Principles of integrity, compliance, and accountability in all our activities.
This document applies to all employees, contractors, consultants, partners, and third parties acting on behalf of the company (“Personnel”).
1. Purpose & Scope
This Code sets expected standards of conduct and serves as a reference for ethical decision-making in every work situation.
2. Integrity & Honesty
- Act with honesty, fairness, and professionalism in all interactions.
- Prohibit fraud, data falsification, or misleading statements.
- Avoid conflicts of interest and prioritize the company’s and customers’ interests.
3. Confidentiality & Data Protection
- Safeguard company and customer confidential information.
- Comply with applicable data protection laws (e.g., privacy principles, data minimization, security).
- Use data only for legitimate work purposes and within authorization.
4. Compliance with Laws & Regulations
Personnel must comply with all applicable laws and regulations, including labor, H&S, taxation, consumer protection, competition, and anti-money laundering.
5. Anti-Bribery & Anti-Corruption
- Prohibit giving/offering/requesting bribes, illicit gratuities, or kickbacks.
- Gifts & hospitality must be modest, transparent, and not influence objectivity.
- Record and report all gifts/hospitality per policy.
6. Conflicts of Interest
Disclose any potential conflict to management/Ethics Committee. Avoid decisions that may improperly benefit you or your family.
7. Fair & Competitive Business Practices
- Prohibit price-fixing, market allocation, or other anti-competitive practices.
- Engage competitors ethically and lawfully.
8. Workplace Conduct: Respect, Safety, Inclusion
- Zero tolerance for harassment, discrimination, or bullying.
- Maintain occupational health & safety and report incidents promptly.
- Support diversity, inclusion, and mutual respect.
9. Company Assets & Information Technology
- Use assets (physical and digital) responsibly for business purposes.
- Follow cybersecurity policies; protect credentials and devices.
- Avoid unlicensed software or license violations.
10. Communications & Social Media
- External communications must be accurate, clear, and authorized.
- On social media, make clear personal opinions are your own and not the company’s.
11. Sustainability & Environment
We strive to minimize environmental impact, comply with regulations, and promote eco-friendly practices across our operations.
12. Third-Party Relationships
- Select vendors/partners based on objective criteria and ethical compliance.
- Require third parties to meet equivalent ethical standards.
13. Reporting Violations & Non-Retaliation
Report suspected violations to your manager, HR, or the Ethics Committee. Reports can be made confidentially subject to applicable law.
Non-Retaliation: Retaliation against anyone who reports in good faith is strictly prohibited.
14. Enforcement, Sanctions, & Amendments
- Violations may result in disciplinary action up to termination and/or legal proceedings.
- The company may update this Code as needed and in line with applicable laws.
15. Acknowledgment & Commitment
By reviewing this Code, you acknowledge understanding and agree to comply, seeking clarification whenever needed.