Code of Conduct

Last updated Oct 9, 2024

Introduction

Scope & Applicability 

Legal Requirements and Human Rights

• The OECD Guidelines for Multinational Enterprises.
• The United Nations Guiding Principles on Business and Human Rights.
• The International Bill of Human Rights.
• The eight fundamental ILO conventions and other relevant conventions, such as:

• • Forced labor/slavery (No. 29 and 105),
  • Union organization and collective bargaining (No. 87, 98, 135 and 154),
  • Child labor and children's rights (No. 138, 182 and 79, and recommendation no. 146),
  • Discrimination (No. 100 and 111),
  • Health, environment and safety (No. 155 and recommendation no. 164),
  • Wages (No. 131),
  • Working hours (No. 14),

Who to ask about the Code?

If you have a question or concern about the Code, be proactive and contact your manager or Intelecy HR. You can also submit a question or raise a concern regarding a suspected violation of our Code (or any other Intelecy policy) to your manager or Intelecy HR.

No Retaliation

Intelecy prohibits retaliation against anyone who in good faith asks a question, raises a concern, reports, or participates in an investigation of, a possible violation of our Code, our policies, or the law. Please contact a member of senior management if you believe that you are the subject of retaliation within Intelecy. Partners must prohibit retaliation in their organizations as well. 

Code of Conduct

As someone working for or with Intelecy, you’re expected to be honest, act ethically, and demonstrate integrity in all situations. You have a duty to follow policies and procedures found in this Code of Conduct, as well as those that are specific to your job. You must also comply with all laws that apply to our business. Most of the time, common sense and good judgment provide excellent guideposts. If you’re unsure about the right thing to do, ask someone on the management team.

Making Ethical Decisions

Before you act: 

• Is this the right thing to do?
• Is it legal?
• Do I have the authority to act?
• Does the action comply with the Code of Conduct and policies and procedures?
• If this action became public, how would it look in the news media?
• Would I be upset or embarrassed if other people found out about this action?

If your answer to any of these questions raises doubts, talk with your supervisor, Intelecy HR or anyone in management. If you’re a supervisor or a manager, you’re responsible for knowing the rules and reviewing the Code of Conduct with the people who report to you to make sure they’re familiar with its contents. You’re also responsible for preventing violations of the Code, as well as detecting violations that may occur and reporting them appropriately.

• Lead with integrity.
• Encourage employees to ask questions and expand their knowledge of the rules.
• Demonstrate integrity by acting promptly and effectively when necessary.
• Educate employees on compliance policies specific to their job responsibilities.

Respectful, Safe & Inclusive Workplace

We are committed to a supportive work environment, where everyone working for or with Intelecy have the opportunity to reach their fullest potential. Members of the Intelecy team are expected to do their utmost to create a workplace culture that is free of harassment, intimidation, bias, and unlawful discrimination. Please read the Employee Handbook for greater detail about how we should conduct ourselves at work.

Fundamental rights 

Any obligations to the workers according to international conventions and/or national rules and regulations regarding regular employment shall not be circumvented by use of short-term engagements (such as the use of contract workers, temporary workers and day workers), subcontractors or other employment relationships. 

All employees shall be treated with respect and dignity. Physical abuse or punishment, or the threat of physical abuse is prohibited. The same applies to sexual or other abuse, and various forms of humiliation. 

All employees are entitled to a written employment agreement, in English, the agreed business language within Intelecy, stating the terms and conditions of the employment. The employer is responsible for ensuring that all employees are aware of and understand their rights and obligations of the employment. 

Apprenticeship programs must be clearly defined with regard to duration and content. 

Equal Opportunity Employment

Employment at Intelecy is based solely upon individual merit and qualifications directly related to professional competence. We strictly prohibit unlawful discrimination or harassment on the basis of race, color, religion, veteran status, national origin, ancestry, pregnancy status, sex, gender identity or expression, age, marital status, mental or physical disability, medical condition, sexual orientation, or any other characteristics protected by law. We also make reasonable accommodations to meet our obligations under laws protecting the rights of the disabled.

Harassment, Discrimination, and Bullying

Intelecy strictly prohibits discrimination, harassment, and bullying in any form – verbal, physical, or visual. If you believe that you’ve been bullied or harassed by anyone at Intelecy, or anyone connected to Intelecy (such as a partner or vendor), please immediately report the incident to your manager or Intelecy HR. Intelecy HR will promptly and thoroughly investigate any complaints and take appropriate action.

No forms of forced labor 

No forms of forced labour, slave labor or involuntary labor are accepted at our suppliers, subcontractors and business partners. 

Migrant workers shall have the same rights as local employees. Suppliers, subcontractors and business partners shall not require the workers to deliver a deposit or identity papers to the employer and the workers shall be free to terminate the employment with reasonable notice. 

