Wattpad Corp. (together with its affiliates, the “Company”) has adopted this Code of Ethics (the “Code”) for its external partners in order to deter wrongdoing and promote:
Honest and ethical conduct, including the proper handling of any actual or apparent conflicts of interest.
Full, fair, accurate, timely, and understandable disclosure in Company filings and public communications.
Compliance with applicable laws, rules, and regulations.
Protection of the Company’s assets, including confidential information.
Fair dealing practices.
Prompt reporting of any Code violations.
Accountability for adherence to the Code.
All external partners must be familiar with the Code, comply with its provisions, and report any actual or suspected violations as described in Section 12 (Reporting and Investigation of Violations).
Back to topThe Company’s policy is to conduct its affairs honestly and ethically, promoting high standards of integrity.
Each external partner must act with integrity and observe the highest ethical standards when dealing with the Company, its customers, suppliers, partners, service providers, competitors, fellow external partners, and anyone else encountered in the course of performing duties for or on behalf of the Company.
Back to topA conflict of interest arises when an external partner’s private interest (or that of a family member) competes with, or appears to conflict with, the best interests of the Company. For example, a conflict may exist if:
An external partner (or family member) obtains improper personal benefits through the Company relationship,
An external partner’s employee or their family member has a private business deal or exchanges personal benefits with a Company employee, which could undermine the objectivity of the partnership, or
The external partner is unable to remain objective in fulfilling its obligations to the Company due to personal or financial considerations.
Conflicts of interest should be avoided unless explicitly authorized by the Company in advance. If you have questions or concerns about a potential conflict—or if you become aware of an actual or potential conflict—you are encouraged to consult your own legal advisor. If it is determined that disclosure to the Company is necessary, please contact wattpad_compliance@wattpad.com
Back to topExternal partners must maintain the confidentiality of information entrusted to them by the Company or its customers and partners, unless disclosure is legally required or expressly authorized. Confidential information includes all non-public information that could be of use to competitors or harmful to the Company (or its customers or partners) if disclosed.
Back to topExternal partners must deal fairly with the Company’s customers, suppliers, competitors, partners, service providers, and other external partners. No one should take unfair advantage of others through manipulation, concealment, misuse of privileged information, misrepresentation, or any other unfair practice.
Back to topExternal partners should protect the Company’s assets and ensure their proper and efficient use. Theft, carelessness, and waste directly harm the Company and are prohibited.
Company assets should be used only for legitimate business purposes, though reasonable personal use may be allowed if it aligns with the Company’s policies. Any suspected fraud or theft should be reported promptly.
Proprietary information (including trade secrets, patents, trademarks, copyrights, business/marketing plans, designs, data, and financial records) must be safeguarded. Unauthorized use or distribution is prohibited and may be illegal.
Back to topAll external partners must comply, in both letter and spirit, with every applicable law, rule, and regulation in the jurisdictions where the Company operates. If you have legal or regulatory questions regarding your obligations under this Code, you should consult your own legal advisor.
Back to topExternal partners who gain access to material non-public information (MNPI) about the Company or its affiliates must never use that information for personal gain or share it inappropriately. Such Insider trading is both in violation of Company policy and relevant laws. Examples of prohibited conduct include:
Trading in the Company’s securities (e.g., stocks, bonds, options) while in possession of MNPI;
Tipping or passing MNPI to friends, family, or others who may trade on such information;
Suggesting trades based on MNPI or otherwise misusing confidential information related to the Company’s financial or strategic affairs.
The Company is responsible for ensuring its publicly filed documents (including SEC filings and financial statements) comply with applicable securities laws and regulations. External partners may occasionally be asked to provide relevant information or data to support accurate and timely disclosures. If you receive such a request:
Respond promptly and accurately within your scope of engagement, ensuring any data or documents are complete and reliable.
Adhere to confidentiality and contractual obligations: Share only what is authorized and necessary for disclosure purposes.
The Company retains final responsibility for reviewing and filing all public disclosures in accordance with its internal controls and legal requirements.
The Company is committed to conducting business in accordance with all applicable anti-corruption and anti-bribery laws, including the U.S. Foreign Corrupt Practices Act (FCPA). External partners shall:
Prohibition on Bribery: Not offer, promise, authorize, or provide anything of value to any government official or private individual for the purpose of obtaining or retaining business or securing an improper advantage.
Facilitation Payments: Refrain from making unlawful “facilitation payments” intended to expedite routine governmental actions.
Accurate Record-Keeping: Maintain truthful and accurate books and records. Do not conceal or misrepresent the nature of any transaction.
External partners must comply with all applicable export control laws, trade sanctions, and customs regulations in the U.S. and other relevant jurisdictions. Key principles include:
Restricted Party Screening: External partners shall not conduct business with countries, entities, or individuals prohibited by U.S. or other applicable sanctions.
Licenses and Authorizations: Required licenses or permits must be obtained before exporting or transferring controlled goods, technology, or software.
Accurate Documentation: Ensure that shipping documents, invoices, and other records reflect correct information about items, destinations, and parties involved.
External partners must not knowingly facilitate transactions involving proceeds from criminal activities or any form of money laundering. In particular:
Know Your Customer: When relevant, external partners should perform reasonable due diligence on their own customers and suppliers.
Suspicious Transactions: Report any transactions lacking a legitimate business purpose or involving fictitious entities to the Company.
Record-Keeping: Maintain accurate records and comply with legal requirements on financial reporting or currency transfers.
Any actual or suspected violation of this Code by an external partner should be reported promptly to the Company.
If you are unsure of your obligations before making a report, you may consult your legal advisor.
If you become aware of any Company employee, officer, or other representative engaging in (or suggesting) conduct that violates this Code or other legal/ethical standards, you are expected to report this concern to the Company.
All reports to the Company based on this Code shall be submitted to wattpad_compliance@wattpad.com.
The Company will investigate reported violations and expects full cooperation from external partners. Investigations will be conducted promptly and thoroughly, consistent with applicable laws.
Back to topThe Company prohibits retaliation against any external partner who, in good faith, reports a known or suspected violation of this Code. Retaliation itself may constitute a serious violation of both Company policy and the law.
Back to topUpon confirming that a violation has occurred, the Company may take appropriate corrective action. Such action can include terminating a business relationship, seeking restitution, or referring matters to law enforcement if criminal activity is suspected.
Back to topAny request for a waiver or exception to this Code must be submitted in writing to wattpad_compliance@wattpad.com and authorized in advance by the Company. If required by law, the Company shall be able to disclose any such waiver through appropriate channels.
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