Legal and Compliance
Notified Accessibility Statement
Notified is committed to digital accessibility, and to conforming to the Web Content Accessibility Guidelines (WCAG) 2.1, Level A and AA and complying with Americans with Disabilities Act (ADA), the Accessibility for Ontarians with Disabilities Act (AODA) and other applicable accessibility regulations.
To accomplish this, Notified has partnered with a specialized accessibility partner to administer our accessibility program and oversee its governance. Their accessibility program evaluates our digital products on an ongoing basis in accordance with best practices and is supported by a diverse team of accessibility professionals, including users of assistive technologies. The platform, moreover, goes beyond minimum compliance requirements by making an assistive CX technology application available to customers who have trouble typing, gesturing, moving a mouse or reading. The application is free to download and it incorporates tools such as mouse and keyboard replacements, voice recognition, speech enablement, handsfree/touch-free navigation and more.
We want to hear from you if you encounter any accessibility barriers on our digital properties. Please contact us at legal@notified.com
Artificial Intelligence (AI) policy
Notified is committed to advancing Artificial Intelligence (AI) technologies responsibly, ethically, transparently and in compliance with applicable laws. Our AI policy outlines the principles and guidelines that govern the development and use of AI in our organization and our client facing products. We are committed to upholding the highest privacy and security standards and promoting the responsible use of AI technologies in accordance with our Privacy Policy (www.notified.com/privacy).
Principles
Human-Centered Approach: We prioritize the security and privacy of individuals affected by our AI systems. We strive to enhance human capabilities, augment human decision-making and protect the fundamental rights of all individuals.
Transparency: We are committed to being transparent about how AI systems are developed, used and the data the AI systems rely on. We provide clear explanations of AI-driven decisions whenever possible.
Fairness and Bias Mitigation: We actively work to identify and mitigate biases in AI systems to ensure fairness and equal treatment for all individuals, regardless of race, gender, ethnicity or other protected characteristics.
Accountability: We hold ourselves accountable for the ethical implications of our AI technologies. We establish clear lines of responsibility for the development, deployment and outcomes of AI systems.
Privacy: We respect individuals' privacy rights and ensure the protection of sensitive information. Data collection, storage and processing is done in compliance with relevant laws and regulations. More information on our privacy processes can be found on the Privacy page of our website (www.notified.com/privacy).
Security: Notified is committed to protecting its customers, partners and employees from unauthorized access to, alteration, disclosure, or destruction of data and information systems whether intentional or unintentional. Notified’s commitment to security is further exemplified by our third-party assessment of our security controls and SOC2 compliance. More information can be found in our Organization Security Policy (www.notified.com/organization-security).
Collaboration: We actively engage with the wider AI community, experts, policymakers and stakeholders to address ethical challenges collectively and share best practices. We support open and constructive dialogues that promote responsible AI development.
Auditability: We maintain detailed records on system development and performance to enable internal and external auditing as appropriate.
Lawful and Ethical: Notified's AI systems and data practices are compliant with applicable laws and in line with ethical norms for research and innovation.
Responsible AI Development
Data Quality: We use high-quality, diverse and representative data to train AI models, minimizing the risk of biased outcomes.
Explainability: We strive to make our AI systems interpretable and understandable to users, enabling them to comprehend how AI-derived decisions are made, whenever possible.
Human Oversight: We maintain human oversight in the development and deployment of AI systems, ensuring that decisions with significant consequences are not made solely by machines.
Continuous Monitoring: We continuously monitor AI systems to identify and address any unintended consequences or biases that may arise during their use.
Continuous Education: We invest in the continuous education and training of our teams on AI ethics and responsible AI practices.
Compliance and Review
Compliance: We comply with all relevant laws and regulations related to AI development and usage and actively engage with relevant organizations contributing to emerging AI industry standards.
Reporting and Whistleblower Protection: We encourage employees to report any ethical concerns related to AI development or deployment. We provide mechanisms for reporting, protect whistleblowers and take appropriate action in response to these concerns (via email at west@getintouch.com).
Regular Review: This AI policy may be reviewed and updated regularly to ensure its relevance and effectiveness. This policy may evolve as AI technology and ethical considerations advance. We are committed to remaining at the forefront of responsible AI practices.
Conclusion
By adhering to these principles and guidelines, Notified is committed to ensuring that AI technologies are developed and used ethically, fostering trust among our customers, employees and the industry as a whole.
Amended and Restated Code of Ethical Business Conduct
This Code of Ethical Business Conduct ("Code") is intended as an overview of Notified guiding principles and not as a restatement of Notified's policies and procedures.
