Lucid Bay Digital s.r.o. Code of Ethics

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At Lucid Bay Digital, we believe that long-term success is built on trust: the trust of our customers, colleagues, and the communities in which we operate. This code summarizes the values and principles we collectively uphold and by which we want to be known.

We champion innovation and strive for economic, social, and environmental sustainability to ensure the long-term success of Lucid Bay Digital. As part of this effort, we are committed to ethical principles regarding our work, the environment, health and safety, and the way we manage our projects.

We are proud of our values. They underpin everything we do and help us make decisions even when there are no set rules. What values do we uphold?

1

The Customer and Quality

We always do what is right for the customer and view the situation from their perspective. When we do something, we do it right. Our commitment to quality is non-negotiable. We turn down orders that would result in substandard work.

2

Respect and Diversity

We support our colleagues and communities, embrace diversity and individuality, and treat one another as equals. We create an environment where everyone feels safe to share their opinions and admit their mistakes.

3

Principled

 

We expect ourselves and others to uphold the highest ethical standards. We act with integrity and transparency, even when no one is watching.

4

Practice over dogma

When it comes to our colleagues and partners, we value real-world experience and practical solutions over a rigid adherence to theory. We look for what truly adds value, not what just “looks right according to the manual.”

5

Personal Development

To ensure we deliver high-quality services, we are constantly striving to improve. We take a proactive approach to our development and learn from both our successes and our mistakes. When selecting colleagues and partners, we prioritize quality over quantity.

To thrive in a changing world and remain true to our values, we expect three things from one another:

Handshake

Our expectations

  • Courage: We aren’t afraid to speak up and communicate openly when we see an opportunity for improvement.
  • Accountability: We take responsibility and prioritize work that aligns with our strategy and the commitments we’ve made.
  • Transparency: We build mutual trust by acting with honesty and openness.

When we all behave appropriately and live up to our values and expectations, we build trust and foster teamwork. Speaking up, therefore, isn’t “complaining”. It’s a sign of responsibility.

SPEAK UP

How to get in touch

Each of us has the right and the responsibility to speak up if we have concerns or see something that is not in line with our values. No one will be penalized for raising a potential issue in good faith.

Where to turn: First, contact your immediate supervisor or any member of management.

If that is not possible or appropriate—for example, if the concern directly involves management—you can contact oznameni@lucidbaydigital.com or submit a report anonymously. We handle all reports confidentially and sensitively, in accordance with the principles of whistleblower protection (Act No. 171/2023 Coll.), and no one will be penalized for a report filed in good faith. Details are set forth in our Whistleblower Protection Policy.

We do what is right for our customers and strive to ensure their complete satisfaction. We can only earn their trust by focusing on their real needs and seeing things from their perspective.

Our customers

Transparency and Fair Dealing

Transparency is our core value. That is why we provide our customers with complete and accurate information, including open communication when we identify a risk or a better solution. We prioritize collaboration and working with our customers to find the right solution over a rigid interpretation of the contract.

Confidentiality and Data Protection

As a digital and consulting firm, we handle our clients’ sensitive information and data. We protect it as if it were our own:

  • We handle personal data in accordance with the GDPR and use it exclusively for the purpose for which it was entrusted to us.
  • We do not share confidential information or the customer’s intellectual property with anyone who is not authorized to access it, and confidentiality remains in effect even after the end of our collaboration.
  • Upon completion of the project, we return the data or securely destroy it in accordance with the agreement with the customer.

Details are governed by our Privacy Policy (GDPR).

Responsible Use of AI and Technology

AI and modern tools are an integral part of our work. We use them responsibly:

  • We do not enter customer data or confidential information into public or otherwise unauthorized AI tools.
  • A human is always responsible for AI outputs. We verify these outputs and guarantee their quality.
  • We are transparent with our customers about where and how we use AI in our services.

Our Company

Proper Financial Practices

Lucid Bay Digital’s financial and accounting controls are designed to provide customers and the public with accurate and truthful information about the financial aspects of our operations.

Protection of Company Assets

How we manage the company’s tangible and intangible assets matters, from the day-to-day use of our systems to the protection of information and intellectual property. We are all responsible for using technological resources properly and professionally.

