Global Code of Ethics
A MESSAGE FROM OUR FOUNDER
At Paragon, we have never treated integrity as a competitive differentiator or a marketing position. It is, and has always been, the foundation on which everything we do is built.
We believe that how you conduct yourself in business — the standards you hold, the relationships you keep, and the decisions you make when no one is watching — defines what your organization actually stands for, regardless of what it says about itself. For us, that means being truthful, being accountable, and treating every person we encounter with dignity and respect. These are not ideals we aspire to. They are standards we are committed to, and we hold ourselves and those who work with and for us to them without exception.
This Code of Ethics is not a legal document. It is a statement of who we are, what we believe, and what clients, associates, advisors, and suppliers can expect from Paragon — and what we expect in return. It reflects decades of professional practice grounded in the conviction that trust, once earned, must be continuously deserved.
We do not work with everyone. We work with the right people.
— Sarah Mae Amde, MBA. CEO and Founder, Paragon Digital Consulting, Inc.
1. OUR ETHICAL FOUNDATION
Paragon's ethical framework is grounded in four principles that are non-negotiable across every engagement, every relationship, and every decision we make:
Truthfulness. We say what we mean and mean what we say. We do not overstate our capabilities, fabricate our results, or represent ourselves in ways that are designed to mislead. We expect the same of everyone who operates within our ecosystem. A single act of deliberate misrepresentation — regardless of its commercial convenience — is sufficient grounds to end a professional relationship permanently.
Accountability. We stand behind our work. When we make recommendations, we make them because we believe they are right for the client's situation — not because they are fashionable, financially advantageous to us, or easy to sell. We do not recommend untested approaches simply because they are novel, and we do not abandon clients when implementation becomes difficult. Accountability means our work must be able to stand up to scrutiny — not just at the moment of delivery, but over time.
Dignity. Every person we encounter — client, candidate, advisor, supplier, or member of the public — is entitled to be treated with respect. We do not tolerate conduct that demeans, marginalizes, or disrespects any individual, regardless of their role, their seniority, or their relationship to Paragon. Dignity is not situational.
Stewardship. We recognize that the trust placed in us by clients, candidates, and the broader professional community is not ours to take for granted. We are stewards of that trust, and we treat it accordingly — by being honest when honesty is inconvenient, by protecting confidences, and by making decisions that serve the long-term interests of those we work with rather than our own short-term benefit.
2. STANDARDS FOR ASSOCIATES AND ADVISORS
Paragon's associates and advisors are extensions of the firm. When you operate within Paragon's ecosystem — whether as a bench associate, an independent advisor, a subcontractor, or a project contributor — you represent Paragon to the clients and candidates you serve. The standards in this section apply to all such individuals without exception.
2.1 Honest Representation of Credentials and Experience
You must represent your qualifications, experience, certifications, and professional history accurately and completely at all times. Misrepresentation of credentials — including overstating experience, claiming certifications not held, or fabricating prior outcomes — is grounds for immediate and permanent disengagement from Paragon's ecosystem and, where applicable, referral to the relevant professional regulatory body.
2.2 Confidentiality
You are entrusted with confidential information belonging to Paragon, its clients, and its candidates in the course of your work. This information must be protected with the same care you would apply to your own most sensitive professional assets. Confidentiality obligations survive the conclusion of any engagement and do not expire. You may not use confidential information for personal gain, for the benefit of a competitor, or for any purpose beyond the specific engagement for which it was shared.
2.3 Conflict of Interest
You are required to disclose any actual or potential conflict of interest — including existing relationships with clients, candidates, or competitors — before accepting any engagement through Paragon. Undisclosed conflicts of interest that come to light during or after an engagement are treated as a breach of this Code. Where a conflict is disclosed, Paragon will determine in its sole discretion whether the engagement can proceed and under what conditions.
2.4 Professional Conduct
You are expected to conduct yourself with professionalism, respect, and integrity in all interactions — with clients, candidates, Paragon personnel, and any other party encountered in the course of your work. Conduct that is dishonest, disrespectful, discriminatory, or otherwise inconsistent with Paragon's values will result in immediate disengagement and may be reported to relevant professional or regulatory bodies where applicable.
2.5 Compliance With Applicable Law
You are responsible for ensuring that your conduct complies with all applicable laws and regulations in every jurisdiction in which you operate on behalf of or in connection with Paragon. This includes but is not limited to employment law, data protection law, anti-bribery and anti-corruption law, and any sector-specific regulatory requirements relevant to your area of expertise.
2.6 Anti-Bribery and Anti-Corruption
Paragon maintains a strict zero-tolerance position on bribery and corruption in all forms. You must not offer, pay, request, or receive any bribe, kickback, facilitation payment, or improper advantage in connection with any Paragon engagement, regardless of local custom or commercial pressure. This standard applies to dealings with public officials, private sector counterparts, and any other party.
Paragon operates as a federally prequalified vendor and holds the requisite security clearances associated with that status. All associates and advisors are expected to conduct themselves in a manner consistent with those obligations at all times, including full compliance with Canada's Corruption of Foreign Public Officials Act (CFPOA), the United States Foreign Corrupt Practices Act (FCPA), and the United Kingdom Bribery Act, as applicable to the jurisdiction and nature of the engagement.
3. STANDARDS FOR SUPPLIERS AND VENDORS
Paragon selects its suppliers and vendors carefully. We expect our suppliers to share our commitment to integrity and to represent themselves, their organizations, and their products or services honestly and accurately at all times.
