Standards should be visible before they are requested.

It is the umbrella document for our policy set. Each commitment is implemented through a numbered policy with its own responsible function. Where a client or funder contract imposes stricter requirements, the stricter standard applies to that engagement.

The statement covers:

• Integrity, anti-bribery and anti-fraud
• Sanctions and financial integrity
• People, labour and human rights
• Safeguarding and protection from sexual exploitation and abuse
• Health, safety and well-being
• Data protection, information security and responsible AI
• Environment and sustainability
• Risk management and business continuity

International frameworks such as the UN Guiding Principles on Business and Human Rights and the principles of the UN Global Compact inform the statement. They are reference frameworks, not a claim of signatory status or external endorsement.

It brings the essential rules of our policies together in one document that each person reads and acknowledges. Where a situation needs more detail, the relevant policy applies.

The Code covers:

• Respect, equality and a safe workplace
• Integrity in business and accurate submissions
• Consent and dignity for people featured in our work
• Confidentiality, data and information security
• Intellectual property and approved use of AI
• Responsible use of resources
• Speaking up without fear of retaliation

Employees and interns sign a personal acknowledgement. Freelancers and consultants accept the Code through their engagement terms.

This principle applies to employees, representatives, experts, suppliers, subcontractors and partners acting within our delivery structure.

Our approach includes:

• Transparent commercial relationships
• Accurate records and documentation
• Appropriate approval responsibilities
• No improper payments or benefits
• Responsible management of gifts and hospitality
• Reporting and review of suspected misconduct

Internal investigation procedures and records are not made public.

A conflict may arise when personal, professional, financial or organizational interests could affect, or appear to affect, objective decision making.

Our approach includes:

• Early disclosure
• Review of the circumstances
• Appropriate mitigation measures
• Separation from decisions where required
• Documentation of material conflicts
• Continued monitoring during implementation

Personal disclosures and internal conflict registers remain confidential.

Anyone may report a concern, including employees, freelancers, suppliers, clients, project participants and members of the public. Proof is not required; reasonable grounds are enough.

The policy provides:

• Confidential internal reporting channels
• Acceptance of anonymous reports
• Acknowledgement within five working days
• Feedback on action taken within three months
• Protection of the reporter’s identity
• Protection from retaliation for reporters and those who assist them
• Independent handling where a recipient is implicated

The policy takes account of Albanian Law No. 96/2025 on whistleblowing and does not limit the right to report to a competent authority. Case records remain confidential.

Requirements are applied in proportion to the size of the supplier and the nature and risk of the work. Where a client or funder imposes stricter supply chain rules for a project, those rules apply.

Suppliers are expected to uphold:

• Compliance with applicable law
• No bribery, collusion or improper advantage
• Disclosure of conflicts of interest
• Accurate information, records and invoices
• Lawful labour conditions and respect for human rights
• Safe working practices on sets and event sites
• Safeguarding and protection from sexual exploitation and abuse
• Confidentiality, data protection and responsible use of AI

Suppliers confirm acceptance through a supplier declaration and flow the relevant requirements down to their own subcontractors.

Our quality approach is designed to support:

• Clear project objectives and responsibilities
• Defined approval and review points
• Consistent delivery standards
• Documented decision making
• Risk identification and corrective action
• Client feedback and continuous improvement

The public page explains our quality commitments and governance principles. Internal workflows, templates and quality management procedures remain controlled.

Assessment is proportionate to possible consequences. Low risks can be accepted by the responsible owner, while high risks require management approval and a time bound action plan.

The program includes:

• A defined risk appetite and decision limits
• Risk screening before bids, contracts and new suppliers
• Project and supplier gates
• A central risk register
• Incident escalation linked to business continuity
• Regular review of trends and effectiveness

The approach is informed by ISO 31000 guidance and makes no claim of risk management certification. The risk register remains internal.

Our business continuity framework considers the systems, personnel, information, suppliers and infrastructure required to sustain critical project activities during disruption.

