XGATE – CRM & Loyalty, Digital Marketing Agency
Last Updated: 2025-05-31

Introduction & Our Commitment

At XGATE, our name is synonymous with trust, innovation, and results. We don’t just manage data and run campaigns; we build relationships. This Code of Conduct is the foundation of those relationships. It outlines the ethical principles and professional standards that guide every member of our team in all our interactions—with our clients, partners, each other, and the public.

This code is more than a set of rules; it is a reflection of our core values and our commitment to conducting business with the highest degree of integrity. Adherence to this code is mandatory for all employees, contractors, and leadership.

Our Core Ethical Principles

Our actions are guided by four unwavering principles:

• Integrity & Honesty: We are truthful, transparent, and ethical in all our dealings. We do what we say we will do.
• Excellence & Innovation: We are committed to delivering exceptional quality, continuously improving our skills, and providing innovative solutions that drive our clients’ success.
• Respect & Inclusion: We value the diversity of our team, our clients, and their customers. We foster an environment of mutual respect, dignity, and equal opportunity where everyone feels valued and heard.
• Accountability & Responsibility: We take ownership of our actions, decisions, and results. We are responsible stewards of the data and resources entrusted to us.

Conduct in Client Relationships

Our clients are our partners. Their success is our success.

• Transparency: We will be clear and upfront about our capabilities, pricing, project timelines, and the expected outcomes of our strategies.
• Confidentiality: We safeguard all client information, strategies, and data with the utmost care and in strict accordance with our agreements and the law. Client data is never used for any purpose other than what is explicitly authorized.
• Honest Advice: We will provide recommendations based on what is best for the client’s business objectives, not what is most profitable for XGATE.
• Performance & Reporting: We will report campaign and program performance accurately and honestly, celebrating successes and addressing challenges with proactive solutions.

Data Privacy & Security

As a custodian of significant customer data, we have a profound responsibility. Our commitment to information security is demonstrated by our ISO27001:2022 certification for Information Security Management Systems (ISMS).

• Global Compliance: We strictly adhere to all applicable data protection and privacy laws globally, including but not limited to GDPR, Hong Kong’s Personal Data (Privacy) Ordinance (PDPO), Singapore’s Personal Data Protection Act (PDPA), and China’s Personal Information Protection Law (PIPL).
• Robust Security: We implement robust technical and organizational measures to protect data against unauthorized access, disclosure, alteration, or destruction. All personally identifiable information (PII) stored on XGATE servers is encrypted both at rest and in motion.
• Ethical Use: We champion ethical marketing practices. We never engage in spamming, deceptive advertising, or the misuse of personal data. We are committed to transparency in how data is collected and used within the programs we manage.

Intellectual Property (IP) Respect

• Client IP: All client materials, data, customer lists, and strategies are and remain the exclusive property of the client.
• XGATE IP: Our methodologies, software, frameworks, and pre-existing knowledge remain the property of XGATE. We grant clients a license to use the deliverables we create for them as outlined in our agreements.
• Third-Party IP: We respect the copyrights, trademarks, patents, and trade secrets of others. We only use licensed software, assets, and content.

A Respectful and Inclusive Workplace

XGATE’s strength is its people. We are committed to:

• Zero Tolerance for Harassment: Providing a work environment free from harassment, discrimination, bullying, or intimidation based on race, color, religion, gender, sexual orientation, gender identity, national origin, age, disability, or any other protected status.
• Open Communication: Encouraging open dialogue, constructive feedback, and the sharing of ideas without fear of retaliation.
• Health & Safety: Maintaining a safe and healthy workplace, whether in-office or remote.

Conflicts of Interest

We expect team members to avoid situations where their personal interests could conflict, or appear to conflict, with the interests of XGATE or our clients. All potential conflicts must be disclosed to management promptly.

Giving and Receiving Gifts

Business courtesies must never influence, or appear to influence, business decisions. Gifts and entertainment should be modest, infrequent, and consistent with customary business practices. Never offer or accept gifts in violation of law or a client’s own policies.

Social Media & Public Representation

• Be Authentic and Respectful: When representing XGATE online, be professional, respectful, and add value to the conversation.

• Be Transparent: Clearly identify yourself and your affiliation with XGATE when discussing industry-related topics.

• Respect Confidentiality: Never disclose confidential information about our clients, our work, or internal company matters on public platforms.

Reporting Concerns & Accountability

Upholding this Code is everyone’s responsibility.

• Speak Up: If you believe a violation of this Code has occurred, or if you have an ethical concern, you are encouraged to report it immediately to your manager, a company director, or via our anonymous reporting channel (if applicable).

• No Retaliation: XGATE prohibits any form of retaliation against individuals who report concerns in good faith.

• Investigation: All reports will be investigated promptly, fairly, and confidentially.

• Consequences: Violations of this Code will result in appropriate disciplinary action, up to and including termination of employment, and may also lead to legal action.

Conclusion

This Code of Conduct embodies the values we hold dear at XGATE. By adhering to these principles, we not only protect our reputation but also strengthen the trust our clients place in us every day. Together, we ensure that XGATE remains a leader in ethical, effective, and innovative marketing solutions.

For any questions regarding this Code, please contact: codeofconduct@xgate.com