FS Estonia and FS IT Code of Conduct

Intellectual property

We protect our companies’ intellectual property and respect the rights of others. This includes software, source code, drawings, documentation, designs, trademarks and know-how.

Ownership and usage rights for work created in the course of business are determined by applicable law and employment or cooperation agreements. We use third-party materials and software only with permission or under the relevant licence terms.

Fair competition

We compete fairly and independently. We do not agree with competitors on prices, bids, allocation of clients or markets, or take part in other activities that restrict competition.

We do not share commercially sensitive information with competitors, including future bid prices, pricing strategies or confidential client data.

Conflicts of interest

Employees must avoid situations where personal, family or financial interests influence, or appear to influence, the impartiality of business decisions.

Potential conflicts must be reported promptly to your line manager or management. Partner selection and other business decisions must be based on objective considerations.

Fraud, bribery and corruption

FS Estonia and FS IT do not tolerate fraud, bribery or corruption. Offering, promising, giving, requesting or accepting money or other benefits to improperly influence a decision or obtain an unjustified advantage is prohibited.

This principle applies to direct actions and transactions through intermediaries. Local customs and commercial pressure do not justify unethical conduct.

Gifts and hospitality

Gifts, invitations and hospitality must not influence business decisions or create a sense of obligation or improper influence. They must be modest, justified and transparent.

Offering or accepting cash or cash equivalents as personal gifts is not permitted. If you are unsure whether a gift or invitation is appropriate, consult management before offering or accepting it.

Accurate records and prevention of money laundering

Company transactions, income and expenses must be recorded accurately, completely and promptly. Documents must reflect actual transactions and work performed.

Falsifying invoices, timesheets, expense reports or other documents, deliberately misrepresenting information and concealing transactions are prohibited.

Unusual payments, unclear sources of funds or unjustified payment instructions require clarification and notification to management. We do not knowingly participate in money laundering or conceal the movement of criminal proceeds.

Confidential information

We protect confidential information belonging to our companies, clients, employees and partners. It may be shared only with people who have a legitimate work-related need and appropriate access rights.

Confidential information must not be used for personal gain or disclosed to unauthorised parties. The duty to protect it continues after employment or cooperation ends, in accordance with applicable law and agreements.

Responsible use of IT resources

Company devices, accounts, software and information systems must be used responsibly, in line with business needs and established rules.

Employees must keep credentials secure, use required safeguards and avoid installing unauthorised software or opening unknown files. Work data must not be transferred to unapproved services or shared through personal accounts without permission.

Suspicious emails, lost devices, unauthorised access or other potential security incidents must be reported promptly to the responsible person or management.

Personal data protection

We respect the privacy of employees, clients and other parties. We collect and use personal data only for justified purposes, to the extent needed and on an appropriate legal basis.

Personal data must be kept secure and made available only to those whose duties require access. It must not be retained longer than necessary, taking applicable retention duties into account.

Potential personal data breaches or misuse must be reported promptly to management so the situation can be assessed and appropriate action taken.

Respect and safety

We treat everyone with dignity and respect. Discrimination, harassment, threats and labour exploitation are unacceptable.

We follow occupational health and safety requirements and project working arrangements. Hazards, accidents and unsafe situations must be reported promptly. Quality and deadlines must never be achieved at the expense of people's safety.

Following the Code

Every employee is responsible for following these principles in their duties. Management supports implementation and handles potential breaches fairly and according to the circumstances.

We review this Code as needed to support our companies’ development and responsible business practices.

FS Estonia and FS IT
2026