Omdena AI: Safeguarding Policy and Procedures

1. Introduction

Omdena is committed to ensuring the safety, well-being, and protection of vulnerable groups and sensitive data in all our activities and partnerships. This Safeguarding Policy and Procedures document outlines our commitment to safeguarding and the procedures that must be followed when working with suppliers who have direct or indirect contact with vulnerable groups or access to non-public data related to these groups.

2. Scope

This policy applies to all Omdena employees, contractors, and suppliers who have direct or indirect contact with vulnerable groups or access to non-public data related to these groups.

3. Definitions

3.1. Vulnerable Groups: Vulnerable groups include but are not limited to children, the elderly, individuals with disabilities, and other marginalized populations.

3.2. Suppliers: Any external individual or organization providing goods or services to Omdena.

3.3. Safeguarding Checks: A comprehensive background check and verification process to assess the suitability of a supplier to work with vulnerable groups or access sensitive data.

4. Safeguarding Checks

4.1. Suppliers who will work directly or indirectly with vulnerable groups or have access to non-public data related to vulnerable groups must undergo appropriate safeguarding checks. These checks may include, but are not limited to:

• Criminal background checks
• Reference checks
• Verification of qualifications and certifications
• Disclosure of any prior safeguarding incidents
• Omdena reserves the right to require additional checks based on the specific nature of the supplier’s work and the level of risk associated with the project.

5. Reporting of Safeguarding Concerns

5.1. Any employee, contractor, or supplier who becomes aware of a safeguarding concern or incident must immediately report it to the designated Safeguarding Officer at Omdena.

5.2. Omdena will treat all safeguarding concerns seriously and confidentially, conducting investigations as necessary and taking appropriate action to mitigate risks and protect vulnerable groups.

6. Training and Awareness

6.1. All employees, contractors, and suppliers who may have contact with vulnerable groups or access sensitive data will receive training on safeguarding policies and procedures.

6.2. Omdena will periodically review and update the training to ensure that all individuals are aware of the latest safeguarding requirements and best practices.

7. Compliance and Consequences

Non-compliance with this Safeguarding Policy and Procedures may result in the termination of the supplier’s contract or other appropriate actions, as determined by Omdena.

8. Review and Revision

This policy will be reviewed periodically to ensure its effectiveness and relevance. Any necessary revisions will be made to align with evolving safeguarding standards and practices.

9. Contact Information

For questions or concerns regarding this Safeguarding Policy and Procedures, please contact the Omdena Safeguarding Officer at [email protected].

Omdena AI: Anti-Terrorism Policies and Procedures

1. Introduction

The purpose of these Anti-Terrorism Policies and Procedures is to ensure strict compliance with international laws and regulations related to the prevention of terrorism financing, including international sanctions, proscriptions, and restrictions. These policies and procedures apply to all employees, contractors, partners, and stakeholders of Omdena.

2. Definitions

2.1. Terrorism Financing: The provision of funds or assets, directly or indirectly, with the intention that they be used or knowing that they will be used, in whole or in part, for the purpose of supporting terrorist activities.

2.2. International Sanctions: Measures taken by governments or international organizations to restrict the financial activities of individuals, entities, or countries that are involved in or support terrorist activities.

3. Compliance with International Laws and Regulations

3.1. Omdena Inc. is committed to full compliance with all international laws and regulations related to the prevention of terrorism financing, including but not limited to United Nations Security Council sanctions, and national laws and regulations.

3.2. All employees and stakeholders must stay informed about the latest updates and changes in international sanctions and other relevant regulations.

4. Prohibited Transactions

4.1. Omdena Inc. prohibits any transactions, financial or otherwise, with individuals, entities, or countries that are subject to international sanctions or proscriptions.

4.2. All employees and stakeholders are responsible for conducting due diligence to ensure that they are not engaging in transactions with prohibited parties.

5. Due Diligence and Risk Assessment

5.1. Omdena Inc. will establish a risk-based approach to assess the potential risks associated with engaging with new partners, clients, or suppliers.

5.2. Enhanced due diligence measures will be applied to high-risk entities or transactions to mitigate potential risks.

6. Reporting and Escalation

6.1. Any employee or stakeholder who becomes aware of a potential violation of international sanctions or suspicions of terrorism financing must immediately report it to the designated compliance Officer.

