Trust Center | Our Business

Conducting Business with Integrity

To ensure that Celonis is a trusted and respected customer, supplier and business partner, each of us must conduct business ethically and in compliance with all applicable laws, this Code, and our policies. We also believe that conducting business in a manner consistent with the highest standards of integrity is essential for building and maintaining successful business relationships, and we seek to do business with companies who share these values.

Striving for excellence and high integrity also means avoiding deceptive, dishonest, or fraudulent activities. Fraudulent actions are not only unethical but may also be a violation of law. You should manage your particular area of business with as much transparency as possible and encourage a work environment that supports the contributions of your fellow employees and is based on our values and ethics.

Avoiding Conflicts of Interest

We are all trusted to act in the best interest of Celonis at all times while performing our jobs. You must devote your full professional effort to your job and avoid conflicts of interest. A conflict of interest, or even just the appearance of conflict, can harm Celonis’ reputation, damage trust with our customers, suppliers and other business partners, and cause serious financial harm to the Company. A “conflict of interest” can arise when your personal activities and relationships interfere with your ability to act in Celonis’ best interest. For example:

Personal relationships and interests

Always disclose in advance, to everyone who is involved in the selection process, any personal relationship with, or personal interest in, a job candidate or supplier.

Outside Activities

Do not accept side employment, contract work, advisory positions, board seats or other affiliations with Celonis competitors, customers, suppliers, or other business partners that could, or could appear to, influence your judgment in a way that could harm the Company. Furthermore, do not start a business that competes with the Company’s current or foreseeable future business, affects your ability to do your job at Celonis, or uses Company confidential or proprietary information or resources.

Personal Investments

Avoid any personal private investments that may appear to interfere or conflict with the activities or business of Celonis or our customers.

Business Opportunities Found Through Your Work

Business opportunities discovered through your work with Celonis belong to Celonis; you must inform your management and not engage for personal benefit.

We cannot list every potential conflict of interest, so when making decisions you should ask yourself: Might it appear to others, inside or outside of Celonis, that my personal interests interfere with Company interests?

Remember

We are all expected to lawfully advance the Company’s interests. If any activity, investment, situation, and or relationship raises a potential conflict of interest, promptly contact ethics@celonis.com or another Do The Right Thing resource.

Gifts and Entertainment

Giving or receiving gifts or sharing meals, travel and entertainment (also called “business courtesies”) with our customers, suppliers, or other business partners is one way to strengthen professional relationships and create good will and sound working relationships. However, these courtesies must not be used to gain unfair advantages with customers. Accordingly, no courtesies should be made if they are intended to influence, or appear to influence, a business decision. Similarly, you may not accept business courtesies

in connection with an agreement to do anything in return, particularly when involved in selecting suppliers. All gifts, meals, and entertainment that you offer or accept must serve a legitimate business purpose, be reasonable and appropriate in the context of the business occasion, comply with all applicable law and both companies’ policies and never reflect poorly on Celonis’ reputation.

Business courtesies should not be offered, given, provided, or accepted by you unless all of the following are true:

It is not cash or a cash equivalent;
The value does not exceed modest limits or customary business practices, as established locally;
The courtesy will not be construed as a bribe, payoff, or attempt to influence a purchasing decision;
The timing is not close to completion of a deal;
The activity is fully visible to, and permitted by, Celonis management;
The recipient is not a government official;
Celonis would not be embarrassed if the business courtesy became known to the public; and
The business courtesy does not violate any applicable laws or regulations.

In order to ensure that business courtesies do not influence, or appear to influence, our business decisions or the business decisions of others, you must follow our Global Travel and Expense Policy, as well as other policies and guidelines regarding business courtesies.

If you are considering extending a business courtesy, or if you have been offered or received a business courtesy, that feels inappropriate, please contact your manager, ethics@celonis.com or another Do The Right Thing resource.