3.1 Accurate Representation
Suppliers must represent their organization, products, services, user base, market position, certifications, awards, and professional recognition truthfully and with documentary support where relevant. Paragon will not knowingly maintain a relationship with any supplier who misrepresents the nature, scale, or credibility of what they offer — whether that misrepresentation occurs before or after a relationship is established.
Specifically, and without limitation, the following constitute material misrepresentation under this Code: fabricating or significantly overstating the size of a user base, client roster, or operational footprint; claiming industry recognition, awards, or certifications that have not been legitimately conferred; representing a product or service as proven or established when it is in development, untested, or has not been deployed at meaningful scale; and making claims about organizational history, tenure, or geographic presence that are not supported by fact.
Discovery of any such misrepresentation — regardless of when it occurs or the nature of the prior relationship between the parties — will result in immediate termination of the supplier relationship. Paragon reserves the right to pursue any remedies available under applicable law where misrepresentation has caused harm.
3.2 Quality and Delivery Standards
Suppliers are expected to deliver what they have committed to deliver, at the standard they have represented, and within the timeframes agreed. Where a supplier anticipates difficulty in meeting a commitment, they are expected to communicate proactively and honestly rather than obscure the issue. Honesty about a problem is always preferable to the discovery of a concealed one.
3.3 Confidentiality
Suppliers who are exposed to confidential information belonging to Paragon or its clients in the course of providing their services are required to protect that information with the same standard of care that Paragon applies to its own confidential information. Supplier confidentiality obligations are governed by the applicable supplier agreement and survive the conclusion of the commercial relationship.
3.4 Ethical Conduct and Values Alignment
Paragon reserves the right to terminate any supplier relationship where the supplier's conduct — whether in their dealings with Paragon or in their broader operations — is found to be materially inconsistent with the values set out in this Code. This includes but is not limited to conduct involving dishonesty, discrimination, harassment, bribery, or any other behavior that Paragon determines, in its sole discretion, to be incompatible with the standards it holds itself to.
Commercial convenience, prior relationship history, or contractual complexity will not prevent Paragon from acting on this right where the circumstances warrant it.
3.5 Anti-Bribery and Anti-Corruption
Suppliers must comply fully with all applicable anti-bribery and anti-corruption legislation, including Canada's Corruption of Foreign Public Officials Act (CFPOA), the United States Foreign Corrupt Practices Act (FCPA), and the United Kingdom Bribery Act, as relevant to their jurisdiction and the nature of their relationship with Paragon. No supplier may offer, provide, or facilitate any payment, gift, or benefit to any Paragon personnel, client, or associated party that could constitute a bribe or improper inducement of any kind.
4. ANTI-BRIBERY AND ANTI-CORRUPTION — GENERAL COMMITMENT
Paragon Digital Consulting, Inc. maintains an unequivocal commitment to conducting all of its business activities free from bribery, corruption, and improper influence. This commitment applies to every aspect of our operations — internal and external, domestic and international — and to every individual who acts on behalf of Paragon in any capacity.
We do not offer, pay, authorize, or accept bribes or facilitation payments of any kind, to or from any party, under any circumstances. We do not use third parties to circumvent this commitment. We recognize that bribery and corruption undermine trust, distort markets, and cause harm to the organizations and communities they affect — and we refuse to participate in them regardless of competitive pressure, commercial opportunity, or geographic context.
Paragon's anti-bribery and anti-corruption commitment is operationalized through contractual obligations with all associates, advisors, and suppliers, and through the internal governance standards applicable to Paragon personnel. It is consistent with and supported by Paragon's status as a federally prequalified vendor operating under the applicable security clearance framework.
5. REPORTING ETHICS CONCERNS
Paragon takes all ethics concerns seriously. If you are an associate, advisor, supplier, candidate, or client who has witnessed or experienced conduct that you believe is inconsistent with this Code — including but not limited to misrepresentation, bribery, conflicts of interest, discriminatory conduct, or any other breach of the standards set out here — you are encouraged to raise your concern promptly.
Ethics concerns may be directed to:
Legal and Compliance Paragon Digital Consulting, Inc. Email: legal@paragondigitalconsulting.com
Matters of significant concern may be escalated directly to the CEO. All concerns raised in good faith will be treated with seriousness, handled with discretion, and investigated appropriately. Paragon does not tolerate retaliation of any kind against any person who raises an ethics concern in good faith.
6. SCOPE, APPLICATION, AND CLIENT ENGAGEMENTS
This Code of Ethics applies to Paragon Digital Consulting, Inc., all of its associates and advisors operating within the Paragon ecosystem, and all suppliers and vendors engaged by Paragon in the course of its operations.
Standards governing the conduct of client engagements — including the mutual obligations, representations, and expectations that apply within a formal professional relationship — are addressed within individual Master Service Agreements and engagement-specific documentation. Nothing in this Code of Ethics is intended to supplement, replace, or conflict with those agreements.
Paragon reserves the right to update this Code of Ethics at any time to reflect changes in our operations, applicable law, or the standards of the professional communities we serve. The date of the most recent revision is noted at the top of this document.
7. CONTACT US
For questions about this Code of Ethics or to raise a concern, please contact:
Paragon Digital Consulting, Inc. Email: legal@paragondigitalconsulting.com
This Global Code of Ethics was last reviewed and updated in May 2026 and supersedes all prior versions. It will be reviewed no less than annually thereafter.
Last Reviewed: 05 May 2026