Our Values

We encourage our Partners to establish a similar Code of Conduct and we will support actions by our Partners to increase awareness and compliance within all areas of this Policy.

Compliance with laws and tax Partners shall comply with applicable laws and regulations as well as avoid criminal tax evasion.

Corruption Corruption is when bribes of any kind are offered, expected or taken, regardless of form, method or purpose. AIM-X does not accept corruption or any other kind of unauthorized influence. Whereas we acknowledge local customs may differ, our Partners must ensure that they have appropriate Anti Corruption policies and procedures in place to ensure that relevant laws are complied with.

Anti-Money Laundering (AML) Money laundering is any arrangement where the proceeds of crime are disguised or made to appear legitimate. AIM-X must never, and we expect the same from our Partners, be part of, or facilitate money laundering, terrorism financing and/or other financial crimes and shall perform reasonable due diligence to detect potential money laundering and terrorist financing in the value chain

Trade Compliance Our Partners must ensure to comply with applicable export and trade sanctions laws, regulations rules and licenses including without limit those of the U.S., the UN and the EU (“Export Laws”). In no event shall a transaction be structured, or documentation be altered to circumvent any Export Laws. In any transaction involving Clear Health Pass, we represent and warrant that:

      • We shall not engage, directly or indirectly, and shall ensure that none of our affiliates engage in, dealings with any person or entity in violation of Export Laws or in violation of any prohibited end-use pursuant to Export Laws. In case of purchases, this means that we are the true purchaser of the goods from Clear Health Pass, and the goods shall not, in violation of Export Laws, be sold, re-transferred or otherwise made available to any party or parties listed on any applicable list of prohibited parties or subject to sanctions imposed by the UN, EU, U.S. or other countries.
      • We shall not do anything which would cause Clear Health Pass to be in breach of Export Laws.

Our Partners must adhere to applicable Export Laws. We might ask for a reasonable amount of information to be provided to us, for our KYC (know-your-customer) requirements.

Human Rights and Labor Human rights are basic freedoms to which all people are entitled. We are committed to respect and promote international human rights in the entire value chain:

      • Safe and secure workplace – Clear Health Pass requires Partners to be dedicated to providing a safe and healthy work environment and work to minimize risks for accidents and other exposure to health risks.
      • Forced labor and child labor – Clear Health Pass does not accept any form of child labor or all forms of forced labor (including prison labor, military labor, modern forms of slavery or any form of human trafficking).
      • Respect – We encourage our Partners to always treat people with respect and not to allow any form of discrimination of employees. We believe in equal opportunity and fair remuneration.

Fair Competition Our Partners shall comply with regulations on fair competition (also called “anti-trust” laws) and will not enter into agreements with competitors that restricts competition, including but not limited to price fixing, allocation of customers, bid rigging, etc.

Environment Clear Health Pass assigns the highest priority to comply with environmental regulation, and to preserve the environment. We expect our Partners to adopt similar standards, at the minimum according to legislation.