Cybersecurity and Information Security

We protect our customers’ information and our own from unauthorized access, use, disclosure, compromise, alteration, and destruction. We implement appropriate technical and organizational measures—access controls, strong authentication, encryption where appropriate, regular backups, and updates. We report any suspected security incidents immediately. Details are outlined in our Information and Cybersecurity Policy.

Sanctions, Money Laundering, and Inside Information

We comply with applicable international and local laws and regulations. These include, in particular:

If other rules are stricter in a given situation, we follow the strictest ones. Details are set forth in our Anti-Corruption and Compliance Policy.

Communication and Social Media

The way we communicate externally and with one another is key to building trust. Statements regarding our business interests must be timely, accurate, and consistent with our values, approval processes, and applicable laws.

Everyone is free to express themselves on their personal social media accounts, including sharing Lucid Bay Digital content approved for such use. However, it must always be clear that this is a personal opinion. Let’s be careful not to post anything that could be considered internal or confidential information.

We are proud to live up to our values and expectations while complying with the law. We do everything we can to maintain the trust and respect of the organizations we work with and the communities in which we live. In doing so, we protect the interests of both our customers and our company.

Equal treatment and respect

Our colleagues

We treat our colleagues and the communities around us with respect. We all play a part in creating a fair environment that respects human rights, diversity, and individuality. Our responsibility includes complying with all labor laws and ensuring that we do not engage in forced labor in any way.

We treat everyone with respect and integrity, on the basis of equality. This is how we attract and retain the best people. We do not tolerate harassment, unwanted, inappropriate, or offensive behavior, or discrimination of any kind, including all forms of sexual harassment. Any behavior that undermines human dignity in the workplace is unacceptable. We uphold the principles of the Universal Declaration of Human Rights and the conventions of the International Labour Organization (ILO).

Principled and Courageous Action by Individuals

Principled behavior and courage begin with each of us taking responsibility. We strive to do the right thing, act with honesty and openness, and speak up when something seems wrong.

Bribery is illegal everywhere in the world. It is up to all of us to know what is expected of us, to prevent bribery and corruption by adhering to the company’s principles, and to report any suspicions so that we can assess risky situations in a timely manner.

A commitment to quality means taking responsibility for improving our processes; we continuously learn from our mistakes and successes and strive to do the right thing the first time. Likewise, we respect free and open competition and compete through the value of our products and services.

Gifts, Hospitality, and Conflicts of Interest

We build business relationships on the quality of our work, not on favors. We accept and provide gifts and hospitality only if they are reasonable, transparent, in compliance with the law, and cannot influence independent decision-making. We never accept or offer cash or its equivalent. We openly disclose and address any potential conflict of interest—whether personal, financial, or family-related—in a manner that does not jeopardize the interests of the customer or the company. Details are governed by our Anti-Corruption and Compliance Policy.

A Healthy, Safe, and Sustainable Workplace

We create a healthy work environment and prioritize occupational health and safety; all colleagues undergo appropriate OHS training, and we report any potential risks. We also ensure a sustainable work pace—we prioritize long-term performance over short-term burnout.

ENVIRONMENT

Sustainability

Although we primarily provide intangible services, we care deeply about the environment in which we live. We strive to reduce our environmental footprint in practical ways: we prioritize electronic documents over paper ones, utilize an efficient cloud infrastructure, and consider our suppliers’ environmental responsibility when selecting them. Where it is clear that a potential supplier is not acting responsibly, we will not enter into a partnership with them.

We do not make political contributions to individuals or organizations. This helps us conduct business transparently, without ties to political parties, and focus on putting the customer first.

Regulations, Laws, and Related Policies

The regulations and laws applicable to our industry are essential to our work. If laws, regulations, industry codes, or other business standards are stricter than this Code, we always adhere to the strictest rules.

Everyone who works for Lucid Bay Digital or on its behalf must adhere to this Code and related policies. Serious or repeated violations of these rules, as well as violations of legal and regulatory requirements, may result in disciplinary action, up to and including termination of employment. We always prioritize remediation and mutual understanding over punishment.

Do you have a question or suggestion regarding this code? Please contact us at jan.sramek@lucidbaydigital.com; this code is a living document, and we update it regularly.

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