Code of Conduct

This Code sets out how everyone working at or on behalf of EFFICIENT DIGITAL MARKETING AGENCY OÜ, trading as Efficient Digital Marketing Agency, is expected to behave. It applies to employees, contractors and subcontractors, on client work and internally. It exists because our entire proposition is that our reporting can be trusted, and that is worth nothing without conduct rules we will actually enforce.

1. Honest measurement above all

We report what happened, not what is comfortable.

• Baselines are recorded before work begins and are never quietly rebased to make a period look better.
• We do not select the attribution window, date range or metric that flatters us after the fact.
• Where a platform’s reported conversions differ from a client’s own revenue data, we report the client’s data and explain the gap.
• Impressions, reach and follower counts are diagnostic. They are never presented as outcomes.
• A bad month is reported as a bad month, in the month it happened.

2. We recommend less when less is right

Anyone here can recommend cutting a channel, reducing a retainer or ending an engagement, and nobody’s standing or compensation may be affected for doing so. We do not bill on a percentage of media spend, precisely so that this rule can be real rather than aspirational.

If we cannot improve on what a prospective client already has, we say so and decline the work.

3. Conflicts of interest

We disclose conflicts before they become a problem. We will not take on a client in direct competition with an existing client in the same market without telling both and obtaining agreement. Personal financial interests in a vendor, platform or tool we might recommend must be declared. We accept no commissions, kickbacks or rebates from platforms or suppliers in exchange for directing client budget.

4. Client data and confidentiality

Client data is accessed only to do the work, only by people who need it, and never used to benefit another client. Accounts are created in the client’s ownership. Access is revoked promptly when someone leaves a project or the company. Nothing about a client — including that they are a client — is shared publicly without written permission.

5. Advertising standards

We will not write, approve or run marketing that is misleading, that makes claims a client cannot substantiate, that exploits fear or urgency dishonestly, or that targets people in a way we would object to if we were on the receiving end. We follow the advertising codes and platform policies that apply in each market, and we will refuse a brief rather than breach them.

6. Respect at work

We treat colleagues, clients, suppliers and each other’s time with respect. Harassment, discrimination, bullying and retaliation are grounds for dismissal. Disagreement about the work is welcome and expected; personal attacks are not. We do not tolerate abusive behaviour toward our team from anyone, including clients, and we will end an engagement over it.

7. Subcontractors

Where we use specialists or suppliers, they are bound by this Code and by the same confidentiality obligations. We remain accountable to the client for their work.

8. Anti-bribery, sanctions and lawful conduct

We neither offer nor accept bribes or improper inducements. We comply with applicable anti-bribery, anti-money-laundering, sanctions and export control law, and we carry out reasonable checks before taking on a client.

9. Raising a concern

If you believe this Code has been breached — whether you work here, work with us, or are a client — write to our email, marked for the attention of the management board. Concerns are looked into promptly and, where possible, confidentially. Nobody is penalised for raising a concern in good faith, and retaliation for doing so is itself a breach of this Code.

10. Consequences

Breaches are handled proportionately, up to and including termination of employment or contract, ending a client engagement, and referral to the relevant authority where the law requires it.

11. Review

This Code is reviewed at least annually and whenever an incident shows it is unclear or insufficient. The current version is always the one published here.