Anti-Bribery and Anti-Corruption

Celonis takes a strong stance against bribery consistent with the antibribery and anti-corruption laws around the world. Because we are committed to seeking and retaining business based on merit and the excellence of our performance, we do not tolerate, permit, or engage in bribery, corruption, or unethical practices of any kind. Further, we do not tolerate bribery or corruption by agents, suppliers, customers or other business partners.

It is strictly prohibited to pay, promise, offer, or authorize a payment, directly or indirectly, of money or anything of value to anyone for the purpose of influencing an act or decision, in order to obtain or retain business, or to secure any other improper advantage. This includes public officials, candidates for office, employees or officers of state-owned enterprises, customers, suppliers, or any other person with whom we currently do business or anticipate doing business in the future. “Anything of value” includes not only cash bribes or kickbacks but may also include other direct or indirect benefits and advantages, such as gifts, meals, travel, entertainment, charitable and political contributions, and offers of employment or internships.

In addition to putting your relationship with Celonis at risk, the penalties for violating anti-bribery laws can be severe, including significant corporate fines, fines on individuals and even prison time. In addition, corruption, or even the appearance of corruption, destroys business relationships and can erode our stakeholder’s trust in our business.

Anti-Money Laundering

Celonis will not be a party to any agreement or action which violates the money laundering laws of any country where we, our suppliers, our customers, or other business partners conduct business. Money laundering is the act of concealing or disguising the existence, illegal origins, and/ or illegal application of criminally derived income so that such income appears to have legitimate origins or constitute legitimate assets. Our dedication to integrity requires strict compliance with all applicable antimoney laundering laws and regulations.

Be alert for, and promptly report, any unusual or potentially suspicious activity that could involve money laundering, terrorist financing, violations of law or regulation, or any other activity that has no apparent legitimate business purpose or is outside the scope of ordinary business activity.

Watch out for business transactions in which a supplier or other business partner:

Provides vague or fictitious information;
Asks for an unusual transaction that has no business purpose; Gives unusual payment instructions or engages in an odd pattern of transactions or payments;
Changes the terms of an agreement or payment at the last minute.

To report suspicious activity, or if you have any questions about whether an activity is suspicious, contact ethics@celonis.com or another Do The Right Thing resource

Fair Competition

Celonis believes that everyone benefits from a competitive marketplace. Accordingly, we follow all laws that promote competition in the locations where we operate and take care to avoid even the appearance of unfairly restricting another company’s ability to compete. We also do not speak dishonestly about our competitors, and we don’t seek competitive information using unethical or illegal means.

When dealing with our competitors, suppliers, or other business partners, you must never enter into an agreement - not even informal or verbal understandings - that is intended to, or appears to be intended to:

Fix or set prices
Divide or allocate markets, customers, or territories
Improperly tie or bundle services by conditioning the purchase of one product or service on the purchase of another
Boycott another company

If any of the above situations arise during your interactions with a competitor, supplier, or other business partner during an informal conversation, meeting, trade show, or in any other setting, immediately stop the conversation and make clear that you cannot participate in such discussions or arrangements. Then, immediately report the incident to your manager and Legal, Ethics & Compliance.

Antitrust and fair competition issues are complex, so please seek help from ethics@celonis.com or another Do The Right Thing resource.

Global Trade Laws & Sanctions

As a global company, we must comply with applicable international trade laws and regulations that restrict where we may send or receive products and services and to whom we may sell our products and services. Further, Celonis is committed to adhering to all applicable government economic and trade sanctions, including but not limited to the US, UK, and EU sanctions regimes.

For example, we must not:

Procure goods or services from, or sell goods or services to, entities and individuals subject to comprehensive embargoes such as Cuba, Iran, Syria, and North Korea (this list may change from time to time)
Engage in unauthorized transactions with sanctioned parties or targeted types of exports to countries subject to trade embargoes such as Russia (this list may change from time to time)
Participate in any international boycott that is not authorized by the U.S. and EU governments

Violating global trade laws is a serious matter and may result in the loss of export privileges, as well as civil and criminal penalties. The laws and rules are complex, so for any questions, please contact ethics@celonis.com.

