CodeTwo
Business Ethics

Anti-corruption Code

Published: 2019-10-07

Fundamental principles of the Anti-corruption Code

CodeTwo, in its internal and external business relations, operates in a fair and honest manner and complies with applicable laws. We maintain high ethical standards in all our activities, observe the rights of our Employees and follow the principles of integrity in connection with our Customers, Contractors, Resellers and other business partners (collectively referred to as "Business Partners").

We require that all our Business Partners:

1. Comply with the general principles of ethics as well as the law, especially with the anti-corruption law. Under no circumstances is it acceptable to violate the law or act in a manner contrary to CodeTwo’s values or this Code.
2. Act with integrity when performing their duties towards CodeTwo and other Business Partners.
3. Adhere to the principle of selflessness, meaning that they must not pursue private interests and expect benefits from them for themselves, their families or friends.

The responsibility for achieving these goals lies with all Business Partners.

CodeTwo’s anti-corruption principles are designed to promote and realize such fundamental values as:

1. integrity in relations with other Employees and Business Partners,
2. building trust in mutual relations and maintaining that trust, especially in relations with Business Partners,
3. transparency in all activities,
4. fairness and decent treatment.

CodeTwo incorporates the anti-corruption policy set out in this Code in all aspects of its activities and undertakes all possible actions to prevent corruption.

What we never do

In accordance with this Code, the following activities are prohibited in any form and manner, regardless of the relationships they occur in:

1. offering, promising or giving financial or personal benefits of any value and in any form,
2. accepting or demanding the financial or personal benefits mentioned above,
3. intermediating in the giving or receiving of the benefits mentioned above,

in exchange for taking specific actions or in connection with the performed tasks and duties, especially if the performance of such tasks and duties would involve abuse or failure to fulfill them.

In addition, it is prohibited to:

1. legalize or attempt to legalize income derived from corrupt activities, e.g. creating funds for marketing activities, which are in fact intended for corrupt activities or creating fictitious accounting documentation (e.g. issuing VAT invoices) aimed at legalizing provided financial benefits,
2. carry out any form of extortion or solicitation that leads to committing the acts mentioned above, e.g. a Business Partner’s employee encourages to corrupt an end user.

All the above-mentioned activities constitute a violation of the anti-corruption provisions, including the provisions of the Polish Penal Code.

In all cases of corrupt behavior, persons giving financial or personal benefits as well as those receiving them are treated equally.

How we identify the risks and respond to corruption

Prevention

The C-level at CodeTwo, as well as CodeTwo’s team and department managers, are obliged to identify the likelihood of the corrupt behavior risks to occur in the tasks they supervise. To this end, they pay attention and react to any situations that may give rise to corrupt behavior by informing the subordinate Employees about the lack of acceptance for such behavior in a clear and unambiguous manner, as well as by indicating the appropriate course of action. Responding to corrupt behavior is the responsibility of every Employee at CodeTwo.

When commencing work with CodeTwo, every Employee or Business Partner is obliged to familiarize themselves and comply with the anti-corruption principles in force in CodeTwo. The Employees need to undergo refresher training regularly, at least once every two years. Any training needs in terms of anti-corruption measures should be reported to CodeTwo’s C-level executives.

Whistleblowing

Every Employee is obliged to immediately inform their immediate supervisor about any potential situation that may give rise to corrupt behavior. In accordance with CodeTwo’s policy on reporting non-compliances and other cases of violations, every Employee is also able to disclose any information that, to their knowledge, may indicate corrupt activities. The disclosure can be made in any way that preserves anonymity.

Any person who reports suspected abuse or refuses to participate in a corruption process shall not be adversely affected by their decision. Such a person, even if their personal data is known or determinable, shall not bear any consequences in this respect.

We also require Business Partners to inform us immediately of any possible identified corruption risks, including the potential ones, that may affect our partnership under an ongoing or negotiated business relationship.

How we prevent corruption in external relations

In all external relations, both with Business Partners as well as other external entities such as public administration bodies, industry bodies, business associations and all other entities, we are guided by the principles of integrity and transparency. We make every effort to ensure that our actions and communications are clear and leave no room for ambiguity in the interpretation of our words and actions.

Industry events and sponsorship

When we organize or attend industry events such as job fairs, conferences, meetings of industry associations, etc., we take into consideration the substantive matters that are the most important to us during such events, i.e. the exchange of knowledge and experience. However, due to the fact that such events give us a chance to present CodeTwo’s products and services as well as to build new business relationships, we also adhere to our anti-corruption standards during them.