Notified's reputation as an ethical company is essential to our success. Our reputation needs to be managed and developed with the same care we extend to our clients. In carrying out the business of Notified, we deal with investors, clients, vendors, government officials, community leaders, the press and the general public. It is essential all of our dealings be legal and above reproach, and must not, in any way, compromise Notified's interests, its policies or its reputation for the highest standards of business ethics.
We believe Notified directors, officers and employees should disclose any activity that may have the appearance of being unethical. In so doing, not only can we take appropriate disciplinary or legal action, but we may be able to take steps to prevent the situation that gives rise to the questioned activity.
Merely operating within the law is just the beginning of the ethical conduct we expect and insist upon. This Code is a broad statement of Notified's expectations regarding legal and ethical conduct. This statement is intended to be interpreted in the spirit of its intent and not literally, as it is virtually impossible to address every situation or condition that may arise.
In the event of any conflict between the Code and the certificate of incorporation or bylaws of the Company, including, without limitation, provisions related to business opportunities presented to members of the Board of Directors, the provisions set forth in the certificate of incorporation or bylaws, as applicable, shall control.
Business Conduct:
Each director and officer should be aware of the ethical practices of each of the people he or she manages. We must maintain the position unethical actions, or the appearance of unethical actions are not acceptable, even though they may seem to be standard business practices in other companies. This Code cannot and is not intended to cover every applicable law or provide answers to all questions that might arise; for that we must rely on each person's good sense of what is right, including a sense of when it is proper to seek guidance from others on the appropriate course of conduct.
Conflict of Interest:
All directors, officers and employees of Notified are expected to avoid any activity, investment, interest or association which interferes with or is reasonably likely to interfere with the independent exercise of his or her judgment when it is related to Notified's interests. Directors, officers and employees of Notified have a duty of loyalty to Notified and must, therefore, avoid any actual or apparent conflict of interest with Notified.
It is impossible to cover every possible conflict of interest. At times it will not be easy to distinguish between proper and improper activity. The most common conflicts are:
- Having a financial interest, directly or indirectly, in any supplier, client or competitor of Notified. All interests of 1% or greater in a supplier, client or competitor should be fully disclosed to Notified’s General Counsel.
- Engaging in a business transaction on behalf of Notified with a relative by blood or marriage, or with a firm where such relative is an officer or representative, without prior full disclosure and written clearance.
- Accepting any money, gifts of other than nominal value, unusual hospitality, loans or any other preferential treatment from any supplier, client or competitor of Notified.
In short, we cannot be influenced by improper personal considerations which might consciously or unconsciously affect our judgment regarding the best interests of Notified. If a director, officer or employee becomes aware of an actual or apparent conflict of interest, he or she should discuss it with the appropriate manager and disclose it to Notified's General Counsel.
Corporate Opportunities:
No director, officer or employee of Notified may:
- Take for himself or herself personally any business opportunity discovered through the use of Notified's property, information or position;
- Use Notified's property, information or position for personal gain;
- Use confidential or non-public information of any of Notified’s clients for personal gain; or
- Compete with Notified.
Employees, officers and directors owe a duty to Notified to advance its legitimate interests when the opportunity to do so arises.
Information About Competitors:
As a business that competes in the marketplace, we seek economic knowledge about our competitors. However, Notified officers, directors and/or employees shall not engage in illegal or improper acts to acquire a competitor's trade secrets or customer lists. In addition, we will not hire a competitor's employees for the purpose of obtaining confidential information about the competitor.
Confidentiality:
All directors, officers and employees should maintain the confidentiality of information entrusted to them by Notified, its business partners, suppliers, clients or others related to Notified's business. Such information must not be disclosed to others, except when disclosure is authorized by Notified or legally mandated. Confidential information includes all nonpublic information that might be of use to competitors, or harmful to Notified or its clients if disclosed. Employees should not disclose confidential information of third parties. For example, you should not disclose a former employer’s confidential information to anyone, including other Notified employees.
Dealing with Suppliers and Clients:
Notified's overall view regarding its relations with suppliers and clients is simple. They must be treated as Notified expects to be treated - with fairness.
Notified strives to ensure it does not have or contribute to adverse human rights impacts (including modern slavery or human trafficking) within its business or through its supply chains. There is an ongoing commitment to engage only those suppliers that uphold the same principles as Notified. In the event suppliers fail to take steps to cease or prevent adverse human rights impacts, Notified will reconsider its business relationships with those suppliers.
