Persooa Responsible Growth Policy 2026 Version 2026.1
Purpose and scope
This policy defines how Persooa understands and delivers responsible growth as a remote-first consulting and implementation organization operating globally in the Synerise ecosystem. It applies to all employees, associates and subcontractors involved in delivery for customers.
Persooa deliberately takes a proportionate and honest approach: we declare only what we genuinely control. We do not make Net Zero, SBTi or carbon-neutrality commitments, and we do not make marketing environmental promises.
Guiding principles
- Growth through value, not through risk - we grow together with our customers, delivering measurable results without shifting legal, ethical or reputational risk onto them.
- Proportionality - the scale of our commitments matches the scale of our actual impact.
- Transparency - we communicate facts, not aspirations dressed up as facts.
- Continuous improvement - we treat responsibility as a process, not a one-off declaration.
Operations: remote-first, cloud-first, paperless
Persooa operates in a remote-first model, without dedicated office space for project teams. Delivery (discovery, design, implementation, reporting), collaboration and signatures are carried out fully digitally (paperless), and artifacts are versioned in secure cloud environments. We use the cloud infrastructure of large-scale providers and design solutions for computational efficiency - the "right-sizing" principle (the smallest effective model and the minimum necessary scope of data, data minimization), reusability of components and an extended hardware lifecycle.
The full, one-page breakdown of operational and environmental practices is contained in the Supplier Sustainability Statement, which is an extract from this policy.
Continuous improvement
- At least once a year we review this policy and update it in response to changes in our business, technology and regulatory environment.
- We gather feedback from customers and teams, treating it as input for improving our practices.
- We measure what we genuinely have an impact on, and we avoid vanity metrics.
Ethics and Code of Conduct
The foundation of Persooa's responsible growth is business ethics, captured in the public Code of Conduct, which is binding on employees, associates and management. The Code covers, among other things:
- Integrity and compliance with the law - acting ethically and observing applicable regulations and internal policies.
- Anti-corruption - a ban on offering and accepting benefits in order to obtain an undue advantage.
- Conflict of interest - the obligation to disclose and to recuse oneself from decisions in the event of a conflict.
- Protection of confidential information and intellectual property - including after the engagement ends.
- Competition law - a ban on price-fixing, market allocation and unfair practices.
- Equal treatment and non-discrimination, and a ban on mobbing and harassment.
- Health and safety of employees and associates.
- Ethics of suppliers and partners - we expect high ethical standards and compliance with the law throughout the collaboration chain.
- Reporting violations without retaliation - safe reporting channels and a ban on retaliatory action against those who report in good faith.
The above principles are not merely declarations - they are operationalized through internal, binding Persooa policies with specific control mechanisms:
- Anti-Corruption and Anti-Fraud Policy - a catalogue of prohibited behaviours, counterparty risk assessment (Transparency International index, PEP links), a documented assessment-report template, and a Management Board decision on cooperation with a non-recommended counterparty.
- Policy for Preventing and Managing Conflicts of Interest - reporting by anyone, assessment by an independent person (after an NDA), exclusion from decisions, register of reports.
- Competition Law Compliance Policy - a ban on bid-rigging, price-fixing agreements, market allocation and the exchange of strategic information with competitors; a ban on the unfair use of contractual advantage.
- Confidential Information Protection Policy - a Trade Secret Protection System, information classification (Basic/Restricted), incident response with an incident log.
These policies are available for review as part of due diligence after signing an NDA.
What this policy does NOT declare
In the interest of honesty and avoiding greenwashing, Persooa does not make the following in this policy:
- commitments to achieve Net Zero,
- targets aligned with SBTi,
- carbon-neutrality declarations,
- unrealistic environmental targets.
This approach protects customers from the risk of basing their own ESG reporting on unreliable supplier declarations.
Document owner: Persooa Management Board. Review: annual. Version: 2026.1. This document is informational and does not constitute a binding contractual commitment.