Code of ethics

OpenClassrooms cares about managing its activities with integrity, ethics, transparency, and seriousness. In this regard, OpenClassrooms is constantly concerned with ensuring the highest level of security and ethics in its business affairs and acts in accordance with its Mission.

Therefore, we are delighted to introduce OpenClassrooms' code of ethics (the “Code”). Our Code promotes responsible and ethical conduct as well as creates accountability for violations of the Code. The Code is also about making the right decisions (we dare), with tenacious professionalism (we persist), acting with honesty (we tell it as it is), and most importantly, treating each other with dignity and respect (we care), while remaining true to our mission.

Each individual has a responsibility to report suspected violations of our Code so that the Company can quickly investigate and take appropriate action. But, some situations do not correspond to any legal or regulatory framework. The Code provides guidance on how to act when specific and clear policies are not available. It should guide you in making fair and ethical choices.

We expect you to read this Code and abide by our principles and policies. We are sure that every one of you will persist in adopting such fair behavior, which is essential to the future of our Company. Thank you for joining us to promote this ethical behavior around you.

If you have any questions about this Code, have a doubt about a situation that could constitute improper behavior, or would like to report any incident, please contact your manager, any member of our Legal Department ( legal@openclassrooms.com), our employee representatives or refer it through our whistleblowing alert platform (signalement.net). We invite you to share this information — you will never be punished for doing so.

Our Code encompasses all individuals working for OpenClassrooms, in any location, or on our behalf in any capacity — this includes employees at all levels, directors, officers, agency workers, seconded workers, and members of our Board of Directors (the “Team Members”). Stakeholders and Mission Committee members should also be familiar with and abide by the Code. While the Code is predominantly intended for Team Members, we anticipate that our contractors, consultants, and other stakeholders (the “Community Members”) collaborating with us will adhere to the Code. We intend to collaborate with contractors, consultants, and other stakeholders who have the same level of expectations as described in this Code. We are committed to helping them achieve these standards, while at the same time shall, if necessary, terminate our relationships with those who do not wish to achieve them.

Our Code applies to any Team Members and Community Members working for OpenClassrooms in any location. In locations where specific policies apply:

• the Code is meant as a complement to such specific policies, and
• in the event of a conflict between the Code and such specific policies, the latter shall prevail over the Code.

Appendix 1 lists the main specific policies implemented within the Group. This list is not exhaustive. Do not hesitate to request such policies if you are concerned by them. For Team Members, those policies are also available on Bamboo.

In case of breach of this Code, OpenClassrooms reserves its rights to take appropriate actions (including disciplinary action in accordance with our Internal Rules/Handbook) with respect to Team Members and Community Members, including termination of contracts. Any material breach of this Code will be reported to our Board.

In the event of a breach by a board member, the Board may decide to request the revocation of the concerned board member.

As a mission-driven and certified B-Corp company, we are particularly attentive to the following key values and principles:

• the prevention of and combat against any form of harassment, bullying, discrimination, and retaliatory practices;
• the promotion of equal opportunities, diversity, equity, inclusion, and employability;
• the freedom of speech, of association, and the right to collective bargaining; and
• the elimination of any form of forced labor.

Consequently, all Team members must engage in practices that are consistent with these values and refrain, directly or indirectly, from performing, participating, or executing any act, step, or attempt that may be qualified as a breach of these commitments.

Team members should immediately report the incident to the People and Legal teams and/or submit a report according to our Whistleblowing Policy if they believe they have been harassed or bullied by anyone or if they have witnessed such behavior at OpenClassrooms.

OpenClassrooms expects its Team Members to foster relationships based on OpenClassrooms' loyalty, trust, and integrity and help others in their development.

We expect Team Members to conduct themselves appropriately while at work, even remotely, and while representing OpenClassrooms at work-related events. We expect the same in any of their communications on social media about and/or on behalf of OpenClassrooms.

In particular, we expect each Team Member to behave in a manner that promotes a professional and productive work environment and to consistently treat others with respect, openness, inclusion, fairness, and courtesy.

At OpenClassrooms, we are fully committed to safeguarding the health, safety, and well-being of all our Team and Community Members, and maintaining a welcoming and violence-free workplace.

OpenClassrooms is also committed to maintaining a workplace free from unlawful drug use and the abuse of drugs and alcohol. The unlawful manufacture, distribution, dispensing, possession, or use of a controlled substance is prohibited in the workplace. This prohibition extends to Company-sponsored events, whether on Company property or elsewhere.