Safeguarding Information

Confidential and proprietary information (“confidential information”)about our people, operations, activities, and business affairs, as well as confidential data that belongs to other parties, such as customers and business partners, must be protected.

Confidential information is any non-public information you may be exposed to as part of your job, whether or not it is marked as “confidential” and can relate to strategic business or marketing plans, operating results, tradesecrets, product development plans, source code, supplier lists, customer information, personnel data including employee compensation and performance information, costs, pricing or service strategies, non-public sales, earnings, or other financial information, and information related to investments, mergers, and acquisitions.

Always keep the following in mind:

Only store and save confidential information in Celonis approved tools (including SaaS) and devices.
Only access or use our confidential information for Celonis’ benefit.
You must not discuss or disclose confidential company information with anyone outside of Celonis unless
- you are authorized to share such information,
- the recipient has a legitimate business need on behalf of Celonis to know the information,
- you are not sharing more than is necessary, and
- you have put safeguards in place to protect it (such as a non disclosure agreement).

Do not reveal confidential information on the internet, including through social media.
Even within Celonis, only share confidential information with people who are authorized to access it and need it to do their jobs. Please note that your non-disclosure obligations continue even after your employment with Celonis ends.
We expect you to follow any confidentiality, non-disclosure, or similar agreements between you and any companies you’ve worked with in the past.

If you have questions about what and how you can share confidential information, contact legal@celonis.com. If you have or receive confidential information that should not be in your possession, do not use it, access it, or delete it, but contact the Legal, Ethics & Compliance Department Immediately

Data Privacy

Celonis is subject to various data protection and privacy laws in the jurisdictions in which we operate. These laws generally require us to be transparent about how we collect, use, and disclose personal data of employees, job applicants, suppliers, customers, other business partners, and any other individuals whose personal data we process, and to have an appropriate legal basis to do so. We are also obliged to implement technical and organizational measures to protect personal data as well as to take certain steps when personal data may have been compromised.

Several laws also grant individuals specific rights regarding how Celonis uses their data.

The definition of “personal data’’ can vary but generally includes information that can be used to identify an individual, such as name, email address, physical address, photographs, or identification numbers.

When processing personal data keep the following principles in mind:

Keep personal data secure and treat it as confidential information;
Restrict access to personal data on a need-to-know basis;
Promptly report incidents involving the potential misuse of personal data to security-incident@celonis.com;
Only process/share personal data that is necessary to fulfill a particular purpose and ensure that the data is deleted after the purpose is fulfilled;
Take special care to protect sensitive personal data with additional safeguards;
Ensure that appropriate data protection terms are in place with any third-party before disclosing or receiving personal data.

We all must comply with applicable data protection and privacy laws as well as Celonis’ policies when processing personal data. If you have any questions or concerns about privacy at Celonis, please contact privacy@celonis.com.

Artificial Intelligence

Artificial Intelligence (AI) has the potential to bring great opportunities to businesses and our society, including enhanced internal collaboration, increased productivity and state of the art innovation.

To enable the use of AI at Celonis, an advanced governance framework supports our AI initiatives for both internal and customer/product related use and allows us to advance our use of Responsible AI in a way that maintains trust with our customers and business partners. This framework is based on industry-recognized Responsible AI principles and is designed to enhance fairness, transparency, security and reliability, data privacy, and accountability.

Information Security

Information security is core to our business. All of us must do our best to protect and maintain our data, and any third-party data we have, every day.