6.2. The Compliance Officer will conduct an internal investigation and, if necessary, report the incident to relevant authorities.

7. Training and Awareness

Omdena Inc. will provide regular training to employees and stakeholders to raise awareness about international sanctions, terrorism financing, and the organization’s policies and procedures.

8. Consequences of Non-Compliance

Non-compliance with these Anti-Terrorism Policies and Procedures may result in disciplinary actions, including termination of employment, legal actions, and reputational damage to the organization.

9. Review and Revision

These policies and procedures will be reviewed and updated regularly to ensure their effectiveness and alignment with evolving international regulations.

10. Contact Information

For questions or concerns regarding these Anti-Terrorism Policies and Procedures, please contact the Compliance Officer at [email protected].

Omdena AI: Anti-Bribery and Corruption

1. Introduction

Omdena Inc. is committed to conducting its business with the highest standards of ethics, integrity, and transparency. This Anti-Bribery and Corruption Policy sets forth the principles and guidelines that all employees, contractors, partners, and stakeholders must adhere to in order to prevent bribery and corruption in any form within the organization’s operations.

2. Definitions

2.1. Bribery: The offering, giving, receiving, or soliciting of anything of value to influence the actions of an official or other person in charge of a public or legal duty.

2.2. Corruption: Any dishonest or fraudulent act that impairs the integrity or proper functioning of an organization or its interactions with external parties.

3. Compliance with Laws and Regulations

3.1. Omdena Inc. is committed to full compliance with all applicable anti-bribery and anti-corruption laws and regulations, both domestically and internationally.

3.2. All employees, contractors, and stakeholders must familiarise themselves with and abide by the laws and regulations related to anti-bribery and corruption that apply to their roles.

4. Prohibited Activities

4.1. Omdena Inc. strictly prohibits any form of bribery or corruption, whether it involves government officials, private sector partners, clients, or any other entity or individual.

4.2. Prohibited activities include but are not limited to:

• Offering, giving, receiving, or soliciting bribes or kickbacks.
• Making facilitation payments.
• Providing inappropriate gifts, hospitality, or entertainment with the intent to influence.

5. Due Diligence and Risk Assessment

5.1. Omdena Inc. will establish a risk-based approach to assess the potential risks of bribery and corruption in its business operations.

5.2. Enhanced due diligence measures will be applied to high-risk transactions, clients, or business relationships.

6. Reporting and Whistleblowing

6.1. Any employee or stakeholder who becomes aware of a potential violation of this policy must immediately report it through the organization’s whistleblowing mechanism or directly to senior management.

6.2. Omdena Inc. guarantees that individuals reporting in good faith will be protected from retaliation.

7. Training and Awareness

Omdena Inc. will provide regular training to employees, contractors, and stakeholders to raise awareness about bribery and corruption risks and the organization’s policies and procedures.

8. Consequences of Non-Compliance

Non-compliance with this Anti-Bribery and Corruption Policy may result in disciplinary actions, including termination of employment, legal actions, and reputational damage to the organization.

9. Review and Revision

This policy will be reviewed and updated regularly to ensure its effectiveness and alignment with evolving legal requirements and best practices.

10. Contact Information

For questions or concerns regarding this Anti-Bribery and Corruption Policy, please contact the Ethics and Compliance Officer at [email protected].

Omdena AI: Conflict of Interest Policy and Procedures

1. Introduction

Omdena Inc. is committed to maintaining the highest standards of integrity, ethics, and transparency in all its business activities.

This Conflict of Interest Policy and Procedures document outlines the principles, guidelines, and procedures that all employees, contractors, partners, and stakeholders must adhere to when dealing with actual or potential conflicts of interest within the organization.

2. Definitions

Conflict of Interest: A situation in which an individual’s personal, financial, or other interests may compromise their professional judgement, objectivity, or the best interests of Omdena Inc.

3. Disclosure of Conflicts

3.1. All employees, contractors, and stakeholders have a duty to promptly disclose any actual or potential conflicts of interest to the designated Conflict of Interest Officer.

3.2. Disclosure should include a full description of the conflict, including any relevant financial interests, relationships, or affiliations that may be affected.

4. Evaluation and Determination

4.1. The Conflict of Interest Officer will evaluate the disclosed conflicts and determine whether they represent an actual conflict that requires mitigation.

4.2. In cases where a conflict is determined to exist, the Conflict of Interest Officer will work with the affected individual to develop an appropriate plan to manage or mitigate the conflict.