Freedom of association and the right to collective bargaining 

All workers shall, without exception, have the right to join or establish trade unions of their own choice, and to bargain collectively. No workers shall be discriminated against if they exercise their right to organize or bargain collectively. 

Trade union representatives shall not be discriminated against or prevented in other ways from carrying out their trade union duties. 

If these rights are limited by law, suppliers, subcontractors and business partners shall facilitate, and in no case hinder, parallel mechanisms for free and independent organization and negotiation. 

Child labor is not accepted 

Children under the age of 15 (14 or 16 in certain countries) shall not be employed to perform work that may be detrimental to their education. 

Children under the age of 18 shall not be employed to perform work that endangers health or safety, including night shifts. 

Recruitment of children as workers in violation of the above clauses is unacceptable. If such child labor is already taking place, efforts must be made to phase out such child labor as soon as possible. At the same time, arrangements must be made to ensure that the children are given the opportunity for livelihood and education until the child is no longer of compulsory school age. 

Wages 

Wages shall be paid regularly, punctually and must be in proportion to the experience, qualifications and effort of the employee, and must at least be in line with national minimum wages or the industry standard wages, and always sufficient to cover fundamental human needs. 

Wages and payment of wages shall be agreed in writing before work starts. The agreement must be comprehensible to the worker. 

Deductions from wages as a disciplinary reaction shall not be permitted. 

Employees must be granted and compensated correctly for any type of paid leave to which they are entitled. E.g., holiday, parental leave and sick leave. 

Working hours 

Working hours shall be in line with national laws or industry standards, and not exceed working hours in accordance with applicable international conventions.  

The workers shall have at least 1 day off per week. 

Overtime shall be limited, and fairly compensated for in accordance with local laws. A maximum of 12 hours per week is recommended. The workers must always receive overtime pay, at least in line with current laws. 

Drugs and Alcohol

Substance abuse is incompatible with the health and safety of our employees, and we don’t permit it. Consumption of alcohol is allowed at our office on special occasions, but we ask everyone to use good judgment and never drink in a way that: (i) leads to impaired performance or inappropriate behavior, (ii) endangers the safety of others, or (iii) violates the law. Illegal drugs in our offices or at work-related events are strictly prohibited.

Safe Workplace

Efforts shall be made to provide the workers with a safe and healthy work environment. Necessary measures shall be in place to minimize and prevent accidents and health detriment, because of or related to, conditions at the workplace. Dangerous and unsafe equipment and buildings are not accepted. 

All escape routes at the workplace shall be clearly indicated, well-lit and shall not be blocked. Evacuation by the escape routes shall be possible during all working hours. All workers at the workplace shall have executed regular fire drills and drills concerning other emergencies. Evacuation plans, fire protection equipment and first aid kits shall be easily available at the workplace. 

All workers shall have access to clean sanitary facilities and clean drinking water. If relevant, options for safe storage of food in terms of health shall be implemented. 

If the employer provides accommodation, the accommodation shall be clean, safe, and sufficiently ventilated and with access to clean sanitary facilities and clean drinking water. 

We are committed to a violence-free work environment. We will not tolerate any level of violence or the threat of violence in the workplace. No one should bring a weapon to work under any circumstances. If you become aware of a violation of this policy, report it to a member of senior management immediately.

Avoid Conflicts of Interest

As Intelecy employees, contractors, consultants and others acting on the behalf of Intelecy, you should avoid conflicts of interest and circumstances that reasonably present the appearance of a conflict of interest, especially if it would create an incentive for you or present the appearance of an incentive for you, (whether directly or indirectly).

• Personal investments (e.g. with competitors)
• Outside employment, advisory roles, and board seats
• Business opportunities found through your work at Intelecy
• Inventions influenced by your work at Intelecy
• Business opportunities involving friends and relatives
• Acceptance of gifts, entertainment, and other business courtesies

If you are unsure if there is a conflict of interest, contact your manager, Intelecy HR or management teams to discuss.

Environment and Use of Local Resources

Environment 

Any national and international legislation concerning the environment shall be complied with. We and our suppliers, subcontractors and other business partners shall hold the required permits and licenses in order to conduct their business and efforts must be made to obtain ISO certifications, or similar certifications, relevant for the business being conducted. 

Loss of biological diversity, long-term damage to ecosystems, pollution of the atmosphere that has consequences for the climate, damage to marine ecosystems and soil degradation caused by the use of chemicals shall be prevented. 

Dangerous chemicals and other substances shall be administered in a responsible manner, including being labeled and stored in a safe manner. Safety data sheets shall be accessible at the workplace at a local language and instructions in the safety data sheet shall be complied with.  

