, ethnicity, race, borderline content, pornography, obscenity, or other offensive, extreme, or illegal statements, videos, or images.

4. Ethics and integrity

4.1 Fair and honest dealing

Business Partners must act ethically and with integrity, avoid deception, and conduct business in a manner that reflects favorably on Plaud’s reputation and goodwill.

4.2 Accurate records

Business Partners must maintain complete, accurate, and truthful records related to Plaud business (including invoices, supporting documentation, and transaction records), and must not create false, misleading, or artificial entries.

4.3 No deceptive or unethical practices

Business Partners must not engage in deceptive, misleading, illegal, libelous, obscene, or unethical practices, and must ensure their conduct does not cause Plaud to breach Applicable Law or industry codes.

5. Anti-bribery and anti-corruption

5.1 Compliance with anti-bribery laws

Business Partners must comply with all applicable anti-bribery and anti-corruption laws and regulations, including (where applicable) the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act.

5.2 Prohibition on improper benefits

Business Partners must not, directly or indirectly, solicit, offer, promise, authorize, give, or accept anything of value to obtain an improper advantage or influence any decision (including with Plaud personnel, Plaud customers, suppliers, government officials, or any third party). Prohibited benefits include, without limitation: rebates (explicit or hidden), cash, gift cards, physical items, securities, travel, hospitality, entertainment (such as banquets or tours), or other material or non-material benefits—except where expressly permitted in a written agreement and compliant with Applicable Law.

5.3 Gifts and entertainment controls

Business Partners must not offer or accept gifts or anything else of value to obtain improper advantages or influence, and must ensure any permitted gifts/hospitality are: (a) reasonable and appropriate, (b) infrequent, (c) transparent and properly recorded, (d) not cash or cash-equivalent, and (e) compliant with Applicable Law.

5.4 No acting unlawfully on Plaud’s behalf

Business Partners may not act in the name of, or for the benefit of, Plaud in any manner that violates Applicable Law or applicable industry standards.

5.5 Subcontractor control

Business Partners must ensure their Business Partner Personnel, Affiliates, and subcontractors comply with this anti-bribery section.

6. Conflicts of interest

6.1 Avoid conflicts

Business Partners must avoid any relationship, transaction, or activity that creates (or appears to create) a conflict with maintaining an objective and fair business relationship with Plaud.

6.2 Disclosure

Business Partners must promptly disclose any actual or potential conflict of interest to Plaud without undue delay, including personal relationships with Plaud employees that could influence decision-making.

7. Competition / antitrust compliance

Business Partners must strictly comply with applicable competition/antitrust laws and must not enter into anti-competitive activities or agreements (e.g., price fixing, bid rigging, market allocation) and must stand against illegal cartels.

8. Responsible communications and content restrictions

8.1 No harmful or unlawful content

Business Partners must not publish, disseminate, or engage in activities involving Dangerous Content.

8.2 No reputational harm

Business Partners must not engage in activities that adversely affect Plaud’s goodwill, reputation, or interests, including posting unfavorable comments about Plaud or its Affiliates on social media or other channels except for lawful whistleblowing, protected activity, or disclosures required or protected by law.

8.3 Compliance safeguard

Business Partners must ensure their public communications and conduct do not cause Plaud to breach Applicable Law or industry codes.

9. Trade controls, export controls, and economic sanctions

9.1 Sanctions and trade controls compliance

Business Partners must comply with all applicable trade controls, export controls, and economic sanctions laws and regulations, including those administered/enforced by the United Nations, EU and member states, the United States (including OFAC and BIS), and the United Kingdom (“Sanctions Laws”).

9.2 No dealings with sanctioned parties (Business Partner warranty)

Business Partners represent and warrant that neither they nor their Business Partner Personnel are a target of Sanctions Laws, and they do not own or control a sanctioned person or entity, and are not owned or controlled by a sanctioned person or entity.