Team Members must actively participate in their own health and safety protection by complying with the health and safety rules in force at their workplace, even remotely, and by participating in the various training courses organized on the topic.

We will thoroughly investigate allegations of threatened or actual breach of health and safety rules and take appropriate corrective actions in a timely manner in case of any offense.

As a Bcorp and mission-driven company, we are committed to environmental sustainability, responsible purchasing, and care for our planet and environment. As such, our supplier charter ensures our commitment to the best environmental and social standards.

OpenClassrooms intends to reduce its environmental impact, managing waste, decreasing our carbon footprint on all emissions scopes, and acting to preserve natural resources and healthy ecosystems.

We expect all Team Members, regardless of their role, to contribute to our efforts to reduce, reuse, and recycle the energy and natural resources required to operate our business and to integrate sustainability into OpenClassrooms' business strategies and processes on a daily basis.

Each Team Member is encouraged to deal fairly and refrain from acting in any way that could damage our reputation with our partners, students, suppliers, service providers, competitors, government officials, and employees.

Each Team Member should not take advantage through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair-dealing practice.

Any situation where competing loyalties could cause a Team Member to pursue something that would benefit themselves, their relatives, friends, partners, companions, or family instead of our Mission might be qualified as a conflict of interest. The list below covers different situations of “conflict of interest” that OpenClassrooms prohibits (this list is non-exhaustive):

• Team Members have a duty to the Company to advance its legitimate interests to the best of their ability: unless otherwise agreed with OpenClassrooms, they may not take business opportunities for themselves (or direct such opportunities to a third party) that are properly within the scope of the Company's activities or that they discover through the use of the Company's property, information or position.
• Team Members shall refrain from engaging in private business or professional activities that could compromise their ability to perform their work for OpenClassrooms objectively.
• A conflict of interest can also arise in case of employment of relatives and close associates; if a Team Member's relatives or close associates have financial or employment connections with OpenClassrooms, competitors, suppliers, or customers, the concerned Team Member must disclose this fact to the People and Legal teams.
• Membership on the boards of customers, suppliers, partners, or competitors of the Company raises potential conflict of interest concerns. If a Team Member is asked to become a member of a board of one of these companies or if they already are a board member of these companies, they must disclose it to the Legal Department and seek prior approval if they have not accepted yet. Same principles apply in case of consultancy services provided to the above stakeholders.

In short, Team members should avoid any situations that may put them in a conflict of interest, and at least disclose any conflict of interest or potential conflict of interest situation to the Legal Team.

If Team Members have any doubt whether a situation could result in a conflict of interest, please contact the People team or the Legal team for help reviewing this situation.

OpenClassrooms is committed to incurring justified expenses and to giving a true financial picture of its business.

OpenClassrooms' money should be spent as carefully as one would manage their own money. Each Team Member bears the responsibility of prudently managing these funds, ensuring the accuracy and completeness of financial records, and upholding internal control protocols.

Receiving gifts or accepting entertainment:

A Team Member (or a member of their family, a relative, a friend, a partner, or companion) may not accept any offer, payment, promise to pay, or authorization to pay any money, gifts or entertainment of value from a partner, consumer, supplier, consultant, or anyone attempting to develop a business relationship with OpenClassrooms that may appear to or tend to influence our business decisions or compromise independent judgment. The only exception is for “modest gifts” (like swags and goodies, or any other goods valued less than 50 euros) and infrequent and reasonable business meals or entertainments, provided that they are not excessive or create an appearance of impropriety.

Giving gifts or inviting to entertain:

Gifts and entertainment offered by the Company to a partner, consumer, supplier, consultant, or anyone attempting to develop a business relationship, influence business decisions, or compromise independent judgment, that goes beyond the level of what is reasonable and customary under the circumstances of the business relationship should be avoided.

Gifts and entertainment offered or received from government officials:

Some of OpenClassrooms' partners are government-owned or controlled and their employees may be considered as government officials. Any gift or entertainment provided to or received from a government official must be modest, infrequent, and reasonable. In case of doubt, please contact the Legal Department.

Team members must adhere to ethical rules that regulate the relationships between interest representatives and public officials to ensure responsible lobbying, especially when they come into contact with public officials, when they request official information or documents, when they disseminate them, or when they organize conferences to which they invite public officials.