5. Mitigation and Management

Methods for mitigating or managing conflicts of interest may include:

• Divestment or removal of the conflicting interest.
• Recusal from decision-making related to the conflict.
• Establishing safeguards to prevent undue influence or bias.
• Transparency and disclosure to relevant parties.

6. Reporting and Records

6.1. Records of all disclosures, evaluations, and actions taken to manage conflicts of interest will be maintained and periodically reviewed.

6.2. An annual report on conflicts of interest will be provided to the Board of Directors or relevant governing body.

7. Training and Awareness

Omdena Inc. will provide regular training and education on conflict of interest policies and procedures to employees, contractors, and stakeholders.

8. Consequences of Non-Compliance

Failure to disclose conflicts of interest or adhere to the procedures outlined in this policy may result in disciplinary actions, including termination of employment or contractual relationships.

9. Review and Revision

This policy and its procedures will be reviewed periodically to ensure their effectiveness and alignment with evolving ethical standards and best practices.

10. Contact Information

For questions or concerns regarding this Conflict of Interest Policy and Procedures, please contact the designated Conflict of Interest Officer at [email protected].

Omdena AI: Human Trafficking and Modern Slavery Policy

1. Introduction

Omdena is committed to upholding the highest ethical standards in all aspects of its operations and to preventing any form of human trafficking and modern slavery. This policy outlines Omdena’s commitment to eliminating human trafficking and modern slavery from its operations and supply chains.

2. Definitions

2.1. Human Trafficking: The recruitment, transportation, transfer, harbouring, or receipt of persons through force, coercion, or deception for the purpose of exploitation, including forced labor or commercial sexual exploitation.

2.2. Modern Slavery: Encompasses various forms of slavery, servitude, forced labor, and human trafficking.

3. Commitment

3.1. Omdena is committed to preventing and eradicating human trafficking and modern slavery in its operations and supply chains.

3.2. Omdena will not tolerate any form of human trafficking or modern slavery and will take all necessary steps to ensure that its employees, contractors, and suppliers adhere to this commitment.

4. Compliance with Laws

4.1. Omdena will comply with all applicable international, federal, and local laws and regulations related to human trafficking and modern slavery.

4.2. All employees, contractors, and suppliers are expected to comply with these laws as well.

5. Risk Assessment and Due Diligence

5.1. Omdena will conduct risk assessments to identify areas within its operations and supply chains that may be susceptible to human trafficking and modern slavery.

5.2. Enhanced due diligence will be performed on suppliers and contractors, especially in high-risk areas.

6. Supplier and Contractor Responsibility

Omdena expects its suppliers and contractors to share its commitment to preventing human trafficking and modern slavery. Suppliers and contractors must:

• Not engage in any form of human trafficking or modern slavery.
• Implement their own policies and procedures to address these issues.
• Cooperate with Omdena’s efforts to assess and mitigate risks in their supply chains.

7. Reporting

Any employee, contractor, or stakeholder who becomes aware of a potential violation of this policy must report it immediately to their supervisor or the designated compliance officer.

8. Training and Awareness

Omdena will provide training and awareness programs to educate its employees, contractors, and stakeholders about the risks of human trafficking and modern slavery and the steps they can take to prevent it.

9. Consequences of Non-Compliance

Non-compliance with this Human Trafficking and Modern Slavery Policy may result in disciplinary actions, including termination of employment or contractual relationships.

10. Review and Revision

This policy will be reviewed periodically to ensure its effectiveness and alignment with evolving ethical standards and best practices.

11. Contact Information

For questions or concerns regarding this Human Trafficking and Modern Slavery Policy, please contact the designated Compliance Officer at [email protected].

Omdena AI: Data Protection Policy

1. Introduction

Omdena Inc. is committed to safeguarding the privacy and data protection rights of our clients, partners, and all individuals whose data we process. This Data Protection Policy outlines the principles and procedures we follow to ensure the responsible and ethical handling of data in our AI development processes, including web scraping activities.

2. Scope

This policy applies to all employees, contractors, partners, and stakeholders involved in data collection, processing, and analysis at Omdena Inc.

3. Data Collection and Use

3.1. Omdena Inc. collects and uses data solely for the purpose of developing AI solutions in collaboration with clients and partners.