All waste shall be recycled as far as is practically possible, and non-renewable resources shall be phased out. The local production site shall not be exploited ruthlessly, and care must be taken so that it is not damaged by pollution. It is expected that suppliers and business partners choose modern and efficient technology that reduces the emission of greenhouse gases and other emissions from products and services. 

The use of water shall be as efficient as possible, and water shall be reused to the extent possible. Overuse and contamination of subsoil water shall be avoided. 

Marginalized population groups 

Production, and use of raw materials for production, shall not contribute to the destruction of resources or the basis of income for marginalized population groups, for example by occupation of large parts of land or other natural resources that these population groups depend on. 

Preserve Confidentiality

Throughout its lifecycle, all nonpublic information that is processed, transmitted, and/or stored by Intelecy must be protected in a manner that is consistent with our contractual and legal requirements and reasonable and appropriate for the level of sensitivity, value, and risk associated with Nonpublic information (please see the Data Classification Policy). Information that contains data elements from multiple classifications must be protected at the highest level of information represented. For example, a document that contains Nonpublic and Public information must be treated as Nonpublic information. Nonpublic information must be secured against disclosure, modification, and access by unauthorized individuals. Therefore, the information must be:

• Secured at rest; and
• Secured in transit; and
• Securely destroyed in accordance with record retention policies and procedures.

Information Security

Employees and Workers are responsible for using Intelecy’s computer resources properly – especially with regard to information security – and you need to be thoroughly familiar with Intelecy’s Information Security policies and procedures.

This requirement applies to everyone working for or with Intelecy, including contractors and partners with access to our systems or information.

• Never share your login information.
• Lock your workstation when you step away.
• Log off your workstation when you leave for the day.
• Clear your workstation, waste can, printers and fax machines of sensitive information, such as PII or company-sensitive information.

Protect Intelecy’s Assets

Intellectual Property

Intelecy’s intellectual property rights (e.g. patents, trademarks, copyrights, trade secrets, and “know-how”) are valuable assets. Unauthorized use can lead to their loss or serious loss of value. You must comply with all intellectual property laws, including laws governing the fair use of copyrights and trademarks. You must never use Intelecy’s trademarks or other protected information or property for any business or commercial venture without pre-clearance from the Marketing team. Report any suspected misuse of trademarks or other Intelecy intellectual property to the Legal or compliance team.

Likewise, respect the intellectual property rights of others. Inappropriate use of others’ intellectual property may expose Intelecy and you to criminal and civil fines and penalties. Seek advice from the Legal team before you solicit, accept, or use proprietary information from individuals outside the company or allow them to obtain access to Intelecy proprietary information. You should also check with the Legal team if developing a product feature that uses content not belonging to Intelecy.

Company Equipment

Intelecy provides the tools and equipment required to conduct respective jobs effectively, but counts on all to be responsible and not wasteful. Uncertain whether personal use of company assets is okay? Ask your manager.

The Network

Intelecy’s network, software, and computing hardware are a critical aspect of our company’s physical property and intellectual property. Follow all security policies diligently. If you have any reason to believe that our network security has been violated – for example, you lose your laptop or think that your network password may have been compromised – promptly report the incident to your manager.

Physical Security

Bad actors may steal company assets. Always secure your laptop, important equipment, and your personal belongings, even while on company premises. Promptly report any suspicious activity to your manager.

Bribery and Corruption

A high ethical standard and overall good business practice shall be maintained. Any and all applicable laws shall be complied with, and a mere following of the minimum conditions of the law is not sufficient in order to maintain high ethical standards. No goods which may be considered unacceptable rewards for obtaining, retaining or managing business activities shall be received or offered. Such benefits can be, for example, cash, goods, travel or services of any kind. 

Ensure Financial Integrity and Responsibility

Financial integrity and fiscal responsibility are core aspects of corporate professionalism. Each person at Intelecy has a role in making sure that money is appropriately spent, our financial records are complete and accurate, and internal controls are honored. This applies to employees, workers, and anyone acting on Intelecy´s behalf. This is applicable every time that we hire a new vendor, expense something to Intelecy, or sign a new business contract.

It’s important that we also keep records for an appropriate length of time. Intelecy’s Data Retention Policy suggests minimum record retention periods for certain types of records. These guidelines help keep in mind applicable legal requirements, accounting rules, and other external requirements. Contractual obligations may sometimes specify longer retention periods for certain types of records. In addition, if you are asked by Intelecy HR or the management team to retain records relevant to a litigation, audit, or investigation, do so until you have been informed that retention is no longer necessary. If you have any questions regarding the correct length of time to retain a record, contact Intelecy HR or the Management team.

