Code of Conduct & Ethics

1. Why this document exists

Blankstate (Traceflow Ltd) builds infrastructure that measures and audits AI. We hold ourselves to the same standards we ask of the systems we observe: deterministic, honest, accountable. This Code of Conduct & Ethics is the everyday version of that commitment. It applies to everyone who works at, with, or on behalf of Blankstate.

2. Scope

All Blankstate personnel — employees, contractors, interns, secondees, and other third-party representatives. References to “personnel” include all of these. Where this Code applies to third parties acting on Blankstate’s behalf, the relevant contracts incorporate it by reference.

3. Our shared commitments

1. Act with integrity. Do the right thing even when it’s harder. Tell the truth, especially upwards.
2. Respect people. Treat colleagues, customers, partners, and the public with dignity and fairness.
3. Protect what is entrusted to us. Customer data, customer trust, and the security of the systems we run.
4. Compete and win lawfully. Build a better product; never cut corners on legality, ethics, or safety.
5. Speak up. If something is wrong, raise it. Blankstate will not retaliate against good-faith reports.

4. Compliance with law

Personnel comply with all applicable laws and regulations in the jurisdictions where they live and work, including:

• Data-protection and privacy law (UK GDPR, EU GDPR, DPA 2018, LGPD, India DPDP, US state-level laws as applicable).
• Anti-bribery law (UK Bribery Act 2010; US FCPA where applicable) — see BKS-ABC-001.
• Anti-discrimination and equal-opportunity law (Equality Act 2010 in the UK; equivalents elsewhere).
• Competition / antitrust law.
• Export controls and economic sanctions — see BKS-SAN-001.
• Anti-money-laundering, anti-fraud, and tax law.
• Employment law of the working jurisdiction.

Where local law conflicts with this Code, personnel apply the higher standard wherever lawful to do so, and consult HR / legal counsel where there is doubt.

5. Respectful workplace

5.1 Anti-harassment and anti-discrimination

Blankstate is an equal-opportunity employer. Harassment, bullying, discrimination, victimisation, and retaliation are prohibited and treated as gross misconduct. This includes — but is not limited to — conduct based on age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, sexual orientation, nationality, or any other protected characteristic.

Concerns should be raised through the manager, HR, or the Speak-Up channel in BKS-WHB-001. Reports are taken seriously, investigated promptly, and acted on.

5.2 Inclusive language and conduct

Treat colleagues, customers, and the public with respect in writing, in voice, in person, and in code review. Disagree on substance; never make it personal.

5.3 Substance use

Personnel are not to be impaired by alcohol or drugs while performing work. Reasonable, occasional social consumption at company events is permitted within local law.

6. Conflicts of interest

A conflict of interest exists when a personal interest competes with — or appears to compete with — your duty to Blankstate. Common examples:

• Outside employment, consultancy, or board roles that overlap with Blankstate’s business.
• A personal financial interest in a Blankstate customer, supplier, competitor, or partner (beyond ordinary public-market holdings).
• A personal relationship in the reporting line.
• Receiving gifts or hospitality that could influence — or appear to influence — a business decision (see BKS-ABC-001 on gifts and hospitality).

You must disclose actual or perceived conflicts of interest to your manager and, for material conflicts, to the Executive Sponsor, who will decide on appropriate management (recusal, reassignment, divestment, or other action). The COI register is maintained by HR.

7. Anti-bribery and anti-corruption

Personnel do not offer, give, request, or accept any bribe, kickback, or improper advantage — directly or indirectly, in dealings with the private sector or public officials. Full requirements, the thresholds for gifts and hospitality, facilitation payments, and reporting obligations are in BKS-ABC-001.

8. Anti-fraud

Personnel do not engage in or facilitate fraud, including expense fraud, misrepresentation of work, falsification of records, or the deliberate provision of misleading information to customers, regulators, auditors, or investors. Suspected fraud is reported through the Speak-Up channel.

9. Honest dealing with customers and the market

• Statements about Blankstate’s products, capabilities, certifications, and roadmap must be accurate and properly qualified.
• We do not over-claim our measurement results; we attach uncertainty and method where relevant.
• We honour our contractual commitments, including security, privacy, and SLA obligations.
• Sales and marketing communications are truthful and not deceptive.

10. Protection of information

Personnel comply with the Acceptable Use Policy (BKS-AUP-001), the Information Classification & Handling Policy (BKS-ICH-001), the Data Protection & Privacy Policy (BKS-DPP-001), and other applicable policies when handling Blankstate, customer, partner, or personal information.

Confidentiality obligations survive termination of the working relationship.

11. Use of AI and automated systems

Given the nature of our work, personnel use AI tools and automated systems thoughtfully:

• We do not paste customer personal data, secrets, or other Restricted information into general-purpose consumer AI tools.
• We do not represent AI-generated content as our own original work where attribution matters (e.g. customer-facing analysis, regulatory submissions).
• We apply human judgement to AI output that could affect a person’s interests; we do not delegate consequential decisions to systems without appropriate review.
• Our Responsible AI commitments are in BKS-AI-001.

12. Health, safety, and the environment

We provide and maintain a working environment that is safe and healthy for the working pattern (predominantly remote). Personnel report safety concerns through their manager. Our environmental commitments — and the structural advantages of our low-compute, low-water architecture — are in BKS-ESG-001.

13. Political activity and personal speech

Personnel are free to participate in lawful political and personal activity in their own time. Personnel do not use Blankstate resources, the Blankstate brand, or their Blankstate role to engage in political campaigning or to make statements that purport to be Blankstate’s position unless authorised to do so.

14. Social media

Personnel may post on social media in their personal capacity, subject to:

• No disclosure of Confidential or Restricted Blankstate or customer information.
• No statement purporting to be Blankstate’s position unless authorised.
• Compliance with §5 (respectful conduct) — the standards apply online as offline.

15. Reporting concerns and Speak-Up

If you see or suspect a breach of this Code or of any applicable law, you are expected to report it. Routes:

1. Your manager (where appropriate and safe).
2. HR.
3. The Owner or executive ownership.
4. The confidential Speak-Up channel in BKS-WHB-001 (speakup@blankstate.ai).

Blankstate prohibits retaliation against anyone who, in good faith, reports a concern or participates in an investigation. Retaliation is itself a breach of this Code and is treated as gross misconduct.

16. Consequences

Breach of this Code is dealt with under the disciplinary process in BKS-HRS-001 §8. Consequences may include training, warning, role change, dismissal, and — in cases involving suspected criminal conduct — referral to authorities.

17. Acknowledgement

All personnel acknowledge this Code on hire and on each material update. Blankstate’s executive ownership signs off the version in force.