9.3 No prohibited use of proceeds / diversion

Business Partners must not directly or indirectly use any proceeds from Plaud-related work, or make them available to any person or entity, in any manner that would result in a violation of Sanctions Laws by any party.

9.4 Notification obligation

Business Partners must immediately notify Plaud if they become aware of any actual or potential violation of Sanctions Laws, or if they or Business Partner Personnel become a sanctioned person.

9.5 Export/customs compliance

Business Partners must comply with applicable export controls and customs regulations governing shipments/transfers of goods, software, technology, and payments. Business Partners must ensure that Plaud’s products are used solely for lawful, civil, and non-military/non-nuclear purposes, and must not be used for the development, production, or use of weapons of mass destruction, missile systems, or military equipment.

Business Partners must not resell, transship, or re-export Plaud’s products to any sanctioned country, natural person or entity.

Business Partners warrant that the provision of all products, services, software, technology, technical data, and related support to Plaud fully complies with all applicable Sanctions Laws, and that no such products, services, or technologies are sourced from, routed through, provided to, or otherwise involve any sanctioned country, region, person, or entity, nor are they used in any manner that would result in a violation of Sanctions Laws by Plaud or any of its Affiliates.

10. Anti-money laundering and anti-terrorism financing

Business Partners must comply with all applicable AML and ATF laws, maintain financial integrity, keep accurate and complete accounting records, and implement measures to prevent money laundering and terrorism financing.

11. Data privacy, information security, and confidentiality

11.1 General privacy and security compliance

Business Partners must comply with all applicable personal privacy and information security laws and protect the privacy of individuals and the security of confidential assets and information.

11.2 Confidentiality of Personal Information

Business Partners must keep strictly confidential the Personal Information of Plaud’s employees and any individuals related to the services, and use such information only for performing the relevant agreement/work orders and as permitted by Applicable Law. Personal Information provided by Plaud must be treated as Plaud Confidential Information.

11.3 Intra-group sharing and offshore transfer

Business Partners agree that Plaud may share information (including Personal Information and deliverables) within Plaud’s corporate group for unified information management, and may transfer such information to offshore servers after completing procedures required by Applicable Law.

11.4 If the Business Partner acts as a data processor

Where the Business Partner processes Personal Information on Plaud’s behalf, the Business Partner must comply with the following requirements:

comply with Applicable Law on privacy and security;
keep Personal Information strictly confidential (as Plaud Confidential Information);
obtain explicit, informed, and written consents from individuals as required and as instructed by Plaud;
maintain records of consents and provide originals upon request;
process Personal Information strictly per Plaud’s documented instructions and Applicable Law;
implement and maintain appropriate technical and organizational measures consistent with industry standards and applicable data protection laws to protect against unauthorized/unlawful processing and accidental loss, destruction, or damage;
assist Plaud in responding to individual rights requests (access, rectification, erasure, restriction, portability, etc.);
notify Plaud of any Personal Information data breach without undue delay and in any event within 24 hours of becoming aware;
cooperate fully with Plaud’s investigation and regulatory/legal compliance obligations;
retain Personal Information only as long as necessary for Plaud’s specified purposes or as required by Applicable Law;
upon completion of services or Plaud’s request, securely destroy all Personal Information and certify destruction;
indemnify and hold Plaud harmless for covered claims and losses arising from breach of these obligations; and
permit Plaud to audit compliance upon reasonable notice during business hours, including access to relevant records, personnel, and systems.
11.5 Protection of confidential assets

Business Partners must protect Plaud’s confidential assets and information (and where applicable, Plaud’s customers’ confidential information) and maintain processes to safeguard such information.

11.6 Intellectual property

Business Partners must respect IP rights of Plaud and third parties, protect entrusted business secrets, and prevent unauthorized disclosure.