3.2. Data collected is limited to what is necessary for the project’s objectives, and efforts will be made to anonymize or pseudonymize personal data whenever possible.

3.2. All data will be processed in accordance with applicable data protection laws and regulations, including but not limited to the General Data Protection Regulation (GDPR).

4. Ethical Web Scraping

4.1. Omdena Inc. acknowledges that web scraping must be conducted ethically and in compliance with applicable laws and website terms of service.

4.2. Prior to any web scraping activities, we will assess the legality and ethical implications of the data collection process.

4.3. We will respect website robots.txt files, adhere to terms of use, and take measures to prevent overloading servers during web scraping.

5. Data Security

Omdena Inc. will implement appropriate technical and organizational measures to ensure the security and confidentiality of data, including encryption, access controls, and regular security assessments.

6. Data Retention

Data will be retained only for the duration necessary to achieve the project’s objectives. Once the data is no longer required, it will be securely deleted or anonymized.

7. Data Sharing

7.1. Data will only be shared with clients and partners involved in the specific AI project, and only to the extent necessary for project purposes.

7.2. Data sharing agreements will be established with clients and partners to ensure data is used only for the agreed-upon purposes.

8. Individual Rights

8.1. Individuals whose data is processed have the right to access, rectify, erase, or restrict the processing of their data.

8.2. Omdena Inc. will assist individuals in exercising their rights and respond promptly to data subject requests.

9. Reporting and Breach Response

Any data breaches or incidents involving unauthorized access to or disclosure of data will be reported to the relevant authorities and affected individuals, as required by law.

10. Training and Awareness

All employees and stakeholders involved in data processing will receive training on data protection principles and best practices.

11. Compliance and Review

This policy will be reviewed periodically to ensure its effectiveness and alignment with evolving data protection laws and ethical standards.

12. Contact Information

For questions or concerns regarding this Data Protection Policy, please contact the designated Data Protection Officer at [email protected].

Omdena AI: Environmental Management

1. Introduction

At Omdena, we recognize that our operations have an impact on the environment. As a platform empowering AI education and impact projects, we are committed to minimizing our environmental footprint, conserving natural resources, and contributing to a sustainable future. This Environmental Policy and Statement of Principles outlines our commitment to environmental stewardship.

2. Environmental Principles

2.1. Sustainability: We are committed to conducting our operations in a sustainable manner, aiming to balance the needs of the present without compromising the ability of future generations to meet their own needs.

2.2. Resource Efficiency: We will strive to minimize waste, reduce resource consumption, and optimize resource utilization in all aspects of our operations.

2.3. Renewable Energy: We will explore opportunities to transition to renewable energy sources to reduce our carbon footprint.

2.4. Environmental Education: We will promote environmental awareness and education among our employees, contractors, partners, and stakeholders.

2.5. Compliance: We will comply with all relevant environmental laws and regulations in the jurisdictions in which we operate.

3. Key Environmental Focus Areas

3.1. Reducing Carbon Emissions: We will work to reduce our greenhouse gas emissions through energy-efficient practices and the use of renewable energy sources.

3.2. Waste Reduction: We will minimize waste generation and promote recycling and responsible waste disposal.

3.3. Sustainable Procurement: We will consider environmental impact factors when procuring goods and services and give preference to environmentally friendly products and suppliers.

3.4. Biodiversity Conservation: We will be mindful of the impact of our activities on local ecosystems and biodiversity and take steps to minimize negative effects.

3.5. Environmental Reporting: We will regularly assess and report our environmental performance to track progress toward our sustainability goals.

4. Partnerships and Collaboration

We will collaborate with like-minded organizations, partners, and stakeholders to promote sustainability and share best practices for reducing our collective environmental impact.

5. Continuous Improvement

We will regularly review and update our environmental policies and practices to ensure they remain effective and aligned with evolving environmental challenges and opportunities.

6. Employee Engagement

We encourage our employees and contractors to actively participate in our environmental initiatives and contribute ideas for reducing our environmental impact.

7. Communication and Transparency

We will communicate our environmental initiatives and performance transparently with our employees, partners, clients, and the public.

8. Accountability

We hold ourselves accountable for the environmental impact of our operations and will take prompt corrective actions in the event of any environmental incidents or non-compliance.

9. Contact Information

For questions or concerns regarding this Environmental Policy and Statement of Principles, please contact the designated Environmental Officer at [email protected].