Contributions to Political Parties, Candidates or Government Officials:
Notified's policy is precise and specific. Contributions by a corporation to political parties or candidates involving federal offices in the United States are expressly forbidden by Federal law. Notified obeys the law. In addition, while political contributions to parties or candidates may be legal in some states and in some foreign countries, no Notified corporate funds may be used for such purposes without the express prior approval of Notified’s General Counsel. Notified is an active participant in the democratic process at the national, state and local levels within the parameters of the law. Notified also encourages all employees to participate in our political system by voting, speaking out on public issues, and becoming active in civic and political activities. It is important, however, directors, officers and employees clearly distinguish their personal views from those of Notified, unless specifically authorized by Notified to speak on Notified's behalf.
Payments to Government Personnel:
The U.S. Foreign Corrupt Practices Act prohibits giving anything of value, directly or indirectly, to officials of foreign governments or foreign political candidates in order to obtain or retain business. It is strictly prohibited to make illegal payments to government officials of any country.
In addition, the U.S. government has a number of laws and regulations regarding business gratuities which may be accepted by U.S. government personnel. The promise, offer or delivery to an official or employee of the U.S. government of a gift, favor or other gratuity in violation of these rules would not only violate Company policy but could also be a criminal offense. State and local governments, as well as foreign governments, may have similar rules.
Accuracy of Notified's Records:
All official records showing the conduct of Notified's business must be accurate and complete in all material respects. All those involved in the preparation of such materials should consider the accuracy of the records of critical importance and should understand Notified does not maintain any off-the-books funds for any purposes. It is Notified’s policy to fully and fairly disclose its financial condition in compliance with applicable accounting principles, laws, rules and regulations. Notified keeps all books and records to fully and fairly reflect all Notified transactions in accordance with generally accepted accounting principles.
There must be full, fair, accurate, timely and understandable disclosure in reports and documents filed with the Securities and Exchange Commission and in other public communications made by Notified.
Retention of Records:
Disposal or destruction of Notified records and files should comply with company policy. In addition, when litigation or a government investigation is pending or imminent, relevant records must not knowingly be destroyed until the matter is closed.
Insider Information:
Federal law and the Securities and Exchange Commission's regulations prohibit the use of "inside" (i.e., material nonpublic) information when trading in Notified's securities. The Insider Trading and Securities Fraud Enforcement Act of 1988 imposes significant criminal and civil penalties for insider trading.
Examples of such information include possible acquisitions, mergers, stock splits, dividends, earnings, new contracts, new products or discoveries, major management changes, expansion plans, data which may be proprietary, or data which has not yet been disclosed to the investment public and other important corporate developments. As a result of these regulations, Notified personnel should follow the Notified Insider Trading Policy located on Notified's intranet.
Dealings with Clients:
Notified's business is built upon the principle of effective, courteous management of client contacts. Notified treats all clients and their consumers with dignity and respect.
Equal Opportunity:
Notified's people have been, and will continue to be, the key to our success. Notified strongly supports and recognizes its responsibility to provide equal employment opportunities to all qualified individuals. Notified places a high value on diversity. Notified strongly believes that all people are unique, valuable, and should be respected for their individual abilities.
In support of this goal, Notified has established a company policy regarding discrimination or harassment on the basis of race, gender, age, color, religion, disability status, veteran status, sexual orientation, marital status or ethnic, national or any other characteristic protected by law. This policy applies to all personnel relationships, including but not limited to, promotions, transfers, training, job assignments, job stations, hours of work, rates of pay, working conditions, terminations, and all terms and conditions of employment.
Legal Conduct and Compliance with this Code:
Notified's policy is that all of its directors, officers and employees shall conduct business on behalf of Notified in full compliance with the laws of the many jurisdictions in which Notified may conduct business. Accordingly, the provisions of the present Code are not intended as a substitute for applicable national laws and regulations and the scope of the Code’s application shall be limited to the extent incompatible with such laws and regulations. Under the laws of certain countries in which the Company has a presence, legal conduct and compliance with this Code may require further adaptations and directors, officers and employees should refer to the appropriate country annex that addresses such matters.
Any director, officer or employee who acquires knowledge of a violation of a law or this Code, or has cause to believe that a law or this Code has been violated, must immediately report this situation to the General Counsel, the Chief Executive Officer, the Chief Financial Officer or outside legal counsel for Notified. If you wish to remain anonymous, you may report a violation of this Code by calling the Telephone Hotline at 800-480-9503. The Telephone Hotline is answered by an independent company and is available 24 hours a day every day. You may also report a violation by email to west@getintouch.com or online at www.lighthouse-services.com/west. No director, officer or employee who reports such a situation, in good faith, shall be penalized for his or her reporting of any violation or suspected violation of a law or this Code. To the fullest extent possible, the identity of a person making a report will be kept confidential. If an Notified person believes that he or she is being treated unfairly because of reporting a violation or potential violation, this should be brought to the immediate attention of the General Counsel or a Vice President of Employee Relations of Notified.