12. Human rights, labor standards, inclusion, and diversity

12.1 Modern slavery, forced labor, and human trafficking

Plaud has a zero-tolerance approach to modern slavery, including forced labor, bonded labor, debt bondage, involuntary prison labor, child labor, human trafficking, servitude, and any form of coercion or exploitation. Business Partners must take proactive measures to prevent, identify, mitigate, and remediate modern slavery risks within their own operations and across their supply chains. All work must be voluntary, and workers must be free to leave employment in accordance with Applicable Law.

(a) Prohibition of forced and compulsory labor

Business Partners must not use, support, or benefit from any form of forced, compulsory, or involuntary labor, including but not limited to:

prison labor where not permitted by law or international standards;

bonded labor or debt bondage (including recruitment-linked debt);

indentured labor;

labor obtained through coercion, threats, intimidation, or abuse of power;

human trafficking for labor or services.

All work must be voluntary, and workers must be free to leave employment after reasonable notice, in accordance with Applicable Law.

(b) No recruitment fees and fair recruitment

Business Partners must ensure that:

workers are not charged recruitment, placement, medical, travel, visa, or onboarding fees, directly or indirectly;
recruitment agents or labor brokers (if used) comply with Applicable Law and this Code;
workers receive clear, written employment terms in a language they understand before commencing work;
employment terms are not substituted or altered after arrival in a manner that is detrimental to the worker.
If recruitment fees have been charged, Business Partners must ensure full reimbursement to affected workers.

(c) Freedom of movement and retention of documents

Business Partners must not:

confiscate, withhold, destroy, or restrict access to workers’ identity documents, passports, visas, work permits, or personal belongings;
require deposits or financial guarantees as a condition of employment;
impose unreasonable restrictions on workers’ movement, including during non-working hours.

12.2 Prohibition of child labor and protection of young workers

Business Partners must not employ child labor. The minimum age for employment must meet or exceed the minimum age defined by Applicable Law and International Labour Organization conventions; working hours for young workers must comply with applicable limits. Workers under the age of 18 must not perform hazardous work or night work.

12.3 Humane treatment and working conditions

Business Partners must treat all workers with dignity and respect and provide workplaces free from discrimination, harassment, violence, bullying, retaliation, intimidation, physical abuse, threats, or any other inhumane, degrading, or abusive treatment; all employment practices must be fair and compliant with Applicable Law. Working hours, rest days, wages, benefits, and working conditions must comply with Applicable Law and must not be used as a means of coercion or control. Business Partners must comply with laws on wages, benefits, and working hours; provide timely, understandable wage statements; and ensure overtime is within legal limits.

12.4 Freedom of association

Business Partners must respect workers’ rights to freedom of association and collective bargaining consistent with local law and international standards.

13. Health, safety, and wellbeing

13.1 Safe workplace

Business Partners must comply with applicable health and safety laws and adopt practices to minimize risk, prevent accidents, and ensure a safe workplace.

13.2 Systematic H&S management

Business Partners should maintain a systematic safety management approach with continuous improvement, including emergency management, fire prevention, and responsible chemical management.

13.3 Minimum controls (where applicable)

Where relevant, Business Partners should communicate hazards and controls, provide training, provide suitable personal protective equipment, and maintain safe facilities, including access to sanitary facilities and drinking water.

14. Environmental responsibility and climate protection

14.1 Legal compliance

Business Partners must comply with applicable environmental laws and permits, including requirements relating to air emissions, wastewater, waste disposal, and hazardous materials.

14.2 Pollution prevention and footprint reduction

Business Partners must take reasonable measures to minimize pollution and reduce environmental footprint associated with providing goods/services to Plaud, including resource efficiency and waste reduction where practicable.

14.3 Hazardous substances and waste management

Business Partners must responsibly handle hazardous substances and ensure compliant storage, transport, disposal, recycling, and management of waste, air emissions, and wastewater discharges.

14.4 Climate and resource efficiency

Business Partners are expected to measure/manage environmental impacts (as applicable), reduce greenhouse gas emissions, and promote efficient use of energy, water, and raw materials.