OpenClassrooms is a non-political organization. Therefore, the Company and each Team Member are prohibited from making contributions to political candidates or political parties on the Company's behalf. If Team Members participate in political activities, please note that they do so in their capacity as a private individual and not as a representative of OpenClassrooms. Their personal, lawful involvement in political matters, including whether or not they choose to make contributions, will not have any bearing on their compensation, job security, or opportunities for career advancement within the organization.

Maintaining complete and accurate records remains an essential task, and it is critical for our business operations, legal duties, and the preparation of our financial statements.

Each Team Member bears personal responsibility for the authenticity of records, reports, and information under their review, whether intended for internal or external use.

Team Members are required to comply with internal accounting and record-keeping policies. Any form of record falsification, including the submission of fraudulent or inaccurate expense reimbursement, claims, or time records, is strictly prohibited.

We consider price, quality, reputation, service, reliability, security, and the terms and conditions of a potential partner or contractor when making decisions related to business dealings. No decision to deal with a potential partner or contractor shall be based on a personal relationship. Please work with the OpenClassrooms Procurement team to conduct proper diligence on partners and vendors before engaging them.

Certain information may be considered as competitive advantage for OpenClassrooms. Our responsibility is to keep it confidential and protected.

This includes using OpenClassrooms' information only for Company purposes and not disclosing it to anyone outside of OpenClassrooms. Even within the Company, only those individuals who truly need to know the information to conduct their business should have access to confidential information.

Confidential information includes but it is not limited to OpenClassrooms' intellectual property, data, financials, employees, business strategy, and corporate information. Team members have to maintain confidentiality and the security of this information. They should protect their devices when in places where they could be lost or stolen, they mustn't share passwords or access codes, nor allow others to use their accounts or devices.

OpenClassrooms' intellectual property (trademarks, logos, copyrights, and trade secrets) is one of its main assets. Therefore, we are all responsible for ensuring that Openclassrooms' intellectual property is well protected.

Any use of our trademarks and logos must be cleared in advance by our Legal Department and Team Members must report any suspected misuse of trademarks, logos, or other Company intellectual property.

Team Members must ensure that a contract with appropriate clauses to protect OpenClassrooms' intellectual property rights and ensure freedom to use results when undertaking collaborative work with third parties (image, music, trademark…) is in place.

As OpenClassrooms cares about intellectual property, it does not tolerate any inappropriate use of others' intellectual property. It may expose OpenClassrooms and the concerned Team Member to criminal and civil fines and penalties.

OpenClassrooms provides computer hardware, software, and communications and network systems exclusively for business purposes. Each Team Member is responsible for ensuring that equipment and network are used for that purpose only.

We prohibit the use of our systems or equipment for any illegal, harassing, bullying, offensive, or sexually explicit activities, as well as any violations of other Company policies, standards, or guidelines. Additionally, any other uses that could have a negative impact on OpenClassrooms are also prohibited.

In case of any doubt whether, as a Team Member, you are using equipment, software, and network in a safe way, please contact the Security team right away.

We do not authorize, offer, or make corrupt payments to anyone for any reason.

We do not authorize to offer, promise, or give, directly or indirectly, anything of value, regardless of amount, to induce or influence a government official or commercial party, or to secure an improper advantage in business dealings.

OpenClassrooms prohibits the use of modern slavery and human trafficking in both our operations and supply chain. Our commitment extends to preventing any instances of modern slavery within our organization or in any of our supply chains. We do not engage in business with any individual or entity suspected of involvement in modern slavery or human trafficking.

• Commitment to eco-responsibility
• Charte du droit à la déconnexion
• Remote First Policy
• Whistleblowing Policy
• Privacy policy
• Information system user charter

• Charte Fournisseurs
• Internal Rules

• Safeguarding including Prevent Duty: it covers abuse, bullying, discrimination, forced marriage, mental health, neglect and self-harm, and radicalization and extremism.
• Health + Safety Policy

• Anti-harassment Training Program (to be provided to all individuals connected to the administration or operation of the Registered Apprenticeship Program)
• Registered Apprenticeship Program Equal Employment Opportunity Poster: Details of OpenClassrooms' commitment to equal opportunity and affirmative action obligations in the Registered Apprenticeship Program
• Drug-Free Workplace Policy
• OpenClassrooms Inc - Handbook