The approach includes:

• Identification of essential operations
• Defined responsibilities and escalation paths
• Information backup and recovery arrangements
• Alternative communication and delivery methods
• Supplier and dependency considerations
• Periodic review of continuity measures

The public page provides a high level overview. Detailed recovery procedures, infrastructure information and internal contact structures are not published.

The policy is informed by the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines for Multinational Enterprises. These frameworks inform our process; they are not certifications.

The policy addresses:

• Equal treatment and dignity at work
• No forced, bonded or child labour
• Fair working conditions and freedom of association
• Rights of people featured in campaigns, films and events
• Rights affected by data and technology
• Proportionate due diligence on suppliers
• Routes for concerns and access to remedy

Assessments, concern records and case details remain confidential.

Our safeguarding approach applies to employees, experts, suppliers, production teams, field collaborators and other individuals acting on behalf of the company.

It is guided by:

• Respect and dignity
• Prevention of harm
• Appropriate conduct
• Safe communication and production practices
• Responsible handling of sensitive information and images
• Clear reporting and response responsibilities

Detailed case management procedures and records remain confidential.

Our approach aims to prevent discrimination and ensure that decisions are based on competence, project requirements and professional conduct.

The policy considers:

• Equal access to professional opportunities
• Fair recruitment and engagement practices
• Respectful working environments
• Inclusive participation in projects and teams
• Prevention of harassment and discrimination
• Responsible representation in communications and creative work

Hazards are assessed before work begins, controls are assigned, and competent people and equipment are made available. An activity is stopped when a serious and immediate danger cannot be controlled.

Our approach includes:

• Risk assessment before routine and non-routine work
• Controls chosen from elimination down to protective equipment
• Safety checks before events and shoots
• Competent operators for rigging, power and specialist equipment
• Emergency and first aid arrangements
• Reporting of hazards, incidents and near misses
• The right to stop unsafe work without penalty

The policy is informed by ISO 45001 and does not claim ISO 45001 certification. Site and task risk assessments are maintained separately.

Our approach focuses on practical measures that can be applied across digital work, production, publications, travel, events and procurement.

These may include:

• Reducing unnecessary material use
• Selecting efficient digital and production methods
• Considering local suppliers and implementation partners
• Limiting avoidable travel and waste
• Using resources responsibly
• Encouraging durable outputs rather than disposable production

The measures applied depend on the nature, location and requirements of each assignment.

Spontan works to prevent avoidable pollution and waste, use resources efficiently and improve the environmental performance of its own activities and of the work it controls for clients.

It covers:

• Environmental aspects and legal obligations
• Offices, energy and water
• Devices, electronic waste and digital delivery
• Print, packaging and waste
• Events, productions, travel and sourcing
• Objectives, data and credible environmental claims

The approach is informed by ISO 14001. It is not a claim of measured emissions reductions or environmental certification.

Our approach is based on:

• Clear and legitimate purposes
• Collection of only necessary information
• Appropriate access controls
• Defined retention practices
• Secure handling and transfer
• Respect for applicable data rights
• Responsible management of suppliers and systems

The public overview explains our general approach. Project specific arrangements may be documented separately where processing requirements are more complex.

Our security approach considers:

• Access management
• System and account protection
• Secure storage and transfer
• Backup and recovery
• Supplier and technology risk
• Incident identification and response
• Personnel responsibilities
• Confidentiality requirements

Only high level controls are described publicly. Technical architecture, security configurations, vulnerability information, incident procedures and access structures remain confidential.

Our responsible AI principles include:

• Human oversight
• Clear accountability
• Appropriate and authorized data use
• Transparency where AI affects outputs or decisions
• Review of risks and limitations
• Proportionate controls based on the use case
• Security and privacy considerations
• Ongoing monitoring and improvement

AI may support analysis, automation, content workflows, matching systems and digital products, but responsibility for professional decisions remains with people.

Our approach considers:

• Semantic and structured content
• Keyboard accessibility
• Readable typography and contrast
• Alternative text for meaningful images
• Clear navigation and focus states
• Accessible documents where required
• Testing across devices and assistive contexts

Accessibility is treated as an ongoing responsibility rather than a one time technical step.