Any employee who ignores or violates any of Notified's ethical standards, and any manager who penalizes a subordinate for trying to follow these ethical standards, will be subject to corrective action. However, it is not the threat of discipline that should govern your actions. Notified expects you to share its belief that a dedicated commitment to ethical behavior is the right thing to do and is good business.
Violations of this Code will result in disciplinary action that may include termination, referral for criminal prosecution and reimbursement to Notified for any losses or damages resulting from the violation. As with all matters involving investigations of violations and discipline, principles of fairness and dignity will be applied pursuant to the procedures developed and used by Notified's Employee Relations Department.
Waivers:
Any waivers of this Code for directors or executive officers must be approved by the Board of Directors of Notified and must be promptly disclosed in a Form 8-K within five business days with reasons for the waiver.
Foreign Hotline Numbers:
Australia: 1-800-983-589
Canada: 844-768-0879
China: 400-120-3529
France: +33-975182340
Germany: +49-32211001267
India: 000-800-100-4371
Mexico: 01-800-681-8161
Philippines: 1-800-1-322-0224
Singapore: +65-31581730
United Kingdom: 0-808-189-3366
Digital Media Innovations UK Limited
Modern Slavery Statement
Digital Media Innovations UK Limited (“Notified”) is a subsidiary of West Technology Group, LLC. This statement (the “Statement”) should be read in conjunction with Notified’ s Code of Ethical Business Conduct, employment policies and procedures and its overall ethics and compliance programme. Notified is committed to continuously improving its practices and procedures to ensure that its business is conducted in compliance with the applicable laws and regulations globally. To that effect, the Code of Ethical Business Conduct provides and establishes the guiding principles to its business units and all of its employees.
The purpose of this Statement is to ensure that Notified is compliant with the principles of the Modern Slavery Act 2015 (the “Act”), including laws against human trafficking in the UK and other jurisdictions where Notified operates. This Statement sets out Notified’s commitment to eradicating any form of modern slavery and human trafficking from its business operations and from any form of its business conduct.
It is Notified’s policy to comply fully with the Act. Notified does not tolerate modern slavery and/or human trafficking in any form and any such act is strictly prohibited within its business and its supply chain. To that end, Notified collaborates with partners and suppliers who are committed to similar principles.
Notified Employees
Notified recognises the importance of the duty to respect human rights for its employees. It strives to be in compliance with and adheres to the internationally recognised principles of human rights and the applicable national labour and employment laws. The Company has a zero-tolerance approach to modern slavery and human trafficking. The Company is committed to acting lawfully and in compliance with the principles of International Labour Organization (ILO), rights of individuals as recognised by the International Bill of Human Rights (IBHR), and other recognised international principles prohibiting human trafficking and slavery.
Notified is highly committed to treating all its employees with dignity and respect and explicitly prohibits human trafficking and the use of involuntary labour. In order to meet this commitment, amongst other things, Notified ensures all work is voluntary, never withholds workers’ original government-issued ID or travel documentation and ensures that forced labour conditions are not entertained or supported within its business.
Supply Chain
Notified is committed to ensuring that there is no modern slavery or human trafficking in its supply chain. Its Code of Ethical Business Conduct reflects this commitment to act ethically, lawfully and with integrity in all of its business relationships. Notified is committed to the implementation and enforcement of stringent contractual controls to ensure modern slavery and human trafficking is not taking place anywhere within Notified’s supply chain.
In addition, Notified expects the same high standards from all its contractors, suppliers and other business partners. Notified includes specific provisions in its contracts that require compliance with all applicable laws and regulations by its contractors, suppliers and business partners. Additionally, Notified expects that its contractors, suppliers and business partners will hold their own contractors, suppliers and business partners to the same high standards as followed by Notified itself to ensure that no form of modern slavery or human trafficking exists within the respective supply chains. Notified believes that with such a progressive and firm approach towards modern slavery and human trafficking, it will increase its positive impact in this sphere.
Training
Notified appreciates and acknowledges the importance of enabling employees across the organisation to understand and respect the principles, objectives and implications of non-compliance with Notified’s Code of Ethical Business Conduct, which specifically addresses human trafficking. This commitment is reflected in the internal training programme that every Notified employee is required to complete on an annual basis which includes a presentation on the principles of the Act to ensure all employees are fully aware of the compliance requirement with the principles set out therein.
The Modern Slavery statement published above has been approved by the Executive Management team of Notified and signed in accordance with the guidelines set out in the Act. Notified recognises that modern slavery and human trafficking are significant global issues and, as such, its Board of Directors will review and, as necessary, update it annually.