Our marketing activities and the sponsorship of external entities are carried out in accordance with the values set out in this Code. When selecting such entities, we make our decisions carefully, driven by the substantive matters as well as the principle of transparency, selflessness and integrity.

During trade fairs and conferences, we pay attention to whether the marketing materials that we give away comply with our internal policies and the law of the country in which the event takes place, as well as to whom these materials are given. We always consider whether, as a result of a wrong interpretation, such a giveaway could be considered as an act of corruption. For more on this, refer to section Giveaways.

Giveaways

We pay special attention to the promotional gifts and gadgets we give away during industry events and in relations with Business Partners. We give away items of low value only. We do not give money or its equivalent, i.e. gift cards, vouchers, etc., or luxury goods such as cosmetics, perfumes, leather goods, alcohol, tobacco products, etc.

Under no circumstances may the promotional gifts or gadgets that we give away constitute a form of influence on any external entity. When giving away such gifts or gadgets to a certain person, we first make sure that doing so in the given circumstances complies with the laws of the country in question.

We do not give any promotional gifts or gadgets with a value of over $50 to persons performing public functions. In relations with such persons, we require that informative marketing materials are dominating such as brochures, leaflets, folders, as well as office supplies that bear CodeTwo logo, e.g. pens, calendars, notebooks, t-shirts, etc.

Business partnership

Building long-term relationships based on mutual trust with Business Partners is fundamental to CodeTwo’s business philosophy.

CodeTwo makes honest efforts to sell its products and services by competing with other entities based on the quality of offered services, implemented in accordance with the principles of ethics we adhere to.

In no way can the actions of individuals representing CodeTwo rely on corrupt practices in exchange for a favorable outcome, order processing, purchase of our services or on other unethical activities. Employees shall immediately inform their supervisors of all non-work-related contacts with Business Partners that may affect business relations and constitute a conflict of interests.

In our relations with Business Partners, we do not give away any gifts that would make it unclear what our intentions are.

We absolutely expect the same or higher standards are applied by Business Partners working with CodeTwo as part of any form of cooperation.

Prior to forming a business partnership between CodeTwo and Business Partners, appropriate actions may be taken to:

1. ensure that the representatives of both entities understand and comply with the principles of CodeTwo’s Anti-corruption Code,
2. assess the credibility of persons representing these entities,
3. insert into contracts appropriate clauses in relation to the adherence to CodeTwo’s anti-corruption standards and compliance with the law.

Donations

Our activities related to the making of any donations (financial or in kind) for the benefit of external entities are carried out in accordance with the internal CSR principles in force in CodeTwo.

No form of donation may be related to unethical activities. We also expect from recipients or sponsored entities to declare that the funds we provide are not used for unlawful purposes.

Employee relations

CodeTwo’s relations with Employees are based on the following principles:

1. mutual respect and trust,
2. cooperation in pursuit of jointly agreed and appointed goals,
3. fair and reliable performance evaluation,
4. efficient work performance.

CodeTwo hires, promotes and rewards Employees by taking into account the qualifications required for a given job, Employee’s motivation to develop their skills and qualifications, and actual work results.

When making the decisions mentioned above, we in no way accept behaviors that could indicate that these decisions were made in exchange for any financial or personal benefits or other illegal activities described in the Anti-corruption Code, for example:

• promoting an Employee in exchange for a promise of financial gain,
• making the decision about rewarding an Employee or paying a bonus dependent on returning a part of that reward or bonus to a supervisor that has made that decision.

Public procurement

When working together with entities subject to public procurement law, we always act in accordance with the law that is applicable to both these entities (as the contracting authorities) and CodeTwo (as the contractor) and that is effective in a country in which the procurement procedure takes place.

As part of tender procedures, we communicate clearly and transparently, in accordance with the rules in force in a given country for contacting tender participants.

Under no circumstances do we provide material or personal benefits, including gifts or gadgets promoting CodeTwo, to the representatives of a contracting authority e.g. during meetings related to a given tender. These rules are universal and apply to CodeTwo and Business Partners both in Poland and all countries of the world.

Knowing about the tender procedure, we do not enter into sponsorship agreements with a contracting authority or make donations for the benefit of that authority. We do not establish any other relations that could unfairly affect the outcome of the tender.

Consequences of violating the Code

Corruption is a prohibited act that causes significant social harm. Therefore, in a situation where we are certain that there has been a serious violation of the Anti-corruption Code, we will be forced to take the appropriate legal steps.

Corruption is a prohibited act under Polish law. Therefore, committing an act of corruption may initiate criminal proceedings against the person who has committed it.

The violation of the principles set out in this Code constitutes a gross violation of the terms of cooperation with CodeTwo and will always result in the termination of the contract between the parties without notice.