To protect our systems and data, you must:

Follow our IT and Security-related policies when leveraging the Company’s network or systems, whether you do so with Celonis issued, or permitted personal equipment.
Always secure your laptop, important equipment, files and personal belongings, whether you are working from home, at a Celonis office or another location.
Always apply good security practices when selecting and using service or user account passwords and device access PINs.
You may use Celonis’ information systems only for purposes for which you have been authorized.
Report any suspicious communications and activity to phishing@celonis.com
You must not, directly or indirectly, allow another person to use your access rights, such as username or password, and you must not use another person’s username and/or password.
Immediately report any security incidents to Celonis Information Security security-incident@celonis.com, including reporting a lost or stolen laptop or mobile device, suspicious system activity, as well as compromised passwords or credentials.
Never use personally owned devices when accessing customer Data.

Company Assets and Intellectual Property

Our assets — including information, physical assets, financial data, and intellectual property — are essential to operating our company successfully. We all have a responsibility to use company assets appropriately for company business and not allow them to be used for any type of personal gain. You are responsible for safeguarding company assets under your control and must take reasonable steps to protect it from theft, misuse, damage, or sabotage.

Intellectual property includes patents, copyrights, trademarks, and trade secrets. The presentation, use, and protection of our trademark and trade name are extremely important to our company. Respect the laws regarding copyrights, trademarks, rights of publicity, and third-party rights. Do not infringe on Celonis’ logos, brand names, taglines, slogans, or other trademarks.

You must also be careful not to misappropriate original materials from other sources as your own, or on behalf of Celonis. Do not use copyrighted materials — including graphics, videos, and music — without a license. This includes your use of AI. Users could be held personally liable for consequences that could arise under applicable intellectual property law.

Company assets also include the equipment and supplies you use and the computer resources you access, including but not limited to hardware, software, email, applications, websites, voicemail, messaging tools, intranet and internet access, computer files, and programs (including any data which is created, stored, sent or received through Celonis’ information systems).

You must not download, use or copy software without a license appropriate for use. You must return all company assets before or on your last day worked.

Financial Integrity and Accurate Records

Celonis engages in finance and accounting-related practices consistent with generally accepted accounting principles and relevant obligations for our Company. You must support these practices and never seek to subvert or evade them. You must never mislead, or provide inaccurate information to any of our finance or accounting resources. Celonis’ financial records must be materially accurate and complete. The records you create, such as accounting records, time and billing reports, expense reports, invoices, purchase orders, payroll records, and sales data,

have an impact on the financial information that the Company discloses and relies on to make business decisions. No company documents or records may be falsified, and no undisclosed or unrecorded accounts of company funds or assets may be established for any purpose. You must:

Create business and financial records that are materially accurate, complete, objective, relevant, timely, and understandable.
Communicate honestly in connection with every proposal, bid, and contract negotiation with third parties.
Only enter into agreements or commitments on behalf of Celonis when you have the required authority, and only enter into agreements, in writing, that contain terms to which Celonis can adhere.
Create records that accurately reflect all the terms of the agreement. There must not be any “side letters” or verbal agreements.

Everyone at Celonis is expected to make responsible decisions about how you spend Celonis’ money. You must act only within your approved authority when negotiating agreements, signing any documents, or otherwise acting on Celonis’ behalf. If you are unsure of your authority limit, discuss it with your manager.

If you see or suspect inaccurate recordkeeping and/or financial

misconduct, or if you have questions or concerns about the company’s accounting, auditing, financial reporting, or internal controls, you must notify CLO@celonis.com or another Do The Right Thing resource promptly.

Business & Travel Expenses

Any business and travel expenses must be authorized, accurately documented, and timely submitted in accordance with internal policies. You should consult your manager or Finance in advance if you are not sure whether a certain expense is eligible.

Record Retention

Business records are company assets. We must maintain the records we need to meet our legal, tax, and regulatory requirements and delete records that are no longer needed, especially when they include personal data. However, you should never delete or destroy information that may be relevant to current or threatened litigation, a government investigation or audit, or otherwise is subject to a Legal Hold unless and until you are authorized in writing to do so by Legal, Ethics & Compliance.