15. ESG, responsible sourcing, and supply chain due diligence

15.1 ESG compliance

Business Partners must comply with applicable ESG-related laws and internationally recognized standards relating to labor, human rights, occupational health and safety, forced labor, child labor, and environmental protection.

15.2 Responsible sourcing and conflict minerals (where applicable)

Business Partners are expected to conduct due diligence to identify, prevent, and mitigate human rights and environmental impacts in their supply chains, including for relevant raw materials where applicable.

15.3 Supply chain due diligence and audit support

Business Partners must pass on human rights and environmental requirements to their tier-one suppliers and cooperate with Plaud audits and remediation planning where incidents or suspicions arise.

15.4 Subcontractor/supplier due diligence for sanctions and ESG

Business Partners must conduct appropriate due diligence on key subcontractors and suppliers to ensure compliance with Sanctions Laws and the ESG/Human Rights requirements in this Code and remain responsible for their supply chain.

16. Reporting concerns, grievance mechanism, and non-retaliation

16.1 Duty to report

Business Partners must promptly report to Plaud any legal violations, violations of this Code, or suspected misconduct connected to Plaud business by sending emails to report@plaud.ai.

16.2 Regulatory and third-party inquiries

If permitted by law, Business Partners must promptly forward to Plaud any subpoenas, regulatory requests, media inquiries, or other third-party requests concerning Plaud.

16.3 Non-retaliation

Plaud does not tolerate retaliation or harassment of anyone who in good faith complains or reports that a potential violation of this Code of Conduct. Business Partners must prohibit retaliation against anyone who raises concerns in good faith or participates in an investigation.

16.4 Cooperation

Business Partners must cooperate fully with Plaud investigations, audits, and remediation efforts.

17. Audits, assessments, and monitoring

17.1 Assessment rights

Plaud may evaluate compliance with this Code of Conduct during onboarding and at any time during the relationship, including requesting written information, evidence-based assessments, certifications/attestations, and (where appropriate) on-site audits. Business Partners must provide necessary cooperation and access to “Inspection Materials” (financial books, vouchers, contracts, inventory records, system data). Plaud shall provide five (5) business days’ prior notice and conduct inspections during normal business hours. Plaud must maintain strict confidentiality regarding Inspection Materials.

17.2 Corrective actions

Plaud may request corrective actions. Business Partners must timely implement corrective action plans and support verification of remediation.

18. Violations, remedies, and termination

18.1 Consequences of non-compliance

Violations of this Code may result in remedial action, suspension, or termination of the relationship without liability on the part of Plaud. Severe, incurable, or unlawful violations may result in immediate termination without liability on the part of Plaud.

18.2 Sanctions-related remedies

If Plaud reasonably determines, in its sole discretion, that a Business Partner has violated, is violating, or is likely to violate any applicable Sanctions Laws, Plaud may, without prior notice and without liability, suspend or terminate the business relationship (in whole or in part), cease performance, and/or withhold deliveries or payments, and the Business Partner shall indemnify and hold harmless Plaud and its Affiliates from and against any and all resulting losses, fines, penalties, damages, liabilities, costs, and expenses (including reasonable legal fees) arising out of or in connection with such violation or anticipated violation.

19. Acknowledgment

Business Partners may be required to acknowledge receipt of this Code and commit to comply with its standards, including ensuring compliance by those acting on their behalf.

Business Partner Acknowledgment

Business Partner hereby acknowledges receipt of the Plaud Business Partner Code of Conduct and commits to comply with its standards. Business Partner further commits to impose substantially similar obligations on its personnel, subcontractors, agents, and suppliers involved in Plaud-related work and to cooperate with Plaud assessments and audits as described in the Code. The absence of the signature below does not affect the validity and application of this document.

Business Partner Legal Name
Authorized Signatory Name
Title
Signature
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