ON-TIME RESEARCH SOLUTIONS OY’S CODE OF CONDUCT

CEO’s foreword

As a new industry, multichannel communication optimization algorithms based on Machine Learning (ML) and call robotics include some aspects to which the standards of other sectors cannot be directly applied. What we do is closely linked to factors associated with privacy, personal data protection, information security and ethical considerations. Often, our operations include a conversation about questions like customer experience and reputation. As pioneers of change, we carry a responsibility for taking these issues into account and thinking about what kind of society we want to build for the future generations.

When it comes to the field of multichannel communication optimization algorithms and call robotics, society has not had time to come up with a comprehensive set of regulations. We are fully aware that, in situations where traditional regulation has not been able to keep up with the latest phenomena, we as individuals as well as a company are responsible for creating rules that will help us build a better future – and for faithfully sticking to those rules.

Here then is a summary of the rules and business principles to which we adhere in everything we do – we call them our Code of Conduct.

We would also like to thank the Data & Marketing Association of Finland (DMA Finland) for their sparring during the drafting process of these principles. With your cooperation, we have had good opportunities to create functional practices and guidelines for our industry regarding call robotics, which are in everyone’s interest. We would also like to thank the Data & Marketing Association of Finland (DMA) for sparring with us during the process of drawing up these principles. Working in cooperation with you, we have a good chance of creating good policies and rules for call robotics industry that will benefit us all.

Teemu Valkonen, CEO, On-Time

“When it comes to advanced technology, like robotics, regulation is always a little bit behind the curve. You can tell a responsible company from the way it creates ethically sustainable operating models and keeps a close eye on the field based on terms and conditions, limit values, recommendations, and other measures.”

Jari Perko, CEO, ASML

1. On-Time’s general principles

Proper appreciation for the benefits of multichannel communication optimization algorithms and automated calls

Multichannel communication optimization algorithms and call robotics has a lot to give in many areas of society but, for most people, it is still a bit of an unknown quantity. We want to be advocates of the useful and legitimate applications of multichannel communication optimization algorithms and call robotics call robotics by showing that, properly used, our service will significantly benefit both the operators using it and their customers.

Ethics as a guideline

With regard to the use of our service, we want to stress that ethics must inform every aspect of multichannel communication optimization algorithms and call robotics. The use of multichannel communication optimization algorithms and call robots and personal contacts are subject to the same rules: the communication must be customer-friendly and legal.

For our part, we want to help create an ethical operating model for the industry. We believe that a framework of rules that works and is sufficiently detailed will benefit us, our customers and, first and foremost, the customers and partners of our customers who answer robocalls.

Sustainable multichannel communication optimization algorithms and call robotics

The only sensible way to make sure that the benefits of multichannel communication optimization algorithms and call robotics will be utilized in the future is by having the operators involved in building an operating framework for the industry. What we need is a sustainable operating model instead of easy winnings, and that is what we want to create for Finland.

We want to avoid the problems that call robots have created, for example, in the United States where the majority of calls are various scams or otherwise unethical. We believe that, as a small language region, Finland is well-equipped to efficiently regulate operations in the call robotics industry and ensure that the operations are on a sustainable basis.

2. Use of On-Time’s service

Using the service

We feel strongly that our service should only be used for activities that are in line with our own policies. To ensure this, we have specified in our terms and conditions the purposes for which our automated call robotics and multichannel communication optimization algorithms service can be used. Customers must accept these terms and conditions in order to use the service.

Our service is meant exclusively for:

• the implementation of automated opinion polls, market surveys, customer satisfaction surveys, other surveys, or stakeholder communication by phone.

Our service may not be used for:

• Direct marketing, telemarketing, fundraising, or political advertising (without the recipient’s explicit consent)

• Conveying political messages or messages that are defamatory or discriminatory, constitute an infringement of privacy, or are otherwise illegal

• Conveying messages that paint a misleading picture of a third party

• Conveying messages that cause direct or indirect damage to a service provider or a third party

• An abnormal purpose, which causes the service to be disrupted or interrupted.

Requirements pertaining to the use of the service by customers

Our customers are responsible for using the service in accordance with the Information Society Code (917/2014) and other established laws. In addition, the use of the service must ensure that:

• The call recipients understand that the call is an automated opinion call, market survey, customer satisfaction survey, another survey, or message to stakeholders

• The call recipients are told clearly who or which party is behind the survey, or message and what the purpose of the survey or message is

• The call, including recordings, is tested before using it for an actual survey or actual communication.

Use in breach of the terms and conditions

If a customer is deemed to have used our service in breach of our terms and conditions, the customer’s access right will be canceled with immediate effect and the customer will be fully liable for any consequences to a service provider or third party arising from the use of the service in breach of the terms and conditions.

If the service provider becomes subject to a claim for damages, charge or a temporary or permanent service interruption as a result of the use of the service in breach of the terms and conditions, the customer who has breached the terms and conditions will be liable in full for the damage caused to the service provider. The service provider reserves the right to amend these terms and conditions.

3. Confidentiality of Operations

Confidentiality is the cornerstone of our operations

Our business is extremely data-intensive, which is why strict confidentiality is the basic requirement of our operations in all circumstances. We do not disclose any data provided by our customers to any third parties.

Data security applies to all of our activities

We adhere to a strict data security policy with regard to data processed both in the virtual environment and in the physical world. When processing personal data, we comply with all legal requirements. The system we provide for our customers also enables the legal processing of personal data.

4. On-Time as an employer

People are the core of our business

Even though the technology is an essential part of the service we sell, the most important thing for us is to work with good people. This applies equally to our employees as well as our partners and customers. The atmosphere at our office is one of fairness, equality, and openness. Each of us can – and should – speak their mind.

The right balance between freedom and responsibility

At On-Time, we appreciate the freedom to influence the content of our work. We are also empowered to make decisions regarding our work. In order to use that freedom and power correctly, we must understand and take responsibility for our company’s goals and results.

We share a personal interest in the industry

We feel privileged to work in an industry we are interested in even outside the parameters of work.

We share a strong interest in all things new, especially automation. Our aim to automate operations springs from a desire to focus on factors that can genuinely make a difference in terms of our happiness. The wish to improve drives us forwards – we are a group of people that is creating something entirely new together.

5. Sticking to our principles

Our principles guide us and our customers alike

Because the legislation is yet to catch up with our industry, we take great care in following our moral and ethical principles. Through our own actions, we want to improve the reputation of multichannel communication optimization algorithms and call robotics as an industry and ensure that its future is bright.

Our duty is to tell our customers about the principles to which they agree when using our service. Sticking to the rules is our responsibility as well as that of our customers.