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Cloud23

Code of Conduct

One standard. Three continents. No loopholes.

This Code applies to every director, employee, contractor and subcontractor of Cloud23, in every market. Judgement, not loopholes.

Last reviewed: August 2026

The one-sentence version

We work inside the systems, data and reputations of Africa's most trusted institutions — so we behave, every day, like the trust placed in us is on the line. Because it is.

01

Integrity in everything

Honest in our dealings, accurate in our reporting, realistic in our promises. We don't overstate to win work, and we don't hide problems once we have it — when something goes wrong, the client hears it from us first, with a plan.

02

Zero tolerance for bribery and corruption

Full compliance with PRECCA and all anti-bribery law. No bribe, kickback, facilitation payment or improper inducement — ever, in any market. Gifts and hospitality stay modest, recorded, and never capable of influencing a decision.

03

Conflicts of interest — declared, not buried

Any interest that could conflict with a client's or Cloud23's is declared in writing as it arises. We keep a conflicts register and disclose relevant relationships in bids. A declared conflict is manageable; a concealed one is a breach.

04

Confidentiality and data protection

Client information is defended as if it were our own. We comply fully with POPIA, honour every NDA, apply need-to-know access, and never use client data beyond the engagement. The obligation survives the project and the employment.

05

Respect, dignity and inclusion

We employ on merit and treat everyone with dignity. Discrimination, harassment, bullying or victimisation is not tolerated — in the office, on client site, or online. We actively build a workplace for South Africa's full diversity of talent.

06

Fair dealing and competition

We compete hard and cleanly. No collusion, bid-rigging, price-fixing or misuse of others' confidential information. Every proposal is independently prepared.

07

Quality is an ethical matter

Sloppy work in a bank creates risk for millions who depend on it. We follow our methodology, test what we build, document what we change, and escalate what we can't fix. Cutting corners is a violation, not a style.

08

Company assets and financial discipline

Company and client assets — funds, equipment, systems, IP, time — are used honestly and for their purpose. Our books are accurate. We claim what we incurred and bill what we delivered.

09

Speaking up

Anyone may raise a concern — to any leader, or confidentially to the CEO — without fear of retaliation. Retaliating against a good-faith whistle-blower is itself a dismissible breach. Every report is taken seriously and investigated.

10

Consequences

This Code is a condition of employment and of every subcontract. Breaches lead to disciplinary action up to dismissal or termination, and where the law is broken, referral to the authorities.

The values beneath it

  • Trust

    Earned through delivery, protected through candour.

  • Client-centricity

    Their outcome is our metric.

  • Integrity

    The same behaviour whether or not anyone is watching.

  • Quality

    Engineering pride in everything that ships.

  • Innovation

    Better ways, responsibly adopted.

  • Growth

    Of our people, our clients and our continent.

Raise a concern

If this Code is being broken, tell us — to any leader, or in confidence directly to the CEO. No one who reports a genuine concern in good faith will face retaliation; protecting the person who speaks up is part of the standard, not an exception to it.

conduct@cloud23.io

Cloud 23 Proprietary Limited · Reg 2022/673078/07 · 1402 Illovo Point, 68 Melville Road, Illovo, Sandton, 2196

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