Taxation

All laws and regulations relevant to taxes in jurisdictions in which we operate shall be complied with. We do not condone, engage in or support tax evasion, or the facilitation thereof. We refrain from practices that are considered aggressive tax planning or that aim to exploit gaps and mismatches in tax rules and regulations. 

All tax reporting shall be based on transparency and accuracy. We shall collaborate with tax authorities and provide all requested information. 

Fair Competition

Competition shall be free, fair and open. Applicable antitrust and competition laws shall be complied with. Anti-competitive agreements shall not be entered into, including price-fixing, customer or market allocation, bid-rigging, or any other actions that could hinder free and fair competition. Commercially sensitive information shall not be discussed or shared with competitors. Market power shall not be used to exclude competitors or exploit customers and suppliers, and illegal restrictions to exploit customers or suppliers shall not be imposed. Competition authorities shall be provided with requested information in a collaborative manner. 

Whistleblowing

All workers have a right to notify censurable condition at Intelecy, suppliers or business partners undertaking. Workers hired from temporary-work agencies also have a right to notify censurable conditions at the hirer's undertaking. Censurable conditions mean conditions that are in contravention of national legislation, international conventions, internal guidelines at the undertaking or ethical norms on which there is broad agreement in society. This may be e.g., conditions posing danger to life or health, corruption, discrimination, unsatisfactory working environment, etc. 

All suppliers, sub suppliers and business partners shall have internal guidelines and routines for procedures for whistleblowing and the processing of a received notification, including that the notification shall be adequately investigated within a reasonable time and that, if necessary, suitable measures are taken to rectify the situation the notice regards. The whistleblower shall receive feedback within a reasonable time regarding how the notification was processed. 

Retaliation against a whistleblower must not occur. Retaliation means any unfavourable act, practice or omission that is a consequence of or a reaction to the whistleblower having notified. 

International Trade Restrictions

Countries can impose various economic sanctions restrictions targeting business dealings with specific countries, economic sectors, entities or individuals of concern. Export controls on the export or in-country transfer of certain restricted items, technology and software are also common. We will comply with all applicable economic sanctions as well as export and import control laws. We will assess whether government authorization is required before engaging in activities involving restricted items, sanctioned parties or countries and will obtain and comply with all required authorizations. We shall never make transactions with companies or persons that are under embargo. 

Personal Data Protection

Personal data protection laws protect the integrity and confidentiality of a person’s privacy through the processing of personal. We are committed to protecting the data privacy rights of everyone working for us and we will only use personal data for lawful and appropriate purposes. We will maintain appropriate technical and organizational measures to properly process and protect personal data. 

Animal Welfare

All animals utilized in the production of products shall be treated with respect, dignity and in line with the five recommendations for animal welfare as set out by the World Organization for Animal Health: 

1. Freedom from hunger, malnutrition and thirst;
2. Freedom from physical discomfort;
3. Freedom from pain, disease and injury;
4. Freedom to exercise normal conduct; and
5. Freedom from fear and stress. 

Animal testing is not accepted. 

Obey the Law

Intelecy takes its responsibilities to comply with laws very seriously. Every Employee, Worker and Partner is expected to comply with applicable legal requirements and restrictions. You should understand the laws and regulations that apply to your work. Contact the Compliance or Legal teams if you have any questions.

Policy Compliance

Compliance Measurement

The Compliance team will verify compliance with this Code through various methods (e.g. periodic manager reviews, tool reports, internal and external audits, and employee feedback).

Exceptions

Any exception to this Code must be approved by the Management team in writing.

Non-Compliance

Any employee who violates this Code may be subject to disciplinary action, up to and including termination of employment in addition to any civil and criminal liability.

Annual Acknowledgment of the Code of Conduct

Once each year, as a condition of employment, Employees and Workers are required to acknowledge that they have received the Code of Conduct and understand its rules. New employees will sign an acknowledgment when they start with the company. Basically, your annual acknowledgment confirms that:

• You’ve reviewed the Code of Conduct and you are required to comply with the Code of Conduct; you will comply with the compliance policies and procedures, as well as policies and procedures related to your job responsibilities;
• You will report any questions or concerns about suspected or actual violations of the Code to your supervisor, anyone in management or Intelecy’s Compliance Officer,
• To the best of your knowledge, you haven’t acted contrary to the Code of Conduct
• You have reported any potential conflicts of interest to the Compliance Department.

Responsibilities for Workers and Partners

Partners (suppliers, subcontractors, distributions and other business partners) must ensure that their own employees and subcontractors comply with this Code throughout their supply chain. Failure to comply may results in corrective actions, suspension of work, or termination of the business relationshoå, in accordance with applicable contract terms.

By working with or for Intelecy, Workers and Partners confirm their commitment to uphold the standards set out in this Code.